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By Erik Devereux
November 22, 2024
This is the second column on paradoxes among theories of public administration that inhabit three distinct levels of analysis: constitutional/institutional, organizational and personnel (read the first column here). This column looks at one such paradox that arises out of the research by Donald Moynihan and his colleagues on administrative burden. For the past decade, this research has yielded seminal articles on how governments manipulate the burden experienced by members of the public when participating in various programs. If governments lower the burden then participation increases; conversely, raising the burden significantly reduces participation.
In a recorded presentation from 2019, Moynihan discusses examples of how burdens impact participation. Among the examples is what happened when the State of Tennessee implemented a recertification process for continued enrollment in Medicaid (TennCare) by sending notices to program participants through surface mail. Over several years 220,000 children were removed from the Medicaid program through failure to recertify eligibility. The families either did not receive the mailed notice, did not understand the notice or could not overcome the burden of recertification even when clearly eligible for Medicaid. Please note that much of the information that the State of Tennessee needed to know for recertification already was in its possession through tax records.
Was this outcome an unintended consequence of well-intentioned public administrators seeking to prevent waste, fraud or abuse of public funds? Moynihan and his colleagues suggest to the contrary that this was intended outcome of a change to administrative procedures pushed by conservative political leaders in Tennessee who oppose welfare programs such as Medicaid. The research shows a strong relationship between the ideological makeup of a state’s leadership and the level of burden imposed on the public to enroll in welfare programs.
A paradox for public administration theory arises here because of the conflict between two distinct views of how implementation works.
In 1986, Paul Sabatier contrasted the top-down and bottom-up approaches to implementation research. Around this same time, Michael Lipsky launched an entire branch of public administration research into the role of street-level bureaucrats in determining implementation at the level of public and, thereby, determining what public policy actually is. Other research has argued that street-level bureaucrats conceive of themselves not as agents of the state seeking to enforce the rules but as agents of the public assisting with overcoming the rules. Reading this research calls into question the top-down, hierarchical view that political leaders choose policies and public servants then implement as ordered.
The findings of the administrative burden research strongly suggest that the top-down perspective is correct when looked at in terms of the relevant evidence. That evidence at the institutional level involves correlating the level of burden with the known goals of political leaders who can influence the burden. But the civil servants in Tennessee who implemented the TennCare recertification process probably did not perceive themselves as setting out to terminate health insurance for 220,000 vulnerable children in low income families. Instead, at the personnel level, if asked those civil servants would be likely to focus on their commitment to excellent, efficient performance of their obligations to implement the directives coming from their agency. They would defend an annual recertification process as an obvious component of any public welfare program. From the bottom up, what happened in Tennessee would not fit the narrative of what is evident looking from the top down.
Can we resolve this paradox? My main point is that we most likely cannot now nor ever will. As with the quantum complementarity referenced in the first column of this series, we see one phenomenon if we go looking at it through its “lens” (e.g., light is a wave) and another phenomenon through a different “lens” (e.g., light is a particle). Both are correct simultaneously even if incommensurable. Efforts to use more research to resolve this complementarity inevitably will fail.
Here is another paradox that intersects the literature on street-level bureaucrats. Citizen agents simultaneously may help some to overcome administrative burdens while actively discriminating against others based on race, ethnicity or other such characteristics. (Moynihan et al are well aware of this, by the way.) Should the bureaucratic discretion of these agents be constrained? How can we reconcile these two different views of the same types of civil servants as either heroes transcending systemic barriers or racists blocking marginalized groups from accessing public benefits? Perhaps we cannot.
In practice, those dedicated to using the instruments of public policy to reduce suffering, prevent harm (especially to children and disadvantaged groups) and otherwise pragmatically address the needs of public will have to pursue multiple strategies that reflect these types of paradoxes. Administrative burden clearly matters. If the goal is the widest possible program participation among those eligible by statute, then burden must be kept low. There is a “sweet spot” regarding the discretion of street-level bureaucrats. Finding exactly where that is requires constant monitoring and interventions to avoid the possible pitfalls. Personnel in public administrations generally will refuse to comply with theories of their behavior. We must accept that and provide research that can help manage the paradoxes.
Author: Erik Devereux is Teaching Associate Professor in the Department of Public Policy, Management, and Analytics at the University of Illinois-Chicago. He has a B.S. from the Massachusetts Institute of Technology (Political Science, 1985) and a Ph.D. from the University of Texas at Austin (Government, 1993). He is the author of Methods of Policy Analysis: Creating, Deploying, and Assessing Theories of Change (available for free here). Email: e
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