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Reducing Voluntary Program Administrative Burden: Lessons from the National Organic Program

The views expressed are those of the author and do not necessarily reflect the views of ASPA as an organization. 

By David Carter
October 3, 2017

Voluntary programs are a popular tool for achieving environmental and social goals. As programs in which private businesses opt into voluntarily production standards, they offer “win-win” scenarios: businesses win from the competitive advantage they get from program participation, and the public wins from the enhanced environmental or social conditions resulting from improved business practices.

Despite the promise of voluntary programs, they face an inherent challenge. To secure public benefits, they must set standards that are strong enough, when coupled with stringent enforcement, to effect meaningful changes in businesses’ environmental or social impacts. Strong standards and stringent enforcement, however, can deter businesses from program participation. Without sufficient participants voluntary programs stand little chance of realizing public benefits.

The United States Department of Agriculture’s (USDA) National OrganicFinancial-planning-Bridge Program (NOP) has been grappling with just this problem. The NOP sets national standards for the production of food marketed as “organic” in the U.S. Participation is voluntary, as producers are only required to follow NOP standards if they choose to label their products organic. Despite robust organic market growth, the NOP has seen declining participation in recent years — something it is combating through strategies to alleviate the administrative burden placed on participants.

The Administrative Burden of Stringent Organic Standards

USDA organic certification is arguably the most stringent standard for “natural” food found commonly on grocery store shelves. Rigorous standards place considerable burden on organic producers and processors. Some of this burden is necessary — it ensures participants adhere to the NOP’s organic principles. Other aspects of the burden are purely administrative in nature.

Drawing on the recent work of public administration scholars Donald Moynihan, Pamela Herd and a number of collaborators, the administrative burden of NOP participation can be usefully thought of in terms of learning and compliance costs:

  • NOP learning costs: learning about NOP standards and deciding whether one’s operation is eligible for participation; determining whether being certified USDA organic makes sense for the operation in question; knowing how to go about getting certified
  • NOP compliance costs: beyond complying with NOP standards, operations must track and document compliance; they submit paperwork verifying their compliance; they pay certification fees

Importantly, some operations are better suited than others to absorb the more burdensome aspects of USDA certification. Larger agribusiness conglomerates typically face few issues in generating compliance documentation, for example, while smaller family farms often find the paperwork requirements to be exceedingly burdensome. As stated by Sam Farr, U.S. Congressional Representative of California: “[T]he concern here is how do the smaller growers, who may not have the resources to pay the cost and do all the background information that’s necessary for certification — the regulatory process is growing exponentially in terms of cost.”

Sound and Sensible: Reducing the Burden of Organic Certification

So how does a voluntary program ensure public benefits through strong standards and stringent enforcement, while simultaneously ensuring that a program’s administrative burden is manageable enough to attract participants?

The NOP is attempting to address the problem through an effort dubbed the Sound and Sensible initiative, launched in 2014. The objectives of Sound and Sensible initiative include identifying and removing certification barriers, streamlining certification process, focusing enforcement activities on more serious regulatory violations and working with organic producers and handlers to correct small issues before they become larger problems.

The initiative outlines five guiding principles:

  1. Efficient processes through the elimination of bureaucratic processes that do not contribute to organic integrity;
  2. Streamlined recordkeeping requirements to ensure that required records support organic integrity and are not a barrier for farms and businesses to maintain organic compliance;
  3. Common sense organic system plans that clearly capture organic practices;
  4. Fair and focused enforcement actions; and,
  5. Focusing on factors that impact organic integrity, as opposed to administrative details.

To realize these principles, the NOP worked with organic industry partners to produce a range of products, from informational infographics and videos touting the benefits of being certified organic, to guidance documents regarding how organic standards are to monitored and enforced — Including a “penalty matrix” identifying how regulatory sanctions should be administered based on the seriousness of a standards violation. In addition, the Sound and Sensible initiative advertises USDA cost-sharing programs aimed at reducing the financial burden of certification fees for smaller organic producers.

 Addressing the Burden of Voluntary Program Participation

It is too early to tell whether the NOP’s Sound and Sensible initiative has been successful making organic certification, in the NOP’s words, “accessible, attainable and affordable while maintaining high standards, ensuring compliance, and protecting organic integrity.” Nonetheless, the NOP case highlights the importance of accounting for administrative burden in voluntary program contexts and offers guideposts for how voluntary programs may seek to balance stringent standards—in the public’s interest—with the administrative burdens that can undermine robust private sector participation.

Author: David P. Carter, Assistant Professor, Public Affairs Program, Department of Political Science
University of Utah,
[email protected], www.policyandadmin.org

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