How can political actors take into account the limitations of evidence-based policy-making? 5 key points

These notes are for my brief panel talk at the European Parliament-European University Institute ‘Policy Roundtable’: Evidence and Analysis in EU Policy-Making: Concepts, Practice and Governance. As you can see from the programme description, the broader theme is about how EU institutions demonstrate their legitimacy through initiatives such as stakeholder participation and evidence-based policymaking (EBPM). So, part of my talk is about what happens when EBPM does not exist.

The post is a slightly modified version of my (recorded) talk for Open Society Foundations (New York) but different audiences make sense of these same basic points in very different ways.

1. Recognise that the phrase ‘evidence-based policy-making’ means everything and nothing

The main limitation to ‘evidence-based policy-making’ is that no-one really knows what it is or what the phrase means. So, each actor makes sense of EBPM in different ways and you can tell a lot about each actor by the way in which they answer these questions:

• Should you use restrictive criteria to determine what counts as ‘evidence’? Some actors equate evidence with scientific evidence and adhere to specific criteria – such as evidence-based medicine’s hierarchy of evidence – to determine what is scientific. Others have more respect for expertise, professional experience, and stakeholder and service user feedback as sources of evidence.
• Which metaphor, evidence based or informed is best? ‘Evidence based’ is often rejected by experienced policy participants as unrealistic, preferring ‘informed’ to reflect pragmatism about mixing evidence and political calculations.
• How far do you go to pursue EBPM? It is unrealistic to treat ‘policy’ as a one-off statement of intent by a single authoritative actor. Instead, it is made and delivered by many actors in a continuous policymaking process within a complicated policy environment (outlined in point 3). This is relevant to EU institutions with limited resources: the Commission often makes key decisions but relies on Member States to make and deliver, and the Parliament may only have the ability to monitor ‘key decisions’. It is also relevant to stakeholders trying to ensure the use of evidence throughout the process, from supranational to local action.
• Which actors count as policymakers? Policymaking is done by ‘policymakers’, but many are unelected and the division between policymaker/ influencer is often unclear. The study of policymaking involves identifying networks of decision-making by elected and unelected policymakers and their stakeholders, while the actual practice is about deciding where to draw the line between influence and action.

2. Respond to ‘rational’ and ‘irrational’ thought.

‘Comprehensive rationality’ describes the absence of ambiguity and uncertainty when policymakers know what problem they want to solve and how to solve it, partly because they can gather and understand all information required to measure the problem and determine the effectiveness of solutions.

Instead, we talk of ‘bounded rationality’ and how policymakers deal with it. They employ two kinds of shortcut: ‘rational’, by pursuing clear goals and prioritizing certain kinds and sources of information, and ‘irrational’, by drawing on emotions, gut feelings, deeply held beliefs, habits, and familiarity, make decisions quickly.

I say ‘irrational’ provocatively, to raise a key strategic question: do you criticise emotional policymaking (describing it as ‘policy based evidence’) and try somehow to minimise it, adapt pragmatically to it, or see ‘fast thinking’ more positively in terms of ‘fast and frugal heuristics’? Regardless, policymakers will think that their heuristics make sense to them, and it can be counterproductive to simply criticise their alleged irrationality.

3. Think about how to engage in complex systems or policy environments.

‘Policy cycle’ describes the idea that there is a core group of policymakers at the ‘centre’, making policy from the ‘top down’, and pursuing their goals in a series of clearly defined and well-ordered stages, such as: agenda setting, policy formulation, legitimation, implementation, and evaluation. In this context, one might identify how to influence a singular point of central government decision.

However, a cycle model does not describe policymaking well. Instead, we tend to identify the role of less ordered and more unpredictable complex systems, or policy environments containing:

• A wide range of actors (individuals and organisations) influencing policy at many levels of government. Scientists and practitioners are competing with many actors to present evidence in a particular way to secure a policymaker audience.
• A proliferation of rules and norms maintained by different levels or types of government. Support for particular ‘evidence based’ solutions varies according to which organisation takes the lead and how it understands the problem.
• Important relationships (‘networks’) between policymakers and powerful actors. Some networks are close-knit and difficult to access because bureaucracies have operating procedures that favour particular sources of evidence and some participants over others, and there is a language – indicating what ways of thinking are in good ‘currency’ – that takes time to learn.
• A tendency for certain ‘core beliefs’ or ‘paradigms’ to dominate discussion. Well-established beliefs provide the context for policymaking: new evidence on the effectiveness of a policy solution has to be accompanied by a shift of attention and successful persuasion.
• Policy conditions and events that can reinforce stability or prompt policymaker attention to lurch at short notice. In some cases, social or economic ‘crises’ can prompt lurches of attention from one issue to another, and some forms of evidence can be used to encourage that shift, but major policy change is rare.

For stakeholders, an effective engagement strategy is not straightforward: it takes time to know ‘where the action is’, how and where to engage with policymakers, and with whom to form coalitions. For the Commission, it is difficult to know what will happen to policy after it is made (although we know the end point will not resemble the starting point). For the Parliament, it is difficult even to know where to look.

4. Recognise that EBPM is only one of many legitimate ‘good governance’ principles.

There are several principles of ‘good’ policymaking and only one is EBPM. Others relate to the value of pragmatism and consensus building, combining science advice with public values, improving policy delivery by generating ‘ownership’ of policy among key stakeholders, and sharing responsibility with elected national and local policymakers.

Our choice of which principle and forms of evidence to privilege are inextricably linked. For example, some forms of evidence gathering seem to require uniform models and limited local or stakeholder discretion to modify policy delivery. The classic example is a programme whose value is established using randomised control trials (RCTs). Others begin with local discretion, seeking evidence from stakeholders, professional groups, service user and local practitioner experience. This principle seems to rule out the use of RCTs, at least as a source of a uniform model to be rolled out and evaluated. Of course, one can try to pursue both approaches and a compromise between them, but the outcome may not satisfy advocates of either approach to EBPM or help produce the evidence that they favour.

5. Decide how far you’ll go to achieve EBPM.

These insights should prompt us to see how far we are willing, and should, go to promote the use of certain forms of evidence in policymaking

• If policymakers and the public are emotional decision-makers, should we seek to manipulate their thought processes by using simple stories with heroes, villains, and clear but rather simplistic morals?
• If policymaking systems are so complex, should stakeholders devote huge amounts of resources to make sure they’re effective at each stage?
• Should proponents of scientific evidence go to great lengths to make sure that EBPM is based on a hierarch of evidence? There is a live debate on science advice to government on the extent to which scientists should be more than ‘honest brokers’.
• Should policymakers try to direct the use of evidence in policy as well as policy itself?

Where we go from there is up to you

The value of policy theory to this topic is to help us reject simplistic models of EBPM and think through the implications of more sophisticated and complicated processes. It does not provide a blueprint for action (how could it?), but instead a series of questions that you should answer when you seek to use evidence to get what you want. They are political choices based on value judgements, not issues that can be resolved by producing more evidence.