Report No: ACS2740 Republic of India IN eGovernance in the North East Reducing Public Administration Constraints (PACs) to Improve Service Delivery: Options and Recommendations to Support Reform Planning of the Government of Assam . June 2, 2014 . SASGP SOUTH ASIA . . \ Standard Disclaimer: . This volume is a product of the staff of the International Bank for Reconstruction and Development/ The World Bank. The findings, interpretations, and conclusions expressed in this paper do not necessarily reflect the views of the Executive Directors of The World Bank or the governments they represent. The World Bank does not guarantee the accuracy of the data included in this work. The boundaries, colors, denominations, and other information shown on any map in this work do not imply any judgment on the part of The World Bank concerning the legal status of any territory or the endorsement or acceptance of such boundaries. . Copyright Statement: . The material in this publication is copyrighted. Copying and/or transmitting portions or all of this work without permission may be a violation of applicable law. The International Bank for Reconstruction and Development/ The World Bank encourages dissemina- tion of its work and will normally grant permission to reproduce portions of the work promptly. For permission to photocopy or reprint any part of this work, please send a request with complete information to the Copyright Clearance Center, Inc., 222 Rosewood Drive, Danvers, MA 01923, USA, telephone 978-750-8400, fax 978-750-4470, http://www.copyright.com/. All other queries on rights and licenses, including subsidiary rights, should be addressed to the Office of the Publisher, The World Bank, 1818 H Street NW, Washington, DC 20433, USA, fax 202-522-2422, e-mail pubrights@worldbank.org. 2 I. INTRODUCTION 1. The Government of Assam (GoA) is engaged in a process of improving services to citizens. The focus on better services to citizens is in line with the National e-Government Plan (NeGP), with a number of existing and anticipated Union Acts, and with recently passed Acts in Assam, especially the Assam Right to Public Services Act of 2012. The approach of the Government of Assam focuses on digitization of data bases, provision of “time-bound” services, improving connectivity across the State, provision of an increasing number of services as “e-services”, rolling-out of Citizen Service Centers (CSC’s) and rolling-out “e- districts” from the present two pilot Districts to all 27 Districts. 2. The GoA is fully aware that progress on service delivery will require attention to both vertical and horizontal connectivity, and it intends to develop a Strategic Action Plan which focuses on these critical elements. While vertical connectivity relates to specific Departments and services (i.e., digitization, improvement of front-end and back end processes related to particular services), horizontal connectivity cuts across administrative structures and processes and addresses administrative practices in general. The horizontal public administration reform issues are the subject of this report. The World Bank Group contributions are intended as inputs into a draft Strategic Action Plan to be discussed with the Government of Assam. 3. The policy dialogue with the Government of Assam and review of relevant documents reveal general agreement on main public administration constraints (PAC’s) to service delivery. In particular, two reports from Assam Commissions were reviewed in detail: the Report of the Assam Administrative Reforms Commission (2005) and the Report of the Assam 2008 Pay Commission (published October 2009). The two reports contain valuable analysis of the situation, and many useful recommendations, for instance, in the areas of revamping service delivery and staff motivation. On the whole, however, the comprehensive reform recommendations could only be partially implemented and may have required a stronger adaptation to the context. 4. The current report proposes a gradual reform approach, with a focus on searching for improvements that can be accomplished with a reasonable effort. Experience of public administration reform processes suggests that progress on public administration reform is most likely to occur in a gradual and experimental fashion, taking small steps and then assessing them and learning from experience. In turn, comprehensive reform efforts involving rapid changes often fall short of their objectives. The approach pursued in this note, therefore, is aimed to identify a provisional set of manageable actions that could be considered for inclusion in a Strategic Action Plan to be agreed among stakeholders in Assam. The note provides a large menu of possible actions, from which a more limited set could be selected for inclusion in the Strategic Action Plan. 5. The present report is structured as follows. Chapter II, "Public Administration Contraints (PAC’s)", provides a detailed diagnostic of constraints identified in Assam, groups them under five headings, and proposes actions to address each of the constraints. Chapter III, "The Way 3 Forward" proposes a process leading to the preparation and adoption by the Government of Assam of a Strategic Action Plan to address to address selected PAC's. II. PUBLIC ADMINISTRATION CONSTRAINTS (PAC’S) 6. The diagnostic identifies a variety of Public Administration Constraints (PAC’s). The PAC’s are grouped under the 5 headings. Following a brief discussion of the PAC’s under each of the five headings, concrete actions to address each of them are presented in table format at the end of each section. The headings are: a. Policy, Legal, and Administrative Framework for Delivery of G2C b. Personnel Capacity and Performance c. Citizen Interface d. Organization and Functions of District Offices e. Administrative Issues PAC’s Group 1: Policy, Legal, and Administrative Framework for Delivery of G2C 7. Assam has designed a comprehensive system for leading and managing the effort to improve service delivery, especially e-service delivery. To manage this system, Assam has set up a State Level Implementation and Monitoring Framework. The top three layers of the framework are designed to deal with horizontal, cross-government issues, as seen in the table below. Policy Making & Supporting Role & Responsibilities Body State E-Gov Council headed Policy approval, guidance, political consensus and funding support by Chief Minister NeGP Apex Committee Strategy direction, intra departmental coordination & overseeing headed by Chief Secretary implementation. IT Department Policy making & implementation & monitoring. Guidance to State MMP and Co-ordination. 8. This institutional structure constitutes a robust framework for policy-making and implementation. It recognizes the need for top-level political direction and leadership (Chief Minister), top-level administrative coordination (Chief Secretary), and a working level focal point for policy development, operational management, and monitoring. Given the Government’s additional focus on PAC’s, the AR&T Department could join the IT Department in performing the management and monitoring tasks. Such joint working is at present the preferred model, but would depend on keeping the two Departments under the same Principal Secretary. The diagnostic suggests that it could be desirable to maintain the structure whereby both the AR&T and the IT Departments report to the same PS. For such a system to be optimally effective, concrete arrangements and procedures would have to be articulated. The following areas could be considered for improvement. 4 Political and Top Administrative Support to E-Governance Agenda 9. Addressing horizontal issues that cut across organizational units within the administration requires commitment and drive from the highest political and administrative levels. To be effective, such commitment and leadership must be on-going. Without commitment, Departments may move at their own pace or face interference from other Departments. This is a particularly risk in Assam, where the very large number of Departments that presently exist renders it more challenging to achieve a unified action.1 Further, the need to complete the legal framework and agree on common procedures across the administration, including a framework for effective for monitoring and reporting, requires top level engagement. 10. The focus at political and top-level administration levels to support dedicated service delivery models and undertaking a comprehensive e-governance agenda could be strengthened. The IT and AR&T Departments, being on an equal level with other Departments, would benefit from higher level commitment and drive to be able to drive the necessary horizontal reforms. The Action Plan could, therefore, consider addressing the issues related to building commitment, and direct involvement of the Chief Minister, the Cabinet, and the Chief Secretary in developing, agreeing, and pushing forward the agenda. Legal Framework 11. There is a growing body of legislation (both Union and Assam) to improve services to citizens and provide the legal basis for e-delivery. It would be beneficial for reforms to ensure that the legal framework is comprehensive and also well understood and implemented. A “User Guide” to the relevant acts might be considered. Accordingly it could be useful to conduct a review of all the legislation (including secondary legislations, formal rules, etc.) to identify gaps or possibly contradictions between the various documents. The review could result in a comprehensive picture of the legal situation and provide specific recommendations for supplementing or revising legal documents to ensure completeness and consistency of the legal basis for a reformed service delivery system. The review might also be used to provide input for the development of a User Guide to the legislation for use by management and staff delivering e-services. Under the present NLTA, the World Bank team is preparing the initial background document2 that might guide the work on the legal framework. The results of this work will be shared with the Government of Assam. 1 Reduction of the number of Departments through rationalization and amalgamation has been proposed by previous Commissions, but is not addressed in this note, since this is considered to be beyond the scope of the present reform effort. 2 See NLTA working note entitled "Operational Requirements for Public Service Delivery Laws for the Govern- ment of Assam" 5 Process for Identifying and Prioritizing Services under Right to Public Services Act (RTPS) and Electronic Service Delivery (ESD) bill 12. The Assam RTPS Act (2012) does not appear to specify a process or criteria for identifying or prioritizing services for inclusion under Section 4 of the Act. Section 4 of the Act merely notes that the Government of Assam “may, from time to time notify services” to be included under the Act. It has been confirmed that the process for identifying services to be notified is presently facing challenges, and cannot necessarily ensure that the services selected are the most important or most urgent for time-bound delivery. In addition to the services identified already for “time-bound” delivery and e-delivery, it could be important to have a process in place for identifying and prioritizing services for notification on an on-going basis. 13. Departments deliver many services, and only some of them are suitable for time-bound delivery and notification. It may be useful to design a process whereby all Departments are required to review their services and to list all the services that could potentially be listed under the RTPS, even if not immediately. Based on such a list, and using pre-agreed criteria, a forward looking plan could be devised for notifying additional services over a given period, for instance 5 years. Such a 5-year plan, if agreed, could also be presented to the public, and could be given an enforceable status through a government instruction. Some of the criteria that might be considered in prioritizing services are:  How important is the service to the population?  How widespread is the use of the service?  Are there currently challenges with delivering this service?  Is the service ready in terms of back-end processes and data base (s)?  Is the service delivered differently in different parts of the State?  Which services have been chosen (and successfully delivered) in other States?  How heavy is the work load of the Department concerned? (There may be a need to pace changes if many of the services fall under the responsibility of one Department.)  Is the service specifically mentioned in a Citizens Charter? Meaningful application of many of these criteria may require extensive consultations and interface with citizens. 14. Services under the responsibility of more than one Department may require a different approach. It has been pointed out that services that require joint cooperation and engagement of more than one Department are more difficult to notify, even where such services may be a priority for other reasons. This issue could be specifically addressed in the 5-year plan to identify and prioritize services, by including timelines for each of the Departments. Once the Citizens’ Charters are completed, their content could also be a consideration in the selection and prioritization process. This type of process could also facilitate the operation of the Innovation Fund proposed for the Project Preparation Advance. 15. Some of the same issues have been identified under the E-Service Delivery Bill (“ESD”) bill, which has been approved by the Union cabinet and is expected to pass in the Union 6 parliament. The bill requires that within 5 years (with a possible 3-year extension) governments should deliver all services electronically unless it is impossible to do so, or unless the service is otherwise excluded. Assam would benefit from a process to identify all the services currently delivered, for categorizing them under one of these three categories, and for ensuring that the services are indeed delivered electronically where it is required.3 This could result in a 5-year (or 8-year) plan, and would further require a mechanism to ensure and monitor progress. 16. Plans could benefit from public comments. In the case of plans for both the RTPS and the ESD, once the plans are drafted, they could be put out for public comments. In particular, citizens could be invited to comment on the selection of services and the standards for delivery. Consideration could be given to combining the RTPS and ESD plan into one comprehensive plan. Process for Prioritizing Business Process Reengineering (BPR) 17. It is suggested to develop a BPR Policy that outlines the methodologies for process improvements, including adoption of best practices from elsewhere. Citizen feedback could be a critical component to include in the process, ensuring the BPR results in improvements which have value to the citizens. This section will be developed further as part of the World Bank team’s work on a roadmap for BPR. ICT Plan Development 18. The absence of a comprehensive ICT Plan was identified by Assam officials as another constraint. It was noted that there is currently no common framework for service delivery, including a strong and supporting ICT infrastructure. A common ICT Plan could be developed addressing legacy issues, infrastructure bottlenecks, horizontal connectivity, wide area networks and data centers, ICT strengthening, standards and interoperability; and future growth and scalability model in terms of technologies and usage. Each Department could be required to make an ICT Plan covering the services, back-end requirements, requirements of horizontal connectivity, capacities and could be encouraged to adopt from a central bouquet of applications that would help in improved efficiencies and better accountability. Monitoring, Reporting, and Adjustment Processes 19. Monitoring and reporting, with a view to improving the implementation of the e- governance agenda, could be another priority. The need for a good monitoring system, both to ensure performance, but equally importantly to facilitate learning from experience and course correction, is universally recognized and accepted. A critical pre-condition for good monitoring is a plan that is specific and concrete enough to be monitored, including clearly defined outcomes and measurement indicators, specifically assigned responsibilities, and clear timelines for delivery. The Strategic Action Plan to be agreed for addressing selected PAC’s 3The three categories are: (i) services to be delivered electronically, (ii) services that cannot be delivered electronically, and (iii) services that can be delivered electronically, but are otherwise excluded (based on the process determined in legislation). 7 could include all of these elements. A scheme for such an Action Plan is presented in the Annex to this note. 20. A strong monitoring body could strengthen results. The monitoring and reporting system could gain from the assignment of clear authority to the monitoring body to enforce standardized reporting, to conduct ongoing monitoring and periodical evaluations, and to propose revision of the plan, as needed. Other bodies (Departments, Deputy Commissioners of District Offices) responsible for delivering specific actions within the Plan would be required to provide information in the agreed form. 21. To be successful as a monitoring body for the Action Plan, the AR&T and the IT Departments could work in close ongoing consultation with all other bodies involved. The role of the monitoring body could include:  Enforcing standardization of reporting  Assisting in co-ordination of items in the Action Plan that cut-across the responsibilities of more than one organization  Building inter-departmental and inter-institutional cooperation  Carrying out evaluation of specific e-Governance projects  Acting as “helpful fixer” of problems as they arise 8 PAC’s Actions Table Group 1: Policy, Legal and Administrative Framework for Delivery of G2C PAC Possible Initiatives for How Comments Include in Action Inclusion in the Action feasible? Plan? Plan (initial (M, S, C. W) estimate) 1. Prepare a policy High This policy statement statement for adoption by could ideally form the Political and Top Cabinet including Mission, opening pages for the Administrative Vision, Objectives and Strategic Action Plan Support to E- Goals for Service Delivery proposed here. Governance Reform Agenda (See more detail in ANNEX 2). 2. Provide regular progress High briefings to Chief Minister and Chief Secretary 3. Seek direct involvement Medium This could be of the Chief Secretary in specified in detail in implementation and the policy document. monitoring 4. Include improved Medium This would also service delivery in the increase direct regular Appraisal of Senior involvement of the Officials, e.g., Principal Chief Secretary. Secretaries and DC’s 5. Conduct review of gaps High Part of this work will and overlaps in legislative be done by the NLTA. Legal Framework framework (primary and secondary) for better service delivery 6. Agree plan for Medium completing the legal framework 7. Develop “user guide to Medium the legislation and the rules 8.Develop a requirement Medium There is clearly a that Departments prepare, possibility to get lists Process for by a certain date, a from other States who Identifying and comprehensive list of all have notified services Prioritizing the services that are already. Services under suitable for time-bound RTPS and ESD delivery under the RTPS Is there a multi-year and can potentially be process established in notified any of the States? If 9 so, can Assam learn from it? 9. Agree a set of criteria High for prioritizing services for notification 10. On the basis of Actions Medium The 5-year plan could 9 and 10, agree a 5-year include a plan for BPR plan for notifying all the as required for the services, including annual notification. notification targets, and monitoring and reporting The 5-year plan could system be subjected to public consultation before it is finalized. 11. Agree a process for Medium Could be combined selecting services to be with the RTPS plan. listed under the ESD 12. Prepare a comprehen- The plan could be sive list of services for subjected to public electronic delivery over a consultation before it 5-year period, including a is finalized. monitoring and reporting system 13. Prepare a BPR Policy Medium A draft policy could be Process for document to be adopted by circulated. Prioritizing BPR the stakeholder department The BPR plan could be linked to the 5-year RTPS notification plan and to the ESD plan. 14. Provide for review of Medium the service processes at least once a year for the initial period of 5 years. 15. Seek feedback from High This could be specified citizen on how to make the in detail in the policy processes more efficient or document. convenient. 16. Include a process for Medium This could also adoption of best practices increase visibility of in service delivery from good practices of the other departments/ Departments and 10 governments provide motivation to improve further. 17. Prepare an ICT policy High This work will be done for G2C service delivery as part of the main Comprehensive and associated backed World Bank project. ICT Plan systems requirements, horizontal connectivity and training for each Department with a 5 year roadmap 18. Assess the need for High To be carried out under data digitization and Innovation Fund. prepare for delivery of Across the Counter Services (ACS) for each Department 19. Take up migration of Medium To be carried out under legacy systems/ and or Innovation Fund. Proof of Concepts/ Pilots for immediate positive impact on service delivery 20. Take up processes for High To be carried out under G2G interactions and Innovation Fund. improvement of internal efficiencies by adopting a basket of common application stack for the Department 21. Draft the Action Plan High The model in the Monitoring, in a form that ensures that ANNEX could be Reporting, and it can be monitored (see modified in Adjustment example in ANNEX) consultation with Processes Assam officials. 22. Draft mandate of IT Medium The mandate could be and AR&T Departments to approved at a high manage and monitor the enough level, and implementation of the clearly publicized to all Action Plan bodies concerned. 23. Ensure adequate High This can be assisted by resources for management the World Bank main and monitoring the project. implementation of the plan PAC’s Group 2: Personnel Capacity and Performance 22. Issues related to personnel capacity and performance were raised repeatedly. This challenge appears to be pervasive, and is a concern at all levels and in the different types of organizations, Departments and District Offices. The items below deal with what appear to be 11 the main issues raised during the discussions with authorities, and also by the various studies and reports reviewed. 23. In addition to the specific activities listed in Table 2, there are numerous benefits of conducting a survey of Assam Government employees. To improve performance, it is important to go to the field and engage employees in expressing the issues that they see as problems. A survey could also be useful in bringing performance-related problems to the attention of senior management and politicians, and for discovering innovative ways to move forward. A Government of India report on a Civil Services Survey (2010) includes a wealth of useful information on issues related to staff capacity and motivation, e.g., chapters on “Learning and Development”, “Commitment and Integrity”, and “Working with External Stakeholders and “Improving Service Delivery”. Such information based on Assam conditions might be extremely useful for designing corrective actions to improve performance. To be useful, such a survey in Assam would need to include in the sample not only All India and Assam civil servants, but also employees in Departments and District Offices. See more details in Annex 3. Level of Motivation 24. The issue of staff motivation is generally recognized as one of the most central constraints on improved performance. Over the years, there have been suggestions that Assam could introduce a financial incentive linked to performance. Most recently, the Assam pay commission (2008) proposed the introduction of a financial incentive based on performance, which they called “Increment Based on Performance” (IBOP). 25. The Commission recommended that the Annual Increments to be given to Government employees should comprise two components: a Fixed Rate of Increment and a Variable Performance Linked component. The fixed Component would be 1% of the basic pay of the employee, and would be paid to all. The variable component would be between 0% minimum and 2% maximum and would comprise the IBOP Component. These percentages are on the low-end of performance bonuses that are paid in other countries, but might be an interesting way to start in India. The Assam Pay Commission indicated that in proposing this increment it was following the recommendations of the Sixth Pay Commission of the Government of India, which had also endorsed a Performance Related Incentive Scheme (PRIS) for the Central Government employees. 26. Nevertheless, the introduction of financial increments based on performance may not be practical in Assam at this time. This leads to the question of whether there are other forms of incentives which are more realistic and likely to be introduced. The Assam Administrative Reform Commission (2005) noted such a possibility. Positive incentives could be non- monetary, linked to individual performance, in the form of recognition, e.g., appreciation letters signed by the Secretary/ CS/ CM, etc., which inspire others and encourage the individual to keep doing well. These could be based on explicit criteria made known to all concerned well in advance so that expectations could be set and performance measured periodically over the year through a participatory appraisal system. As noted by the Commission, there could only be achieved through a better performance appraisal system. 12 27. One of the main challenges related to better performance appraisal and motivation may be the lack of clear lines of reporting and along with lack of a sense of belonging and of a team spirit among employees. In fact, many employees appear to feel that they are just moved around and not actually a part of distinct organizational units, without clear lines of management and defined responsibilities. This appeared to be a problem particularly in the District Offices, but this may be a problem elsewhere. Clearer Organization Charts and established management and reporting systems would also allow for better work planning and delegation of responsibility to well-performing employees. Accordingly, this might go some way to contribute to better motivation, regardless of financial rewards. Staff Capacity 28. Training is critical to capacity building, especially at a time of change, and the introduction of new service delivery procedures. Given the restrictions on incentives and promotion, good training policies and programs are one of the best approaches to improving performance. According to the Results Framework Document (RFD) of the AR&T Department, two of the Department’s six objectives are concerned with training: (1) Designing, developing and implementation of training programs for capacity building of civil servants; and (4) Strengthening of State training institutions. 29. The AR&T department has passed circulars requesting Departments to devote 0.5% of their budget to training. A draft “Training Policy for Assam” also contains many other good suggestions. Significantly, the draft proposes training for all. Equally important, it proposes a decentralized approach to training, whereby every Department shall adopt a Systematic Approach to Training, which would include a training needs assessment, planning, design and delivery of training, and also evaluation and assessment. Attention is also given in this draft to the need to reach the Districts. But implementation remains uncertain. A suitable monitoring mechanism to supervise implementation of the training policy could be set up to strengthen training. Recruitment 30. The personnel working in the Assam administration consist of the following: about 120 IAS, about 1100 ACS, about 400,000 employees (well over half of the employees are in the District offices). In addition, there are about 50,000 contractual employees (mostly in the District Offices). Data provided by the government indicates the vacancy rate per department is about 12-15%, with the ACS rates somewhat higher than employee rates. Vacancies in contractual employees are not included in these numbers. 31. Estimates indicate that the performance of staff could be enhanced. Most observers indicate that a high proportion of government employees are not performing well (with as many as 30-40% are not performing as expected). In a system where there are limited tools for improving the performance of existing staff because job security and seniority are important principles, recruitment of high quality new staff is important for improving the overall quality of the workforce over time. There appear to be some challenges in achieving optimal levels of recruitment in Assam, although the issue of what stands in the way of recruitment may require 13 additional analysis. It appears that few Department or Districts recruit and hire immediately upon availability of an open position. Oftentimes, positions are open for years. 32. It is likely that in any Department/ District the reason for not recruiting is a combination of factors. These could include litigation, financial considerations, blockages caused by Service Rules (reserved posts, promotion posts), political considerations, and others. However, fiscal restrictions on hiring were lifted in 2012, and Departments are free to go ahead and fill vacancies (except grade 4, where there is an effort to reduce and also contract out). 33. The Public Service Commission (“PSC”) recruits all Assam Civil Service (“ACS”), but also senior ranks of “employees” in certain State Services. Recruitment is not fully standardized. Each District Office and each Department does its own recruitment, and has somewhat different criteria for recruitment (as per their own “Service Rules”). Service Rules 34. The Assam Pay Commission (2008) noted that in many Departments, there are no Service Rules. Personnel administration was carried out through some Executive Orders. Even in Departments where Service Rules are in existence, they are often found to be incomplete. In some cases, the Service Rules do not cover all the employees of the Department. In other cases, it was found that the Rules are not modified to accommodate changes that have taken place in practice. The result is that many Departments are involved in court cases related to promotions and filling up of vacancies. 35. Challenges related to the Service Rules were raised extensively during the missions. It was noted that many of the Service Rules are out of date, that they are not consistent across Departments and across District Offices. There may also be rigidity in designation of positions as either “recruitment positions” or “promotion positions”. Although the Personnel Department initiated some work on revising the general principles for preparing Service Rules, this process is ongoing and needs further work and decisions. 14 PAC’s Actions Table 2: Personnel Capacity and Performance PAC Possible Initiatives for How Comments Include in Inclusion in the Action feasible? Action Plan Plan? (initial estimate) (M, S, C, W) Overall Staff 1. Conduct a survey of Medium This survey could ideally Performance employees to identify cover many aspects related to issues and possible personnel performance in improvements general, including specific proposed actions in this Table. 2.Provide financial Very low Probably not practical at this Motivation bonuses along the lines of time. However, the GoI has IBOP recently introduced a policy on performance bonuses. 3. Design a new Appraisal Medium Teamwork and personal System performance could be recognized. 4. Develop clear and Medium Knowing where you belong realistic Organization in the organization is critical Charts and reporting lines to motivation and performance. 5. Develop “team work” Variable Depends on clear and and delegation within realistic organization charts teams Staff Capacity 6. Implement Training High Consider the need to adopt Policy of Assam the policy and target at the level of the cabinet. 7. Introduce Action Plan Medium Specify monitoring and Time Lines for mechanism capable of Implementation of training enforcing the policy. policy 8. Ensure Implementation Low This may require financial of the Plan by all resources and a monitoring Institutions system. 9. Conduct a “training Medium needs assessment” for staff at all levels, with focus on skills needed for e-governance and e- delivery 15 Recruitment 10. Carry out detailed High assessment of recruitment “bottle necks” and make recommendations for reducing them 11. Reduce recruitment Variable Depends on the kind of bottle “bottle necks” necks identified. An intermediate step may be to choose one or two as a start. May require financial resources. Service Rules 12. Develop policy for High A draft revised service Rules revision and upgrading of was prepared by the Service Rules Personnel Department about a year ago, but is still in draft. It is not clear if it addresses all the major roadblocks created by the current Service Rules. 13. Agree process for Medium The use of Service Rules is implementing revision of mandatory, but not all Service Rules across departments adopted them. Departments and District Offices 14. Upgrade Service Rules Low across institutions PAC’s Group 3: Citizen Interface 36. Citizen interface is critical to improving services at all phases of the process. In order to ensure that services are actually improved from the perspective of the citizen, citizens would need to be consulted at all phases of the process, from the formulation of general policy, to the selection and actual delivery of services, and during monitoring and evaluation. The initiatives being implemented and planned in Assam require continuous consultations and feedback over time. By its nature, engaging the public cannot be done centrally, by a designated agency, it has to be carried out by all who design and deliver services, which means most Departments and all District Offices. Framework for Citizen Charters 37. Citizen Charters will become a requirement under the Union Act on “Right to Time Bound Delivery of Goods and Services and Grievance Redress”. The Act is not yet passed, but Assam has reported that “departments are requested to prepare Citizen Charters, which 16 will include details about Designated Public Servants, Appellate Authorities, Reviewing Authorities, Time Limit, User Charge, Eligibility Criteria, and other pertinent information. For the awareness and greater benefit of citizens, the Citizen Charter will be displayed in the offices of Designated Public Servants and other important places.” 38. The Government of India has published a detailed Handbook on how to prepare Citizen Charters, how they are to be structured, publicized and evaluated. It includes many valuable suggestions and examples. There is also a compendium of Charters which, as of 2011 (last update) includes 729 examples of Union and State Charters (two from Assam). 39. Reviews carried out over the years of the experience in India and elsewhere with Citizen Charters confirm that a central purpose of Citizen Charters is to improve services through transparency and public empowerment. Along these lines, the main challenges related to Citizen Charters are a lack of sufficient citizen consultations at the front end and lack of adequate publicity (“hanging it on the wall is not enough”) once the Charters are ready. In fact, there is a risk that the Charters become “pro forma” exercises, with little or no impact on the lives of citizens. In addition, there is an agreement in Assam that there is a strong need for mechanisms in place for continuous citizen feedback on performance, in addition to the instrument of grievances or complaints. 40. There are opportunities to enhance the process of preparing, publicizing, and monitoring Citizens Charter in Assam. One measure could be to agree a cross- departmental policy and system for preparing and approving Citizen Charters, including a common template/format, as well as a process for monitoring and reporting their implementation on a continuous basis. Public Information and Consultation 41. Assam has been engaged in a number of projects to improve public services through e- delivery and other means. The plan is to intensify these efforts, e.g., through notification of services under the RTPS and ESD, roll out of E-Districts, Citizen Service Centers, expansion of Citizen Charters, and other means. Taken together, this effort is significant but its success depends, to a large extent, on the use made by citizens of all the new possibilities. The information provided to the public about this reform could be more comprehensive and effective. 42. In particular, there is a need for “citizen friendly” information, going beyond formal guidelines and pronouncements. For this, it could be beneficial to utilize widely used media, such as newspapers, radio, and television, and possibly direct meetings with citizens and citizen groups in various locations across the State. Experience teaches that a good approach for reaching a large proportion of the population could be to develop and adopt a communications plan, based on conditions in Assam, which would be prepared by communication experts, possibly from outside the administration. PAC Actions Table 3: Citizen Interface 17 PAC Possible Initiatives for How Comments Include in Inclusion in the Action feasible? Action Plan? Plan (initial (M, S, C, W) estimate) Common 1. Develop an Assam High This could be based on the Framework for Guide to Citizen Charters, extensive existing guidelines Citizen Charters including how to prepare for India or some States. and monitor 2. Develop training for Medium public officials, especially frontline officials, on how to conduct interface with citizens Public 3.Engage communications High There is an opportunity to Information and professionals to prepare a “lead the way” with activities Engagement communications plan for proposed elsewhere in this Assam improved services document, e.g., with respect initiative to the RTPS and ESD 5-year Action Plans and the BPR process. The plan could include a management process and budget for its implementation and monitoring. PAC’s Group 4: Complex and Unclear Organization and Functions of District Offices 43. The structure, functions, and capacity of the District Office (Deputy Commissioner’s Office) were identified as an area requiring additional support. The insufficient organizational and personnel capacity in the offices of Deputy Commissioners and the subordinate offices, given the huge burden of governance which continues to grow, was noted, as well as the differences of personnel numbers and workload between the various District Offices. The challenge is also noted often by reports about public administration in India and Assam. As the frontline office for many of the services being reformed, the functioning of these offices is of critical importance. In fact, it would be difficult to improve services significantly without strengthening the performance of the District Offices which act as the point of interface with citizens on many of the services under consideration. For example, the India Second Administrative Reform Commission (in its 15th Report on “State and District Administration”, April 2009) noted the following problems, among others:  Lack of clarity in functional allocation and subjects and mapping them to specific institutions within the DC Offices. 18  Multiple accountability lines exist within and across the DC office, line departments, other agencies and local bodies.  Lack of coordination between various structures and convergence in service delivery functions in the regions. 44. The Commission also made a number of recommendations on structure and functions of the District Offices, including:  There is a need to realign the functions of the Deputy Commissioners/District Collector so that he concentrates on the core functions such as land and revenue administration, maintenance of law and order, disaster management, public distribution and civil supplies, excise, elections, transport, census, protocol, general administration, treasury management and Coordination with various agencies/ departments.  Steps should be taken to ensure that the Collector plays an effective coordination role in activities and programmes of other Departments at the district level. 45. The organization charts of District Offices illustrate their functions.4 The documents indicate that the Deputy Commissioner has many constitutional and legal responsibilities. It was indicated, however, that some of the DC functions are not constitutionally required, possibly including development activities. The DC also chairs many Committees, and there have been recommendations by the various Reform Commissions that the number of Committees could be significantly reduced. 46. Many line Departments of the State have personnel in the regions, with complex reporting lines to the department and the DC. A typical District Office employs about 10,000 persons, of which about 15% are lowest level (drivers, office help, etc.), and about 80% level 2 and 3 who do the case work. These personnel are organized in Branches, and many of them have dual reporting, both to the DC and to line Departments (e.g., Revenue, Rural development). 47. The diagnostic revealed a number of challenges. Reports reviewed, as well as interviewees noted that the District organizations are difficult to manage, the management system is limited, and the DC himself is seriously overloaded. This challenge can be exacerbated by the lack of delegation of authority to lower levels, so that many issues (including issues of minor importance) are required to rise to the top for decision. 48. Restructuring the organization and functions of the District Offices could be critical to the success of the reform. One approach for analyzing institutions in terms of mandate, structure, resources, capacity, and overall functionality, and for proposing specific recommendations in these areas, is to conduct Functional Reviews. Assam could consider the idea of undertaking a Functional Review of the District Offices. There are a number of options for proceeding, for example it would be possible to begin with a small number of Offices rather than doing them all at once. Including the Panchayats in the 4The team was provided with a couple of organization charts of a typical Deputy Commissioner’s Office in hard copy. 19 Review is a possibility, as it would create a cohesive approach to front-line delivery reform, but this merits a discussion about the status of the decentralization effort in Assam. A good starting point could be to focus on the District/Block/Circle level in the initial phase. 49. The World Bank has extensive experience with conducting Functional Reviews in many countries, and could provide assistance to Assam if this appears to be an effective approach. Experience elsewhere shows that Functional Reviews may result in far-reaching reform recommendations including potential changes in job responsibilities, changes in lines of reporting, and options for organizational restructuring. As Functional Reviews are time-consuming, and also raise expectations, it would be advisable to use this tool only if there is a clear vision and strong support for implementing changes suggested by the review. See more detail of Functional Reviews in Annex 4. PAC Actions Table 4: Organization and Functions of District Offices PAC Possible Initiatives How feasible? Comments Include in for Inclusion in the (initial Action Plan? Action Plan estimate) (M, S, C, W) Organization 1. Functional Review To be A project to carry out and Functions of District Offices determined functional reviews in the of District Regions, even for a small Offices number, will be substantial. On the other hand, it may have a good payoff in terms of service delivery given the centrality of these Offices to the delivery system at grassroots level. 20 PAC’s Group 5: Administrative Issues 50. The analysis revealed that a complexity of administrative procedures can impact service delivery. Simplification and streamlining of procedures, reduction in processing levels, and the “Paperless Office” were identified as important priorities. The AR&T Department is currently working on a procedures manual. 51. There could be an opportunity to streamline procurement procedures. Officials noted that even small items for offices can require complex and time consuming procedures. One senior official indicated that: “There are multiple levels for decision making and various approvals such as administrative, technical and financial, which are repetitive in nature and time consuming, which hinder timely delivery of services”. A second official indicated that “old and outdates laws and procedures” is a huge problem. The “Manual of Office Procedure” is out-outdated; it does not take account of the introduction of digitization into office work. 52. The Assam Administrative Reform Commission included the following recommendation : “The Manual of Office Procedure (Secretariat) 1981 should be updated, simplified, and adequate number of copies should be printed. The current Manual is old, bulky, and almost out of print, though the main ideas contained therein are still valid”. There is also a separate Manual of Office Procedures for District and Subordinate Offices (1983), but only a partial version could be found on the internet. The introduction to this Manual states that it is based on the Assam Record Handbook, 1925. PAC Actions Table 5: Administrative Issues PAC Possible Initiatives How feasible? Comments Include in for Inclusion in the Action Action Plan (initial Plan? estimate) (M, S, C, W) Administrative 1. Revise the Manual High The revision could identify Issues of Office Procedures and address the main inefficiencies in the current procedures. The Manual could address departments and DC offices. A team could be formed to prepare a new Manual and drive forward adoption and implementation. 21 III. THE WAY FORWARD 53. This note proposes for consideration over 30 actions to address the identified Public Administration Constraints. The PAC’s themselves were generally agreed upon during the World Bank team missions to Assam in February 2013, and were confirmed on the team mission in May 2013. 54. The next stage is a detailed review of this document within the Assam Administration. This will now be undertaken by the AR&T and IT Departments, who will circulate it to other Departments and seek their input. In particular, Assam could carefully review the proposed actions in the Tables, and agree upon a list of potential actions to address the PAC’s. 55. Reforms may require a selective and gradual approach. The full list of options identified in this report can probably not be undertaken within a short period. Trying to do too much at once could be counterproductive, which suggests a further prioritization of reform measures. Once the World Bank team receives from Assam the potential list, the team will prepare a draft Strategic Action Plan for discussion and finalization by the Stakeholders Workshop to be held late in 2013. A summary of the proposed next five steps is in the Table below. 22 Proposed Next Steps Steps Responsibility Output 1. Circulation of this document AR&T and IT Discussion of the actions proposed in the to Departments in Assam Departments document and views on their inclusion in the Strategic Action Plan. Consideration could be given to including the DC Offices Other actions may be proposed. 2. Collection and consolidation AR&T and IT Revised list of potential Actions for of the views across the Assam Departments inclusion in the Strategic Action Plan Departments 3. Preparation of Draft Strategic World Bank Team Draft Strategic Action Plan Action Plan 4. Review of Draft Strategic AR&T and IT (Revised) Draft Strategic Action Plan Action Plan Departments Stakeholders’ Strategic Action Plan for adoption by the 5. Finalization of the Strategic Workshop Government of Assam. Action Plan General Issues 56. The task of agreeing upon a final list to propose to the Stakeholders Workshop could follow consideration of a set of general issues and specific criteria . A critical strategic decision is how broadly to focus the reform effort. One approach for making this determination would be as follows: (i) undertake a comprehensive reform effort of all significant Public Administration Constraints which affect service delivery; (ii) conduct a more targeted reform effort but still undertake some carefully selected actions across government to improve service delivery; or (iii) conduct a reform effort which focuses exclusively on identified services for reform at Departmental level, and address Public Administration reforms solely within the given institutions that are delivering the identified service. A number of considerations are relevant here. 57. First, it would be important to confirm the main objectives of the Strategic Action Plan. The objective of the Action Plan could address horizontal public administration constraints that affect negatively the effort to improve G2C service delivery. This takes account of international and national reviews that confirm that it is difficult to make significant improvements in service delivery with a narrow focus on specific services which is also important but not sufficient. Service delivery reform requires broader reform of political and administrative behavior in order to be effective and sustainable. 58. Second, Assam the appropriate time frame for the Strategic Action Plan could be determined. The analysis suggests that a reasonable time frame could be somewhere between 23 3 and 5 years. It is difficult to complete many of the proposed actions in less than 3 years, and experience shows that anything longer than 5 years is likely to lose its relevance. The time frame is an important decision, and it will affect the selection of actions to be included. 59. Third, the Government of Assam could agree upon a system and focal point for the management of the Action Plan, including how Assam is going to drive actions that require implementation by Departments other than the AR&T and IT Departments. A monitoring framework will have to be included. As noted above, driving a horizontal reform process requires top-level engagement. While such a commitment is being developed, it might be more realistic to focus the Action Plan on activities that can be managed directly by the AR&T and IT Departments. Criteria for selecting Specific Activities to be Included in the Action Plan 60. The following criteria might be applied to select actions to be included in the Action Plan:  Is the proposed action within the competency of Assam, or does it touch on Union competencies? It would generally be more effective to focus on activities that are wholly within the competence of Assam.  How important is this action to achieving better service delivery? If the objective of the Strategic Action Plan is better service delivery, it would be important to select actions with maximum effect on this objective.  How realistic is to expect that this action can be successfully achieved and completed? There are many public administration strategies around the world that have not reached their objectives. A major cause for this is lack of realism, a failure to ask questions about the readiness of the administration to adopt and implement the reforms.  If completed, how likely is this action to deliver useful results? The actions proposed in this document are there in order to achieve specific results. But even if they are successfully completed, there remains a question of whether the expected outcomes would actually result, and/or if one might expect negative unintended consequences. It is not possible to determine all of this in advance, but it is worth considering, and leaving out activities with doubtful prospects. Will the proposed action give rise to strong objections from various quarters that are likely to derail it? Serious objections from important players in the system need to be anticipated and addressed.  Is there a significant cost associated with this proposed action, and is there a likely source of financing to meet this cost? The costs of the selected activities would have to be assessed. For some of the proposed activities, the World Bank project may provide financing, but it would be useful to identify these carefully and early. 24 ANNEX 1: Proposed Format for Strategic Action Plan to be agreed at Stakeholders’ Workshop Action Institution(s) Success Time line Progress Comments Financial cost and in charge Indicators Monitoring financial source (A specific manageable (quarterly) list to be agreed in the Workshop) Action 1 Institution in Indicators The foreseen Progress Comments on actions The required budget for charge of used for time for indicators or challenges arising implementing relevant For example: Develop a performing verifying completion of are the when implementing action and budget source policy document for the action the action the action following: action planned to finance the adoption by Cabinet is/was action. including Mission, Additional performed A – entirely Vision, Objectives and institutions Goals for Service that need to B – greatly Delivery Reform be involved C – partly or consulted D – at initial phase E – not at all Action 2 Etc. 25 ANNEX 2: Policy Statement for Adoption by the Government 1. Assam plans to move forward with an ambitious programme of service delivery improvement using IT and supported by public administration improvements. The programme is rooted in the NeGP and in a number of Union and Assam laws. Commitment from the top political level, Chief Minister and the Cabinet could be beneficial for program implementation. The various separate laws and other documents could be reviewed to provide a clear, succinct, easily understandable statement and commitment to improving services to citizens in a coherent and comprehensive manner. 2. It is proposed that the Cabinet of Assam consider adopting and publishing a policy decision indicating its commitment to improving services to citizens especially e-services. The decision could indicate clearly: (i) the objectives of the policy; (ii) the specific results to be achieved; (iii) the focal point of responsibility for delivery (both political and administrative); and (iv) the process for monitoring and reporting to the public on the achievements of the policy. 3. The policy could be supported by an Action Plan that can be monitored. The Strategic Action plan proposed for consideration by the Government could support the policy statement, and might serve as a useful Annex to the decision. 4. The policy decision could be short, non-legalistic, and easy to understand by citizens and might elaborate the following: (i) Objectives of the policy A succinct and suitable set of objectives is provided by the GoI Second Administrative Reform Commission in its report on “Promoting e-Governance”, and these could be easily adopted as Assam’s objectives. They are: a. Better service delivery to citizens b. Ushering in transparency and accountability c. Empowering people through information d. Improved efficiency within Governments (ii) Specific results to be achieved The targeted results could be both ambitious and realistic. They could include commitment to notify a certain number of services under the RTPS and ESD, reduce the time for provision of certain services over a given period (e.g., 3 years), open a certain number of CSC’s, digitize certain services, etc. Some of the items from the Strategic Action Plan could be specifically listed. (iii) Focal point of responsibility for delivery (both political and administrative) It could be beneficial for the implementation of the policy to identify specifically which Member of the Cabinet (ideally the CM) would take personal responsibility for delivering 26 the results, and which senior civil servant would be assigned to supervise the delivery. The senior civil servant could report to the responsible Member of Cabinet. Unless it is the Chief Secretary, the policy might have to specify the authority given to the responsible civil servant to manage the activities across government. (iv) Process for monitoring and reporting to the public on the achievements of the policy The senior civil servant assigned to supervise delivery could be given authority to monitor progress as per the Action Plan. This could include an instruction to all Departments to report results according to an agreed format at the agreed times. The role of the responsible Member of Cabinet could specifically include regular (quarterly or semi-annually) progress reports to the public. The role could also include regular reporting to the full Cabinet, including identification of roadblocks and proposed solutions. 27 ANNEX 3: SURVEY OF ASSAM GOVERNMENT EMPLOYEES 1. A number of the PAC’s identified in this report deal with staff capacity and performance, but there is insufficient information in Assam about the causes of the problems, and the best approaches to address these PACs. A staff survey could provide some useful information about problems and solutions. In addition, a staff survey can have other useful impacts, such as raising awareness of staff-related issues, and giving staff the satisfaction of being involved and listened to. Needless to say, once a staff survey is conducted, this is bound to raise expectations for management to listen and respond. A survey that does not result in action can potentially have more negative than positive impact. 2. Surveys of government employees are conducted regularly in some countries such as the UK, Canada, and Australia. 3. The UK and Canada conduct regular surveys that cover the entire administration, and include employees at all levels. Thus, for example, in the UK, the 2012 survey was distributed to about 480,000 employees, and completed by 297,318 people in 97 organizations (response rate of about 62%). Similarly in Canada, the 2011 survey was distributed to over 278,000 Federal Government employees in 89 organizations. The response rate was 72.2%, so that over 201,000 employees took the time to express their views. 4. The Australian approach uses a stratified sample rather than a census approach. The 2011 employee survey (the ninth such survey) was undertaken by the Australian Public Service Commission. The survey was conducted by a private research company, and sought the views of a representative sample of Australian Public Service employees at all levels from agencies with at least 100 employees. The survey involved a stratified random sample of 17,326 employees. In all, 10,222 valid responses were received, representing a 59% response rate. 5. A Civil Services Survey was also conducted in India in 2010. However, unlike the case of the other countries, where the survey covered employees at all levels, the India survey covered only selected services, and only employees at the higher levels. The survey addressed 18,432 persons, and the response rate was about 26% (4,808 responses). Although the results of this survey cannot provide direct knowledge about the situation in Assam, there is much to learn from the questions used, and some of them could be used if it is decided to conduct a survey in Assam. 6. It would be useful to consider conducting a staff survey in Assam, and including employees from all levels. A decision in principle could be taken before proceeding to planning, deciding on a specific approach, costing, and implementation. In the process of designing the survey and the questionnaire, it would be very useful to consult with those who carried out civil service surveys in various countries and, in particular, the ARPG which conducted the survey in India. 7. There are a number of options for carrying out the survey, and it could be considered involving a professional firm in the design and implementation. One 28 option is a sample, the other option is to involve all employees (as in the UK and Canada) and aim for a good level of response. This full-coverage approach allows for comparisons between organizations (Departments, DC’s) and, as such, has both advantages and risks. As to method, there is the possibility of an online survey, or a paper distribution (or a combination of both). There are good examples of questions from many previous surveys, but it would be critical to focus on priority questions for Assam. The number of questions that can be included is somewhat limited, as it appears from past experience that the time required for responding should not be too long (20-30 minutes), or there will be a serious drop in completion rate. 8. Details of the surveys, results, and questionnaires can be found in the following websites:  India: http://www.accountabilityindia.in/sites/default/files/blogfiles/1375_civilservicessurve yreport2010.pdf  UK: http://www.civilservice.gov.uk/about/improving/employee-engagement-in-the-civil- service/people-survey-2012  Canada: http://www.tbs-sct.gc.ca/pses-saff/2011/introduction-eng.asp  Australia: http://www.apsc.gov.au/about-the-apsc/parliamentary/state-of-the-service/employee- survey-results 29 ANNEX 4: FUNCTIONAL REVIEW OF DISTRICT OFFICES (i) What is a Functional Review? 1. The starting point for Functional Review is the assumption that public administration institutions exist to perform functions in order to achieve the objectives of the political system on behalf of society, and that only the performance of these functions justifies their existence, their structures, their activities, and their resources. The purpose of Functional Reviews is to assist governments in moving toward a situation whereby public administration institution collectively, and each institution individually, perform all the necessary functions and only the necessary functions, in the most efficient and effective manner. A Functional Review begins with an attempt to clarify the roles, missions and objectives of the administrative bodies under study, and to derive from these the relevant functional requirements. 2. In theory, Functional Reviews can have four primary objectives:  To eliminate redundant functions. Any function performed by the institution for which no justification can be found is a candidate for elimination. The purpose of eliminating functions can be cost-savings, but might also improve internal operations of the institution, remove unnecessary burdens from the private sector, reduce the need for internal coordination, and improve transparency.  To reduce duplication between and within institutions. All administrative systems are a product of gradual development, and tend to develop duplications over time. Functional Reviews can be used to examine the system critically in order to identify such duplications. This is a different objective from eliminating redundant functions.  To add missing functions. In some cases, it is discovered that the institution is not performing optimally because certain functions are not assigned. One example is internal coordination, another is human resources management. Some large organizations (and the District Offices are large organizations) are hampered by insufficient attention to such important management functions.  To rationalize the distribution of functions. Functions within institutions are often split between different units in ways that reduce performance efficiency and transparency. For example, two different units may be delivering services to the same entities. In such cases, the purpose is to co-locate similar functions in order to improve service delivery and reduce the need for internal coordination. 3. Functional Reviews are conducted on the basis of a fairly standard methodology, adjusted in each case to the institutions under study. The methodology identifies the functions performed by the institutions, and then provides indication on whether each function should be:  Abolished because it is not required to in the public interests, or there is no demand for them from the public 30  Transferred to another institution because there are greater synergies with other sectors  Reduced in quality of volume because it is not a priority function relative to the goals of the institution  Rationalized with other similar types of function within the institution to realize economies of scale, and improve decision making, communication, and service delivery  Decentralized to lower levels of government  Privatized fully or partially 4. Once it has been decided which existing or new functions will remain, the functions are grouped into organizational units on the basis of agreed principles. The next phase of the Review deals with developing the institutional structures to perform the necessary functions, including management, reporting, and estimates of the human resources needed. In the case of a review that covers a number of similar institutions, as in the case of the District Offices in Assam, an attempt is made to make the institutions as similar as possible (although local conditions are taken into account and can create exceptions and modifications to this principle). (ii) Why conduct a functional Review of District Offices? 5. There is widespread concern over the structure, functions, and capacity of the District Office (Deputy Commissioner’s Office). The insufficient organizational and personnel capacity in the offices of Deputy Commissioners and the subordinate offices is often noted as well as the inconsistency of personnel numbers and workload between the various District Offices. The problem is also noted by reports about public administration in India and Assam. As the frontline office for many of the services being reformed, the functioning of these offices is of critical importance. In fact, it would be difficult to improve services significantly without addressing the performance of the District Offices which act as the point of interface with citizens on many of the services under consideration. In addition, a comprehensive review of these offices could assist any process of decentralization of functions to the Panchayats. (iii) How to conduct a Functional Review of the District Offices 6. The first issue is a decision in principle to conduct Functional reviews. While there is a fairly well-developed methodology, the decision would need to address the scope of the review. There are a number of options. The first is to cover all the offices, but this task would be very large and difficult to manage in a reasonable time. The second is to pick a sample of, for example, 5 offices with the intention of developing general recommendations that would apply to all the offices. There is also a possibility of choosing just one office, but it is unlikely that such a review would support general recommendations; thus, this type of narrow approach is not advisable. Another issue is how far down to go, and especially whether to include the Panchayats. The design of the functional review process could consider the service delivery chain closest to the citizens 31 but also maintain a practical focus on where and how most citizens currently access services. This may well result in a primary focus on the District/Block/Circle level, and a secondary focus on Panchayats. Given the country’s continued devolution process, it would be useful to design the study in such a way that it can shed light on the functional/organization realities and needs of Panchayats. 7. Functional Reviews could require an expert team of consultants working closely with Assam, especially the District Offices. Their day-to-day cooperation in the study could be critical, and they will probably need to establish a Working Group to cooperate with the study team. The World Bank has extensive experience with conducting Functional Reviews in many countries, and could potentially provide assistance on this to Assam if this seems like the right way to proceed. However, experience elsewhere shows that Functional Reviews often result in far-reaching reform recommendations including proposed changes in job responsibilities, changes in lines of reporting, and organizational restructuring. As Functional Reviews are time-consuming, and also raise expectations, such reviews are best undertaken when the Government considers them in conjunction with the subsequent implementation phase and envisages to take action based on the recommendations. 32