Abstract
One of the major issues public administration scholarship has confronted over the years is the absence of a thorough examination of factors that undermine valuable citizen–state interactions. Extensive research aims to describe the nature of government processes, as well as explain policy outcomes associated with those processes, when citizens directly interact with government employees. In Administrative Burden: Policy Making by Other Means, Pamela Herd and Donald Moynihan paint a vivid portrait of the policy-making process that expands beyond conventional descriptions of the policy process by including the construction of administrative burden as a political tool to serve policy goals. To that end, this book offers a valuable addition to the body of public administration scholarship by examining how the quality of citizen outcomes in the policy process is shaped by political forces less visible to average citizens.
Herd and Moynihan build a multifaceted thesis describing the political process of burden construction. They argue that administrative burden constitutes a cost that citizens must bear during interactions with government, but the costs of burden are disproportionately shouldered by the society’s least advantaged. Those individuals with resource limitations (e.g., cognitive, financial, or educational) tend to confront higher volumes of administrative burden while also possessing diminished capacity to effectively navigate its demands. However, contrary to some conventional perspectives, they argue that administrative burden is not solely derived from administrative choices designed to facilitate program implementation. Burden also amounts to a political tool employed by elected officials to serve partisan and/or ideological ends.
Although administrative burden might be necessary to serve important public purposes under some circumstances, in others legislators construct burden with the express intent of limiting access to government programs or fundamental rights of citizenship. Using burden to reduce program enrollment or infringe upon constitutional rights, the authors argue, compromises critical democratic values such as transparency and access to government. This nuanced argument demands that public administration research address at least two central questions with respect to administrative burden. First, under what circumstances are administrative burdens (un)justified? Second, if one determines that enhanced burden is not justified, how can programs be designed to shift the burden away from citizens toward the state. Throughout Administrative Burden, Herd and Moynihan offer rich and detailed insights into these two questions.
In Chapter 1, Herd and Moynihan begin by building a comprehensive definition of the term administrative burden. Specifically, they offer a conceptualization rooted in the costs citizens bear when they interact with the state. Three forms of costs coalesce to shape overall administrative burden. First, learning costs refer to those costs that citizens confront when seeking information about a specific program or service. Second, compliance costs refer to those costs that citizens encounter in an attempt to follow the rules and regulations established in the program. Finally, psychological costs refer to the costs borne by service recipients related to inherent stressors or perceived stigmas associated with participation in a program or receipt of service.
After carefully defining administrative burden, Herd and Moynihan situate the concept within a broader explanatory framework describing its antecedents and consequences. The construction of burden simultaneously originates from an implementing organization’s administrative capacity and underlying political beliefs that shape elected officials’ attitudes about the benefits of burden. Those organizations with enhanced administrative capacity, in terms of resource availability or administrative expertise, can reduce citizens’ experienced burden. Alternatively, many policy goals exist in conjunction with deeply held ideological beliefs. While some burden arises accidentally, other burden is created purposively to reinforce political values. These political values may be expressly stated by legislators, or they may be implicitly grounded in alternative justifications for burden creation. On the other side of the explanatory framework, citizen outcomes represent the distant effect mediated by other factors such as the presence of third parties to relieve burden, the perceived experience of the individual forced to confront the burden, and the individual’s coping resources. Therefore, legislators may construct burden to achieve policy goals they are unable to attain through traditional legislative channels, but factors outside of legislators’ control can diminish the effect of burden on citizen outcomes.
Over the next eight chapters, Herd and Moynihan invest effort detailing burden in several specific policy areas and examining how those burdens shape specific citizen outcomes. Herd and Moynihan discuss diverse policy areas, including voting access, abortion policy, the Affordable Healthcare Act (ACA), Medicare, the Supplemental Nutrition Assistance Program (SNAP), Medicaid, the Earned Income Tax Credit, and Social Security. In these chapters, Herd and Moynihan use multiple forms of evidence to carefully describe the learning, compliance, and psychological costs inherent in each of these policy areas and to clearly illustrate the connection between burden and program enrollment or political participation. As one example, Herd and Moynihan collect administrative data to show how fluctuations in SNAP participation are related to decoupling SNAP eligibility from traditional welfare and eliminating automatic enrollment in SNAP based on participation in related programs. Both these changes had the effect of increasing administrative burden to the detriment of program participation for those eligible.
The final chapter explicitly address the questions of (a) how to determine when a given level of burden is unjustified, and (2) if unjustified, how can government reduce them? Herd and Moynihan argue that a professional norm of assessing burden, rooted in an evidence-based approach, serves as a useful mechanism to determine the extent to which a given level of burden is justified. The professional norm of assessing burden demands that administrative actors employ empirical evidence in an effort to assess competing values. This sort of assessment demands that increased compliance, learning, or psychological costs be weighed against the stated benefits of burden. If the evidence-based assessment concludes that the burden is unjustified, Herd and Moynihan offer several strategies to reduce the burden citizens experience. These strategies might include enhancing accessibility of information (reduction in learning costs), using administrative data from other programs for enrollment or registration purposes (reduction in compliance costs), or offering welcoming messages to potential recipients (reduction in psychological costs).
This book should be commended for its extensive examination of multiple policy areas based on a common set of concepts. Any explanatory model with the ability to meaningfully describe phenomena across a set of policy domains as diverse as those examined in Administrative Burden offers a valuable tool at the disposal of the administrative theorist. Perhaps more importantly, this book offers strategies for structuring a more productive policy debate. One of the most contentious examples illustrating the value of this approach relates to voter identification laws. Those who advocate for the utility of voter ID laws insist that they serve a necessary deterrent to election fraud. Those who oppose voter ID laws, on the contrary, insist fraud reduction serves as a convenient justification for the real intent to disenfranchise select groups of voters. Evaluating burden as suggested by Herd and Moynihan demands examining expressed, rather than implicit, intent. In other words, if the true intent of a legislator is to disenfranchise voters using fraud reduction as a justification, and the data show negligible decreases in fraud, the justification loses merit. As such, an evidence-based assessment forces advocates of burden construction to state the parameters upon which the burden is evaluated.
As with any high-quality theoretical work, Administrative Burden raises questions that beg for empirical examination. One area for additional investigation might include expanded examination of widely different degrees of compliance, learning, and psychological costs within a single policy area. Researchers need not expect that the three forms of costs are perfectly correlated, which means it is possible to imagine a three-dimensional typology of burden. How, for example, would a program high in psychological costs but low in compliance and learning costs differ from a program high in learning and compliance costs but low in psychological costs? This seems a valuable question to address given that Herd and Moynihan advocate for evaluating burden based on consequences and benefits. Perhaps some forms of costs exact greater consequences compared with others.
Finally, researchers may profit from additional empirical examination of policy domains traditionally associated with liberal politics. Herd and Moynihan are careful to note that they examined social policies where conservative politicians have been fairly successful in burden construction to achieve policy goals. Yet, they also offer a caution to readers. One should not assume that only conservative politicians pursue burden construction as a policy tool. Detailed examination of other issues traditionally favored by the left, such as limiting gun rights, could illustrate the utility of the evidence-based approach for examining burden independent of ideological preferences.
Given the potential for generating additional empirical research, Administrative Burden will appeal to research-oriented audiences, including professors and advanced graduate students. Moreover, scholars interested in public management and policy studies will likely find the arguments offered by Herd and Moynihan stimulating. It is also likely that certain elements of Administrative Burden will appeal to a practical audience. Public servants, or students aspiring to join the ranks of public service, in the policy domains examined by Herd and Moynihan can gain insight into the management of programs in these areas. Overall, Herd and Moynihan offer a valuable theoretical contribution to public administration, and their work is likely to stimulate significant amounts of empirical research examining the theme of administrative burden.
