The administrative burden of forms can stop people getting the services they need
Today’s post about the role that forms can play in creating administrative burden is from Dr Jeremiah Brown (@jeremiahtbrown). Jeremiah is a Lecturer with the Public Service Research Group (@PSResearchG) in the UNSW Canberra Business School.
Forms are innocuous, dry, and often boring pieces of bureaucratic technology that most people consider as an inconvenience. But despite their relatively innocuous nature, forms play a critical role in the collection of information and often represent a filtering mechanism in gaining access to programs or support in the modern welfare state.
There are few activities we undertake across our lives where forms are not some part of the process. These can be largely outside the domain of the state, like completing a registration form to join a new sporting club, through to bigger life events like marriage, where you must lodge a form notifying the state of your intention to marry (and another when you get married), or finally, the completion of the death registration form for a person that has passed away.
In a recent paper in the Australian Journal of Public Administration, myself, Gemma Carey, and Eleanor Malbon looked at what’s in a form, and how the questions on forms can create administrative burden for the people who are completing them. In the paper we analysed the first form people need to complete when applying for the Australian National Disability Insurance Scheme (NDIS).
Administrative burden can be understood as “an individual’s experience of a policy’s implementation as onerous”. In the last decade the concept of administrative burden has become increasingly popular in public administration research as a framework to help understand the ways that it is getting more and more difficult to access government services.
Within the administrative burden literature, researchers consider three different types of burden related costs that individuals might go through:
1. Compliance costs: the time, effort, and financial costs associated with meeting administrative demands
2. Learning costs: people need to seek information about the existence of programs and eligibility criteria, and learn how to navigate the programs
3. Psychological costs: the stigma of applying for programs that have negative perceptions attached to them; feeling disempowered, stressed or frustrated
Each of these different types of administrative burden costs can be present on forms in different ways. This is an issue for public policy, because if the costs of completing forms are too high, it may lead to people failing to complete the form, and consequently not accessing the program or support that they are entitled to access.
Let us consider how the different types of costs relate to forms and applying for support.
Compliance costs on forms can come from a form or application being unnecessarily long, or from needing a large volume of supporting documentation. This can be exacerbated when the supporting documentation is expensive to obtain. For example, NDIS applicants need to have detailed medical assessment information and this can be thought of as a compliance cost. The harder that information is for the applicant to obtain, the more challenging the application is to complete.
Learning costs can be high when information about programs is hard to obtain, when eligibility criteria are opaque, or when utilising the program is complicated. This is a common issue for people once they gain access to the NDIS, with participants describing the market based provider system as overly complex and with a steep learning curve.
Finally, psychological costs can be complicated to identify and evaluate as they can have a deeply personal element to them. For example, someone who has Multiple Sclerosis may be able to undertake household tasks and cleaning without assistance most days, but need support on some days. This is further complicated because they do not know which days they will require assistance, only that they will need some form of support. It would be beneficial in terms of the level of assistance provided to write that assistance is required every day (as it may be required any given day), but this can also feel disempowering for the person writing it on their form.
In addition to the more obvious ways that forms can produce administrative burden, there are also more subtle ways that they can be burdensome. Some questions can vary in how difficult they are to answer for a person based upon the complexity of their life. To help identify questions that might be more complicated than it seems at face value, we developed the following framework of question complexity:
1. Simple: There is only one possible answer for the question, and no ambiguity around the answer even for individuals with complex circumstances.
2. Notionally simple: In normal circumstances, the question only has one (simple) answer, but the complex circumstances of a person may mean that they cannot give a single straightforward answer.
3. Complex: The question is complex because it may have multiple answers for a person, and the parts they emphasise in their response depend on how they read the question.
Most questions on a form are simple for most people. ‘Are you an Australian citizen?’ is a simple question as the answer is either yes or no. But some questions that appear simple at face value can be complex for someone who has complicated circumstances. For example, a question asking an applicant to provide their home address is simple for most, but not for everyone. How does a person who does not have stable housing answer this question? For many online forms, if they do not provide an answer, they cannot submit the form, and this means they cannot complete the application.
There are also complex questions that we all can understand as complex. When thinking about the NDIS application, examples include questions about the impact that a person’s primary disability has on them. It is complex because it is open to interpretation, and as mentioned above, it is also complex because the person might have a variable experience with the impacts of their disability. Complex questions are a space where the word choices applicants make can become important. They are often easier for middle class applicants to answer, because these applicants are more likely to be proficient in the language of bureaucracy.
Ultimately, the complexity of questions is important because it determines who can complete an application and who cannot. If someone needs to complete a form to receive support, then suddenly a seemingly innocuous question on a form becomes a very serious problem for them. Further to this, if we think about the people who are most likely to be experiencing complex circumstances that make it hard to answer notionally simple questions, they may also be the people most in need of support – like people lacking stable housing or those seeking access to the NDIS. This can be thought of as an example of the inverse care law, where the people who need the most care are least likely to be able to access it.
If we want to better understand problems of access and administrative burden, then one place to start looking is that innocuous little piece of bureaucracy, the form.