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Guide to Cabinet's Impact Analysis Requirements

6. Getting started

How you scope and plan your process will have a strong bearing on the quality of the product. Incomplete problem definitions, and failure to consider all feasible options are frequent causes of inadequate Impact Analysis. These problems cannot be easily fixed late in the policy process.

The Regulatory Quality Team and your Treasury policy team are available to provide feedback and advice on these areas.

As such, early engagement should be part of your early thinking (or your Start Right process - see paragraph 6.4 below), and therefore ideally occurs well before a decision is made to pursue a regulatory solution that might require your agency to prepare a Regulatory Impact Assessment.

6.1.  When, how and with whom to engage

Early in your policy process you will develop a problem definition and identify likely options. We strongly advise you ask the Treasury to test your initial ideas before you proceed further with the analysis and also seek feedback from your Quality Assurance panel/specialist.

This feedback will be especially valuable when your agency considers that the problem is materially important in terms of its human, social, economic or environmental impacts, and your policy process is likely to explore options to introduce, amend or repeal legislation.

You will have to decide when the best time to get feedback is, but ideally it would be both:

  • after tentative decisions have been made to pursue action or commission a policy project
  • before your agency is committed to a particular approach

You may use the Early Engagement for Impact Analysis Form on Treasury's Regulation webpage, an equivalent agency document, or a document from the Start Right toolkit if it covers the same material.

6.2.  Using early feedback to check you are on track

The feedback will focus on the types of things a Quality Assurance panel would look for in the final assessment of the problem definition and options identification.

At this early engagement point the feedback is not a formal assessment. Instead it will indicate whether the work is broadly on the right track, and where more analysis or information might be needed. The feedback may do one or more of:

  • suggest areas for further exploration
  • refer you to analogous analysis undertaken in other policy areas
  • suggest contacts in other agencies who may also be able to provide useful early input
  • pose questions around gaps in logic, evidence, data, etc.

Depending on the issues, there will likely be discussions in addition to written feedback.

If there are serious concerns at this stage, the feedback will identify them.

Seeking and responding to feedback may create extra work in the early stages of your impact analysis. But if the feedback identifies potential weaknesses or missing elements, then it will save time and effort later in the process and help you provide your Minister with robust advice.

Another benefit of early engagement is as a ‘heads up' to both Treasury and your Quality Assurance panel/specialist about what is in the pipeline. This helps reviewers plan their work and can speed up the turnaround time for the formal Quality Assurance process.

When you seek feedback, please indicate your timeframe. Providing the timeframe is reasonable, Treasury will make best-endeavours to respond.

6.3.  Early confirmation of your Regulatory Impact Assessment process

As part of your early engagement, the Regulatory Quality Team may determine whether a Regulatory Impact Assessment is required and, if so, what is the appropriate template and who is responsible for arranging Quality Assurance. Where possible, the Regulatory Quality Team will confirm this as part of their early feedback.

6.4.  Other early considerations in the policy process

The Policy Project also recognises the potential for early, robust consideration to efficiently drive improvements to policy quality. The Policy Project's Start Right is a set of tools and guidance designed to assist policy practitioners to consider all the important drivers of policy quality early in the policy-making process. Start Right covers both regulatory and non-regulatory policy, and is both compatible with and supportive of the Impact Analysis process.

Start Right recommends early “Validation and Testing” activities relating to the assessment of the policy problem / opportunity and key assumptions. In regards to regulatory policy, the Impact Analysis process is the most appropriate manifestation of those activities.

For more information, see the Policy Project webpage (www.dpmc/govt.nz/policyproject) or contact policy.project@dpmc.govt.nz.

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