50 Policy implementation

Geoffrey Hawker

Key terms/names

administrative discretion, bottom-up policy, co-design, nudge policy, street-level bureaucrats, top-down policy


Public policy making is a complex process and there are many different policies and types of policy.[1] The management of material and human factors always presents challenges to those espousing a policy. Achieving an objective requires time, resources and, usually, competent helpers and perhaps a degree of luck. Some policies, to change a taxation scale for example, may seem simple, though the purpose of such a change – perhaps to improve the productivity of individuals or of the whole economy – may be much harder to achieve or even identify. Other policies – the rollout of a vaccine to the endangered elderly in nursing homes, when supplies prove hard to get – may seem difficult to achieve from the outset.

But more than time and resources are needed, and it is not just the policy makers who are challenged. If we understand the putting into effect of objectives as ‘implementation’, then those affected by the policy – not just the policy makers alone – may have significant influence on how implementation is achieved. The interpretation of policy and the exercise of judgement and discretion throughout the whole field of the policy can come into play.

Policy can be coercive, as when penalties are imposed on speeding motorists, but the penalties must be effectively applied lest the law be held in contempt. Policy can be designed to encourage the good life but not enforce it, as when citizens are urged to eat healthily for their own benefit and also perhaps to reduce the costs of health care – but the citizens must be given relevant information, and be able to understand it, if good choices are to be made. How people respond may in either case influence the way in which future policies are developed. Many policies combine elements of both coercion and choice, and we can, for convenience, term these approaches respectively ‘top down’ and ‘bottom up’.

Both approaches are now common in the literature that examines and explains problems of implementation, but it was not always so. The bottom-up approach was not common almost anywhere in the world until some 40 years ago; the very use of the word ‘implementation’ became common only in the same time period. This should alert us to the fact that our understanding of concepts and their application in the real world reflects broad beliefs about, for example, the role of government, the rights of citizens and the assumptions we learn to make about how the world can and should work.

In the discussion below, we deal with three time periods. They relate specifically to Australia, though they fit, if sometimes approximately, other Western nations. Any periodisation of history must to some extent understate counter- and cross-currents but the development of thinking about implementation is clear enough:

  1. A long period of about a century (1880–1980) in which the control of public policy passed from elites to democratic majorities but issues of implementation, whilst not entirely ignored, were largely thought to be addressed in the dominant (top-down) view.
  2. A short period of about twenty years (1970–90) when the growing complexity of government, and what some perceived as governmental failures, stimulated intense interest in problems of implementation and led to a much-expanded view of bottom-up policy making and implementation.
  3. The current period (since about 1990) when those problems and failures also fuelled solutions, or what were said to be solutions, that reduced the scope of government and shifted many issues of implementation to agencies not directly part of government; now top-down and bottom-up approaches coexist rather uneasily together. We live in this period, and questions are increasingly being raised about the efficacy of market solutions. That might presage a new period, a possibility we consider in conclusion.

Policy un-defined

Two influential writers on our subject, Pressman and Wildavsky, whose work is considered further below, once claimed that because ‘implement’ is a verb, it must be connected to a noun. That is, ‘to do something’ involves a ‘thing’. Later they admitted this was an oversimplification, and they were right to do so.[2]

To refer to the ‘objectives’ of ‘a’ policy is to make some assumptions that may not be true. Not all policies have clear or stated objectives, sometimes deliberately so, and sometimes policies are so combined that we cannot identify ‘a’ policy. During the federal election campaign of 1987, for example, an Australian prime minister, Bob Hawke, promised that child poverty would be abolished within three years from the time he spoke. This promise was not achieved. But as Hawke later explained, he had misspoken, and had merely meant to say that no child would need to live in poverty at a certain point in the future[3]. Still, he did not say exactly what policies would lead even to the lesser objective. Similarly, at that time and since, many political leaders have promised that the gap in life expectancy between Indigenous Australians and other Australians would soon or fairly soon be reduced to parity, something also far from achievement today.[4] We might excuse these cases by saying that it is hard if not impossible to know exactly how to achieve such objectives even if the objectives are (in general) good. We could add that all this was aspirational talk, designed to set a direction or broad goal, and that policy must be defined much more definitely if we are to talk of ‘implementation’.

Indeed, it is reasonable to proceed that way – but only if we return later to the ambiguities, some deliberate, that make implementation so complex. To insist that policy should be defined in definite terms is a starting point, but we should keep in mind that it is an analytical starting point that may fail to capture the ambiguous and contested world of human life. Ambiguity and contest should not be seen necessarily as negatives and must not be ruled out as extraneous or irrelevant matters, so our understanding must be extended later to capture those circumstances too.

There is more. If we think only of policy as something definite that goes through different stages from conception to the final impact it may have on people or society as a whole, then we will understand something about our world – but only something. We will see below that public policy is much more a negotiated process and that policy can change its content as it proceeds across the stages of what we call implementation. This is not an easy thought, and it raises serious issues of who is accountable for public policy: who is to be judged on the results of a policy when many minds and hands may have shaped it?

Top-down implementation

In taking first the simple view, in considering policy as an objective or set of objectives that can be expressed in an intelligible and intended way, we begin ‘at the top’. That is typically with governments, ministers and senior officials and advisers who shape and state what the policy is, and secure support for it through mechanisms appropriate to the political system involved. In Australia, this is through laws and budgetary allocations (and often, therefore, the dedication of individuals to work on certain activities) that have majority support in the parliament. Policy can also be expressed by executive action in a less structured way: for example, when in an emergency a government orders military personnel into an area to rescue individuals at risk. But that does not alter the starting point of a directive, or order, or plan of steps to be taken.

Administrative discretion

Many earlier writers on implementation have assumed that this ‘starting point’ of policy, however exactly established, was not only the obvious and natural but also the only legitimate way to start. Of course, we might all hope that top down is a realistic description of implementation in certain circumstances – as in the emergency situation just mentioned. That example also suggests a limitation to control from the top that has long been recognised: specific circumstances may require a flexible interpretation of a policy, if, say, a police officer disregards a speeding motorist when a life is at stake in a medical emergency. Such an exercise of discretion might be permitted under law or regulation – itself a step in an implementation process – but will not prescribe in any detail the precise exercise of discretion. Discretionary powers of this sort, exercised by officials at relatively junior levels, were long thought to be limited and narrow in scope and thus were not seen to qualify control from the top in any substantial way.

There were always critics of administrative discretion. Hewart’s The new despotism, published on the eve of the 1930s Great Depression, before Keynesianism was understood, is a famous example.[5] As Lord Chief Justice of England, Hewart criticised quasi-judicial decision making by the civil service and the subordination of parliament, which, he said, resulted from the growth of delegated legislation. His later critics argued conversely that the judicial system of his time had failed to protect human rights.[6] It was not until a later period, considered below, that ‘administrative discretion’, as defined by Hewart in a limited and even negative way, became something larger and more positive.

The critical point is that until the recent period, the top-down approach assumed without much question the legitimacy of the policy makers – that they were rightly empowered to make the policy choices they did, including the steps of an implementation process.[7] For most of the time in a nation like Australia, that assumption was widely shared, but not at all times and not universally, and less so today than yesteryear. In order to understand recent changes, it is important to understand the basis of dominant thinking across a century and more.

Policy and public policy

The image of legitimate authority that underpins such thinking (softened in practice as it could be through the exercise of discretion) was derived from an earlier age when ‘policy’ existed but, we could say, ‘public policy’ did not. In the pre-modern and pre-democratic era, monarchs and despots had power to settle policy and to enforce it, even though they had also to consider how to compel individuals to comply, as in paying taxes, say, or in rendering labour to the squire. Public policy became possible only when competing versions of a policy could at least in principle be legitimately espoused and fought for: that is, became possible as competitive politics emerged, taking shape mainly in the policies of political parties but also within interest groups and organisations of many sorts, including trade unions and business associations.

This is not to say, at this or any time, that the parties are necessarily very different in what they espouse, or that citizens necessarily examine the policy promises in detail, or even that political parties believe everything that they claim to espouse. Those are not relevant points at this stage of our discussion. Our aim here is not to idealise the electoral process or to say that the quality of debate about policy in the public sphere is any better than a citizen finds it to be. All the same, policy choices are said to be made within the public arena by a democratised citizenry, and to be shaped largely, though not entirely, through the contest of political actors mainly formed as parties or related groups. It will be a relevant point below that the contest over policy by no means ends with electoral contests and with election outcomes; it is exactly the ability of citizens, and groups and other organised interests, to pursue their policy interests through the processes of implementation, whenever and however they can manage, that marks our modern times.

A government that wins an election and sets out to implement its policies – the promises made at the election, usually – does not, in short, have the untrammelled authority of the rulers of pre-modern times. Policy makers have to work at maintaining their legitimacy, even when they seem to be at the top and in control. That can change the way top-down implementation works in practice and can be seen clearly in our modern period. During the COVID-19 pandemic, for example, some top-down mandates were enforced and largely accepted – the wearing of masks on public transport, for example. On the other hand, vaccines were made available but not mandatory, probably because any attempt to make them mandatory could have led to large-scale rejections of the policy. Indeed, the more or less voluntary system still saw considerable protests and disturbances, showing that implementing a policy, no matter how beneficial the policy makers think it to be, can require the assent of the citizens or at least a significant number of them.[8]

The Australian auditor-general reports on the implementation of the vaccine rollout

The distribution and delivery of COVID-19 vaccines was one of the largest exercises in health logistics in Australian history. It ‘required rapid and flexible planning, decision-making and implementation, to respond to the changing health, social and economic impacts of COVID-19, as well as the effective and timely acquisition and distribution of vaccines once they were created’.

The Australian National Audit Office conducted a review of the rollout and found that, overall, the rollout ‘was planned and implemented effectively’. But it also found that the Department of Health’s implementation of the rollout was only ‘partly effective’.

While vaccines were delivered with minimal wastage, Health’s administration of vaccines to priority populations and the general population has not met targets. The vaccine rollout to residential aged care and residential disability were both slower than planned, and the vaccination rate for Aboriginal and Torres Strait Islander people has remained lower than for the Australian population.

In summary: ‘Health underestimated the magnitude and complexity of rolling out in-reach services for the residential aged care and disability sectors and did not engage sufficient in-reach providers early in the rollout’.[9]

Policy makers know this. They act as though policy were top down, but they do not always want to try to truly make it so. Former prime minister Morrison thus emphasised the traditional view when, early in his prime ministership, he delineated the role of ministers and officials. He claimed to ‘respect the experience, professionalism and capability [of] … the public service … both in terms of policy advice and implementation skills.’ But, he added, ministers ‘set the policy direction’ and then expected public servants ‘to get on and deliver it’.[10] But in the COVID-19 period, ministers of all stripes deferred to medical opinion from public health officials and were seen to be doing so at least most of the time. ‘Setting a direction’ and ‘delivering it’ are not necessarily easy to separate. We return to examples like this below, to illustrate how top-down implementation is played out today.

In summary to this point, we can say that the reality of implementation rests on the knowledge that enfranchised citizens have opportunities other than elections to pass judgement on the policies of a government and how they are implemented. It is not just the substance of a policy that might be evaluated by a voter but the likelihood that it is a feasible policy, one that can be implemented. A policy perceived to be unrealistic will not win support, which is why Hawke was so derided for his child poverty ‘slip’. Promises (albeit usually implied) of successful implementation can be vital to political success.

Perhaps Anthony Albanese had Hawke in mind when, in the run-up to the federal election campaign of 2022, he answered a question about his party’s ‘commitment … to have 24/7 nurses in aged care’. He replied that ‘24/7 care’ was

certainly our objective … if we could wake up the morning after the election and it was all fixed, that would be good. But that’s not possible … [you must] make sure that the funding’s available … that you work with the nurses’ federation … [and] with state and territory governments … [and] with the aged care sector.[11]

Time and skill in negotiation at least were required, he implied, and ‘his side’ would be better at that (‘would take more relevant factors into account in carrying implementation through’).

In using this example, we have already moved to the current period when ideas about implementation have moved well beyond the simplicities of the top down, but first we turn the historical pages back a little to give context to our current times.

Implementation as a ‘new problem’

The inquiry into the workings of the British civil service (the Fulton Committee 1968) prefigured later concerns when it reported that the upper levels of the administration were strong in framing policy but weak in following through a chain of execution.[12] From the early 1970s, policy analysts began increasingly to raise questions about how implementation could be made more effective. They reflected growing concerns about the complexity of government that were being expressed also within the governmental and associated institutions they were writing about. Different perspectives emerged: some attempted to support and extend the role of government while others sought to reduce it. In either case, attempts were made to augment the capacity of citizens to influence policy formulation and implementation, though methods differed.[13]

‘Perfect implementation’ – last days?

Before considering these attempts, we should note that the top-down view received a thorough if succinct exposition at the very time that it was receiving influential critique; social phenomena, as much as material objects, sometimes come into sharpest focus as they appear in context or pass ‘into history’. The British writer Lewis Gunn thus identified ten requirements that needed, ideally, to be met for effective policy implementation.[14] The impossibility of meeting the requirements underscored the need for a more realistic approach. Implementation could succeed fully, he wrote, only if ten ‘preconditions’ were met (see box).

Preconditions for effective policy implementation

  1. Circumstances external to the implementing agency do not impose crippling constraints.
  2. Adequate time and sufficient resources are made available to the program.
  3. Not only are there no constraints in terms of overall resources but also, at each stage in the implementation process, the required combination of resources is actually available.
  4. The policy to be implemented is based on a valid theory of cause and effect.
  5. The relationship between cause and effect is direct and there are few, if any, intervening links.
  6. There is a single implementing agency that need not depend upon other agencies for success or, if other agencies must be involved, that the dependency relationships are minimal in number and importance.
  7. There is complete understanding of, and agreement upon, the objectives to be achieved; that these conditions persist throughout the implementation process.
  8. In moving towards agreed objectives it is possible to specify, in complete detail and perfect sequence, the tasks to be performed by each participant.
  9. There is perfect communication among, and coordination of, the various elements or agencies involved in the program.
  10. Those in authority can demand and obtain perfect obedience.[15]

Gunn wrote in a journal aimed primarily at an audience of practitioners, not students or academics, and he was not suggesting that all these conditions could be met, or even that a single one of them could be. His ‘very practical purpose [was] to … think more systematically about the reasons for implementation failures and about approaches to improving the implementation process’. He was ‘concerned with exploring the idea of perfect implementation and [did] not necessarily offer [the list] as an ideal since some of the costs of attaining it might properly be regarded as unacceptable in a free society’.[16] He thus introduced, without any further explanation, a key concern of the critics who came to the fore at this time. Could the citizens of a society be empowered to respond to policies they disliked or saw to be unfair, and could it be possible for them then to intervene in the processes of implementation? And could officials have any freedom to ‘adjust’ policy implementation when they could see that it was not meeting what were said to be the objectives of the program?

We pause to consider just one example of the impossibility of achieving the points Gunn listed. To allow adequate resources (Gunn’s first point) could only be done at the cost of other policies, since the policies of any government at any time are multiple; there is necessarily a contest for resources that is never ending, and what is sufficient at one time may not be at another time. Some policies start by being well endowed and then are stripped of resources as rival policies crowd them. ‘Hypothecation’ is said to be a way of protecting a policy by funding it at a fixed rate from a specific source: for example, by using part of the fuel excise for road maintenance. But guardians at the treasury try to limit such arrangements, and the source of funding seldom remains constant.[17]

A new approach

Such concerns were well evident in what is generally held to be the landmark study in this new period of critique – Pressman and Wildavsky’s examination in 1973 of certain employment policies in the USA with the headline title Implementation.[18] The subtitle gave the flavour of their concerns:

How great expectations in Washington are dashed in Oakland; or, why it’s amazing that federal programs work at all, this being a saga of the economic development administration as told by two sympathetic observers who seek to build morals on a foundation of dashed hopes.[19]

Their study seemed indeed to show that government had become more complex and demanding: resources were not infinite, what resources were available became dispersed across different agencies operating at different speeds, and the expectation that employment subsidies would attract hirers of labour turned out to be an unjustified hypothesis; and the rest of Gunn’s principles found, in one way or another, their antithesis. Their account of implementation in a specific time and place thus crystallised a set of issues that other writers were also grappling with at the time.

But if Pressman and Wildavsky are credited with having the first word, they certainly did not have the last. Their study took the viewpoint of policy makers struggling to be effective, and they gave attention to the need for policy makers to understand the thinking of those affected by policies but they said very little from the viewpoint of those so affected. They set an agenda of problems that others tackled with more radical approaches, more radical at least from the perspective of the still prevailing top-down assumptions.

And in Australia …

Attention was quickly given to Pressman and Wildavsky’s work in official and academic circles in Australia and could be said to mark the first occasion when ‘implementation’ – sometimes with a capital ‘I’ – became recognised in a formal sense in government policy. A royal commission that was then reviewing the workings of the federal public service took note of implementation as an issue that would be raised when its own recommendations went to the government, and it succeeded in recommending a specific unit in the prime minister’s department to monitor the fate of its recommendations.[20] The unit could be regarded as the precursor of later units intended to guide the implementation of public policies more generally. We return to these current institutional arrangements below.

Apart from its concern with the fate of its own recommendations, the royal commission considered the deficiencies of policy making from the top more generally, and its proposals have been exhaustively discussed elsewhere.[21] Critical to its approach was the proposition, in the second paragraph of its long report, that recent years had seen ‘a great extension of the functions of government and of the Commonwealth government in particular as well as important changes in the attitudes and expectations of the community in relation to government’.[22]

In later years, the extension of government functions did not quite follow the course the royal commission had anticipated, but its concern with community expectations about government proved accurate enough. Thus, the commission noted that citizens who were provided services by the government would increasingly ‘expect not just promptness, efficiency and courtesy in their delivery but will expect to be satisfied about the conditions of their eligibility, priority and allocation’ – in effect, the details of implementation in their individual cases.[23] Necessarily, officials would be called upon to become increasingly responsible to the wishes and attitudes of their clients or customers (‘citizens’, in the main, that is), a development the commission thought ‘wholly beneficial’.[24] Indeed, the commission went further, arguing that in the Public Service ‘some degree of discretion should exist at all levels. Only then can decisions take adequate account of the special circumstances of the individual case’.[25]

The commission’s stresses on official discretion and client initiative were not the only themes in its report but were some of the most important – and also controversial to those commentators who thought that discretion and client activism worked against, even contradicted, clear lines of ministerial accountability.[26] But the commission has, on the whole, proved to be in step with later thinking, which has interpreted the accountability of ministers in a more varied way, allowing not only for a reinvigorated oversight by the parliament (a traditional concern) but also for external accountabilities of new forms. The most notable examples, all of them flowing to some degree from the report of the commission and taking institutional form in the period we are considering here, include freedom of information legislation, the remedies of the ‘New Administrative Law’, and the office of ombudsman. All permit some degree of control over the detail of implementation by those beyond the structures of government itself, potentially opening ways for the clients of government to find ways to deal with what they perceive as injustices and inefficiencies affecting themselves.[27]

Additionally, an emphasis on official discretion to provide flexibility in implementation took shape in laws and policies establishing equal employment opportunity, on the grounds that a more representative bureaucracy could be more sensitive to the needs of different clients. Proposals for ‘industrial democracy’ in the Public Service in the 1980s were part of the same wave of reform. The design of participative mechanisms of consultation between ‘workers’ and ‘managers’ were experimented with and some tentative steps were taken to engage public sector workforces with their clients.[28] These moves survived less well than the changes to administrative law and to equal employment opportunity, but were to some extent reconsidered in later years when notions of policy co-design (below) came to prominence.

Street-level bureaucrats

Earlier notions that decried administrative discretion (such as Hewart above) were already well under challenge from thinkers like R.H. Tawney (1880–1962), the English economic historian and social critic who clarified why rules needed to be applied differently according to individual needs and why exercises of discretion were therefore required. He argued that equality of provision:

is not identity of provision. It is to be achieved not by treating different needs in the same way, but by devoting equal care to ensuring that they are met in the different ways most appropriate to them … the more anxiously indeed a society endeavours to secure equality of consideration for all its members the greater will be the differentiation of treatment which … it accords to the special needs of different groups and individuals among them.[29]

The importance of official discretion was emphasised and extended in later scholarship, finding expression especially in the influential work of Lipsky (1980), bearing the title Street-level bureaucracy, but with a cautionary subtitle – Dilemmas of the individual in public service. He pointed to the significance of lower-level officials in translating the policies of a government into action across the whole field of public policy. Providing the public with goods and services required judgement, not automatic application, and, when resources were tight, discriminations between clients of different status could be important in making a policy successful, even though issues of favouritism or corruption might also enter and would need to be controlled. At the same time, any discretion allowed to officials, or taken by them, risked stressing them unreasonably as they negotiated difficult clients, their peers and (in more modern times) competition from agencies with similar missions. None of this was easy to accomplish but was necessary for equitable policy, Lipsky and others argued.[30]

Though Lipsky and other later authors did not suggest that all problems of resource scarcity and imperfect human behaviour could be solved through street-level decisions, their analysis opened the way for a focus on organised sectors of workforces to take advocacy, about social policies especially, into the public domain and thus potentially create new policy. This possibility began to address issues of policy design and to suggest that creation and implementation can come together as a joint process. Of course, they always were, since these are analytical categories, and the top-down policy makers in earlier times certainly experienced ‘feedback’ from their junior staff and from the public, sometimes through media reporting. But the developments summarised above brought new actors into the drama and opened new ways for influence to be brought into the policy cycle.

We return to this point in conclusion but must first consider the countervailing tendencies of this period: that is, how the move to ‘small government’ has affected thinking and action about discretion and citizen engagement in the processes of policy design and implementation. The Australian innovations of the period and the thinking of analysts here and elsewhere as summarised above came together at the very time that the new wave of critical thinking about the role of government came into prominence and, soon enough, dominance. The implications for implementation have been profound.

The current period

The move to small government from the 1980s onwards in the countries of the West took emblematic shape in the actions of the Thatcher and Reagan governments in the UK and the USA. Australia had its own proponents and also its own pattern of downsizing government. The causes, forms and consequences of this secular movement of ideology and practice, including the movement to the New Public Management (NPM) approach, are dealt with elsewhere in this volume.

Essential points in our context include the movement of government away from the direct delivery of services to individuals, especially in social security and employment support, and from direct intervention in the economy, in forms of de-nationalisation involving communications, transport, power generation, banking and more. Government moved not so much from a large to a small role as from being a direct to an indirect provider of services and rules, from ‘rowing’ to ‘steering’ in the phrase that became almost a cliché. This was a simple way of putting matters but did rightly emphasise the renewed emphasis of government on regulatory activity. The functionality of government was dispersed to institutions operating on the margins of government or beyond as in corporate bodies (to some extent controlled by reporting requirements that were said to retain old ideas of accountability to governments and ministers) or placed entirely in the market economy (so that the mechanisms regulating capital were applied). The job of many public servants became the management of contracts that set and evaluated standards for the new managers who were usually employees of contracting and consultancy firms. They now made the decisions about implementation that once might have been made by public servants, on such mundane but important details as to the quality of blankets in a prison or the hours of exercise allowed to inmates in a home.[31] In some instances, the failures of contractors allowed the contracting agency to avoid blame for poor implementation.[32]

A number of justifications for these changes were put. One, that government had become cumbersome and unresponsive to citizens, was the very reason that the reformers of the 1970s proposed the changes they did. The anti-state proponents went in a different direction by claiming that private sector methods of management (and hence implementation) were inherently better than those of the public sector, and that meant they were also cheaper. Claims were also made that the new methods increased competition by breaking governmental monopolies of provision and were thus again likely to be cheaper to the consumer; it is true that the single points of government provision were often replaced by multiple agencies offering services to the public, especially in telecommunications, infrastructure and transport. Thus, tax relief could be offered to voters and the public debt reduced; such promises must explain many of the decisions by successive governments of all parties to adopt the contracting out methods so advocated. Underlying these propositions was a reliance on the perspective of the individual citizen as the key actor, choosing services from a range of agencies that operated competitively to reduce cost and improve the quality of what was delivered.

At least, those were the claims made. They inform the system of governance we now live within. But the ideas of the reformers of the 1970s and of the small government exponents of the 1980s are also now mixed in ways that give new meaning to implementation. We can distinguish three perspectives that have, to varying degrees, practical application: nudge policy; the public official as policy entrepreneur; and co-design.

Nudge policy

This is a growing mode of policy design and implementation, spreading across many political systems otherwise dissimilar.[33] It is apparently a voluntary rather than a coercive approach. It rests on studies of human behaviour drawn from the behavioural sciences – that is, following the testing of theories of cause and effect (noted by Gunn to be essential).[34] Those affected by a policy are given choices, to accept or reject what a policy offers. What the policy designers think are good choices are of course made clear, and the policy is presented in such a way that there are incentives (‘nudges’) to push the citizen to a good choice. The COVID-19 rules about social distancing, washing hands and wearing masks exemplify the approach: the citizen was both encouraged to do the right thing for the sake of others and warned of the consequences to themselves if others did not also respond positively. A fully coercive approach would be unlikely to be effective (rebellion by the citizen) and would demand resources impossible to find from a coercive government (top-down failure again).

Many other instances can be found in the way that issues and choices about, for example, cancer screening, private health membership, returning to work, childhood obesity, healthy eating, and domestic violence have been approached. In these and many other cases, the citizen is provided with information that enables them to make (as the policy designers hope) the best choice, and support can be given to sustain those choices as (to take just the last example) in referral centres and refuges. Those facilities are an important part of making an anti-violence policy work, but they cannot be made mandatory, or so it is said.

Critics of nudge policies point out that citizens are by no means equal in their access to or understanding of information and may not be socially positioned to take advantage of whatever remedies a nudge policy offers. Those with language or health or employment issues, and so on, may struggle to have the time and motivation to make a good choice. Nudge policy design follows the market analogy that citizens are individuals empowered to look after themselves if given sufficient and correct information, but that idea can devalue cooperative and collective efforts. Australia has, for example, implemented the international covenant that opposes modern slavery; the government thus makes information about the supply chains of Australian companies available in a regular way so that the citizens who wish to do so can avoid transactions with those companies shown to score badly. But, as one researcher has said, the idea is flawed because ‘consumers don’t have the time to trawl through thousands of modern slavery documents. Nor are civil society and the media always able to carry out this analysis. It’s not really accessible information for consumers’.[35] The ‘aware’ individual is empowered – but individuals may need help from other people and from collective organisations to exercise their power.

The public official as policy entrepreneur

The term ‘policy entrepreneur’ is relatively recent and usually carries a positive connotation. Its use is commonly dated to Kingdon’s work, describing how such individuals find or create opportunities to bring together their understanding of a problem with policy solutions and political sensitivity.[36] The approach has until recently rested on the identification of individuals as actors and is almost always associated with the creation or development of policy rather than its implementation. It is possible to extend the term, conceptually at least, to include more collective modes of policy making and to incorporate specific steps of implementation within that. Thus, some recent writing has tried to bring together the perspectives of the street-level bureaucrats with the espousal of bureaucrats as ‘policy entrepreneurs’.[37] This is to suggest not only that officials at ‘street level’ can exercise discretion (whether ‘properly’ or not) but also can take the initiative in devising appropriate policy, based on their experience of the problems of implementation, and can persuade other policy actors such as politicians or influential interest groups to act accordingly. The emphasis on collective action is again important, as it suggests that groups with common purpose are likely to be much stronger in advocacy than individuals are. This might be too obvious a point to make were it not for the emphasis placed on the individual as recipient and (sometimes) maker of policy.


Co-design can be seen to bring together a number of the perspectives outlined above. As the ‘co’ suggests, instead of policies emanating from a single point of authority, the very definition of a problem and how it is to be tackled is considered in a broader context involving multiple perspectives. A combination of those affected – as consumers of existing policy, or those concerned to develop new policies, or officials with experience in the development of policies, or, perhaps, organised interests with a cause to advance – are brought together to generate and test ideas that rely upon lived experience. Those contributing to the design may use many different techniques, including storytelling, model building and role-playing in building a common approach. Experiences of ‘implementation gone wrong’ are likely to figure largely.[38]

It cannot be said that this approach has been thoroughly tested and reported, and it has certainly not been applied across all areas of policy. It can be time-consuming and costly. Though some successes have been claimed, others maintain that their own involvement turned out to be merely a form of window-dressing for decisions that had already been taken. The most common form of co-design is the fashionable use of ‘stakeholders’ as a shorthand term for engagement that can vary from co-design in some full sense to consultation on less-than-vital issues to merely ritualistic gestures. There is unlikely to be any consistent approach or outcome from co-design as a method; the motives of the sponsors and the capacity to exert power of those involved must be assessed in each case.

At the top again

We conclude by bringing the main points above into juxtaposition with a current and authoritative statement of high significance about implementation. This is the section of the website of the Department of Prime Minister and Cabinet (PMC) that expounds the approach that public servants should take to implementation. It is substantial and detailed, with videos and other aids to understanding, and it has counterparts in the sites of the state and territory governments.

It is, of course, not a chapter in a textbook or a scholarly article. It is rather a set of prescriptions for the training of public servants, but it is well worth reading by the student for what it says and for what it does not say. It is not about ‘policy entrepreneurs’, though it does advocate in many places that public servants must correctly identify the problem that they are attempting to resolve with a policy instrument capable of successful implementation. That policy instrument is presented as a choice between ‘regulation’ and ‘no regulation’: the provision of services is not an option. The regulatory choice requires the existing forces of the market to be managed (permits, standards and fees, for example) and the latter choice is another name for nudge policy (‘let the client decide’). At the same time, the flexible and open nature of contemporary government is stressed in the key summary of these choices:

  • Are your stakeholders adequately involved or informed about progress?
  • Do you have the right number and type of stakeholders? Not too many, just enough to provide useful feedback and keep you on your toes?
  • How are you keeping them informed of progress?
  • Are you listening to stakeholders as well as talking to them? Ask them for ideas on implementation or risk issues; if they are the right kind of stakeholder, they will have a helpful view you might not have previously considered.[39]

More details from the checklist are provided in the box.

The good implementation checklist

Have you put your intended policy outcome into words?

  • What does success look like and how will you get there?

  • What are the measures your performance will be judged by?

  • Have you collected enough benchmark data to assess whether your policy has had the desired effect over time?

Who are the decision makers and how are they accountable?

  • Have you adequately considered governance?

  • Are the roles and responsibilities of each person, group or agency involved clearly defined and documented?

  • Is there a shared understanding of who is responsible for each decision?

  • Are there reporting and review arrangements in place?

  • Are you keeping it simple? Don’t allow project management processes to become an end in themselves.

  • Are you able to manage problems proactively and escalate issues, risks and disputes to the right person or body quickly?

Are your stakeholders adequately involved or informed about progress?

  • Do you have the right number and type of stakeholders? Not too many, just enough to provide useful feedback and keep you on your toes?

  • How are you keeping them informed of progress?

  • Are you listening to stakeholders as well as talking to them? Ask them for ideas on implementation or risk issues; if they are the right kind of stakeholder, they will have a helpful view you might not have previously considered.

Are you on the lookout for risks and threats to success?

  • Remember: the aim is not to eliminate risk but to identify, assess and manage risk. Be proactive in avoiding known risks and vigilant in identifying new ones.

  • Develop and maintain your risk management strategy in conjunction with stakeholders.

  • How will you evaluate your policy during and after implementation?

  • Plan from the start what will be measured, how it will be measured, why and who you will report this to.

  • Good evaluation questions include: Are we doing the right thing? Are we doing it the right way? Are there better ways to get the same result?

  • Evaluation should not passively consider the performance of the policy, but actively question the ongoing need for the policy. Ask yourself if the policy continues to perform a useful purpose. Is it still required or can it be done away with?

Do you have the right amount and type of resources to implement your policy?

  • Look at people, financial and delivery resources across the life of the implementation, not just whether you have enough to implement the first stage of your policy.

  • Have you weighed up the costs of using different delivery mechanisms? Make an informed choice on what resources will be required to deliver your desired outcome.[40]

Whether the stakeholders have authority and agency, or merely give legitimacy, are questions to be considered. Nudge and co-design – implied in the PMC page, though those terms are never used – embody complex processes that can seem contradictory. That is true of implementation in all its aspects. Neither top-down nor bottom-up implementation can account completely for the challenges of understanding it, or of applying the ideas in practice. Different writers express this truth differently, but with the same intent. Colebatch, Hoppe and Noordegraaf say that there will ‘never be one, definitive account of policy work because policy is too ambiguous and contested to be defined in neutral ways, and because policy is an ongoing process, that evolves over time and eschews fixed and static demarcations’.[41]

As Hill summarises the issues, the reality of implementation:

is not imperfect control but of action as a continuous process of interaction with a changing and changeable policy, a complex interaction structure and outside world which must interfere with implementation because government action impinges upon it and implementing actors who are inherently difficult to control. (original emphasis)[42]

Implementation is, in a real sense, the whole of policy making. Without implementation there is no policy making. Without policy making, there is nothing: nothing to be disputed, nothing to be agreed, nothing to build, nothing to do.


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About the author

Geoffrey Hawker is an honorary professor in Politics and International Relations at Macquarie University. He has worked as an academic in seven universities, as a public servant in Australian state and federal government, and for a decade as the principal of a consultancy firm. He has been a president of the Australian Political Studies Association and of the African Studies Association of Australasia and the Pacific and is currently editor-in-chief of the Australasian Review of African Studies. He manages a permaculture practice and education facility in country near Sydney.

  1. Hawker, Geoffrey (2024). Policy implementation. In Nicholas Barry, Alan Fenna, Zareh Ghazarian, Yvonne Haigh and Diana Perche, eds. Australian politics and policy: 2024. Sydney: Sydney University Press. DOI: 10.30722/sup.9781743329542.
  2. Hill 1997, 133.
  3. Koziol 2017.
  4. The Rudd government, for example, aimed to ‘close the life expectancy gap within a generation’: Department of Families, Housing, Community Services and Indigenous Affairs 2008, 5.
  5. Hewart 1929.
  6. Crossman 1956.
  7. Governments of the centre and left, coming into office for the first time or after a long absence, were typically likely to take an ‘instrumental’ view of their power to command policy, and were often disappointed; in Australia, the experience of the Whitlam Labor government (1972–75), mentioned further below, is a prime example.
  8. Graham et al. 2021.
  9. Australian National Audit Office 2022, 6, 67.
  10. Morrison 2019.
  11. Albanese 2022, 4.
  12. Garrett 1972, 45.
  13. deLeon and deLeon 2002.
  14. Gunn 1978, 169–74.
  15. Gunn 1978, 169–74.
  16. Gunn 1978, 169–70.
  17. The systematic review of policies with a view to reducing some so that others might grow began in Australia with an inquiry appointed by the Whitlam government at the start of its term, chaired by Dr H.C. Coombs (Coombs 1973) – not to be confused with the royal commission of 1974, also chaired by Coombs, that is considered below.
  18. There have been many later commentaries; see e.g. Schofield and Sausman 2004.
  19. Pressman and Wildavsky 1973.
  20. Matthews 1978.
  21. See for example Smith and Weller 1978.
  22. Royal Commission on Australian Government Administration 1976, 3.
  23. Royal Commission on Australian Government Administration 1976, 1, 15.
  24. Royal Commission on Australian Government Administration 1976, 1, 15–16.
  25. Royal Commission on Australian Government Administration 1976, 1, 35.
  26. Parker 1978, 345–59.
  27. Moran 2005.
  28. Hawker 1984.
  29. Tawney 1952, 49–50.
  30. Lipsky 1971. Though this chapter is about public policy, we can note that management theorists were thinking similarly about the organisations of the for-profit private sector; ‘classical’ (a version of top down) management was giving way to methods that allowed workers ‘to make the fullest possible contribution to … plans and decisions’ (Garrett 1972, 63). This points to the deep social changes underlying the routines of organisations, whether governmental or private.
  31. Barrett 2004, 259–60.
  32. Thus the Australian Bureau of Statistics (ABS) suggested that the ‘denial of service’ (DDoS) attacks that marred the 2016 census could be attributed to its contractor, the IBM company: ‘The online Census system was hosted by IBM under contract to the ABS and the DDoS attack should not have been able to disrupt the system. Despite extensive planning and preparation by the ABS for the 2016 Census this risk was not adequately addressed by IBM and the ABS will be more comprehensive in its management of risk in the future’: ABS 2016, 4.
  33. Einfeld and Blomkamp 2021.
  34. Madanay and Ubel 2021; see also Ball and Head 2021.
  35. McGaughey et al. 2021 quoted in Blakkarly 2022, 36; see also McGaughey et al. 2021. For media reporting of a company’s behaviour, that might be considered ‘implementation’ of the policy, see for example Barrett 2022.
  36. Kingdon 1984.
  37. Cohen and Aviram 2021; see also Visintin et al. 2021 and David 2019.
  38. Blomkamp 2018.
  39. Department of Prime Minister and Cabinet 2022.
  40. Department of Prime Minister and Cabinet 2022 – the PMC Implementation Plan (Extract): Regulatory Impact Analysis (RIA) and Implementation.
  41. Colebatch, Hoppe and Noordegraaf 2010, 243.
  42. Hill 1997, 139.


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