Thursday, 3 August 2023

Labyrinth: the Productivity Commission Draft Report on Closing the Gap

 

…. that our stars,

Unreconciliable, should divide,

Our equalness to this.

Antony & Cleopatra Act V, scene 1


The Productivity Commission (PC) has released a draft report on its review of progress on closing the gap (link here). The draft report package comprises a nine page plain English executive summary (which I found extremely useful); a 15 page Executive Summary which includes six draft recommendations and a series of requests for information/feedback; a 101 page Draft Report, and a series of seven information papers totalling around 280 pages.

 

The review arises from the terms of the National Agreement on Closing the Gap (link here), in particular, clauses 121 to 124. In particular, clause 121 states:

The Productivity Commission will undertake a comprehensive review of progress every three years … It will provide an analysis of progress on Closing the Gap against the priority reforms, targets, indicators and trajectories, and examine the factors contributing to progress, including by drawing on evaluation and other evidence. 

 

The political and media reaction to the Draft Review has been predictable with a large focus on the report’s implications for the Voice (which to my mind prioritises means over ends). The Australian ran a series of articles on 26 July 2023 (behind its paywall) with headlines such as ‘Closing the Gap failures “show why the vote must succeed”’ (a view espoused by Minister Burney); ‘Indigenous watchdog “with bite” called for regardless of voice vote to deal with Closing The Gap’; ‘Closing the Gap scheme flounders within states of cynical disregard’ (arguing the states have dropped the ball); and an editorial headed ‘Bureaucracy firmly in the sights’. The Chair of the PC, Michael Brennan published an article in the AFR on 30 July (link here $) titled ‘The gap won’t change without fundamental change’. The money quote was his assessment of progress on closing the gap as ‘in large part, a hotted up version of business as usual’. Crikey published an analysis (link here) with the headline ‘Why the Productivity Commission thinks a Voice is needed to Close the Gap’. This is arguably a misinterpretation of what the PC intends. In a perceptive comment on that article, Jon Altman wrote, inter alia, that the PC

continues to produce detailed and expensive report after report carefully documenting the nation’s failure to properly address Indigenous disadvantage. But it does not address the first order issue: is the National Agreement on Closing the Gap framework a sound basis for policy formation? And will valorising equality for Indigenous populations as state-defined statistical subjects generate positive wellbeing outcomes for First Nations people in all their diversity?

 

Like Jon, I wish to focus on the policy issues rather than the quotidian political debate about the Voice (important as that is).

 

The nature of the PC review

There are a number of seriously problematic issues with the draft review (which I will seek to identify below); but these can be traced in large measure to a more fundamental issue: the PC appears to have veered away from the comprehensive review envisaged in the Agreement. The terms of reference for the review provided by former Treasurer Frydenberg in April 2022 state, inter alia:

Scope of the review: In undertaking the review, the Productivity Commission should:

1. analyse progress on Closing the Gap against the four Priority Reform outcome areas in the Agreement;  2. analyse progress against all of the socioeconomic outcome areas in the Agreement; and  3. examine the factors affecting progress. 

 

These tasks can be interpreted in one of two ways. They might be pursued broadly and holistically, in effect asking the strategic question: is the current Closing the Gap process meeting the objective of the agreement laid out in clause 15 of the National Agreement? Or they might be addressed narrowly and less consequentially, in effect asking the question, are the terms of each element of the agreement being met whether or not they are impacting the overall outcome being sought. Unfortunately, on my reading of the report, the PC has adopted the latter approach. I made this argument more expansively in my submission to the review (link here submission #5) based on my reading of an early issues paper.

The result is that despite nearly 400 pages of investigative narration, we don’t really obtain an effective readout on the required new policy roadmap for closing the gap. Instead we get what seems at times an interminable litany of proposals for improved ways to hold governments accountable for particular cogs in the complex machine that comprises closing the gap. I am all for holding governments accountable, but there is an implicit assumption embedded in calls for improved accountability that governments are in fact focussed on implementing actions designed to achieve the overarching objective of the National Agreement. If that assumption is wrong, then all that will be achieved will be more complexity, more engagement/involvement, more process, more bureaucratic kludge, and no change.

 

How might we determine if that assumption if in fact correct? The answer is by examining the tangible plans that exist to achieve the objective. Take this analogy. If I have an objective to build a new home, I develop a plan (let’s call it an implementation plan). I buy some land. I consider what I need to make the home useful to me. I engage an architect, and develop detailed designs and have the design specifications costed. I allocate financial resources both for the capital costs (construction) and for the ongoing maintenance. If there is a mismatch between design and available financial resources, I either adjust the design or allocate more financial resources. This is not rocket science. If I don’t have a plan; if I don’t develop designs that provide tangible links between my aspiration/vision and the ultimate outcome; if my designs are not able to be constructed at present because the materials required are not available; or if I don’t allocate resources and have some idea about how much it will cost; then an objective observer would conclude that I am not serious…

 

In relation to closing the gap, the National Agreement sets out the aspirational plan and steps to achieve the ultimate objective (clause 15 says it is reduced inequality between indigenous and other citizens). But Governments have failed to take it further. The implementation plans produced so far (required under the agreement) are not in fact implementation plans, but lists of what governments are already doing with some marginal new monies added. The PC identified that jurisdictional implementation plans were not fulfilling their intended purpose. See Box 4 on pages 27-8. I don’t agree with the detail of the PC analysis; for example, the Joint Council has agreed that the implementation plans be produced annually, a matter which strikes me as ridiculous, yet not commented upon by the PC.

 

To return to the house construction analogy, you don’t develop an implementation plan iteratively for each month or quarter of construction, but for the complete project. Instead the PC argues for codesign of these plans which is superficially attractive to Indigenous interests, but will inevitably produce delay and a bureaucratic morass (already a problem with this whole process). The time for Indigenous codesign is in developing the targets. Governments then must deliver against them, consulting and codesigning with relevant Indigenous interests as they go. The fact that jurisdictions do not have adequate and effective implementation plans is a fundamental flaw that requires rectification.

 

In relation to identifying the cost of closing the gap, including perhaps its constitutive elements, Governments have made no commitments. Instead, they merely publicise the financial commitments they make, often with little transparency of what the expenditures are achieving. Worse still, in contrast to the original Closing the Gap architecture under COAG (known as the National Indigenous Reform Agreement or NIRA), governments do not in general utilise decade long financial allocations. The problem with this general approach is that there is no way of knowing whether the financial commitments of governments are adequate or not. It is a truism that money is not everything, but in this case, it is an essential component of strategies to reduce inequitable access to services and basic infrastructure (like housing). Adequate funding may not be sufficient, but it certainly essential.

 

In my submission to the review, I argued that the PC should seek to estimate the likely total cost of closing the gap. To return to our analogy, we don’t start building a house without knowing what it will cost. Unfortunately, the PC has ignored this element of my submission. It is bad enough that governments do not estimate these costs, but it is an egregious dereliction of responsibility for the ‘independent’ reviewer to ignore this issue. No other area of public policy is seriously analysed without a focus on cost. In areas of high ideological salience like defence, the debate over cost is assessed not just in terms of real growth rates, but the proportion of GDP allocated to the task (link here). In Indigenous affairs, all we get is an incessant flurry of media releases announcing this grant and that, often directed at squeaky wheels.

 

One of the consequences of this seemingly deliberate blindness by the PC is to promulgate and maintain the myth that closing the gap is solely of concern to Indigenous interests. If adequate resources are to be allocated to addressing Indigenous disadvantage, then mainstream attitudes need to change. This requires understanding which is best obtained by encouraging wider community involvement in the processes associated with closing the gap. [As an aside, the forthcoming vote on the Voice is another example of the importance of building wider community understanding in relation to the issues of core concern to Indigenous citizens.]

 

A further issue identified by the PC relates to the status of the targets in the Agreement. This is addressed at length in Information Paper 6, but it is too convoluted to dissect here. Instead I suggest interested readers look at the plain English Executive Summary (link here). Alternatively, see the discussion on page 5 of the draft review. Here are some choice extracts from the Summary (pp. 6-7) regarding targets and data (emphasis added):

For clear progress on the socio-economic outcomes and Priority Reforms, the Agreement says there must be: • performance tracking • public reporting. But doing this has been a big challenge.  The Priority Reforms are the basis of the Agreement. Even so, governments report no data on: • the agreed targets  • indicators that support the Priority Reforms.  These are critical gaps in data. 

Also, progress on socio-economic outcomes is measured against national targets. It is not clear how to hold governments accountable for what happens at the regional level.  There are no data developed for: • any of the targets under the Priority Reforms • 4 of the 19 socio-economic targets • roughly 140 supporting indicators  • more than 120 data development items. 

We probably will not see these data developed within 10 years from the start of the Agreement (that is, by 2030).  More effort is needed to: • improve governance  • prioritise data development.

 

In other words, we have the policy architecture, but not the means to implement it. The PC recommendation is for a dedicated government agency to drive data development. I beg to disagree. To return to the house construction analogy, we have constructed the frame, but the walls and roof are missing as the relevant materials are not yet available or developed. Do we appoint another builder to supervise the current builder, or go back to the drawing board?

 

I suggest the Commonwealth should step in and initiate an immediate process of radical simplification to take this process back to its core purpose. There is a need to consider once again what the targets are actually for: instead of providing a policy roadmap indicating that we are heading in the right direction, they have been transformed into an attempt (that is bound to fail) which seeks to guide us each and every step along the way. Nineteen targets times eight jurisdictions plus hundreds of supporting indicators and data development items again across eight jurisdictions, all under constant change and refinement, and we have a data labyrinth which is guaranteed to ensure that any one foolish enough to enter is swiftly lost in the bowels of the machine.

 

There are a range of other issues embedded in this draft review that require detailed consideration by those interested in seeing Indigenous inequality and exclusion removed from Australian society. I will address a few below in no particular order.

 

Conceptual issues

 The philosophical and ethical issues that are embedded within the notion of closing the gap receive too little attention by policymakers. The tension between the state’s rhetorical focus on removing inequality and the right of citizens, particularly Indigenous citizens, to choose fundamentally alternative ways of living (implicit in the rhetoric of self-determination), which Jon Altman alluded to in his comment to Crikey quoted above, is of enduring relevance in the policy quest to close the gap. It is an issue that is generally avoided as ‘too hard’ by policymakers, yet lies at the heart of much Indigenous distrust of governments and their bureaucratic processes. Altman explores this issue at length in this submission to the PC inquiry into an Indigenous evaluation strategy (link here sub.#23). The PC has entirely ignored these issues in its draft report; a reflection in my view of its lack of analytic interest in exploring what it is that the Closing the Gap process is seeking to achieve.

 

Deficit discourse and remote disadvantage

One of the key polemical drivers of the Closing the Gap refresh process initiated by the former LNP Government which led eventually to the National Agreement was an ostensible reaction to the notion of deficit discourse which advocates argue is designed to blame Indigenous citizens for their own disadvantage. This is clearly an important policy insight, one that has recently been highlighted in relation to mainstream disadvantage by the Robodebt Royal commission (link here page iii). Yet when this concept is taken to extremes, it undercuts the whole point of closing the gap.

 

Unfortunately throughout the draft report, the PC appears to have adopted and endorsed such an extreme interpretation uncritically, thus setting up a polemical dichotomy where governments can do no right and must be held accountable for every shortfall and (paradoxically) where Indigenous interests are ongoing victims without agency. So for example, in Information Paper 6 (Link here pp. 14-5), the PC writes:

Review participants indicated a role for performance monitoring in supporting a paradigm shift in policy narratives about Aboriginal and Torres Strait Islander people. This shift moves policy discourse away from framing Aboriginal and Torres Strait Islander people as a disadvantaged minority towards rights-bearing peoples with strong connections to diverse cultures, Countries, and communities that have withstood current and historical institutional racism …  In its submission, the Lowitja Institute explained: Data is a powerful tool. Data can be used to hold governments and the community-controlled sector to account on actions under the National Agreement, however there is a risk that this can be decontextualised and misused if data sovereignty and data governance mechanisms are not in place. The oversupply of deficit-based data has created a discourse that sees Aboriginal and Torres Strait Islander peoples presented as a problem, or as wholly responsible for inequities…. (sub. 15, p. 7). (emphasis added)

 

One consequence of this aversion to anything that even hints at deficit discourse is that important issues at the core of ongoing Indigenous exclusion and disadvantage are being deliberately written out of the policy relevant narrative and thus the policy agenda. It may not be a coincidence that given the current demography of Indigenous Australia (link here), it would be theoretically possible to conjure a positive narrative on progress in closing the gap while ignoring the needs of remote Australia. The losers from this process are the most disadvantaged Indigenous citizens, particularly those in remote regions. So for example, in the 101 pages of the draft report on the status of closing the gap, there are only seven mentions of the word ‘remote’, most just passing references, and there are no specific statement by the PC referencing the fact that Indigenous disadvantage is deepest and most severe in remote regions. The closest is a reference in a case study on the Torres Strait on p.62 where the Torres Strait Council refers to its very remote location as an issue.

 

Yet the PC itself, in its July 2023 Annual Data Compilation Report identifies (albeit in cautious bureaucratese) the dire state of disadvantage in remote regions (link here page 30):

People living in a more remote area may experience additional barriers to better outcomes; for example, not having access to key government services or infrastructure at the same level as people living in other areas. Aboriginal and Torres Strait Islander people typically experienced poorer target outcomes as remoteness increased, which was mostly not the case for non-Indigenous people … Aboriginal and Torres Strait Islander people living in more remote areas also saw less progress toward target outcomes. Target outcomes typically only improved for Aboriginal and Torres Strait Islander people in major cities and regional areas where there may be fewer barriers, including better access to key infrastructure. There was little or no improvement in remote and very remote areas. The exception was for target 9A ‘appropriately sized housing’ where outcomes improved the most in very remote areas, though they remain well below the outcomes in less remote areas…

 

Or more starkly, in the same report the PC states (emphasis added):

One jurisdiction where the worsening outcomes are particularly concerning is the Northern Territory. The Northern Territory’s outcomes worsened across eight target indicators and in most of these they were already performing relatively poorly at baseline compared to other jurisdictions. For example, the adult imprisonment rate in the Northern Territory increased at the highest rate despite already being above the national average at baseline.

 

It is worth noting that the NT has the most geographically concentrated remote population, and has the weakest financial base in the federation.

 

Priority Reforms

The PC’s approach to assessing progress on the Priority Reforms, particularly Priority Reform 3, is in my view deeply flawed. I dealt with this in my submission to the review, so won’t duplicate it at length here. The key point is that increasingly, mainstream policies and programs are gaining greater salience across the indigenous policy domain. Ensuing mainstream agencies are focussed on addressing Indigenous disadvantage in their core activities is crucial to ensuring that there is a whole of government focus on these issues. Yet treating the priority reforms as akin to mechanically constructed targets, and measuring important but incidental issues such as levels of racism within agencies as the metric of success is a recipe for failure and non-performance. Unfortunately, the PC does not see this as they ignore this issue in its entirety.

 

Concluding comments

The problem with this draft review is that it is fundamentally misconceived, and fails to step back and look at the nation’s approach to closing the gap holistically. This was a crucial opportunity only three years into the revised process, and unfortunately, the PC has failed to grasp it. There is a lack of real policy analysis throughout this report, and the attached information papers.

 

As a consequence, the review fails to ask the hard questions and ignores many aspects that should have been front and centre. For example, there is no substantive assessment of the operations of the Joint Council. There is no assessment of the capability requirements on the Coalition of Peaks and whether the current levels of support are adequate. There are mentions of states failing to deliver on their commitments, but no real solutions offered in response. There is no recognition of the primacy of the Commonwealth in the federation, and the implications of the deliberate strategy embedded within the architecture of the agreement for the Commonwealth to outsource its overarching responsibilities to the Joint Council and the states. There is no analysis of the nature of the refreshed targets which are increasingly not focussed on comparative economic and social status, but are framed in terms of absolutes (ie improvements on current levels).

 

There is no recognition that the current design architecture for the agreement, while incomplete and thus subject to ongoing remedial work, is simultaneously over designed and in need of radical simplification. As presently configured, it guarantees that the Coalition of Peaks (representing Indigenous interests) will be wading through bureaucratic sludge for the next ten years, and thus effectively distracted from the main policy game. It also ensures that the probability of the national agreement imploding under the weight of its accumulated complexity is high and bound to grow. Proactive reform is preferable to stasis followed by abolition.

 

The bottom line however is that the six recommendations of the draft review (see pages 10-15), if implemented, would in my view not make any substantive difference to the nation’s progress on closing the gap within five or even ten years. They are an amalgam of doubling down on the current hyper-complexity of the policy architecture along with a hefty dose of blind faith in the bureaucratic leadership of the nation. Did the robodebt royal commission not make any impression at all on the PC? Notwithstanding the PC Chair’s view in his recent AFR article that governments are engaged in ‘a hotted up version of business as usual’, the draft recommendations in this report might be characterised in similar terms.

 

I have a recommendation for the Commonwealth Government. Issue the PC with revised terms of reference, and perhaps an extension of time. Request them to (a) develop an estimate of the cost of addressing the entrenched inequality facing Indigenous Australians; (b) map out a realistic timeframe and strategy for achieving that objective; (c) make a more fundamental analysis of the current status of the Closing the Gap architecture; and (d) provide options for radically simplifying the structure and design of the current architecture while retaining the four priority reforms. And for good measure, keep it to fifty pages. Such a report would then allow the Commonwealth Government to meaningfully and honestly engage with Indigenous interests and the states and territories.

 

3 August 2023

Note this post was amended on 4 August to correct a number of typographical and grammatical errors

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