The Australian Communications and Media Authority now believes more than half of its activities demonstrate world-leading performance, based on a new self-assessment report to be released tomorrow.
The report considers 113 separate business activities, 64 of which “are seen as fulfilling the character of world-leading performance” by the regulator. They include 43 proudly put forward as “case studies where the ACMA considers it is world-leading, or adapting to change through setting emerging practice” and 21 described as “sustaining, contributing to and supporting” its high standing in the world.
The remainder of the 113 organisational endeavours are broken down into two other categories signifying there’s more work to be done: 16 are seen as “emerging” with the potential to become examples of world’s best practice, and 33 are “still in development or [areas] where the ACMA aspires to further improvement”.
ACMA’s “Meeting our Standard” project began in 2008, when chair and CEO Chris Chapman set an aim to be “the world’s best” at what it does, and be recognised as such. But how? There is no internationally recognised standard for accurately judging the world’s best converged communications and media regulator, and Australia’s information referee decided it was not feasible to create one. Delivering the Charles Todd Oration in 2012, Chapman explained the approach that was taken:
“Because measuring converged communication regulation performance in a globally valid way is inherently problematic, we chose to take a narrative approach, using descriptive case studies, rather than one of meaningful measurement. Judging the world class nature of the case studies was based similarly on an internal assessment, which was then validated with internal and external peer review.”
Chapman told The Mandarin he recognised that setting such an ambitious standard — in this case the highest possible — could be “threatening” to the organisation’s management and staff, and “counterproductive” if poorly executed.
“External recognition of the accomplishments is part of the process, part of the communications process, which is why we’re releasing the third iteration … It’s an ongoing narrative … and it’s designed to communicate and implicitly provoke a response, to provoke feedback, to seek confirmation, to seek guidance, to seek external views,” he said today.
Subject matter experts called “case study champions” took charge of each area identified as potential best practice and worked collaboratively on an internal website. The site was opened up to all staff members, who were invited to contribute via a wiki-style editing process.
“Whether you’re in the bleeding edge of interaction with field operations, or you’re in a corporate role involved with revenue assurance, everybody is encouraged to document their narratives, everyone’s encouraged to identify future improvement opportunities — what [the report calls] ‘in development’ — and so it’s a very healthy exercise to bind the organisation together, to share information, to encourage participation of all staff members,” said Chapman.
The internal review process inside ACMA allows staff of all levels across nearly 50 different sections a chance to validate each other’s successes, and the case study champions seek external feedback as well. The report explains:
“While the internal review was underway, case study champions contacted regulatory colleagues and other peers seeking feedback and review of the performance described in the case studies. They also asked for views about where the ACMA could improve, as well as comparative international, regional or local information about similar programs or activities …
“International comparisons are made with similar regulatory policies where information is available. While some case studies demonstrate world’s best practice or world-leading performance, others may showcase a unique Australian solution or approach, show something that a world-class converged regulator must do to claim to be world-leading, or are examples of emerging world practice in adapting to change.”
Chapman says the “regulatory colleagues and peers” come from a database of key stakeholders that is approaching 1000 entries, representing the four converging worlds of broadcasting, telecommunications, spectrum regulation and the internet.
“Each of those worlds has many layers, they’ve got many competing sectors, they’ve got many industry associations and they’ve got many counter-parties internationally,” he explained. “And so domestically and internationally, from a number of key regulators to a number of key industry bodies in Australia, we have any number of opportunities to get feedback.”
The new report also describes additional responsibilities to carry out the Coalition’s red-tape cutting agenda:
“As part of a broader government initiative to reduce the regulatory burden for business and the community, the ACMA is modernising its regulatory framework, by systematically and diligently removing outmoded and burdensome elements. The aim, based on first principles thinking, has been to assess the fit of regulatory tools to the convergent network-driven economy, simplifying remaining standards, regulatory policies and instruments, and aligning them with enduring public policy outcomes. The ACMA is therefore currently engaged in a vigorous program of regulatory reform, including the removal of redundant instruments and a large number of reporting requirements, with a move to review and auditing. Regulatory costs to industry will be significantly reduced in the coming years.”
Planning for a converged media future
Since ACMA’s inception in 2005, Chapman has recognised it operates in a rapidly and constantly changing environment, as the four worlds of communication it supervises converge in the digital age. The shoot-for-the-moon standard is part of a strategy to keep the agency relevant, allowing it to go on with its mission “to make communications and media work in Australia’s public interest”.
“The standard was designed to provide traction and focus internally, and to aid and facilitate the transformation of the agency from what was a very highly technical, highly efficient but nonetheless traditional, conservative organisation, to one that is agile and flexible and is innovative and can handle any challenge thrown at it,” said Chapman.
The last update, in March 2013, assessed 94 areas of activity and also placed them into four categories, but these were given different names and only the top 37 were said to show ACMA “meeting or leading world’s best practice”. Another 15 were described as “emerging” followed by 19 that were “aspirational” and 23 “in development”. In 2011, the first report against the nascent standard looked at 83 operational areas and found 27 meeting it.
Chapman says the evolution of the assessment framework over the years has two aspects. “One is … that we don’t claim to be world’s best or world leading or best in breed in every area of activity. That would be hubris in the extreme. The reality is that we tell the world our assessment that in a number of areas, we can do better; we need to do better. And that’s reasonably naked. It’s as much an open admission that there is further work to do as it is an acknowledgement — internal, admittedly — for work well done,” he said.
So while sceptical observers might criticise the exercise as a way of ACMA drafting and filling out its own report card, Chapman says it is also “being very honest” about where more work needs to be done. “And I think that’s a very healthy admission,” he added.“We are forever reprioritising our workload and reprioritising where we spend money …”
“The second aspect is that the structure has evolved … to the point where we’ve built in this ‘sustaining’ category. We, like all aspects of government, are understandably under scrutiny for performance, and accountable for the money the government provides and the way we spend it. And that scrutiny and that accountability is only going to go in one direction, obviously, and that’s further increases. We are forever reprioritising our workload and reprioritising where we spend money, because our annual allocations are going south and our workload, as a gross generalisation, is going north.
“And so we have to do more with less all the time and yet maintain our relevance and deliver on our outcomes, and the reality is that we have to just draw a line on some aspects of our regulatory processes.”
The introduction of a category below the “world-leading” case studies for operations that are “sustaining world’s best practice” in this year’s report reflects the choices ACMA has to make about where it spends its money, according to Chapman, as well as the fact that some activities are “a bedrock for everything else”.
“The overall category of ‘world’s leading and sustaining’ is, as a percentage, increasing over time,” he said. “I think that’s a very positive run rate.”
The ACMA boss also points out the agency is well positioned for the new uniform reporting framework being developed for the Australian public service under the new Public Management Reform Agenda, thanks to the project.
“We weren’t to know when we started this exercise that it was coming down the turnpike, but one of the guidelines provided with respect to this new framework was an encouragement of agencies to use greater narratives of what they do, and I couldn’t help but think that was a nice confirmation, because we’re taking a risk, we’re putting our head up above the parapet, we’re putting it out there, and lo and behold you get some encouragement that … you’re [already] doing something in the right direction,” Chapman said.
External review of the assessments goes beyond industry stakeholders and interested fellow regulators. Anyone who disagrees with the assessments or wants to have their say on the regulator’s performance is invited to do so using an online comments box on the ACMA website, after each new “Meeting the Standard” update report is published.
This open invitation to anyone to have their say was “a vital sanity check on our own assessments”, Chapman said in his 2012 speech, not long after the release of the controversial Convergence Review. After the speech, he told reporters he was “gobsmacked” by the review’s recommendation that ACMA — the Commonwealth’s fourth largest collector of taxes and levies — be replaced.
In an increasingly contested environment where even agencies like ACMA need to constantly demonstrate their worth, “Meeting our Standard” becomes more than an internal assessment process towards a guiding target. It is clearly a strategic communications exercise as well, and one that is aimed as much at the government of the day as industry stakeholders and the public.