Challenges to policy transfer between countries.

Introduction:

Cross-national policy experience is having increased effect on policy actors. The concept of policy transfer is interlinked with the broader concept of policy learning and policy networks (Borzel, 1998: 265-267). There is also growing agreement that policy transfer is not a separate process but rather a part of broader policy process (Wolman, 1992: 44). Due to the complexities of policy processes, there is increasing trend of learning from others’ policy practices. Many scholars propose different views on policy transfer which reflects the complexities as well as opportunities and challenges of policy transfer. While various mechanical and linear approaches are prescribed; role, interest and motivation of actors are illustrated; and politics of trade between buyer and seller is analysed, policy transfer still lacks a comprehensive framework that standardises the smooth and efficient transfer across actors, institutions, issues and geographies.

I attempt to assess the challenges of policy transfer. The discussion is divided into three parts. First, the concept of policy transfer is explained by differentiating between policy transfer and other policy practices. The second part is focused on analysing the challenges of policy transfer. The third part concludes the essay with highlight of the challenges to policy transfer between countries. Where appropriate, empirical evidence are presented to assess or further corroborate the epistemic logics.

Concept of policy transfer:

Policy transfer, diffusion, convergence and lessons learning or drawing are a process or set of procedures that covers the evolution, experience, and effects of a particular policy issue in one context or country to another context or country. Lesson drawing draws on foreign experience to offer an alternative to a policy problem facing national policymakers in their country (Rose, 2005: 23). Rose further explains that since lesson drawing provides the option to look at the present context of policy in origin, it can avoid the prescription of ‘one-size-fits-all.’ Before deciding on the final import, the policy actors can also choose from various lessons in different countries. However, it is a common practice that countries with similar political and socio-economic ambiences often look at each other to draw the lessons from. On the contrary, the developing countries with limited resources or fragile institutions, are often influenced by the developed countries and supranational organisations to draw lessons from them.

The concept of diffusion refers to the idea that policy choices made in a given place and time are often influenced or determined by the policy alternatives made elsewhere (Berry & Berry, 1999: 169-200; Gray, 1994; Walker, 1969: 880-899). Or in simpler word, diffusion is a process of policy choices made in one country with effect in another country (Braun et al., 2006: 299; Meseguer et al., 2009: 537) or even between different units (Marsh et al., 2009: 287) and focuses on process rather than outcomes (Elkins et al., 2005: 598). On the contrary, Knill (2005: 767-768) argues that policy convergence differs from policy diffusion and transfer in two ways; analytical focus on effects and difference in the dependent variables, i.e. convergence explores the changes in policy similarities and not on the adoption of patterns or the contents and processes that serve as variables to the policy diffusion and transfer.

Policy transfer, on the other hand, is more of a combined form of different concepts which is similar regarding process but has variations in approaches (Cairney 2012: 250). With some common characteristics between policy transfer, imitation and lesson drawing, which is not ‘overly significant’ as Dolowitz and Marsh (1996: 345) note, policy transfer employs some peculiar features. They define policy transfer as a ‘process in which knowledge about policies, administrative arrangements, institutions and ideas in one political setting (past or present) is used in the development of policies, administrative arrangements, institutions and ideas in another political environment’ (Dolowitz & Marsh 2000: 5). The definition, thus, stands the transfer aside from other similar concepts. Dolowitz & Marsh also offer a ‘Policy Transfer Framework’ which consists of six questions: why policy transfer? Who are the key actors? What is transferred? Source of lessons drawing? Degrees of transfer? Constraints of transfer? In addition to these six questions, they also find a new question focusing on the processes of policy transfer in relation to its success and failure of the transferred policy.

The integration of various aspects of the policy transfer attempt to avoid the derivative policies as well as focus more on the processes. Since the public policy actors are facing increasing complexities and pressures to have more robust and evidence-based policy solutions, policy transfer, thus, focuses on one or more of three areas of normal policy analysis: description, the process of policy transfer; explanation, the need for a policy transfer; and prescription, the ideal way of policy transfer (Evans 2009: 238). In practice, however, the decision makers and types of transfer also influence the goal, process and outcomes.

There are two types of policy transfer; voluntary and coercive. The voluntary transfer is associated with Rose’s (1993) lesson drawing which deals with the free selection of policy or practice adoption from another place or time and which is often the result of perceived dissatisfaction with existing policy arrangements (Bennett 1991: 215-233; Dolowitz & Marsh 1996: 344-349). On the opposite, coercive transfer focuses on creating an obligatory environment to accept a transfer. Dolowitz and Marsh (1996, 2000) explain that in the coercive transfer, agenda is set elsewhere and the importing country is expected to adopt a policy from somewhere to avoid the negative consequences. Coercive transfer can be categorised into two parts; direct and indirect. The direct coercive transfer is when one country or organisation forces another country or organisation to adopt a particular policy or practice. On the other hand, a range of factors, such as technological advancement, and pressure from global economic behaviours, influence a country to accept the certain policy or practice falls under indirect coercive transfer. It is worth to consider that there is, in practice, not much difference between voluntary and indirect transfer as both are influenced by external conditions or conditionalities, and a desire to stand with the international community. Such ‘desire’ is often created by exporting countries either directly or through supranational institutions and policy entrepreneurs with some ‘incentive’ in return of adopting the transfer. The next section of the essay discusses these conditionalities and incentives as well as other challenges to a policy transfer.

Challenges of policy transfer:

Due to the integration of various elements, types, actors and conditionalities, policy transfer is not a full-proof prescription. It has different scopes and challenges. This section of the essay focuses on the actors involved, nature, and determinants of the policy transfer.

1. Different actors with differing interests

Actors engaged in the policy transfer to create the demands, selling the idea and buying the ‘product’ is one of the key elements of policy transfer. Who conducts the policy transfer has attracted increasing attention in recent decades (Page 2000: 3-4). Various scholars propose different notions regarding the key players involved in deciding a policy transfer. Page (2000: 3) identifies two groups of agent engaged in a policy transfer; policy entrepreneur and policy salaried employee. The entrepreneurs identify and encourage others to import policy solutions whereas the salaried employees follow the instructions to find the solution elsewhere and recommend the best alternatives. Dolowitz & Marsh (1996: 345) categorise six actors in policy transfer; elected officials, political parties, bureaucrats/ civil servants, pressure groups, policy entrepreneurs/experts and supra-national institutions. Furthermore, due to the liberalisation and technological advancement, traditional notion of governance and public policy face a gap between demands and supply sides. Reinicke et al. (2000: ix-xi) emphasize that global policy networks are the new forms of entities to address the ‘governance gap’ in some of the pressing global issues and often engage in five core activities: (ii) facilitating and setting up global standard, (iii) gathering and disseminating knowledge, (iv) creating new markets for goods, services and practices, and (v) functioning as innovative implementation mechanism for traditional intergovernmental treaties. In addition to the actors involved in the policy transfer, it is also important to understand the players who finally decide on a transfer.

Government actors, institutions and politicians play a decisive role in policy making, change and transfer. In addition to the national organisations, as a focus of intergovernmental and supranational institutions for policy export, regional and local government institutions also play a considerable role in a policy transfer (Wolman & Page 2002: 497-498). At the international level, supranational organisations, policy entrepreneurs (backed by supranational organisations or exporting country), epistemic community, multinational or transnational corporations, powerful/innovative countries play a crucial role in either forcing or creating a ‘demand’ for policy import/transfer. Furthermore, globalisation promotes the role of intergovernmental agencies such as the Organisation for Economic Cooperation and Development (OECD) and global financial institutions (Benson & Jordan 2011:369; Stone 2004: 556). The European Union, for example, is a very active policy entrepreneur who often recommends best practices from dominant countries to other nations as well as transfers large-scale policy solutions to the candidate countries as a condition should a country wish to join the EU (Radaelli 2000: 26-27).

While the importing countries or institutions benefit from ‘readymade’ solutions of a policy problem, that they are not able to experiment or resolve themselves due to lack of resources or expertise, the benefit level is often discriminatory. The decision to transfer, even once, can establish longer term relationship of borrowing and lending (Cairney, 2012: 251) and while the importing country benefit temporarily, the exporting actors or countries remain dominant to set up conditions for longer term benefits. Different actors’ involvement in numerous steps or variations lead to a conflicting understanding of the objective behind a policy transfer. Also, most of the actors engaged in the policy transfer are often not the very influential ones in domestic policy subsystem (Dolowitz and Marsh, 1996: 345) and thus, a ‘good’ policy alternative cannot guarantee a smooth export and succeed in achieving the intended outcomes.

2. Conflicting views over the nature of transfer

Although policy transfer is a set of processes often guided by a framework, there is no persistency regarding the type or nature of policy measures. Import and export on policy matters significantly differ by type and extent (Cairney, 2012: 257). Since public policy is a complex and mulita-dimensional concept, Bennett (1991: 218) identifies five aspects; policy goals, policy content, policy instruments, policy outcomes and policy style. While this categorization is mechanical and linear, they tend to remain insensitive to the aspects of feedback and also lack clearly defined and analytical classification. Even if the regulatory policy outcomes remain alike across countries, the political processes or styles by which the outcomes are reached vary from one country to another. For example, Canada and the United States practised different methods or styles in adopting the Alachlor Regulation (Hoberg (Jr.) 1990: 261). Considering Benett’s five aspects as ‘too narrow’, Dolowitz and Marsh (1996: 349-350) propose seven objects of policy transfer: policy goals, structure and content; policy instruments or administrative techniques; institutions; ideology; ideas, attitudes and concepts; and negative lessons.

The policy change also suffers from the distinction like transfer as it varies across policy practices, patterns and countries. As discussed in the second section, based on Dolowitz and Marsh’s concept of policy transfer, the voluntary transfer is not completely free of external influences. Rather, factors, such as economic needs or meeting an international standard, often creates demand for a policy transfer (1996: 348-349). While coercive transfer has two divisions, there lies a fragile line between direct and indirect nature of a policy transfer. The issues of conditionalities, often set by supranational institutions, and voluntary international agreements, under the mechanism of transnational communication, play decisive roles when direct imposition of policies on one country by another is not possible (Holzinger & Knill 2005: 780-781). Holzinger and Knill, however, argue that the imposition of a policy by an international institution sometimes help the exporting government to introduce a policy solution despite opposition from its populace. There is, nonetheless, an agreement among the scholars that such imposition of policy to a country, whether by a country or by an international institution, promotes asymmetry of power (2005: 781; Hopkins et al. 1997: 513-514; Bennett 1991: 227-228). There is also conflict over the level of coercive measures (Cairney, 2012: 255). For example, establishment and legitimation of capitalist institutions in the developing world (Cammack 2004: 208-209), reinforcing ‘best practice’ (Stone 2004: 556), stringent rules of copyright and patent protection (Wade 2003: 80), and conscience capitalism in for-profit and non-profit entities (Farrell 2015: 528-529), are some of the widely used conditionalities which are guided by the conception that the importing countries cannot, by themselves, fix the policy problem without external export of policy solutions or practices.

The conflicting views on the nature of policy transfer do not always pressurise the developing countries; rich nations suffer as well. Bennett (1991: 228) claims that the effect is more coercive if a state is slow to act. For example, the Council of Europe and OECD developed an international agreement on the treatment and protection of trans-border data and demanded that countries lagging behind, such as the UK, to either readjust the domestic law or face the consequence of exclusion from the groups (1991: 228). Hence, different types and natures of policy measures complicate the process and affect the outcomes.

3. Determinants of success and failure

Dependency on importing organisation, resource constraints, clear cause-and-effect conditions, adequate information about policy and its functions, and whether the policy borrowing is hugely different than the original form (Rose 1993: 132) are some of the primary determinants of the successful policy transfer. Developing countries importing policy solutions often face more difficulties setting up preconditions for a successful policy transfer due to various reasons such as weaker institutions, fluid political environment, uncertainty in the market, resource constraints and socio-cultural differences (Dolowitz 2003: 106-107; Massey 2010: 212-213). Moreover, the uniformed, incomplete and inappropriate transfer can lead to failure (Dolowitz and Marsh 2000: 17). For example, the dysfunctional policy transfer in national tax blacklists not just copied the existing mistakes from the source but added additional ones, and in an extreme case, the inattentive policy makers even blacklist their own country, Venezuela (Sharman 2010: 636). Also, lack of ownership (Hopkins et al. 1997: 512), absence of regular follow up on policy choices (Cairney, 2012: 260), and ambitious and unclear policy issue leaving a lot of discretionary space to the implementing agencies (Duina 1997: 161-162), are other issues of policy convergence and conditionalities in the importing countries that can risk failure of a policy transfer. For instance, the governments seek out help from IMF even without facing economic hardship, and this exhibition of risk-prone behaviour is guided by the desire to be seen as a reputed and credible country by exporting political solution practised elsewhere, preferably from high performing countries (Meseguer 2006: 170-171). Reconstructing higher education in Kosovo is another example of the challenges of a policy transfer. The model is imperative for three reasons: one, a single case can consist of the elements of both voluntary and coercive transfer; second, policy entrepreneur and exporter have different views, and interests affecting the objective of a transfer; and third, even in a high degree of asymmetric interdependence, subordinate actors succeeded in cultured resistance tactics affecting the smooth transfer and successful policy outcome (Bache & Taylor 2003: 297-298).

On the other hand, the notion of bounded rationality for policy issues should not result from coercive policy transfer. Bounded rationality often pressurises the importing countries for faster policy transfer and does not allow enough time for creating a conducive environment or even reorganising the institutional arrangements crucially important for the unproblematic policy transfer and the positive outcomes (Cairney, 2012: 261). This is a common and well-proven practice that government or policy actors naturally learn from their mistakes, dissatisfaction or even the failure of any domestic policy issue (Dolowitz and Marsh, 1996: 348) before they try to learn or borrow from another country. However, Page (2000: 6) and Walker (1969: 889) argue that the search for policy solution in external countries with different political, social and economic environments do not necessarily provide the best alternative and repeatedly ascertain unrealistic given the difference between importing and exporting countries. Rose (1993: 98-99), on the contrary, argues that the similarity in policy conditions, geography and ideology, do not necessarily ensure the absolute likelihood of policy transfer between the importing and exporting countries.

Countries are more and more being influenced by external conditions, e.g. global economic forces, technical advancement and the role of supranational organisations, for policy transfer rather than their needs or conditions (Dolowitz and Marsh, 2007: 7). For example, Japan borrowed police system from Germany (Page, 2000:6) whereas any political system or country seeking ‘ideal democracy’ looks at Sweden and Germany is promoted as an ideal policy example of inflation control (Rose, 1993: 107-108). Also, exporter’s capacity to further lending with modification or improvements differs from country to country. And this asymmetric preconditions puts some countries in a position of ‘victim’ whereas some profit from policy transfer. Conversely, the preconditions or capacity of the borrowing country depend on issue-specific patterns of policy transfer. In addition to the patterns, multiple layers of the governance system also invite more intricacies in an efficient policy change.

Policy transfer, if linked with multilevel governance (MLG), becomes more complex as this bond, policy transfer and MLG, spreads across multiple levels of governments. Adoption of policy transfer at one level may undermine interdependence and lack of cooperation at another further exaggerating implementation gap and consequence of policy transfer (Carney, 2012: 262). In some successful cases, however, the symmetric partnership between concerned policy actors can help in standardising the policy alternatives which function well even in countries with differing characteristics. For example, the Bologna Process is established as an international platform for a two-cycle degree structure which was drawn from the OECD countries, promoted by international organisations and later, redefined, refined and is finally functioning as a considerable level of cross-country policy practice even without a binding legislative measures (Voegtle et al. 2011: 92).

Conclusions:

Policy change or policy making has different concepts such as policy transfer, diffusion, convergence and lessons leaning. With some common characteristics between policy transfer, imitation and lesson drawing, policy transfer represents some distinct features, i.e. similarity in processes and but variation in approaches. There are two natures of policy transfer: voluntary and coercive and coercive can be divided into two types; direct and indirect coercive transfer. Since various global external conditions create demand for policy transfer, it is, in practice, difficult to draw a clear line of distinction between voluntary and indirect coercive transfer. While the voluntary transfer is influenced by external factors and demands, there exist an overlap between voluntary and coercive policy transfer. In the absence of a standard set of parameters, nature of the transfer varies and create stricter conditionalities for the importing country. The variation of the natures affects the processes and outcomes of a policy issue.

Policy transfer is often influenced by bureaucrats and politicians, through state institutions, and other intragovernmental and supranational organisations. But, the non-state actors and epistemic communities also play important roles in creating the demand and exporting and importing policy solutions. While various actors are involved in the process of a policy transfer, only a few make the final decision among the choices. However, the actors who decide on the policy transfer often are not the most influential in domestic policy subsystem. Hence, the diverse actors and their interests often create a gap between exported policy and policy objectives.

Various factors determine the success or failure of a policy transfer between countries. Domestic Prerequisites: social, economic and political environment; governance system and layers; commitment, interest, capacity and ownership of actors and agencies involved; nature of policy problem; and resources to import and sustain the transfer, determine the quality of transfer and adoption. On the other hand, policy transfer is also challenged by external factors or conditionalities: who is importing; nature of transfer; conditions and motivation; the relationship between importer and exporter; and the likelihood of success. In practice, however, many good policy practices suffer from haste policy transfer due to imprecise decision or imposition by policy supplier.

Complex policy issues are difficult to borrow comparing to the simpler one whereas some countries benefit more and even trade to others after enhancement. Concisely, policy transfer is not purely objective or technical, rather a political process and the challenges primarily diverge by issue, nature, approach, credibility and likelihood to solve a policy problem in borrowing country and motivations and conditions of exporting countries.

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