Agency analysis of the National Board of Appeal for Student Aid (2020:9)
The Swedish Agency for Public Management (Statskontoret) has been tasked by the Government with performing an agency analysis of the National Board of Appeal for Student Aid.
The National Board of Appeal for Student Aid examines and decides on appeals against decisions by the Swedish Board of Student Finance (CSN) regarding granting and reclaiming student finance. The agency also tries appeals against CSN's decisions regarding apprenticeship allowance and education entry grants. The National Board of Appeal for Student Aid does not however make decisions regarding repayment cases. The National Board of Appeal for Student Aid is the highest instance in the matters on which it decides and it is therefore not possible to appeal against its decisions. The agency's decisions are general recommendations to CSN regarding how regulations for the various forms of student financing should be applied.
The National Board of Appeal for Student Aid has a secretariat employing approximately 17 full-time equivalents, as well as a separate decision-making body, the Board of Appeal. The Board of Appeal only decides on important cases of principle, while the secretariat deals with routine cases. The National Board of Appeal for Student Aid's appropriation for 2019 was SEK 15.3 million.
The agency succeeds in meeting its goal for the turnaround of cases but not for following up its activities
In the opinion of Statskontoret, the National Board of Appeal for Student Aid fulfils its assignment in terms of dealing with cases in the allotted time; however, the agency does not plan and follow up other more qualitative operational goals in a systematic manner. As a result, the National Board of Appeal for Student Aid has few means for accessing whether it is performing its work effectively and if its operations are legally certain and of a high quality.
Furthermore, as a relatively small agency, the National Board of Appeal for Student Aid has the possibility for short and informal decision-making processes. In our opinion, the oral culture currently prevalent within the agency presents risks to efficiency, legal certainty and quality.
Internal governance and the division of responsibility require clarification
Our analysis shows that the National Board of Appeal for Student Aid needs to clarify internal governance and prepare written internal procedures. The agency should refine the roles of the Director General and Deputy Director General and make clear the division of responsibilities between them. Statskontoret believes that their main duty should be to lead and develop core operations while delegating administrative tasks and HR issues to other functions.
In order to streamline operational support at the National Board of Appeal for Student Aid, the agency should either gather such tasks within a single function or cooperate with another government agency to obtain certain administrative functions jointly.
The agency should also prepare a written document that clarifies the agency's working methods and the roles of its various functions. In our opinion, such written procedures are especially important for an agency that functions much like a court of law, in order to ensure that that the National Board of Appeal for Student Aid's case management and judgements are as unambiguous and consistent as possible.
There should also be a specific forum in which departmental managers can regularly discuss and exchange experiences with one another, rather than waiting for a specific need to arise. There should also be forums where all staff and managers can discuss issues affecting the entire organisation; for example, in conjunction with the preparation of the agency's Operating Plan.
There is room for development of Government control and the agency's documentation to the Government
In our opinion, uncertain governance and oral procedures represent a risk when, for example, staff leave the agency or are on long-term sick leave or in the onboarding of new employees. These risks may adversely affect the legal certainty of the agency's case management. The Government should therefore use its dialogue with the agency to, inter alia, monitor how the National Board of Appeal for Student Aid is ensuring the legal certainty of its decision-making process.
We also feel that the National Board of Appeal for Student Aid should clarify its requests for more resources in budget documentation submitted to the Government, including comparing its forecasts regarding the total number of cases it is likely to handle with actual outcomes.
The agency should analyse its skills provision and digitisation requirements
Our assessment is that the National Board of Appeal for Student Aid should analyse the skills that the agency will require in order to fulfil its assignment. This analysis should cover how responsibility for operational support and administration can be streamlined and how the agency can utilise training measures more strategically. In particular, the analysis should include the agency's need for legal expertise.
Furthermore, within the framework of its Operating Plan, the National Board of Appeal for Student Aid should provide concrete proposals for how the agency intends to increase the pace of digitisation within its organisation.
The Board of Appeal should be afforded greater insight into decision-making
The secretariat of the National Board of Appeal for Student Aid decides on almost all cases arriving from CSN. These cases never reach the agency's special decision-making body, the Board of Appeal.
We propose that the Board of Appeal should be given greater insight into the decisions reached by the secretariat. This would increase the importance of the Board, utilise the expertise of its members to a greater extent and strengthen the legal certainty of case management. The goal should be for members to form an opinion on whether or not the Board should decide on more cases and, if so, which types of case should primarily be escalated to the Board of Appeal.
We propose that the Government use agency dialogues to follow up on how the National Board of Appeal for Student Aid works to ensure the legal certainty of its decisions, the quality of its operations and the service the agency provides to those who lodge an appeal.
We propose that the National Board of Appeal for Student Aid:
- refines the roles and working methods of its management;
- ensures that the agency has basic internal governance documentation in place;
- more actively applies management by objectives to quality and services, as well as systematically following up these objectives;
- analyses the agency's long-term skills provision requirements, especially in terms of legal expertise when recruiting staff to prepare cases;
- in its Operating Plan, specifies how the agency intends to digitise its operations;
- ensures that members of the Board of Appeal are given greater insight into decisions reached by the secretariat; and
- in upcoming budget documentation submitted to the Government, follows up previous annual forecasts in comparison to actual outcomes for cases handled, as well as clearly justifying requests for an increased appropriation.