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Several countries that have made significant headway in building up integrated MIS structures even where ICT infrastructure is a constraint.
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Þ Therefore, digital programme level MISs support social protection delivery by enhancing accuracy and integrity of data through appropriate data quality controls and verification, improving efficiency and effectiveness of programme operations, and enhancing accountability and citizen empowerment through public portals, self-registration portals, dashboard and programme reporting mechanisms.
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Þ Scheme design has implications for information systems and management, where complex schemes require higher degrees of institutional capacity than simpler designs. Þ Contributory schemes have inherently complex information management requirements, especially regarding contribution collection and compliance, which call for specific governance and management information systems, and social security agencies tasked with implementing contributory schemes tend to have higher institutional capacity.
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Þ Paradoxically, it is often the weaker (social development) line ministries that are tasked with implementing more complex non-contributory schemes, such as those requiring collection of additional monitoring information to support the targeting and compliance monitoring processes, which place a strain on collection, transmission, processing, and management of data.
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Þ For non-contributory schemes, the simpler the programme design, the more effective, accurate and manageable the tools will be, particularly in low-resource contexts where ICT infrastructure, administrative capacity and human resources are limited. 3.2 MIS for an integrated138 sector—high-stakes choices, with implications for governance Integration in information management across different social protection programmes can take several forms.
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It can occur between only a few programmes or institutions, or it can be broader, even sector wide. Integrated digital platforms serving multiple social protection programmes can take two main forms, depending in large part on the broader policy objectives, and, whether sector- wide integration involves both core lifecycle and other schemes.
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This section introduces the components and pre-conditions for MIS integration; different models/levels of MIS integration, their different objectives, and functions, as well as advantages and disadvantages; considers additional risks to seeking technological solutions to coordination/integration; and explores emerging international frameworks to ICT-based solutions to support social protection coordination.
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3.2.1 Digital and integrated social protection information systems – components and pre-conditions Chirchir and Barca (2020) identify five key components required for digital and integrated information systems in social protection, including: • ICT infrastructure required in each country context, including hardware and telecommunications (e.g., data capture technology, servers for hosting databases and software, cloud-based technology).
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138 Integrated and coordinated are used interchangeably throughout this section. 3 Mid-level governance 45 • A registry/database system to easily organize, store and retrieve large amounts of data.
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• Software to manage, link and process data, including linkages between frontline and back- office processes; and • Brain ware, or trained human resources (e.g., IT skills, programme management and business process engineering skills, analysis skills, promotion, and capacity building skills) capable of leveraging the system’s technology at all levels of administration; and • An enabling institutional setting to provide appropriate legal and policy backing, institutional framework, budget, and operating standards and procedures.
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Although these components would still be needed when setting up a basic programme MIS, they are crucial when establishing a digital and integrated information system. Moreover, social protection systems constitute an ‘ecosystem’ with three ‘pillars’ for information management: • Pillar 1: Supporting programme-specific operations and functions.
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• Pillar 2: Supporting integrated operations and functions across the social protection ‘sector’ or system; and • Pillar 3: The broader set of registries and information systems that exist within a national information system. These pillars are depicted in Figure 3-2. Figure 3-2: The three pillars of a social protection information management ecosystem Source: Adapted based on Chirchir and Barca (2020), Figure 4.
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3 Mid-level governance 46 Coordination is required within each of the pillars with regards to different functions, as well as across them.
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When seeking digital solutions to social protection challenges, governments must be aware of where in the ecosystem the challenge or solution is situated (at programme level versus cross-programme or between social protection and other sectors), as well as what implications an intervention in one area might have for the development and coordination of the overall system.
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While the Government’s immediate attention is often drawn to developing appropriate ICT-based solutions at the programme level (Pillar 1), there is growing recognition of the vital importance of investing in sector-wide solutions (Pillar 2) and integrating them with the broader sets of registries and information systems in the wider national context (Pillar 3).
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Þ Therefore, governments must think strategically about how the social protection system is nested within the broader social protection information ‘ecosystem’ and ensure that the management of individual programmes and schemes corresponds and contributes to broader planning and development of the whole sector’s information systems.
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3.2.2 Models for integrated information management – social registries and single registries (integrated beneficiary registries) 139 Figure 3-2 depicted the position of within-sector (Pillar 2) integration vis-à-vis programme-level functions (Pillar 1) and cross-sector integration (Pillar 3). However, social registries and single registries140 do not perform the same functions.
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While social registries and single registries both seek to improve integration within the social protection sector, they have fundamentally different objectives, and moreover, they serve different policy landscapes. Whereas social registries are limited to the coordination of residual, supplementary programmes, single registries enable integration across the whole sector, including core lifecycle schemes.
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This distinction is often lost on countries that are promised high-tech solutions to all social protection challenges through a social registry. As Chirchir and Barca (2020) note, “the development of a social protection information system is at least as much a political process as it is a technical process” (p. 48).
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In line with the proliferation of poverty targeted schemes in recent decades, several countries have invested heavily, with donor support, in improving the accuracy of poverty targeting systems in their countries. Social registries have been heavily promoted by certain donors, notably the World Bank, as a tool for countries to solve complex cross-programme coordination problems.
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However, it should be noted that they aim almost exclusively at supplementary social assistance programmes, which should comprise a small share of a country’s total social protection portfolio, including from an investment perspective. The idea behind social registries is to build central databases that contain household data, including predictors for income, which form the basis for the proxy means test (PMT).
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Social registries aim to integrate certain core functions of programme management,141 including outreach/communication, registration and needs assessment of potential beneficiaries, by collecting information on potential beneficiaries through a census survey using the social registry’s standardised registration tool, providing a single source of information about the potential eligibility and enrolment status of beneficiaries.
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Because their purpose is to allow for the application of eligibility thresholds based on means, households are then ranked according to criteria established, for example, through a PMT. Defined protocols enable data sharing across other poverty-targeted social protection programmes that may or may not have the same eligibility criteria. In this way, a 139 Brief descriptions of additional successful MIS integration experiences referenced in this section are included in Annex 4.
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140 Single registry and integrated beneficiary registry are used interchangeably. The latter term reflects rapidly evolving terminology in the field. See Barca and Chirchir (2014) or Chirchir and Barca (2020) 141 See Section Box 3-1 for a detailed discussion of the core administrative processes involved in social protection programme management. 3 Mid-level governance 47 social registry provides information to programme-level MISs (Pillar 1) while also drawing on external databases when relevant.
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There are several significant risks and drawbacks associated with social registries, not least of which is their narrow focus on supplementary social protection schemes. First, the emphasis on efficiency gains from social registries is often based on the motivation to reduce fraud and (inclusion) error in social protection systems.
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However, exclusion errors are much more serious from a rights-based perspective, especially in low- and middle-income countries where large proportions of the population are living in poverty.
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Second, despite countries investing heavily in these systems, social registries do not appear to have improved targeting significantly in places that have them.142 Social registries not only do not prevent exclusion errors; they risk exacerbating them as they systematise the same exclusion errors across multiple programmes (whereas exclusion errors are confined to one programme when registration and assessment is done at programme level).143 Therefore, if extending coverage is the priority, then management information systems must be leveraged primarily toward increasing coverage (avoiding exclusion errors) and only secondarily for reducing inclusion errors, including fraud.
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Moreover, the implicit assumption — by many Governments and donors that support social registries — is that households should not be allowed to receive multiple benefits at once. However, in a lifecycle framework, individuals and households can and should be allowed to receive multiple benefits at one time, according to their individual needs and vulnerability, while assessment of household income or means is a separate process.
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In high-income countries, income from other benefits can be considered in an assessment of overall household income in means tests; however, social registries do not hold information on the programmes and services accessed by beneficiaries and therefore cannot perform this function. This is only possible when social registries are integrated within a broader integrated beneficiary registry, or single registry (discussed below).
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The information contained within social registries is generally not useful for supporting programmes that are not poverty targeted or household based (for example, lifecycle schemes like old age pensions or child benefits, or any individual programme), and therefore is not useful for providing sector-wide coordination.144 In contrast, single registries — or integrated beneficiary registries — according to Chirchir and Barca (2020), “provide a consolidated overview of ‘who receives what’ benefits to support coordination, planning and integrated monitoring” (p. 24).
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Single registries act as a ‘data warehouse’ which can be used to establish common delivery systems or serve as a nexus between programme MISs and external databases, including national IDs, tax registries, civil registries, or disability databases – important for determining eligibility for disability benefits, as well as for linking other cash benefits to disability-related services.
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Therefore, unlike social registries, whose primary objective is to harmonise registration across (similar types of poverty-targeted) programmes, single registries have as their primary objective to provide reliable information for evidence-based decision making, planning and sector-wide coordination. They therefore enable governments to address several the core challenges confronting the governance of social protection systems.
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Figure 3-3 depicts a hypothetical integrated social protection information management system, where the clear distinction between the role of a social registry as compared with a single registry, including the latter’s ability to integrate information management across both supplementary (household targeted social assistance programmes) and lifecycle (individual entitlement, or tax-financed programmes, and social insurance) schemes, is apparent. 142 See Annex 3.
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142 See Annex 3. 143 Chirchir and Barca (2020) 144 Barca and Chirchir (2014); Chirchir and Barca (2020); Chirchir and Farooq (2016) 3 Mid-level governance 48 Figure 3-3: A potential integrated social protection information management system Source: Reproduced and updated with permission based on Chirchir and Farooq, (2016), Figure 1. Single registries enable several processes that contribute to better social protection system-wide governance.
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When successfully implemented, they correspond to a number of good governance principles: for example, they allow for better financial planning and sustainability (e.g. through improved predictability in beneficiary populations and benefit amounts); improved accountability (e.g. through improved case management across multiple programmes); improved performance of the system (e.g. through coordinated monitoring and evaluation tools); and transparency (e.g. through publicly accessible dashboards).
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through publicly accessible dashboards). Countries that have achieved significant integration through single registries include Turkey, Uzbekistan, and South Africa (see Annex 4). Table 3-1 summarises the objectives and associated measures of success of single registries, as outlined in Chirchir and Barca (2020), and indicates the key principles of good governance they address.
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3 Mid-level governance 49 Table 3-1: Objectives, indicators, and examples of good national practice in Single Registries (Integrated Beneficiary Registries) Objectives of Single Registry (Integrated Beneficiary Registry) Measures of success Main principle of good governance furthered Examples of national good practices I. Provide reliable information for evidence-based decision making, planning and coordination across the sector • Consolidated data on who receives what and when.
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• Comprehensive reporting and analytics for all programmes based on harmonised indicators (national M&E framework and annual targets) • Coherence/coordination • Financial sustainability • Accountability Uzbekistan, South Africa, Turkey, and Mauritius Sub- objectives Validate potential beneficiaries to address error/ fraud • Consolidated validation of potential beneficiaries against external databases (national ID/civil registry) if no social registry • Coherence/coordination • Accountability Kenya, Chile, Uruguay, Turkey, Uzbekistan, China, and Mauritius Manage beneficiary enrolment against agreed targets • Analytical reports comparing enrolled beneficiaries with planned expansion across multiple programmes.
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• Dashboards to compare beneficiaries against geographic quotas across multiple programmes • Coherence/coordination • Financial sustainability • Accountability • Predictability • Transparency Kenya, Chile, Uruguay, Turkey, Uzbekistan, China, and Mauritius Identify/manage overlaps and gaps across existing programmes • Reports on beneficiaries receiving multiple benefits.
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• Linkages (layering/sequencing) between benefits and services to ensure universal coverage (multi-tiered systems) • Transition of beneficiaries across schemes • Coherence/coordination • Financial sustainability • Dynamism/responsiveness Kenya, Chile, South Africa, Uruguay, Turkey, Uzbekistan, China, and Mauritius Assess the effectiveness, impact, and sustainability of the scheme • Consolidated information on social protection interventions and beneficiaries (supply) • Coherence/coordination • Financial sustainability • Predictability • Transparency Kenya, Chile, Uruguay, Turkey, Uzbekistan, China, and Mauritius II.
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Enable integrated delivery systems across programmes • Platform for joint management of selected delivery system functions across programmes (if relevant and feasible) • Coherence/coordination Chile, Uruguay, Turkey, Uzbekistan, South Africa, and Mauritius III.
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Increase accountability and transparency • Provide public reporting interface (dashboard) with summary statistics on beneficiaries, disbursements, and complaints • Transparency • Accountability Kenya, Chile, Uruguay, Turkey, Uzbekistan, and Mauritius Source: Adapted based on Chirchir and Barca (2020).
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3 Mid-level governance 50 Although social registries and single registries provide foundational models of integrated information management systems in a number of countries, it is possible to integrate information for every element within the social protection delivery chain as stipulated in Table 3-2, performing a key coordination function at the operational level.145 A payments platform is used to integrate information on payment functions for multiple programmes and provide linkages to payment services providers.
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A grievances and appeals function are an integrated information function for integrating registration, management and resolution of complaints and appeals for multiple programmes within social protection sector. Finally, beneficiary management platform integrates beneficiary updates and cases for multiple social protection programmes.
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It is worth noting that these integrated information management elements within social protection delivery chain could be weaved into a superior integrated information system depending on countries social protection governance set up and social protection maturity.
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For instance, South Africa’s SOCPEN is used to administer six social grants and 2,300 concurrent users by consolidating information across registration, enrolment, payment and complaints and grievance management functions.146 Table 3-2: Integrated information management elements along social protection delivery chain Programme MIS process/function Integrated information management functions Outreach and registration Social Registry Assessment of needs and conditions Eligibility assessment and enrolment N/A Payments and service delivery Payment’s gateway or platform Complaints and appeals Grievance and appeals platform Beneficiary management Beneficiary management platform Monitoring and data analytics Integrated Beneficiary Registry It is important to note that, when pursuing greater coordination through MISs, the choice is not between a social registry or a single registry, but rather concerns the scope of ambition for coordinating the entire sector and the relative emphasis placed on each tool.
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For countries that are seeking greater integration across programmes, whether between contributory and non- contributory benefits, between core lifecycle and other social protection programmes, or between social security income transfers and access to other services (e.g., linkages between labour market interventions and unemployment benefits), a single registry can be a powerful tool. However, social registries may play a valid, but more limited role in tightening coordination across means-tested schemes.
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Þ Therefore, social registries offer a very limited potential for coordination across a collection of means-tested programmes, whereas single registries hold greater promise for system- wide integration, including across core lifecycle (contributory and non-contributory) schemes. 3.3 Risks and additional considerations While integrated information systems can help solve several governance challenges, they also risk creating or amplifying others.
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These risks and additional considerations are briefly outlined here:147 145 See also Chapter 4. 146 Barca and Chirchir (2014) 147 Chirchir and Barca (2020) 3 Mid-level governance 51 1. Underlying infrastructure and data quality. As with any system, the data contained in an integrated registry is only as good as the component parts that make it up.
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Therefore, MIS systems must first ensure that the system is adequately serving the core administrative processes at programme level before aggregating to a higher level. This depends, in part, on the underlying ICT infrastructure available in a country, and there are certainly some contexts in which paper-based or semi-electronic MIS will still be required,148 though this situation is rapidly changing.
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In Uzbekistan, the application for social allowances is captured in multiple channels including paper at the Mahalla (local office) then digitised at the district level where there is ICT infrastructure. Optionally, data can be captured at the Single Windows or public e-citizen portal. Overall, there are broader telecommunication infrastructure in rural areas in many developing countries. 2. Human and financial resources.
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2. Human and financial resources. An investment in improved information management technology can be costly – including costs related to ICT infrastructure, software and brain ware and maintenance. Simpler information systems involve lower costs and are necessary in low-resource contexts. (And, where capacity is lacking for development and maintenance, governments must safeguard against additional risks that emerge related to contracting out to third parties.)
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For these and other reasons, low and middle-income countries –where underlying business processes, financial management and M&E frameworks are nascent— are generally best served by starting small and gradually introducing newer and bigger solutions. 3. Governance silos can impede coordination. For single registries or integrated beneficiary registries to function properly, however, there must be a ‘whole-of-government’ approach to sharing and managing social protection information.
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A lack of participation by key stakeholders can the ability of the social protection sector to act in a coordinated way. For example, regulatory frameworks that grant high degrees of autonomy to implementing agencies (notably, traditional contributory social security institutions) may in fact create obstacles to information sharing and integration.
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In many countries, social security institutions operate with high degrees of independence, because they are manged by executive boards, are often not required to report to higher authorities within Ministries on key matters. For example, in Uzbekistan, a Memorandum of Understanding had to be developed building on the Cabinet of Ministers Resolution to link the Single Registry to other 13 government databases.
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Therefore, policymakers must be aware that good governance principles applied in different parts of the social protection system (institutional autonomy) can at times work at cross-purposes with others governance principles (coordination).
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In this case, where laws and regulations that were enacted to safeguard specific institutions against political pressures and preserve financial integrity, may hinder, or undermine central government efforts to ensure a coherent and coordinated approach to information management and integration.149 4. Additional risks to the right to privacy.
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Additional risks to the right to privacy. Regardless of the level of integration, it is vital that social protection MIS systems build in protections related to the right to privacy and data security, even (and especially) where the broader governance context does not require it. Not only is the right to privacy a fundamental human right,150 but the risks and exposure to potential breaches are compounded in a digital age.
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Integrated MIS systems elevate the level of risk from the programme level to the national level and must embed adequate safeguards and strict protocols to prevent accidental and intentional breaches. For example, many countries that have pursued integration —such as Kenya, Uzbekistan, Uganda, 148 Chirchir and Kidd, (2011) 149 This independence and the risk to social protection expansion extends beyond MIS integration into nearly all aspects of sector-wide policymaking and coordination.
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150 As enshrined in the Universal Declaration of Human Rights (Article 12), the International Covenant on Civil and Political Rights, and ILO Recommendation 202. 3 Mid-level governance 52 Uruguay, and Chile — typically implement MOUs, data protection and sharing protocols in addition to the data protection laws. 5. Automation and systematic exclusion.
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5. Automation and systematic exclusion. While social registries, based on a single assessment and data capture, have a high risk of systematically replicating exclusion errors across multiple programmes, the risk of exclusion due to automation is present to some degree with any digitisation.
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As social protection systems become more digitised, governance frameworks must be developed to protect against automatic exclusion through strong grievance mechanisms, with clear rules related to appeals against computerised decision making.
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Indeed, the EU has recently outlawed decision making based solely on automated processing.151 Each of these issues can be an obstacle to various aspects of governance, and good governance requires anticipating and accounting for these risks as part of any high-level strategic planning for increased integration in social protection management information systems.
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Þ Therefore, while greater integration in social protection MISs can be a powerful tool to facilitate better system-wide governance, it is not without its own risks and likewise requires prudent governance to manage. 3.4 Emerging international frameworks for ICT in social protection It is important to note that countries need not start from scratch and are not operating in a vacuum when considering implementing ICT-based solutions.
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International organizations have developed several frameworks, guidelines and resources countries and institutions can consult.
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For example, the UN’s e-Government152 framework, specifically Stage 4 which deals with “joined up government” (integrated services, processes, systems, data, and applications), offers a useful set of resources and standards for applying ICT-based interventions in facilitating social security coordination.153 In addition, the ISSA, which has more than 320 member institutions in more than 150 countries,154 has developed a detailed set of guidelines to support social security institutions in the application of ICT-based solutions for service delivery.
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These guidelines offer support to implementing agencies as they attempt to navigate through the complex decisions surrounding digital interventions affecting their schemes and programmes.
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The ISSA Guidelines include three parts: ICT Governance and Management (including sections on governance, management service delivery, investment and value management); Key Technologies (with sections on interoperability, data security and privacy, mobile technologies, and data analytics); and Social Security Components (with sections on master data management, ICT-based implementation of international social security agreements, e-Health, and implementation of social security business processes).
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Although the ISSA Guidelines are targeted toward individual social security institutions (which may be implementing a variety of programmes), Ruggia-Frick (2016) proposes five models for coordination (integration) beyond single institutions.
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Social security agencies, because of their relatively strong institutional capacity and political and financial clout, are critically important actors 151 See General Data Protection Regulation (Article 22) 152 E-Government is defined by UNDESA as “utilizing the internet and the world-wide-web for delivering government information and services to citizens” (see https://publicadministration.un.org/en/research/un-e-government-surveys) 153 See e.g.
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UNDESA (2016) and Ruggia-Frick (2016) 154 ISSA members consist primarily of national social security agencies empowered with administering social security benefit. In high- income countries, their remit generally covers the whole gamut of social security/protection benefits and services in a country.
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However, in most low- and middle-income countries, the national social security agency often only implements contributory schemes for the formal sector, although more and more countries are placing newer tax-financed or otherwise non-contributory programmes, especially pensions, under the administrative responsibility of the social security agency. This is the case, for example, with Viet Nam’s social pension, as well as many social pensions in Latin America.
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3 Mid-level governance 53 to engage in, and, where possible, lead national efforts to integrate and coordinate social protection information management systems.
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However, doing so at the service of coverage extension is not without its challenges, given the historically limited coverage and vested interests of these institutions and their members in low- and middle-income countries.155 These different models touch on various ICT-related aspects of social protection programmes, from ICT governance and interoperability to data protection and security, among other dimensions.
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They also address cases of cross-national coordination and portability of rights, which is already a challenge for schemes covering the formally employed (where rights are typically enshrined in law) but will become increasingly relevant for the entire social protection sector, including tax-financed schemes, as systems continue to develop, and rights become more firmly embedded in statutes.
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The proposed models, from simplest/least integrated to most complex/ most integrated, are: 1) Coordinated processes; 2) Common front-end; 3) Shared information system; 4) Common software application; and 5) Common operational platform. The main features of these models and corresponding examples156 at the sectoral, cross-sectoral, and international levels, are summarised in Table 3-3.
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155 See also Section 4.4 for further discussion of the challenges of bringing on board the diverse actors and interests in a common national social protection expansion agenda. 156 Several the examples included in the table are described in greater detail in Annex 4; others are cross-referenced in original sources. 3 Mid-level governance 54 Table 3-3: Models of coordination and examples, from least integrated/complex (left) to most integrated/complex (right) Description and examples Coordinated processes.
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(Model 1) Common front-end (Model 2) Shared information system (Model 3) Common software application (Model 4) Common operational platform (Model 5) Description Consists of independent systems with processes that exchange data and/or perform cross-institution Internet-based service executions (e.g., through Web Service invocation); Relatively simple but effective model, which minimizes the complexities of managing common resources.
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Consists of independent systems delivering client services by means of a common portal; Enables the implementation of one- stop-shop e- services. Consists of independent systems sharing an information system with relevant data, such as a registry of beneficiaries. Consists of a business software application implementing social security functions that is shared by the coordinating entities; Software may be either executed “as a remote service” or executed locally and distributed as a package.
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Consists of a common operational platform in which are executed joint business processes implementing functions of the coordinated programme; Provides ICT operations.
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Examples (by level or pillar) Sectoral (corresponds to Pillar 2 in Chirchir and Barca, 2020) • Data exchange between social security and tax authorities (various countries) • Data exchange on beneficiaries’ income in the Netherlands and occupational accidents in Switzerland • ILO’s Single Window Service in SP programmes • Social Security services in Australia and Spain • Unemployment benefits in Belgium • Integrated MIS (IMIS) in Kenya, Indonesia, Mauritius, South Africa, and Turkey • Integrated MIS in Indonesia and Kenya • Case management in the US • Contribution collection in Costa Rica, France, Republic of Korea National, cross-sector (corresponds to Pillar 3 in Chirchir and Barca, 2020) • Health insurance in Chile, Colombia, Uruguay • ILO’s Single Window Service in SP programmes • One-stop shops (e.g., Canada) • Shared MIS systems for CCTs in Brazil, Chile, Costa Rica, Jamaica, Mexico, Uruguay • RNCPS in France • ILO Single-Window Service in Cambodia* and India • Contribution collection in Oman • Contribution collection in Argentina and Uruguay • CCTs in Chile and Uruguay • Integrated MIS in Mauritius, South Africa, Turkey • ILO Single Window Service in Cambodia*, India, and Pakistan • Contribution collection in Argentina and Uruguay 3 Mid-level governance 55 • Health insurance in Colombia and Uruguay • CBSS in Belgium • • CBSS in Belgium International • International social security agreements • • EESSI in the EU • MERCOSUR-SIACI • EESSI in the EU • EESSI in the EU Source: Based on Ruggia-Frick (2016).
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* Note: In Cambodia, while the Single Window Service was considered and initial efforts were made to establish key components, the service was never fully piloted or implemented. 3 Mid-level governance 56 These models and corresponding examples highlight the potential for greater social protection coordination at different levels. There is a growing number of examples internationally, and each experience addresses a unique set of challenges, making identification of ‘best practices’ challenging.
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Nevertheless, cross-country learning in social protection information management, facilitated through internationally validated guidelines, can play a particularly important role in shaping national decisions around the governance and development of MISs, and particularly integrated ones. Þ Therefore, countries need not re-invent the wheel but can learn from international guidance as well as from other countries facing similar challenges at similar stages of developing their social protection MIS capacity.
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4 Frontline ‘street level’ governance 57 4 Frontline ‘street level’ governance The previous sections have offered a birds-eye view of the high-level and information management processes and structures that are associated with good social protection system governance. This section explores how well systems ‘interface’ with key stakeholders and rights holders at the point of service delivery or enforcement of compliance.
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It identifies appropriate frontline governance structures that contribute to build trust in the system among end users (including both rights holders, as well as stakeholders such as social partners or private-sector actors engaged in delivery).
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This is, arguably, among the most important functions of a social protection system, since positive experiences with the system can strengthen the social contract, while negative experiences can undermine it.157 The following paragraphs highlight the key challenges and good practices for facilitating the fulfilment of reciprocal social obligations.
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While each stage of delivery is important, we focus here on five key structures and points of interaction between rights holders and stakeholders and the social security system: compliance with social contributions; coordination at the operational level; payment of benefits; grievance and appeals mechanisms; and stakeholder participation in scheme management.
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4.1 Securing and facilitating payment of social contributions Ensuring efficient collection of contribution and enforcing compliance among companies and workers who are obliged to contribute, remains among the most longstanding and daunting challenges within the framework of governance of contributory social security schemes.
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Timely and effective contribution collection is situated squarely on the front lines — at the interface between workers, employers, and governments — and is the basis for sustainable financing of schemes.
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But, more importantly, “implementing rigorous contribution collection and compliance processes strengthens the legitimacy of social security as a societal institution.”158 It follows, then, that high rates of non-compliance are one indicator of low trust in the system and, often, poor governance and a weak social contract.159 The aim of this section is not to repeat already established international guidelines on contribution collection and compliance,160 but to draw on them to examine a selection of tools and experiences in governance of contribution collection and compliance at the service of coverage extension.
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In this way, improved governance in compliance with social contributions concerns the ability of social security systems to actively facilitate these processes to close coverage gaps, rather simply following the letter of the law.
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Indeed, the previous section revealed that legislative frameworks for contributory systems are already among the strongest features of the broader social protection policy landscape in low- and middle-income countries.161 But legal coverage has not been followed by effective coverage in most cases.
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This is in part because social security institutions historically played a reactive role with respect to coverage extension, where increased coverage was viewed as an outcome of formalization, when in reality, social security affiliation is part of the very definition of formality in many contexts and is therefore inseparable and indistinguishable.162 The corollary to this 157 See Annex 5 for a discussion of the relationship between social protection and the social contract.
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158 International Social Security Association (ISSA), (2019b) 159 The payment of taxes is also part of this broader reciprocity but is not specifically considered here. 160 Ibid. 161 The ISSA Guidelines on contribution collection and compliance presume that institutions are operating within a broader legal framework setting out obligation. International Social Security Association (ISSA), (2019b).
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162 ILO (2018) 4 Frontline ‘street level’ governance 58 is a realization that social security coverage can precede formalization and indeed is a crucial means of achieving it in many contexts.
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Therefore, supporting the effective extension of contributory social security coverage, through the facilitation of contribution compliance, is increasingly recognised as part of the state’s duty, and indeed, coverage extension is explicitly included in the ISSA Guidelines on Contribution Collection and Compliance (see Box 4-1).163 Box 4-1: International guidelines for coverage extension through facilitating contribution collection and compliance Guideline 6 of the ISSA Guidelines on Contribution Collection and Compliance states that “The institution [should] develop strategies to maintain and extend the effective coverage of contributory social security, by promoting the exhaustive inclusion in the collection system of all contributors covered by the social security regulations or, if this is not the case, through coverage extension.” Moreover, it proposes that the management “should define specific goals and implementation measure aimed at extending and maintaining coverage” and “define specific performance indicators to evaluate the achievement of these goals and measures.” The mechanisms proposed for operationalizing these guidelines include: • Developing specific information and communication approaches to target different contributor groups.
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• Defining specific contribution rules for difficult-to-cover groups such as informal economy workers, self- employed workers, rural workers, migrant worker, and domestic workers, considering financial aspects and implementational feasibility. This could include, among others: o Options for calculating contributions differently, for example by basing contributions on the local minimum wage, or the average income for the specific work sector, or previous year’s earnings.
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o Options to support payment of contributions, for example flexibility of payment dates such as yearly, quarterly, or pre-calculating contributions amounts and simplified administrative procedures, or government subsidies and incentives. • Following up on coverage of and issues related to contribution collection and compliance in different contributor groups.
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• Following up about migrant workers and those temporarily working abroad, and the applicable regulatory framework(s), notably international social security agreements. Finally, the Guidelines propose setting up a specific management unit to be responsible for following up, including monitoring performance indicators, on those aspects of the strategic plan that apply to coverage extension. Source: International Social Security Association (ISSA), (2019a).
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Moreover, compliance cannot be concerned merely with enforcement of existing regulations but must be forward-looking and strategic. It goes beyond mere technical solutions and potentially involves: • Clarifying, modifying, and adapting rules around obligations, where these are not clear, including clearly defined roles of different actors and institutions at all levels (national, inter- institutional, and institutional). • developing a strategic plan for improving contribution collection.
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