Submissions of authority: Does key civil service decision-making process work?

Submissions to ministers are integral to how government works, but the system may not lead to the best decisions

By Andrew Greenway

10 Apr 2017

On my very first day as a civil servant, I began writing a list of the unfamiliar bits of language seasoning those early conversations in the back of my notepad. As you would expect, there were lots of acronyms. These were joined by names, reflecting that peculiar Whitehall truth that true power is being known by your first name only.

One of the first terms to join this list was submission. It took a few days for me to work out what one of these mysterious things was. Although the word was used in a context that made it clear they were notes to ministers sent by officials, the word ‘submission’ didn’t seem to match the tone it was used in. Submission is servility, yielding to a superior force. Even in weaker form, it means to present an argument for consideration. Yet the civil servants I met often didn’t see it like that. A submission seemed to be neither as a contrite presentation nor a neutral gambit. It was far closer to a fait accompli, a statement of how things ought to be. There just wasn’t time for anything else.

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Submissions are such a ground-in part of how the civil service works, it’s difficult to step back and think about they are fit for purpose. To answer that, you have to go back to what submissions are for.

The main purpose of a submission is to frame a decision taken by a responsible minister. Options are presented, supporting evidence appended, a recommendation put forward for assent. That much is obvious. But in the managerial era of the civil service (as opposed to the more mercurial era that came before it), submissions play another role. They are a forcing function for departmental consensus. They keep the organisation coherent. Most submissions have to run a sign-off gauntlet before getting near Private Office. Has the press office seen this? What about Finance? Does the perm sec need to be happy? What about the scientists, the statisticians, the economists and the special advisors?

What’s interesting about these two functions is that they serve different masters. The first serves the minister, who needs to have confidence in their decisions. The second serves the permanent secretary, who needs to ensure their charges present a controlled and united front. As a rule, politicians tend to thrive on ambiguity. Civil servants tend to abhor it.

It is worth asking whether the traditional submission – the typical, highly structured three-page note with accompanying annexes –  does either of these difficult jobs well. Why? Because this format is the primary means by which our elected representatives take thousands of decisions over the course of a parliament. These directly affect our daily lives. We all have an interest in the lens through which they make those calls, big and small. Besides, I’m a great believer in the idea that the real story is always hidden in the most boring places. Submissions aren’t sexy.

The standard submission has three things in its favour. It is a well framed canvas to paint an argument on. It is a forcing function for ensuring discussions happen across teams. And it provides a permanent written record.

All this is good. In some instances, especially when the decision is a well-bounded, rule-based question, a short paper is perfect. ‘There are only three ways to change this regulation, minister. This one is illegal, and this one is imbecilic. We suggest this one instead.’

The problems arise when you think back to what the job to be done is. It is a minister wanting to make an informed, timely decision. Let’s leave aside the obvious absurdity that no minister – literally none, ever –  will read every word of every annex. Focusing on that issue makes it easy to blame the politicians for being workshy. This shouldn’t be our reaction. Civil servants have to meet their minister’s needs. If they aren’t bothering or able to read the subs, that’s our fault, not theirs. Even if they don’t work as hard as the officials, it is still our problem.

Ministerial decisions take many shapes. Many require a judgment call about highly uncertain environments, with hundreds of permutations. No paper can do justice to these, and decent civil servants know that. Yet the format forces them to suspend this knowledge. A typical submission presents a small number of options with risks attached. This, not to put too fine a point on it, is just guessing at stuff rather than taking proper steps to reduce the uncertainty. Those steps might mean doing something different from trying to write better words.

Which brings us on to problem two. Submissions reward a specific type of official. If you’re an artful drafter of officialese, you are everyone’s friend. Eloquent papers flow from your keyboard. Ministers admire your copy, and by proxy, you. Things get approved. You become known as someone who gets things done, and reap the attendant plaudits. Except you may not be someone who gets things done. You may be someone who gets submissions approved, and that is a very different thing. Decisions do not equate to delivery. The worst decisions actually mitigate against effective delivery. Submissions reward writers. An effective civil service needs more than a way with words.

The final problem with submissions is a practical one, and comes back to their role as a consensus builder around departments. Most ministers have no idea how long it takes from a submission to go from blank sheet of paper to sitting in their red box. I have seen submissions float around a department for months. They bounce around in comment wars, without a minister having any idea any work is happening. By the time it does reach them, the pressure is on. Officials need a decision now. Without it, delay is inevitable. Already pissed off that something they asked for six weeks ago has only just arrived, ministers now have to decide whether to accept a delay, or be bounced into the pre-cooked recommendation.

There is a case for looking hard at how the civil service helps ministers to take decisions. This is especially true when those decisions are full of ambiguity. Submissions often fail to help ministers clearly understand the assumptions their officials have made to reach their recommendations. They deserve a fair chance to interrogate them.

The good news is that the civil service has good form in this area. The 2050 Calculator, built by DECC during the last Parliament, allowed ministers to select from over 20,000 permutations of what the future UK energy system could look like. Digital teams have shoved prototypes of new services in front of senior officials and politicians to show how the consequences of policy decisions play out with real people. You can’t do that with a submission. There should be a lot more of it. While there’s nothing wrong with clear policy options and robust economic analysis, they aren’t the only tools in the box.

As well as looking beyond fine words, one thing that the best civil servants have done to help ministers pick their way through an uncertain world is be humble. They have admitted when they don’t know, when they’ve made a best guess. Even better, they have opened up their assumptions to outside experts and the public. Having done so, they said ‘here’s our best shot –  can you help us do better?’

Sure, this might introduce a little more ambiguity. But better to have real humility than false certainty.

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