Select Committee on Agriculture Seventh Report


IV. SIMPLIFICATION WITHIN THE UK

Responsibility for the implementation of IACS in the UK

32. Agriculture has always been a devolved issue within the UK, with each of the four administrations making their own arrangements for the administration of IACS. Not surprisingly, therefore, the system is evolving at different rates within the different parts of the UK. For example, Scotland has already introduced a Geographic Information System and an updated appeals procedure; Northern Ireland has developed a database known as APHIS (Animal and Public Health Information System) for identifying and recording animals, which enables officials to identify those animals on which premium is to be paid, requiring only the farmer's signature on the claim; and the National Assembly for Wales Agriculture Department has undertaken a considerable number of measures under its JIGSAW (Joint Initiatives for Government Services Across Wales) Programme to improve the quality and delivery of CAP services to customers and to improve the co-ordination and access to services of those in the agricultural industry in Wales.[93] The division of responsibilities between the four UK agriculture departments requires that our recommendations on implementation of IACS in the UK be aimed at MAFF and its administration of the system in England. Nevertheless, there is a considerable degree of read-across, particularly given the extent to which the departments work together.[94]

The IACS Report

33. As noted earlier, in 1999 MAFF attempted to identify areas of IACS administration amenable to simplification through the appointment of the IACS and Inspections Working Group. The Government's response to the Group's report was extremely positive and a year after publication the Group reported that it was "very pleased overall with the commitment shown and the progress being made in the implementation of almost all of the recommendations".[95] The only exception was the lack of success in redefining the concept of "producer groups" as used in the EU legislation on the sheep annual premium scheme.[96] Indeed, such was the satisfaction with the rate of progress that Mr Curry, Chairman of the Group, felt that it might not be necessary to hold further meetings to review the implementation of the Group's recommendations after the end of 2001.[97] Not everyone was quite as sanguine. The NFU, for example, identified as top priorities remaining to be addressed the introduction of an appeals mechanism, the completion of the Cattle Tracing System and the move towards computerisation and electronic submission of forms.[98] There are therefore still areas in which further progress is both possible and desirable.

Application forms and scheme literature

34. In order to apply for IACS subsidies, every year farmers have to complete a general form for IACS (which also doubles as an arable area aid payments application) and individual forms for any other schemes for which they might be applying. Accompanying the IACS form, sent out in the spring to all previous applicants, are guidance notes to help the farmers fill in the forms correctly. These forms and notes are reviewed each year and changed as necessary to incorporate new regimes or amendments to existing ones. Provided that they include the essential minimum requirements, national authorities are free to design the forms as they wish and to use them to elicit information on national schemes.[99] Scheme literature therefore varies greatly between the Member States in accordance with the approach adopted in individual countries. On guidance, for example, an authority may decide to issue brief documents on the basis that farmers prefer to seek advice on individual queries from officials. Elsewhere, as in the UK, the authority may prefer to issue comprehensive guidelines. The European Commission praised the UK's scheme instructions to farmers and inspectors as being "of a very high calibre indeed and for ever being upgraded and improved".[100] The NFU too had no problem with the length of the guidance as long as "it is written in clear, simple English that people can understand".[101] However, farmers' representatives in Northern Ireland strongly preferred the literature issued in the Republic of Ireland and we note that the IACS Working Group called for the adoption of "greatly simplified scheme literature supported by a more accessible advice service for farmers" in the UK.[102] The Government response to the IACS Report indicated that progress on this was to be taken forward through the new CAP Payments Agency (CAPPA). Given the delays in implementing the agency, it may be necessary for MAFF to review its timetable and procedures in order to meet this commitment on scheme literature in good time. We recommend that MAFF ensure that the IACS scheme literature and supporting advice system be reviewed in time to implement the 2002 scheme guidance notes, regardless of the development of CAPPA.

35. On the forms themselves, Mr Slade from the Commission told us that the UK versions were "among the more complex and among the more complete forms that are used in Europe", although "not necessarily the most complex".[103] Complexity causes problems for the farmer in two ways. First, complex forms are likely to take longer to complete and therefore pose a greater burden on the business. It would be helpful to quantify this burden. The Farmers' Union of Wales cited government research in 1995/96 which estimated that a typical farmer would spend 250 hours a year in completing MAFF or Welsh Office paperwork, at a cost to his business of £2,700.[104] Although the NFU reported that MAFF requested details from farmers of the time spent in completing forms,[105] MAFF indicated that no more recent estimate had been made.[106] In Scotland, SERAD has very recently published a Survey of Producers on the Complexities of IACS Scheme Administration which includes estimates of the average time taken to complete various application forms. These range from a low of approximately three hours for the extensification premium scheme to a high of ten hours for the arable area aid scheme (in all cases taking into account just the form itself and not maintenance of supporting farm records).[107] This information serves to illustrate the real cost of form-filling to farmers and should assist in identifying the most burdensome parts of the forms and how they could be improved. We recommend that MAFF use the data gathered at the time of the submission of IACS forms to assess the real cost to farmers of the paperwork involved.

36. Second, complexity increases the potential for errors, both by farmers and by officials inputting the data manually from the form. Whilst many of the most common errors are in transposing numbers from ear tags or field numbers,[108] these can be exacerbated by the complexity of the form onto which the information has to be transferred. In the last processing year, MAFF accepted 12,000 to 14,000 instances of obvious errors in arable area claims and a similar number in livestock claims.[109] To these figures should be added other genuine errors which could not be dealt with so leniently. This error rate is unacceptable and must be reduced. As a first step, we recommend that MAFF conduct detailed analysis of not only what errors are commonly made but how and why they are made in order that the results may inform the future design of claims forms. Once this has been done, there are three possible approaches to addressing the problem, based on the immediate, medium and long term.

Simplification of forms

37. The length and complexity of forms is not simply a matter of how material is presented; for example, the UK form contains far more in the way of guidance notes than the short Irish form. It also results from the inclusion of additional questions and requests for information.[110] MAFF officials denied that "there is very much in the way of gold-plating in our form at all" and argued that the length of the form was dictated by the large number of regulations covering its dual purpose of "populating the database" for the IACS system as a whole and providing a claim form for the arable area payment scheme in particular.[111] By making the form complete at this stage, it might forestall the need to ask for information at other times.[112] MAFF reviews the IACS forms every year, taking account of whether all information is required and recent changes to regulations,[113] but officials argued that previous attempts to simplify the forms, for example by introducing a "no change" box for farmers claiming forage only, had led to increased rates of error among claimants "because they had not thought their way through the form".[114]

38. MAFF officials accepted that the current system was designed around the existing computer database and that as this was updated so the forms might be simplified.[115] However, we believe that progress in this area could be made much faster if MAFF were prepared to go back to first principles as has happened in Ireland. There, a concerted effort by the Government and farmers' representatives has led to massive simplification of the application forms and scheme literature, based on the reduction of the potential for errors to the bare minimum. Some of the measures taken, such as sending out forms with the information already printed on them ("pre-populated forms", to use the jargon), have also been adopted in the UK but others have not (for example, accepting that the submission of bar-coded cattle passports obviates the need for farmers to list ear-tag numbers on the form when claiming special beef premium on castrated male animals, thus preventing transcription errors by claimants or processors). We were surprised that officials in Northern Ireland and MAFF had not subjected the Irish IACS form to detailed analysis as a guide to what could be achieved with paper forms. Our own analysis suggests that the English forms request far more information of farmers which the Irish system must obtain from other sources in order to satisfy European Commission requirements. We recommend that MAFF conduct a full analysis of the Irish forms with a view to reducing UK IACS forms along similar lines. The move towards e-forms should not be used as an excuse to delay this exercise. Although electronic forms may help in preventing errors, it will be some considerable time before they are used exclusively and the effort involved in overhauling the paper forms would not be wasted in the meantime.

Electronic forms

39. MAFF has a target to achieve 95 per cent electronic service delivery capability by March 2004 and one of the first projects to be included in this is the basic IACS form. A pilot exercise run last year in the Anglia region was both successful and popular, with the result that from this year all farmers and their agents in England are able to submit their applications electronically. As of January 2001, 10,000 farmers had expressed interest in doing so.[116] Those who choose to proceed will be faced with e-forms pre-filled with data from last year so that they only have to check and enter changes. The forms, designed to resemble the paper versions with which farmers are familiar, are "intelligent", meaning that they can "perform extensive validation checks, pre-fill answers based on previous responses, guide you through the forms to ensure that only relevant questions are answered, calculate totals [and] highlight inconsistencies as the form is completed."[117] The use of e-forms should therefore reduce the time taken to fill in the form and the possibility of error. Results from the East Anglia trial are encouraging in this respect, with all the forms submitted clearing validation straight away compared to a normal rate of just 40 per cent.[118]

40. Farmers' leaders have welcomed the introduction of e-forms because of their assistance in reducing the potential for clerical errors.[119] We believe that e-forms can also make a considerable contribution to the modernisation and improved efficiency of the processing part of the system. Concerns remain that a two-track procedure might emerge, with those who cannot or will not use computers becoming left behind. The consultation process on the use of electronic forms raised the idea of third-party agents to help these farmers. We will be interested to see how this develops. We also have yet to hear details of any training packages for farmers to encourage the take-up of the electronic facility. We fully support the development of electronic forms and welcome the progress MAFF has made in this area. Nevertheless, we recognise that in order to make the use of forms more attractive, MAFF (or CAPPA) will have to appeal beyond the circle of those farmers who already use computers. The IACS and Inspections Working Group has suggested that "thought should be given to running 'road-shows' and 'workshops' to assist industry in their understanding new technology and the completion of forms" and cautioned that "Government must not lose sight of the needs of those businesses that are not able to fully embrace 'e-business'".[120] We support both conclusions. We note that MAFF has run a series of "UK On-line" roadshows organised by the British Chamber of Commerce to provide and inform farmers about e-IACS 2001 and e-business in MAFF but more remains to be done if MAFF is to reach those farmers who are reluctant to use computers. We recommend that MAFF develop plans to address these concerns.


93  Ev. pp. 87-88, paras 3, 8; Ev. p. 101, para 20; Ev. pp. 123-5, paras 10-13. Back

94  Ev. p. 43, para 17. Back

95  Ev. p. 1. Back

96  IbidBack

97  Q 6. Back

98  Qq 78-79. Back

99  Qq 138, 145. Back

100  Q 140. Back

101  Q 102. Back

102  IACS Report, rec 4. Back

103  Q 138. Back

104  Ev. p. 81, paras 17-18. Back

105  Q 91. Back

106  Q 239. Back

107  www.scotland.gov.uk/library3/agri/surveyofsmallproducers.pdf Back

108  Q 253. Back

109  Q 260.  Back

110  Q 145. Back

111  Q 235. Back

112  IbidBack

113  Q 236. Back

114  Q 240. Back

115  Q 236. Back

116  HC 231, Ev. p. 2. Back

117  www.maff.gov.uk/ebus/eforms/eforms.htm Back

118  Q 197. Back

119  Ev. p. 17, para 3.2.2. Back

120  Ev. p. 2. Back


 
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