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.
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.
By making the form complete at this stage, it might forestall
the need to ask for information at other times.
MAFF reviews the IACS forms every year, taking account of whether
all information is required and recent changes to regulations,
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
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.
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.
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.
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."
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.
40. Farmers' leaders have welcomed the introduction
of e-forms because of their assistance in reducing the potential
for clerical errors.
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
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
p. 43, para 17. Back
p. 1. Back
96 Ibid. Back
138, 145. Back
Report, rec 4. Back
p. 81, paras 17-18. Back
107 www.scotland.gov.uk/library3/agri/surveyofsmallproducers.pdf Back
112 Ibid. Back
231, Ev. p. 2. Back
117 www.maff.gov.uk/ebus/eforms/eforms.htm Back
p. 17, para 3.2.2. Back
p. 2. Back