barbieri und ongaro 2008_eu agencies-what is common and what is distinctive compared with...

7/25/2019 Barbieri Und Ongaro 2008_EU Agencies-What is Common and What is Distinctive Compared With National-level Pu

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EU agencies: what is common and what is distinctivecompared with national-level public agencies

Dario Barbieri and Edoardo Ongaro

Abstract

The number and relevance of EU agencies have rapidly increased over the years:EU agencies nowadays constitute an important part of the EU institutional land-scape. The article investigates the EU agencies through categories of analysis wellestablished in studies of public management focused on the phenomenon ofagencies at the country level: structural disaggregation, autonomy, and contractu-

alization. It emerges that EU agencies are relatively homogeneous, an aspect thatdifferentiates European agencies from the highly heterogeneous world ofnational-level agencies. The main features of the EU agencies are examined, theEuropean type of agency is identified and defined, and the way the EU agencymodel differs from country-level agencies is analysed. Research agendas on thereform of the European Union might benefit from systematic investigation of EUagencies: theoretical frameworks drawn from the public management field canprovide a significant contribution in this respect.

Points for practitioners

EU agencies are no longer residual organizations: they are a significant compo-nent of the functioning of the EU system and policy networks. By investigating thefeatures of such agencies through the conceptual lenses of public management,and through comparison with the (much more investigated) national-level agen-cies, the article provides an outline of EU agencies in terms of structural relations

with the other EU institutions, autonomy, and modalities of steering and control.Reforms of the EU through the establishment or revamping of agencies couldbenefit from the systematic consideration of such features.

Dario Barbieri and Edoardo Ongaro, Professors, Universit Bocconi and SDA Bocconi School ofManagement, Milan, Italy.

Copyright 2008 IIAS, SAGE Publications (Los Angeles, London, New Delhi and Singapore)

Vol 74(3):395420 [DOI:10.1177/0020852308095310]

InternationalReview of

AdministrativeSciences


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Keywords: contractualization, European Union, public agencies,semi-autonomous organizations, steering and control

IntroductionThe employment of semi-autonomous organizations for the execution of publicfunctions is a phenomenon in many respects as old as public administration, at leastat the country level (Hood and Schuppert, 1988; Van Thiel, 2001). The problems ofgovernance of these bodies have a long history in studies of public management andpublic administration (Wettenhall, 2005). Agencies are an important subject of reform

talk (OECD, 2002) and scientific analysis (Thynne, 2004). However, providing a defini-tion of public agency has proved to be quite a difficult task. In an initial attempt atdefining the phenomenon, Pollitt et al. (2001) identify an agency as a public organi-zation at arms length from the main administration (there is a degree of structuraldisaggregation between the agency and the parent administration), carrying outpublic tasks assigned on a non-competitive basis, having a core staff of publicservants, being in principle financed by the state budget, and subjected to at leastsome administrative law procedures. The issue of the governance structure of thesedisaggregated bodies and in particular the analysis of the agency phenomenon

through the central dimensions of: (1) the nature and degree of autonomy of theseorganizations, and (2) the modalities whereby the steering and control over agenciesis wielded are central to this debate. Prominent research agendas in public man-

agement shaped around such basic concepts are providing important findings aboutthe phenomenon of agencies at the national level (Lgreid et al., 2005; Pollitt andTalbot, 2004; Pollitt et al., 2004; Verhoest et al., 2004).

What is the potential of such research agendas if applied to European Union (EU)agencies? It is the aim of this article to go along this path and investigate the EUagencies through categories of analysis that are now well established in studies ofpublic management focused on the phenomenon of agencies at the country level. Byapplying such categories of analysis (outlined in the final part of this section and illus-

trated in detail in the section EU agencies: dimensions of analysis and case evidence),

it emerges that EU agencies are relatively uniform when compared with the highlyvariegated world of national-level agencies. The finding is quite puzzling, since thereseems to be a broad agreement by scholars investigating the phenomenon of agen-cies at the national level about the high heterogeneity of such bodies (Caulfield,2004; Fedele et al., 2007; Lgreid et al., 2005; Ongaro, 2006; Pollitt and Talbot,2004; Pollitt et al., 2004; Thynne, 2004; Verhoest et al., 2004): this aspect as well as

the characteristics of EU agencies more broadly are examined in this article.First of all, some features of the peculiar nature of EU governance the broader

context in which agencies operate are outlined. Conceptualizing the EU govern-

ance is a huge task (see, inter alia, McCormick, 2005, for a general introduction; andNugent, 2006, ch. 21, for a thoughtful synthesis). For the purposes of the presentcontribution, as a first step the perspective of the intergovernmental/supranational(dynamic) balance of the EU (Nugent, 2006: 55761) will be adopted: intergovern-mentalism refers to arrangements whereby nation states, in situations and conditions

they can control, cooperate with one another on matters of common interest; supra-

396 International Review of Administrative Sciences 74(3)


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nationalism refers to situations in which states work with one another in a mannerthat does not allow them to retain complete control over further developments.Factors that point to the supranational characteristics of the EU are the significantfunctions attributed to the European Commission (including its policy initiation role),

the increasing powers of the European Parliament, the role performed over the entirehistory of European integration by the European Court of Justice. Factors that point to

the intergovernmental characteristics of the EU include the leading role of theEuropean Council in terms of taking virtually all major decisions on the general direc-

tion and policy priorities of the EU, and the key legislative role of the Council ofMinisters (and the practice of attempting to reach consensus, even where majorityvoting is permissible, whenever a state declares that it has an important interest atstake). EU agencies are problematic to assess according to the intergovernmental/supranational balance: they are non-majoritarian institutions established throughpublic acts of delegation by the EU Commission and in this sense they are suprana-

tional bodies that have in the EU Commission their main parent administration, andthat in some respects condition from the outside the member states (supranationalinfluence). At the same time, however, in other important respects EU agencies areinstrumental to forms of cooperation led by member states.

Another important issue concerns the functions performed by the EU agencieswithin the policy process. EU agencies are mainly confined to the implementationphase, though some of them may wield a role also in policy formulation. In anattempt at applying Kingdons model of the policy process (Kingdon, 1994) to the

European Union, Richardson (2001) conceptualizes the EU policy process in fourstages agenda-setting, policy formulation (alternative specification, in the original

wording of Kingdon), policy decision, and policy implementation. All EU agencies areinvolved in the implementation phase of an increasing number of EU policies; someof them have an influence also on the policy formulation phase (as an example, see

the case of the European Environment Agency, EEA, examined in Appendix 2),though not in the sense that they exercise formal decision-making powers, that arethe exclusive competence of treaty-based EU institutions (under the so-called Meronidoctrine), but because they provide data, information, and (mainly informal) pro-

posals that may eventually influence the actual formulation of the content of theEuropean public policy (formal policy decisions are adopted by the competent EUinstitutions).

The administrative features of such bodies represent another important aspect. EUagencies share many of the features of the EU bureaucracy (Stevens and Stevens,2001; on the Commission, see Hooghe, 2001, and Page, 1997), though with oneimportant difference: their locations are scattered throughout Europe. Thus the inter-national composition of the staff of these bodies and their condition as expatriateson a permanent basis (at least for a significant portion of the staff) elements in

common with the other EU institutions interact with a living place which is differentfor each agency, and is not Brussels (thus the equivalents of the anthropologicalstudies conducted by Abeles, Bellier and McDonald, 1993 cited in Stevens andStevens, 2001 and various subsequent publications on EU officials have still to beproduced for these relatively new bodies).

EU agencies have grown rapidly in number and competences during the 1990s

Barbieri and Ongaro EU agencies 397


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Table 1 List of EU agencies (first pillar)

Agency Established Location Policy sector(s)

CdT 1994 Luxembourg InternalTranslation Centre for the (Luxembourg) administrationBodies of the European Union

Cedefop 1975 Thessaloniki Social policiesEuropean Centre for Development (Greece) Employees trainingof Vocational Training

CFCA 2005 Vigo Internal marketEuropean Fisheries Control Agency (Spain)

CPVO 1994 Angers Intellectual propertyCommunity Plant Variety Office (France) Products

communitarianmovement

EAR 2000 Thessaloniki External relationsEuropean Agency for (Greece) ReconstructionReconstruction projects

management

EASA 2002 Koeln TransportsEuropean Aviation Safety Agency (Germany) Internal market

enhancement

ECDC 2004 Stockholm Public healthEuropean Centre for Disease (Sweden)Prevention and Control

ECHA 2006 Helsinki Intellectual propertyEuropean Chemicals Agency (Finland) Internal market

EEA 1990 Copenhagen EnvironmentEuropean Environment Agency (Denmark)

EFSA 2002 Parma (Italy) AgricultureEuropean Food Safety Authority Public health

EIGE 2005 Site to be Social policiesEuropean Institute for Gender Equality decided Human rights

EMCDDA 1993 Lisbon Public health,European Monitoring Centre for (Portugal) Social policiesDrugs and Drug Addiction Crime monitoring

EMEA 1995 London Public healthEuropean Medicines Agency (GB) Products

communitarianmovement

EMSA 2003 Lisbon TransportsEuropean Maritime Safety Agency (Portugal) Internal market

enhancement

ENISA 2004 Heraklion InformationEuropean Network and (Greece) Internal MarketInformation Security Agency

continues


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and, especially, the 2000s (see Table 1) and they now represent a significant part ofthe communitarian institutional landscape: a part that is still under-investigated. In thisarticle the main features of the EU agencies are analysed and it is investigated

whether there is a European type of agency and how it differs from the (highly var-iegated) world of national-level agencies investigated in public management studies.The main research questions can be formulated as follows: Does a European type ofpublic agency exist? What are its features? And how does it differ from the world of

the national- and sub-national-level agencies?

The list1 of the agencies that are investigated in this article is reported in Table 1.The agencies constituted under the second and third pillars of the EU are excludedfrom the analysis, as are the ones created under the Euratom Treaty, because of theirpeculiar scope and characteristics. There is still no agreed definition of EU agency(Groenleer, 2006) and there is no definition in official EU documentation, which usu-ally refers to agencies as delegated bodies. EU agencies differ from three other types


Table 1 cont.

Agency Established Location Policy sector(s)

ERA 2004 Lille- TransportsEuropean Railway Agency Valenciennes Internal market

(France) enhancement

ETF 1990 Turin External relationsEuropean Training Foundation (Italy) Social policies

EUROFOUND 1975 Dublin Social policiesEuropean Foundation for the (Ireland) EmployeesImprovement of Living and circulationWorking Conditions

European GNSS Supervisory 2004 Site to be Transports

Authority decided Internal marketenhancement

FRA 2007 Vienna Free citizensEuropean Union Fundamental (Austria) movementRights Agency Human rights

FRONTEX 2004 Warsaw Free citizensEuropean Agency for the (Poland) movementManagement of Operational Crime monitoringCooperation at the External Borders

OHIM 1993 Alicante Intellectual propertyOffice for Harmonization in the (Spain) ProductsInternal Market (Trade Marks communitarianand Designs) movement

OSHA 1994 Bilbao Public healthEuropean Agency for Safety and (Spain) Social policiesHealth at Work

Source: http://europa.eu/agencies/index_en.htm (accessed December 2007).


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of European entities commonly associated (in the communitarian institutional setting)to the concept of delegated bodies. In Krehers classification (1997), the followingbodies cannot be considered EU agencies: internal bodies or departments of theEuropean Commission (for instance, the Statistical Office of the European Union Eurostat which is independent from the Commission but is still considered a service,in the organizational sense, within the same Commission); institutions explicitly listedin the European Union Treaty (for instance, the European Central Bank, which isdefined by Everson, 1995, as an organization charged with the pursuit of distinctConstitutional-type normative goals); institutions created on an intergovernmentalbasis that is outside the legal framework of the European Union (like the EuropeanUniversity Institute in Florence). In this article, following and expanding the notionelaborated by Pollitt et al. (2001, 2004), EU agencies are defined as those structural-ly disaggregated organizational solutions, established by EU institutions, that have theabove-reported features and that occupy a certain portion of space in the [autono-my] [steering & control] conceptual space.

EU agencies have been studied from different theoretical angles. From a politicalscience perspective, studies have been conducted on the effects of the settlement ofEU agencies on the governance mechanisms of the EU as a whole as well as on theinternal governance mechanisms of the same agencies (Barbieri, 2006b; Everson,1995, 2005; Flinders, 2004; Hix, 1998; Kreher, 1997; Vos, 2000), occasionally also

through comparisons with the US political system (Shapiro, 1997). EU agencies play asignificant role in the regulatory framework of the EU: many scholars have devoted

their attention to the influence of EU agencies on EU regulatory regimes (Caduff andBernauer, 2006; Coen and Thatcher, 2008; Dehousse, 1997; Eberlein and Grande,2005; Egan, 1998; Gehring and Krapohl, 2007; Lafond, 2001; Majone, 1997, 2003;Randall, 2006; Thatcher, 2002). Some scholars have focused their analysis on issuesof accountability of EU agencies (Bergstrm and Rotkirch, 2003; Curtin, 2005; Majoneand Everson, 2001; Vos, 2005). Other scholars, from a law studies perspective, haveinvestigated the influence the establishment of EU agencies has had over the com-munitarian law (Chiti, 2000, 2004; Dehousse, 2002; Vos, 2003). Another stream ofrelevant contributions to the debate on EU agencies comes from theoretical per-

spectives closer to economics (Borrs et al., 2007; Kassim and Menon, 2003; Krapohl,2004; Pollack, 1997).

Investigations on EU agencies seem instead to have been neglected in the publicmanagement literature: this article aims to fill this gap and explore the potential ofapplying frameworks drawn from the public management camp to the study of EUagencies. The analysis is conducted by comparison with national-level agencies,

which entails the need to define the term of comparison (what are the features ofnational-level agencies?). This step has been carried out: (1) by broadly surveyingliterature in public management for identifying the (variable) features according to

some specific categories of analysis (what types of autonomy national-level agencieshave, what mechanisms of steering and control are in operation, etc.); (2) by specifi-cally making reference to a framework of analysis developed for the study of theItalian public agencies (Fedele et al., 2007), as a suitable template for structuring theempirical evidence; and (3) by employing as a term of reference the so-called tripodmodel, a practitioners model which has been widely accepted as a model to



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describe and interpret the phenomenon of agencies at the national level. The tripodmodel was first theorized by Pollitt et al. (2004): they refer to agencies as bodies thatare structurally disaggregated from the parent ministry, that have a focus on theoperations (on the policy delivery phase of the policy cycle), enjoy relevant manage-rial autonomy and are steered through forms of results-based control. This third pointrequires additional explanation: many criticisms have been made of the tripod modelin the terms of worldwide convergence towards such a model nothaving theoreti-cal nor empirical grounding. The reasons for considering the tripod model are that:(a) it is instrumental to testing the hypotheses of convergence (i.e. we give anotherchance to the convergence hypothesis that maybe in a very specific institutionalsetting like the EU might find a chance of not being falsified); (b) it is a model near tohand to define by comparison of the features of the EU type of agency. The countriesconsidered in drawing the characteristics of national-level agencies are the UnitedKingdom (Carter and Greer, 1993; Greer, 1992, 1994; James, 2001; Pollitt and Talbot,2004), Sweden (Christensen and Wise, 2003; Pierre, 2004) and Italy (Barbieri, 2006a;Fedele et al., 2007; Ongaro, 2006), three countries representing substantially differentpatterns of public agencies in terms of their features, role in the public sector, and his-

torical development. In the final sections, findings concerning the main research ques-tions and implications for future developments of research on the topic are discussed.

Methodology

The research design is based on the following steps: first, drawing on literature, thecategories of analysis have been identified (structural disaggregation, autonomy, andcontractualization) and specific indicators for each category operationalized (seeTable 2, column 1, and the following section). The indicators have been identified insuch a way as to make it possible to use data drawn from secondary sources (publicdata, including: the statutes of agencies; the official evaluation reports issued by theCommission and the evaluation reports made by external and independent scholarson behalf of the Commission and of the European Parliament; multi-annual reportsand work plans; accounting, budgeting, and auditing documents issued by the same

organizations as well as official documents discharged by the Commission and theEuropean Parliament; Court of Auditors official reports). This has paved the way for

the second step: the application of the indicators to the entire population (as definedin the previous section) of EU agencies (see Table 2). Then (the third step), in order todeepen the understanding of the actual operations of EU agencies, and to be able togo beyond the analysis of the legal-formal (however relevant) features of EU agen-cies, a multiple case study on two agencies, based on interviews and on-the-fieldinvestigation, has been developed (Appendices 1 and 2). In this way, the main frame-

work of analysis based on secondary sources has been integrated with in-the-field

analysis of the cases of the European Medicines Agency (EMEA) and the EuropeanEnvironment Agency (EEA).

The selection of these two agencies is due to their different characteristics: EMEAis an authorization agency responsible for granting permissions, EEA is a co-ordination/information agency collecting, analysing and redistributing information.The EMEA has a relevant executive role in the delivery of the policy (in this case, the



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pharmaceutical policy, though the formal power to grant authorizations remains withthe Commission), while the EEA is an independent information collecting agency (onthe distinction between executive and independent information collection agencies,see Kreher, 1997) that may exercise a role in the policy formulation phase, as policyfacilitator and, maybe, also as policy impetus agency (Everson, 1995; Everson et al.,1999).

EU agencies: dimensions of analysis and case evidence

The concepts employed in the analysis are those of structural disaggregation,autonomy, and contractualization; contractualization is to be interpreted as a sub-component of the broader category of steering and control the reason for focus-ing on contractualization is that it is a qualifying element of the tripod model. The

three concepts will be subsequently illustrated.In Talbot (2004), structural disaggregation is described as a purchaserprovider

split, or as a policyoperations or policy formulationpolicy implementation divisionof labour, that is, a form of functional specialization. Contractualization refers to therelationship established between the purchaser and the provider, or the actor(s) for-mulating the policy and the actor(s) in charge of the operations: a sort of contract (inorganizational terms) defines what the agency should do, in return for receiving astated amount of resources. The contractual relationship should entail a results-oriented focus in which results are specified in terms of outputs and outcomes. Those

two categories of analysis must be complemented by the notion of autonomization(Pollitt et al., 2004). Autonomization assumes that establishing a separate body is notsufficient if it is not given enough autonomy to perform its functions. The relativeautonomy entails the need to regulate the relationship between the agency and itsparent administration (namely the Commission). This can be done through conctrac-

tualization, as well as through re-regulation, i.e. establishing a new and different setof rules from the ones in operation for the parent administration (Talbot, 2004). Therole of EU agencies is primarily focused on the provision of inputs to the policy-making process and the management of the implementation phase, though in some

cases it is limited to technical support to the European Commission by means of sci-entific advice or information delivery, or to a purely administrative role (as in the caseof the CDT and EAR).

Turning to the operationalization of such concepts, structural disaggregationrefers to the characteristics of the separation between the agency and the parentadministration and is measured in terms of: institutional distance between the agencyand the Commission (which increases if the agency has legal status, whether itresolves upon its statute, and whether it has a corporate board); degree of complex-ity of the tasks performed by the agency (how disaggregation is fulfilled: the variety

of policy areas in which the agency operates, the heterogeneity of the outputs andfunctions performed); institutional specialization of the operations (this concept refers

to the existence of a clear separation between the policy level and the operationallevel).

Autonomy presents three dimensions: financial, managerial, and strategic (orpolicy autonomy). Financial autonomy refers to the capacity to acquire extra financial



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resources, in addition to Commission funding: the higher the level of extra fundsgenerated, the greater the financial autonomy. Managerial autonomy measures theautonomy of the agency with reference to the management of its financial, human,and organizational resources, in terms of the autonomy of the chief executive (theexecutive director, in EU terminology) in determining the staff size, the agency orga-nizational structure, and the appointment of agency managers. Indicators of mana-gerial autonomy are also the chance for the agency staff not to be subjected tocommunity regulation, and the opportunity for the agency to deliberate on financial

transactions and expenditure levels. Strategic autonomy refers to the influence of theagency on the formulation of the policy targets and on the selection of instruments

to implement the policy.The degree of contractualization refers to the existence of the contract between

the Commission and the agency, its features and the monitoring and rewarding toolsinherent in the contract. The notion of contractualization is used in order to analyse

whether the Commission can steer the agency through the contract. The indicatorsmeasuring the degree of contractualization have been defined as follows: existenceof the contract, contents, set of tasks regulated by the contract; existence of a linkbetween targets and human resources management (in terms of evaluation andpossibility of removal of management if the targets of the agency are not achieved);existence of a link between the achievement of the target and the provision of addi-

tional resources to the agency; existence of a system for monitoring the contract.The agencies operative (at the time of writing) in the EU constitute the population

object of the investigation (Table 1): for each of the above features it has beenspecified whether it is absent (no, in the table), it fully exists (yes in the table) or itpartly exists (partly in the table). The difficulties in measuring such dimensions haveled to consider the third option partly beyond the yesno dichotomy, in order tograduate the evaluation in some instances.

It emerges that, contrary to what happens at the national level (e.g. see Fedele etal., 2007, for the same framework of analysis applied to the Italian case), in manycases there is a significant degree of homogeneity (all agencies present similarfeatures) at a level of analysis at which a significant heterogeneity in country-level

agencies is detectable. At a more detailed level, it would very likely be possible to dis-criminate between agencies (e.g. presence/absence of a member of the boardappointed by the Commission, and whether s/he is an official of the Commission orappointed by the Commission): in this work the aim is to describe whether a type ofEU agency exists or not (e.g. all EU agencies have a board, while at the national level

there is differentiation regarding this characteristic). For this reason it is interesting tohighlight that most of the indicators used are homogeneous for all agencies and fewindicators point to differences among EU agencies. The results are summarized inTable 2 and Table 3 and are described in the next paragraph.

Before presenting the analysis and comparison with national-level agencies, somecommon features that characterize the EU agencies are described (drawing onBarbieri, 2006b). The mandate of the agencies and the range of their powers aredelimited and identified in the founding statute: EU agencies have legal personalityand in all instances are managed by an executive director. The executive director isresponsible for the management of the agencys activities, in line with the agencys



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Table 2 Structural disaggregation, autonomy and contractualization dimensions of EU agencies

Agency

CdT CedefopCFCA CPVO EAR EASA ECDC ECHA EEA EFSA EMCDDA EMEA EMSA

IndicatorStructural disaggregation

A. INSTITUTIONAL DISTANCE

A-1. The agency has legal status Yes

A-2. The agency resolves upon its Statute No

A-3. Corporate board Yes

B. TASK COMPLEXITY

B-1. The agency operates in more than one

policy area

B-2. The agency delivers heterogeneous No No Yes No No Yes Yes Yes Yes Yes Yes Yes Yes

outputs/services

B-3. The agency wields a plurality of public No No Yes Yes Yes Yes No No No Yes No Yes Yes

functions (regulation, control, production)

C. INSTITUTIONAL SPECIALIZATION on operationC-1. The separation between Policy (ministry) Yes

and Operation (agency) is clear

Autonomy

D. FINANCIAL AUTONOMY

D-1. The agency can acquire further resources No No Yes Yes No Yes No Yes Yes No Yes Yes No

through contracts with other administrations,

outside Commission funding

D-2. The agency can sell its products/services No

D-3. The agency can borrow on capital market No

E. MANAGERIAL AUTONOMY

E-1. The chief executive can determine the size of Partly

agency staff

E-2. The chief executive can determine the agency Partly

organization structure

E-3. The agency staff is not subjected to Community No

regulation

E-4. The chief executive appoints the agency No

managers

E-5. The agency can deliberate on financial

transactions and expenditure levels Partly


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Table 2 cont.

Agency

CdT CedefopCFCA CPVO EAR EASA ECDC ECHA EEA EFSA EMCDDA EMEA EMSA

Autonomy (cont.)

F. STRATEGIC AUTONOMY

F-1. The agency influences the formulation of No No No No No Partly Partly Partly Partly Partly Partly No Partly

policy targets

F-2. The agency can determine the instruments to Yes

implement policies

Contractualization

G. DEGREE OF CONTRACTUALIZATION OF

COMMISSIONAGENCY RELATIONSHIP

G-1. Formal existence of a contract Partly

G-2. Contents of the contract:

a) Targets and resourcesb) General (generic) goals

c) Regulation of the relationship b)

G-3. The entire set of tasks of the agency are Partly

regulated by the contract

G-4. Agreement on contract is an input to the No

budgeting process

G-5. Targets in the contract are an input for No

HRM/evaluation of the management

G-6. Failure in achieving contracted targets is one Yes

cause of removal of top management

G-7. Agency is provided with additional resources No

on achievement of targets

G-8. Existence of a system for the monitoring of Yesthe contract


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Table 3 Comparison of structural disaggregation, autonomy and contractualization dimensions of EU, triagencies

EU Tripod Mo

Structural disaggregation

IndicatorA. INSTITUTIONAL DISTANCE High High

(though agencies do not resolve upon theirstatutes uniform values for all agencies)

B. TASK COMPLEXITY Low Low(agencies operate only in one policy area)

C. INSTITUTIONAL SPECIALIZATIONS High Highon operation (uniform values for all agencies)

AutonomyIndicator

D. FINANCIAL AUTONOMY Low Low(though a few agencies can acquire further

resources outside Commission funding)E. MANAGERIAL AUTONOMY Low High

(uniform values for all agencies)F. STRATEGIC AUTONOMY Low Low

(concerning the formulation of policy targets)High

(concerning the determination of policy instruments)

ContractualizationIndicatorG. DEGREE OF CONTRACTUALIZATION Low High(PERFORMANCE CONTRACTING) (uniform values for all agencies)


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mandate. The executive director should neither solicit nor accept instructions fromany government or other EU body, except in cases provided for by the regulationestablishing the agency. The executive director is usually appointed by the manage-ment board on proposal of the Commission, even if some exemptions exist. Themanagement boards (for an overview, see Table 4) are composed mainly of repre-sentatives of the European institutions and member states. In the case of agencies

with a social remit, there is a larger representation of social partners. In some cases,representatives of the professional sectors are appointed, without voting right. Directrepresentatives of the European Parliament are not present: in some cases, inde-pendent experts appointed by the European Parliament sit on the managementboard. The management board can dismiss the director and establishes the internalrules of the agency. The management board approves the annual programme ofactivities, the annual activity report and proposes the discharge of the budget to theEuropean Parliament. Advisory Committees in some cases are present in the organi-zational structures of the EU agencies: they are usually composed of independentexperts and they are required to deliver opinions to the executive director on draftversions of the acts of the agency.

The activities of the EU agencies are monitored and subjected to rules issuedby the European Parliament, the Council and the European Commission. The Com-mission plays the role of the main (executive) controller of the activities of theagencies. From a legal point of view, the connection between the pre-decision anddecision phases of the policy process (involving the Commission, the Parliament and

the Council) and the operational, policy implementation level (formally assigned tothe delegated bodies) is strictly regulated. EU agencies do not hold formal decisionpowers concerning the formulation of the policy (though in some cases they caninfluence the definition of policy targets, i.e. they influence the alternative specificationphase of the policy formulation process (Kingdon, 1994)). External financial controlsand judicial controls are also present.

Case analysis: differences between EU and national-level agencies

This section examines the features of the EU agencies (Table 2) and compares themwith the features of national-level public agencies (Italy, Sweden, and the UnitedKingdom) as well as with the ideal-typical features of the tripod model (findings of

this comparison are summarized in Table 3). The tripod model is derived from theconceptualization elaborated by Pollitt et al. (2004). The findings of the multiple casestudy on the two agencies EMEA and EEA are reported in Appendices 1 and 2 such findings are employed for complementing the analysis with in-depth investiga-

tion based on first-hand empirical evidence.

DisaggregationA premise: given that in a number of instances entirely new tasks were assigned toagencies established ex novo, in these cases tasks have not been disaggregatedfrom the parent administration (the Commission) to agencies. However, the notion ofdisaggregation is employed as an umbrella concept, even though in some instances



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Table 4 Composition of management board, advisory forums and scientific committeesof EU agencies

Agency Management board Advisory forum Scientific committee

CdT 1 r. per member State2 r. of the Commission1 r. from each body orinstitution calling uponthe centres services

Cedefop Per member State:1 r. of the government,1 r. of employersorganization, 1 r. ofemployees organization.

4 r. of the CommissionCFCA 1 r. per member State, 1 r. per Regional

4 r. of the Commission, Fisheries Council4 r., without right to vote,of the fishing industry

CPVO 1 r. per member State,1 r. of the Commission

EAR 1 r. per member State,2 r. of the Commission

EASA 1 r. per member State, Representatives from

1 r. of the Commission aviation personnel,manufacturers,commercial andgeneral aviationoperators, maintenanceindustry, trainingorganizations andair sports

ECDC 1 r. per member State, 1 r. per member3 r. of the Commission, States National2 experts appointed by Authority

the Parliament

ECHA 1 r. per member State Forum for exchange Committee for Riskof information on Assessment (1 r. perenforcement activities member State),(1 r. per member Committee forState and 5 experts) Socio-economic Analysis (1

r. per member State),member State Committee(1 r. per member State)

EEA 1 r. per member State, Up to 20 independent

6 r. of the Commission scientists from the memberStates

EFSA 15 members appointed 1 r. per member Nine Chairpersons ofby the Council (in State EFSAs Scientific Panelscooperation with plus six independentParliament and scientistsCommission)

continues


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Table 4 cont.


EMCDDA 1 r. per member State,

2 r. of the Commission,2 experts appointed bythe Parliament

EMEA 1 r. per member State, CHMP (Committee for2 r. of the patients Medical Products fororganization, 1 r. of the Human Use): 1 r. perdoctors organization, member State, 1 r. per1 r. of the veterinarians each EEAEFTA State, uporganization, 2 r. of the to 5 experts co-optedCommission, 2 experts by CHMP; CVMP

appointed by the (Committee for MedicinalParliament, , 1 r. per Products for Veterinaryeach EEAEFTA State Use): as CHMP; HCMP

(Committee for HerbalMedicinal Products): 1 r. permember State, 1 r. per eachEEAEFTA State; COMP(Committee for OrphanMedicinal Products): 1 r. permember State, 1 r. per eachEEAEFTA State, 3 experts

appointed by theCommission on EMEAsproposal, 3 r. of thepatients organization, 1 r.of the Commission; PDCO(Paediatric Committee): 5members of CHMP, 1 r. permember State, 3 r. patientsorganizations, 3 r. of health-care professionals

EMSA 1 r. per member State,

4 r. of the Commission,4 r., without right to vote,of the professional sectors

ENISA 1 r. per member State, 30 experts representing3 r. of the Commission, the relevant3 r. of the stakeholders stakeholders

ERA 1 r. per member State,4 r. of the Commission,6 r., without right to vote,of the professional sectors

ETF 1 r. per member State, Around 120 experts2 r. of the Commission appointed by the

management boardfrom member States,eligible country, fromthe social partners atthe European level

continues


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tasks were new and no public institution at the EU level was in charge of performingthem before they were assigned to an EU agency.

A. Institutional distance A-1. All agencies have legal status and are legally distinctfrom the Commission. As a consequence, they can operate under the law of the statein which they are located and are legally responsible for their actions in front of thelegal bodies of the country. Another consequence is that agencies can sign contractsand acquire goods under their responsibility in the states where they operate: thedistance from the Commission is in this respect relevant. Even if they operate legally

in the member states, however, agencies are responsible to EU bodies for their acts.National-level agencies present a more varied picture, as they may not have legalstatus, and the degree of separation between the department and the agency canvary widely.

A-2. Agencies do not resolve upon their statute. At the national level it is quitecommon that agencies do not resolve upon their statutes, though it may occur: there


Table 4 cont.


EUROFOUND Per member State:

1 r. of the government,1 r. of the employersorganization, 1 r. of theemployees organization.2 r. of the Commission

FRA 1 independent person Independent expertsappointed each by: from the membermember States, Council Statesof Europe. 2 r. of theCommission

FRONTEX 1 r. per member State,

2 r. of the CommissionOHIM 1 r. per member State,

1 r. of the CommissionOSHA Per member State: Three advisory groups

1 r. of the government, (made up of members1 r. of the employers of the managementorganization. 1 r. of the board and othersemployees organization, nominated by the3 r. of the Commission Agency): Risk

Observatory, WorkingEnvironment

Information, andCommunication andPromotion

Note: R in second column stands for representative. In the table only the advisory forums andscientific committees made up of external members and/or representatives of member States andstakeholders are listed.


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is high heterogeneity at the country level concerning this point. The tripod modeldoes not require an agency to resolve upon its statute.

A-3. All agencies have a corporate board and a director; in some cases, there isalso an advisory forum and/or a scientific committee. The presence of a managementboard, with the compulsory representation of the member states, and in almost allinstances the presence of an appointee of the Commission (and in some cases thepresence of experts nominated by the Parliament) seem to point at some degree ofinstitutional distance between the agency and the (multiple) parent administrations.In some cases, stakeholders are represented in the management board. National-level agencies present a wider differentiation.

B. Task complexity B-1. Each agency operates in one and only one policy area which applies to most country-level agencies, though with exceptions. The tripodmodel foresees a clear focus of agencies on the operations in one policy area, and

this is the case for all EU agencies. However, in a number of instances, more than oneDirectorate General (DG) of the EU Commission performs as the parent administra-

tion. For instance, in addition to the relationships with the DG Budget, the DG InternalAudit Service and the DG Personnel and Administration (like all agencies), the EMEAis linked to the DG Enterprise and Industry, its main parent administration, but also to

the DG Enlargement and the DG External Relations, and it has interconnections alsowith other DGs, such as DG Agriculture and Rural Development, DG Employment,Social Affairs and Equal Opportunities, DG Health and Consumer Protection.

B-2/3. It emerges that agencies can deliver both homogeneous (e.g. Cedefop,ENISA) and heterogeneous (e.g. EFSA, EMSA) outputs and services and execute eitherone category or, more often, more than one of the main functions identified. This evi-dence counteracts a requirement of the tripod model, if we interpret it as beingcharacterized by specialization on a single task but it confirms the trend at thenational level, where in many cases agencies perform a multiplicity of functions (withUK Next Steps agencies more focused on relatively well-specified tasks than Italian orSwedish agencies).

C. Specialization in operations C-1. In almost all cases, there is a clear separationbetween policy and operations. This evident split is formalized in the principle ofseparation between decision powers (assigned to the Commission and other EUinstitutions) and policy delivery tasks (assigned to the agencies). The specialization inoperations is a feature of the tripod model. National agencies, however, are muchmore variable creatures.

Autonomy

D. Financial autonomy D-1. Some agencies can acquire further resources out-side EU Commission funding through contracts with other administrations. Only afew agencies are given the opportunity to finance themselves by means of feescharged to customers; this is the case with CPVO, EMEA and OHIM. In budgetary

terms, agencies fall under the so-called non-compulsory part of the EuropeanCommissions budget: for this reason, in addition to its power of discharge, the



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European Parliament may also impose strict accountability requirements, such asreporting procedures and attendance at parliamentary committees. Country-levelagencies are much more varied concerning this dimension.

D-2/3. EU agencies cannot sell their products on the market nor can they raiseloans. The rationale for this strict rule is that it represents a mechanism to maintain thefinancial equilibrium of the overall budget, which might be affected by the opportu-nity to operate on the financial markets. In this respect, the financial autonomy of EUagencies can be considered to be low. At the national level the degree of financialautonomy varies: NPM-oriented agencies (typified by the UK Next Steps agencies)or agencies totally disaggregated from the parent ministries (see the Swedish case;Pierre, 2004) usually enjoy higher levels of financial autonomy than in other countries,such as Italy (Fedele et al., 2007), but the majority of agencies even in this latter casecan extend their funding by selling products/services.

E. Managerial autonomy The managers of EU agencies have limitations in deter-mining the size of the staff of the agency, which is approved by the Commission

together with the agency budget. Moreover, the director and the managementboard have limited scope in determining the organizational structure of the agencyor in deliberating on financial transactions and expenditure levels; there are limitationsalso to the appointment of agency managers. All in all, managerial autonomy seems

to be low compared to agencies in Sweden, the UK, and also Italy, and for sure it islow compared to the tripod model. Indeed, it appears that EU agencies have no

actual difference in terms of their managerial autonomy from what would be achiev-able by internally decentralized units of the European Commission (managerial dele-gation; see Levy, 2003, for an analysis of decentralization and centralization as aneffect of management reform in the European Commission).

F. Strategic (policy) autonomy EU agencies have basically no autonomy in defin-ing policy targets, though they can wield indirect influence on policy formulation, e.g.by selecting and shaping the format of the information on which policy decisions arebased, as in the case of the environment agency (EEA), but they have some or signifi-

cant autonomy in defining policy instruments. The country-level world of agenciesis varied concerning this aspect (ranging from agencies often involved also in policyformulation, as in Sweden, to agencies usually more confined to policy implementa-

tion, but with exceptions, as in Italy).

Contractualization

G. Degree of contractualization of the relationship between European Com-

mission and agencies Using the term contract to describe the relationships

between the Commission and the agencies could be considered improper since theterm contract implies a set of objectives to be reached and rules to be respected toget back predetermined rewards: in the EU setting such a type of document is notdetectable. What is required of all agencies is compliance to certain budgetary pro-cedures, including the production of documents and written communication con-cerning objectives and performance requirements, as well as follow-up procedures



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mainly involving the Commission and the Court of Auditors, but increasingly also theEuropean Parliament and the Council.2

Annual reports or work plans can be considered as kinds of contracts affecting thebudgetary process or the evaluation of the human resources, but, even if they canaffect the budgetary procedure and can have serious consequences on the amountsof funds assigned to the agency, there is no direct and formal relation between

targets, results and punishments/rewards, hence there is no performance contract.The director is evaluated on the basis of the targets reached and can even beremoved if s/he fails in achieving the targets, but performance management systems,

where they exist, are internal to the agency and they are not employed in an exter-nal contractual relationship between the Commission and the agency. EU agencies in

this respect are not tripod model agencies; indeed, the very limited degree of conc-tractualization, and especially of performance contracting, is a key element of differ-entiation of EU agencies from the tripod model (a differentiation which is quitecommon also in national-level agencies: many studies report about the relativeabsence or patchy diffusion of performance contracts, with the partial exceptions of

the UK and a few other countries).

Discussion

In this article we make an initial attempt to explore the potential of an importantportion of the public management research agenda on agencies when applied to the

EU agencies. To this purpose, the main features of the EU agencies have beenanalysed in terms of the way they are disaggregated from the parent administra-

tion(s), the level of autonomy, and the degree of conctractualization, and it has beeninvestigated whether there is a European type of agency and how it differs fromnational-level agencies.

What conclusions can be drawn concerning the research questions? Does an EUtype of agency exist, and what are its features? It emerges that a sort of European(Union) type of public agency does exist, or at least that some common distinctivefeatures are recognizable and overall a significant degree of homogeneity is

detectable in the EU agencies, when compared with the highly variable world ofnational agencies. What are the main features of the EU type of agency? All EUagencies have legal status, and they do not resolve upon their statute. The gover-nance structure of the agencies includes the presence of a corporate board and adirector. Each agency operates in one and only one policy area. Data indicate that

those agencies can deliver both homogeneous and heterogeneous outputs andservices and, in almost all cases, there is a clear separation between policy and oper-ations. Decision powers on policy formulation are assigned to the Commission or theother EU institutions and operative tasks are assigned to agencies. Considering the

aspects of autonomy, agencies have no autonomy in defining policy targets but havesignificant autonomy in defining policy instruments. As regards financial autonomy,even if some agencies can acquire further resources outside the Commission fund-ing, the agencies cannot sell their products on the market nor raise loans, and over-all financial autonomy is very constrained. The flexibility in managing personnel and

the organizational design is limited: there is a high degree of uniformity in the orga-



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nizational structure of EU agencies and there is limited room for changing the struc-ture and the policies of human resources management (see also Vos, 2005). If thecontractualization of the relationship between the agencies and the Commission isconsidered, the elements of NPM-ness are very limited (if present at all): there is nocontract in the organizational sense, though there is some form of conctractualiza-

tion, nor is there a performance contract. Many agencies developed performancemanagement monitoring systems and financial indicators and time measures, butprimarily for internal use (i.e. not driven by a performance contract, nor finalized at it).

To sum up, there is an EU type of agency, which is not the widely debated tripodmodel, but a different model, with a very limited degree of conctractualization, limitedfinancial autonomy as well as very limited managerial autonomy concerning person-nel and the organizational design, though it does have autonomy in the definition ofpolicy instruments (features of the EU type of agency in a comparative perspectiveare reported in Table 3). A finer-grained analysis (which is advocated, see final sec-

tion) may find differentiation between EU agencies in more specific aspects withineach of the dimensions considered but at the level of these dimensions, there is aclearly identifiable EU type of agency with recognizable and distinctive features thatdifferentiate it from the tripod model as well as from national-level agencies.

Conclusion and developments

The results of the investigation point to the existence of a model of EU agency, an

aspect which makes the EU differ from the varied landscape that can be found whenexamining national-level agencies; although it should be added that such a type ofEU agency is heavily influenced in its detailed sketching by the tasks actually per-formed by each agency, by the time period in which an agency has been establishedand by its interaction with external stakeholders (see the cases of the EMEA and EEA).

A first set of questions for future research stems from this finding: what explains thehomogeneity of EU agencies? How did such homogeneity emerge over a relativelylong time span (the first EU agencies date back to the 1970s, though most agencies

were established during the 1990s and the 2000s) and given the different circum-

stances under which they were established? Is the evolving power balance within theEU the main explanation for homogeneity (and particularly, is the struggle betweenmember states and the Commission for wielding influence over first pillar agencies afactor leading to uniformity in the shape of granting low autonomy and applying acommon set of controls to all EU agencies), or are there other factors at work? Andhow do they combine in determining relative uniformity?

Shifting from the search for explanations of uniformity to thepolicy implications ofit, future research work may also address issues of efficiency and effectiveness. Asecond set of questions thus includes: does uniformity imply greater efficiency? And

if so (and this point is of course to be demonstrated), what could be the drivers ofincreased efficiency (what kind of economies can be gained so that the same outputscan be delivered with less resources)? And does uniformity imply greater effective-ness? Or is uniformity an impediment to adaptation to the different characteristics of

the various policy sectors in which EU agencies operate?We advocate a research agenda on EU agencies rooted in public management



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that might contribute to the debate on how to reform EU institutions: EU agencies area widely under-investigated phenomenon, or at least under-investigated with theconceptual lenses of public management. Studies concerning even more under-investigated issues, such as the performance of EU agencies, the influence that EUagencies wield over the functioning of policy networks operating at the Europeanlevel (where EU agencies often perform as hub of the network, see the cases of theEMEA and EEA), and the role EU agencies may have for re-launching European inte-gration through an administrative, low politics approach, could provide furtherinsights for would-be reformers engaged in the process of EU reform (on the issue ofpromoting good governance in the EU and the potential of resorting to agencies,see also Everson, 2005). Such a type of knowledge appears indeed more and morenecessary in the face of the new challenges posed by the turbulent environment in

which EU institutions operate, the enlargement of the Union in 2004 and 2007, andthe increase in the administrative workload of the Commission (and the strategicchallenges it entails for the Commission, see Metcalfe, 1999, 2000a).

Whatever its limitations, the study outlined in this article points to the considera-tion that the organizational form of agencies can and should also be studied in theEU setting by resorting to theoretical frameworks drawn from the public manage-ment camp. The proposed categories of analysis, even if taken from studies address-ing national and sub-national settings, appear to be fitting also for investigation of theEU agencies. An elaboration of the categories of analysis as well as an extension of

the empirical evidence might be helpful for the development of the research agenda

on EU agencies and their influence on the broader functioning of the EuropeanUnion.

Appendix 1. The case of the EMEA (European Medicines Agency)

The agency has been structurally disaggregated from the DG Enterprise and Industryof the Commission. The EMEA has the main task of assessing medicinal productssubmitted by pharmaceutical companies, while the Commission receives the final

technical decision of EMEA on the approval of medicinal products, verifies the fairness

of the administrative procedures, and gives formal authorization to the commercial-ization of the products. Some categories of pharmaceutical products are compulsori-ly examined by EMEA, others follow a system of mutual recognition among nationalpharmaceutical authorities, though more and more frequently pharmaceutical com-panies address EMEA for authorization to the commercialization (79 initial marketing-authorization applications were received in 2006, compared to 41 applicationsreceived in 2005). Before the settlement of the EMEA, the communitarian pharma-ceutical policy was poorly regulated at the central level and the role of the memberStates was prominent, due to the nature of the comitology process as well as to the

prominence of national authorities in the authorization of pharmaceutical products. In1987, following Directive 83/570, a committee was set up with the purpose offostering coordination among the national agencies. It was only since the settlementof the EMEA that the centralized procedure of authorization was established and hasgradually become more reliable; the creation and extensive utilization of lists ofexperts (approximately 2300) involved in the technical evaluation process has gradu-



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ally increased the reliability of the centralized procedure of scientific assessment (atotal of 257 scientific-advice, protocol-assistance and follow-up requests were final-ized in 2006, compared to 191 in 2005). The EMEA relies on external support, devel-oping close professional relationships with national organizations and the epistemiccommunity (Metcalfe, 2000b). For what concerns financial resources, the EMEAreceives its funds from both the Commission and the pharmaceutical companies.The level of financial autonomy in terms of acquiring further resources outsideCommission funding is high (approximately 70 percent of the overall budget). Thefunctioning of the pharmaceutical regulation processes is generally deemed to haveincreased after the establishment of the EMEA. In the list of elements supporting thisanalysis there is, first, the very small amount of the EMEAs decisions rejected by theCommission (16 over 304 in the period 19952005), and, second, the increasingnumber of centralized procedures since 1995, which points to the EMEA beingattractive compared to national authorization authorities. The professional nature of

the EMEA and its organizational networking as well as its being closely integratedwithin the relevant epistemic community are central for it to perform a role as huborganization inside the networked pharmaceutical regulatory setting. By operating as

the hub of a network of national organizations devoted to pharmaco-vigilance, andco-opting national experts in its scientific committees, the EMEA has pushed nationalagencies to operate in an EU strategic space (in the sense that national agencieshave to collaborate with all the other pharmaceutical agencies throughout Europe)and it has the potential to foster a degree of collaboration and exchange of practices

at the EU level.

Appendix 2. The case of EEA (European Environment Agency)

The EEA can be defined as a provider of inputs data on the environment to theDG Environment in order to elaborate policy proposals. Formally, the establishment of

this agency stems from the disaggregation of the data-gathering function (compe-tence of the EEA), while decision-making powers in terms of formulation of policyproposals on environmental issues remain with the Commission. The debate about

whether the core task of the EEA is data gathering, or (also) data analysis, or evenmore largely the elaboration of initial policy proposals is crucial. Schout (1999) pointsout that the EEA has frequently gone beyond its data gathering role and [it] has

worked on information for the public: the EEA had, or at least tried to have, a morepolicy-oriented role. The Regulation 1641/2003 streamlined the EEAs structure andmade it less divisionalized; the EEAs activities were overall better integrated in the EUenvironmental policy-making process. The organizational changes of 1999 and 2004created a more complex and decentralized structure. There has also been an evolu-

tion of the relationship between the EEA and the DG Environment during the years:

the same Commission has officially reported that in the first years after the settlementof the EEA there was from time to time a divergence of views regarding these priori-

ties and activities, particularly between the Commission and the EEA, but since 2003there was a fairly clear common understanding of the respective tasks, althoughthere is still occasional disagreement (Commission of the European Communities,2003). The EEA has been asked by the European Parliament, the European



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Commission, and the member States not only to report and advise on the state of theenvironment and of the technical issues concerning environmental protection and

the sustainable use of natural resources, but also on the effectiveness of key envi-ronmental and sectoral policies and their implementation (Office for OfficialPublications of the European Communities, 2003). The EEA manages a network ofnational and sub-national organizations gathering environmental information, andverifies the scientific reliability of the data gathered: its funding mainly depends on

the DG Environment. The network of organizations collecting information in thenational states operates to a large extent through projects designed by the EEA andhaving the EEA as its main contributor: it is through this funding that the EEA influ-ences which projects are put into the pipeline at the EU level (Martens, 2005). It isalmost universally accepted, inside the Commission, that EEA is playing not only asubsidiary role in the DG Environment, but is a major player in the EU environmentalpolicy cycle. The call of the Commission in 2003 for stronger integration of the activ-ities of the EEA within environmental policy may also be interpreted as a recognitionby the Commission of the prominent and in a sense autonomous role performed by

the EEA in the EU scenario. The EEA has increasingly played an effective role in co-ordinating the national and sub-national organizations dealing with environmentalissues and has assumed an uncontroversial position in the EU environmental policyfield. The europeanization of procedures and techniques and the consequentuniformity of environmental data, which allows reliable comparisons of the state of

the environment across Europe, is also an important achievement of this agency.

Notes

The article is the joint work of the authors; however, in the final writing the sections Methodology,Conclusion and developments, Appendix 1, and Appendix 2 have been written by Dario Barbieri;the sections Introduction, and Discussion have been written by Edoardo Ongaro, while the otherparts have been jointly written. We are grateful to Professor Christopher Pollitt and threeanonymous reviewers for their constructive comments.

1 EIGE (European Institute for Gender Equality) and European GNSS Supervisory Authority areincluded in Table 1 but, at the time of writing, are not operative.

2 This kind of performance reporting is compulsory and involves primarily the Commission andthe European Parliament. It is a competence of the Court of Auditors to evaluate how well theagency has applied the principles of sound financial management economy, efficiency andeffectiveness to the management of its budget. All agencies are subjected to theassessment of their performances, known as performance audits and value for money audits.The internal auditor, in each agency, advises the agency on dealing with risks, issuesindependent opinions on the quality of management and control systems as well asrecommendations for improving operating conditions.

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