2. Grounding the National Integrity and Corruption Prevention Strategy (ENIPC) of Costa Rica
The chapter analyses Costa Rica’s National Integrity and Corruption Prevention Strategy (ENIPC). The ENIPC provides a vision and is a major achievement towards a comprehensive and coherent integrity system in the country. However, it is key to ensure that ENIPC’s objective of developing a concrete integrity policy is achieved. This policy should be adopted at the highest level and have clear and measurable objectives, activities and responsibilities. The chapter further proposes avenues to set up a central integrity monitoring system and to ensure a broad evidence-base to inform monitoring and evaluation exercises.
A strategy for public integrity is essential for supporting a coherent and comprehensive integrity system. However, a strategy is not an end in itself but rather a means to an end. The process of strategy development is indeed as important as the resulting strategy. An inclusive and rigorous process can help select relevant strategic objectives that are meaningful to citizens and businesses; prioritise and sequence actions in an open manner to address the most crucial integrity risks; and provide the necessary evidence for the interventions that are most cost-effective and likely to have the greatest impact. Strategies are also a way of demonstrating commitment and can be used to establish institutional responsibilities. If however strategies do not lead to visible gains – for example, due to inadequate implementation – they can at best become irrelevant and at worst erode public confidence in national authorities (OECD, 2020[1]).
The OECD Recommendation on Public Integrity states that adherents should “develop a strategic approach for the public sector that is based on evidence and aimed at mitigating public integrity risks, in particular through:
Setting strategic objectives and priorities for the public integrity system based on a risk-based approach to violations of public integrity standards, and that takes into account factors that contribute to effective public integrity policies;
Developing benchmarks and indicators and gathering credible and relevant data on the level of implementation, performance and overall effectiveness of the public integrity system” (OECD, 2017[2])
This chapter analyses Costa Rica’s National Integrity and Corruption Prevention Strategy (Estrategia Nacional de Integridad y Prevención de la Corrupción, ENIPC), launched in August 2021 (ENIPC, 2021[3]). It suggests concrete recommendations, in particular related to ensuring an effective implementation and achievement of its goals. In particular, Costa Rica should ensure that the objective of developing an integrity policy as set out in the ENIPC is achieved, that this policy is adopted at the highest level and provides clear and measurable objectives, activities and responsibilities.
Furthermore, the chapter emphasises the relevance of monitoring and evaluating integrity policies (OECD, 2017[4]). Though interconnected, it is important to distinguish between monitoring and evaluation. Monitoring corresponds to a routine process of evidence gathering and reporting to ensure that resources are adequately spent, outputs are successfully delivered and milestones and targets are met. Policy evaluation, in turn, is a structured and objective assessment of an ongoing or completed initiative, its design, implementation and results. The goal of policy evaluation is to determine the relevance and fulfilment of objectives, its coherence, efficiency, effectiveness, impact and sustainability, as well as the worth or significance of a policy (OECD, 2020[5]; OECD, 2017[4]).
The ENIPC provides a commendable long-term vision built on a broad consensus, but needs to be grounded into a policy adopted at the highest-level that assigns clear responsibilities and resources
Costa Rica’s National Integrity and Corruption Prevention Strategy 2021-2030 (ENIPC) emerges from the acknowledgement of the lack of a formal policy or instrument capable of channelling all the efforts and legislations developed on the subject of anti-corruption and integrity. Between October 2019 and December 2020, the Attorney for Public Ethics (Procuraduria de la Ética Pública, PEP) and Costa Rica Íntegra (the national chapter of Transparency International) jointly led the development of the ENIPC through a participative process involving civil society, academia and the private sector.
Costa Rica launched the ENIPC in August 2021 and declared it of public interest by Executive Decree 43248-MJP on 27 January 2022. Overall, the ENIPC is organised in 5 components, which contain 46 initiatives in 13 action plans (ENIPC, 2021[6]):
1. Governance in the fight against the corruption: The purpose of this component is to establish a governance model for the prevention and enforcement of corruption in the country that articulates State and non-state actors. The component also foresees the development of a National Anti-corruption Policy and a monitoring and evaluation system.
2. Management of human talent to fight corruption: This component includes the promotion of ethics in the public administration and the incorporation of the entire public sector to the National System of Ethics and Values through the National Commission of Ethics and Values (CNEV). Furthermore, it aims at establishing a homogenous framework for disciplinary sanctions.
3. Promotion of social oversight and participation: The objectives outlined in this component are to be co-ordinated with the Open State Action Plan. It aims at strengthening mechanisms for citizen oversight and participation, at promoting effective reports and protection of whistle-blowers and includes measures aimed at promoting education for integrity and participation.
4. Corruption risk management in the interaction between the public and private sectors: The component contains activities aimed at mitigating corruption risks in public procurement and increase awareness and training of integrity standards in the private sector. It also seeks to promote a simplification of procedures for permits and licenses and aims at strengthening the regulations on conflict of interest, lobbying, bribery and trading in influence.
5. Access to information and accountability: The last component includes activities on open data and for simplifying administrative procedures for citizens. In addition, Costa Rica has not yet approved a law on access to information. As such, the ENIPC aims at fixing current legal deficiencies and at promoting public servants’ skills and abilities for the publication of open data. This component also aims at developing training programmes for civil society on open data and its uses.
The ENIPC effectively articulates different existing regulatory and institutional arrangements, helps fostering synergies and co-ordinating efforts from relevant integrity actors (Chapter 1) and provides a long-term vision to address the most urgent challenges related to anti-corruption and integrity policies in the country. This long-term vision until 2030 allows an incremental approach in implementing the objectives and to ensure continuity, which is particularly needed in the area of integrity policies.
The strategy can be considered as a major achievement and milestone for promoting integrity and anti-corruption in Costa Rica. Yet, as recognised in the ENIPC, the strategy does not clarify how to institutionalise the much-needed co-ordination to provide coherence and stability to the integrity system; including the involvement of the territorial and institutionally decentralised public administrations. The ENIPC acknowledges this by placing the governance of integrity policies at the top of the five components (ENIPC, 2021[6]). In particular, the ENIPC establishes the need for a National Anti-Corruption Policy, to be elaborated in an open and participative process, and the need for guidelines as well as a follow-up mechanism based on indicators that allow to monitor the implementation and evaluate the impact of the proposed actions.
The OECD Public Integrity Indicators measure, amongst others, the quality of such strategic frameworks. Figure 2.1 provides an overview on the sub-indicators of the OECD Public Integrity Indicator for Principle 3 of the OECD Recommendation on Public Integrity, following criteria established by the OECD Working Party of Senior Public Integrity Officials (SPIO). It shows that the ENIPC can be seen as a good practice with respect to the “inclusiveness and transparency of the intergovernmental and public consultations” that led to the strategy, with respect to the “evidence-based problem analysis and diagnostic tools underlying the strategy” and the “minimum content of the strategy”. In all three sub-indicators, Costa Rica scores above the OECD average. However, the ENIPC scores zero in the sub-indicator measuring the “Transparency of evaluation practices and use in decision making”. On the one hand, this is due to the fact that there has not been any previous evaluation as there are no predecessor strategies, but on the other hand also because, while the ENIPC foresees an evaluation, the actions do not list this as a concrete activity. Furthermore, the action plans within the ENIPC also do not include estimates for capital and operational expenditures or costs for specific activities. As the ENIPC is not yet being implemented, the implementation rate is also zero.
Note: OECD countries used to calculate the OECD average include, Australia, Austria, Belgium, Canada, Chile, Colombia, Costa Rica, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Israel, Italy, Japan, Republic of Korea, Latvia, Lithuania, Luxembourg, Mexico, Netherlands, New Zealand, Norway, Poland, Portugal, Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Republic of Türkiye, United Kingdom, and the United States.
The best performers for each indicator were: Indicator 1, Argentina, Colombia, Czech Republic, France, Hungary, Latvia, and Lithuania; Indicator 2, Czech Republic and Mexico; Indicator 3, Latvia, Lithuania, Mexico, and Poland; Indicator 4, Latvia; Indicator 5, Czech Republic, Latvia, Lithuania, Romania, and the United Kingdom; Indicator 6, Hungary; Indicator 7, Lithuania, and Poland; And, indicator 8, Czech Republic, Latvia, Peru, and Romania.
Source: OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/
Therefore, as a priority, Costa Rica should work towards establishing the National Anti-Corruption Policy, as established in Activity 1.2.1 of the ENIPC. Ideally, the co-ordination commission recommended in Chapter 1 should lead this exercise. To reflect the preventive focus of this policy, Costa Rica could consider branding it as a National Integrity (and Anti-corruption) Policy. The policy should provide a rationale for the selection of the specific objectives as well as an action plan that reflects the underlying theory of change. Moreover, as will be analysed later in this chapter, Costa Rica should develop and choose realistic and achievable indicators, including inputs, outputs, outcomes and impacts.
The MIDEPLAN could play a key role in promoting integrity through the National Planning System, by ensuring that integrity is included in the National Development Plan 2022-2026
To ensure that goals such as those included in the ENIPC and the forthcoming National Anti-corruption (or Integrity) Policy are translated into concrete actions and impact, they need to trickle down into the strategic and operational plans of relevant integrity stakeholders in Costa Rica. Without such an alignment with the standard national planning, there is a risk that the activities to promote integrity are considered by public entities as an additional burden, without clear resources. The ENIPC could then remain an empty strategy with no relevant impacts.
In Costa Rica, the Ministry of National Planning and Economic Policy (Ministerio de Planificación Nacional y Política Económica, MIDEPLAN) leads the country’s National Planning System. This system is organised in multi-level plans: the Institutional Strategic Plans (Planes Estratégicos Institucionales, PEI), Institutional Operational Plans (Planes Operativos Instituciones, POI), the Sectoral Plans and the Plan-Budget Articulation Matrix (Matriz de Articulación Plan-Presupuesto, MAPP). On top of that, by Law 8131, the National Development Plan (Plan Nacional de Desarrollo, PND) is the strategic framework that guides all public policies and plans, according to the level of autonomy of the related institutions.
The current 2018-2022 PND does not contain any reference to integrity and anti-corruption issues. In the past, the 2015-2018 PND stated that it is essential to promote a national culture of ethics, transparency and accountability and included the issue as one of the three strategic pillars (“an open, transparent, efficient, government in a frontal fight against corruption”). In addition, the 2015-2017 Open Government Partnership Action Plan stated that the fight against corruption is a priority area (OECD, 2016[7]). The fourth Open State Action Plan of Costa Rica 2019-2022 commits to strengthening citizen capacities and mechanisms for the prevention of corruption in the public administration by providing open data.
Based on the direction of the new elected government, the MIDEPLAN prepares the new National Development Plan 2022-2026 within the seven months following the start date of the government period on 8 Mai 2022. Therefore, the new PND 2022-2026 offers a unique opportunity to include strategic priorities related to public integrity, linked to the ENIPC. In particular, through the MIDEPLAN, Costa Rica could include into the PND 2022-2026 the goal of working towards a public integrity system and establish the following two priorities:
The commitment to improve coherence and co-operation amongst actors of the integrity system through a co-ordination mechanism that could be inspired by the recommendations provided in Chapter 1 of this Integrity Review
The open and participative elaboration of the National Anti-corruption (Integrity) Policy as prioritised by the ENIPC and its incorporation into relevant plans of the National Planning System.
The National Development Plan could encourage subnational level to develop their own integrity policies, particularly with the aim of creating synergies through the territorial development plans
As mentioned in Chapter 1, to achieve impact in building a culture of integrity, reaching the territorial level, particularly municipalities, is key. Indeed, the risks of corruption compared to the national level are often different and arguably could be higher at the territorial l level for various reasons. First, a significant share of public funds is spent on subnational levels. Given this level of spending on public investment and procurement, ensuring integrity and anti-corruption at subnational level is critical to make the best use of public funds. Second, subnational governments’ responsibilities for the delivery of typically a large share of public services (e.g. water and sanitation, waste management, licences and permits, education, health) increases the frequency and directness of interactions between public authorities, citizens and firms. These interactions create both opportunities, especially as they can facilitate local accountability and participation, and risks for integrity (OECD, 2021[8]).
The recent COVID-19 crisis has amplified existing corruption risks, while obliging governments to take quick decisions and releasing significant public funds to help communities at risk and mitigate the socio-economic consequences of the crisis (OECD, 2020[9]; OECD, 2020[10]). Given their responsibilities, municipal governments are at the frontline of the crisis management and recovery, while being confronted by COVID-19’s asymmetric health, economic, social and fiscal impact (OECD, 2021[11]).
At the same time, pursuing change at the territorial level through contextual integrity policies offers unique opportunities. Given the responsibilities of local governments in service delivery and local development, integrity policies also may be able to achieve visible results for citizens, which allows to contribute to building trust in government and to increase the political buy-in from leaders to continue with reforms. Territorial governments are likely to be better placed to identify corruption risks and opportunities for more effective integrity and anti-corruption measures adapted to the regional context. One-size-fits-all solutions imposed from above are not recommendable. Nonetheless, a co-ordinated approach and clearer guidance from the central administration would contribute to a more functional integrity system, by ensuring coherence of messages and measures.
In Costa Rica, several institutions, such as the Attorney for Public Ethics (Procuraduria de la Ética Pública, PEP), the Comptroller General of the Republic (Contraloría General de la República, CGR), the National Commission for Ethics and Values, (Comisión Nacional de Ética y Valores, CNEV) or the Ombudsman (Defensoría de los Habitantes de la República de Costa Rica, DDHH) carry out activities to raise awareness and to reinforce public integrity in Costa Rica’s regions. For example, the PEP has worked with the CGR to conduct audits of anti-corruption policies in six municipalities. It has also worked, alongside the Deputy Prosecutor for Probity, Transparency and Anti-Corruption (Fiscalía Adjunta de Probidad, Transparencia y Anticorrupción, FAPTA), on the "Municipal Citizen Observatory” (Observatorio Ciudadano Municipal), assisting citizens to demand transparency in municipal management. Moreover, the PEP has worked with the IFAM on a training programme for new municipal authorities (for the 2020-2024 period), which included a course in ethics and probity in the public function. In turn, the CNEV provides feedback to the municipalities that have implemented Institutional Commissions on Ethics and Values (Comisiones Institucionales de Ética y Valores, CIEV) (see Chapter 1).
However, as described in Chapter 1 and despite these efforts, Costa Rica faces significant challenges in ensuring a coherent implementation of integrity policies at territorial levels. During the interviews conducted by the OECD, civil society organisations stressed that the planning and prioritisation of integrity policies at the subnational level, on average, is still weak. In fact, most of the consulted stakeholders for this Integrity Review agreed that the territorial level was mainly unaware of the ENIPC at the time these interviews were carried out (July 2021), which may indicate that the approach for elaborating the ENIPC could have involved municipalities in a more systematic way. Many interviewees shared the view that the lack of integrity policies at territorial levels stem from a weak management culture, overly political discussions over technical issues, budget constraints and a lack of commitment by local leaders.
As such, Costa Rica should work more closely with the territorial decentralised administration to develop their own integrity policies. The recommendation in Chapter 1, which is also included in the ENIPC, to extend the Ethics Management Model (Modelo de Gestón Etica, MGE) to municipalities would be an important step towards a more effective implementation of integrity policies, as the MGE requires to carry out diagnostics and develop action plans (Box 1.2 in Chapter 1).
In addition, MIDEPLAN could provide guidance on how to develop plans at territorial level that reflect local priorities, needs and opportunities while offering a sufficient degree of coherence across the country. In particular, the new National Development Plan could require municipalities to implement the MGE and to include integrity issues in their local development plans and/or the Cantonal human development plans. Entities at the national level such as MIDEPLAN, the PEP and the CNEV could provide support. Municipalities should be given the appropriate resources (human, financial) to fulfil their responsibilities and the national government should work towards promoting mechanisms for co-operation between subnational levels of government (OECD, 2017[2]), as recommended in Chapter 1.
A central integrity monitoring system, which produces regular reports on the advances of the implementation of the ENIPC, could help to manage and communicate progress towards integrity goals
A key element of the ENIPC is the creation of a Monitoring and Evaluation (M&E) system to inform citizens about the level of implementation of the strategy. This M&E system allows promoting the understanding of the expected goals and results pursued by the ENIPC and should respond to the articulated vision to allow, from a systemic perspective, monitoring the implementation by governmental, private sector and civil society actors and to regularly evaluate the achievements.
An M&E system is a crucial element both for ensuring an effective implementation and as an accountability and communication instrument to citizens and public officials alike. The M&E system should translate each strategic goal stated in the ENIPC into clear policy objectives and actions, including time frames, responsibilities and resources. These, in turn, should be translated into measurable indicators that will keep track of the progress towards the main strategy goals (OECD, 2017[4]). As such, the M&E system should be developed at the same time as the National Anti-corruption (Integrity) Policy.
The monitoring process should be based on:
Indicators that measure aspects of the implementation of integrity policies, focused on inputs, activities and products.
Indicators that measure the level of achievement of the desired outcome and intermediate outcome and, as far as possible, at impact level.
The indicators that measure aspects related to the implementation process capture features that are under the control of the implementing agency or institution. In turn, outcome indicators measure the achievement of the goals to which the implemented policy wanted to contribute. While policy makers usually do have some control over the implementation process, they do not have complete control over the outcome as many exogenous variables can interfere, contribute or undermine the achievement of the policy goal. While public institutions can be hold accountable for the implementation and the achievement of committed products, the discussion around outcome need to be more nuanced and consider this attribution gap (OECD, 2017[4]).
Furthermore, the breakdown of policy objectives into activities contribute to underpinning the monitoring exercise taking into account clear institutional responsibilities. Even though monitoring should be carried out by every actor that is responsible for implementing the actions and should be part of the daily routine, a central integrity monitoring system can contribute in the collection, unification and analysis of decentralised information and data. As such, a central monitoring system contributes to a macro analysis regarding the development, the progress and the delays of the implementation of the activities as well as on the key achievements. A central monitoring system thus contributes to obtaining a coherent and complete picture that facilitates decision-making.
The central governing body that steers the co-ordination commission recommended in Chapter 1 to articulate the country’s integrity system should lead this central monitoring system. Chapter 1 further recommended that this function should be performed by the PEP as the Technical Secretariat of the co-ordination mechanism. In addition, as part of the proposed co-ordination commission, the MIDEPLAN can ensure that the monitoring of the progress of integrity policies is incorporated into the National Planning System.
The central monitoring system could draw the data from different sources, which will be discussed in the next section. The indicators should enable to inform timely actions by management. Indeed, the core objectives of monitoring is to identify the challenges and opportunities to inform decisions and allow corrective adjustments during the implementation. As such, monitoring should be understood as a mechanism that contributes to and effective public management (OECD, 2017[4]). To enable this, monitoring needs to be institutionalized by linking the monitoring process to the decision-making and the implementation process. Clear mechanisms and procedures to discuss progress and implementation bottlenecks should be established. For example, regular inter-institutional round tables among the stakeholders of the ENIPC should be encouraged. Again, ideally, this would take place in the sub-commission on prevention recommended in Chapter 1.
Finally, the development of a central monitoring system can enable the generation of a benchmarking system that compares the implementation status of public entities. Such a benchmarking can stimulate and motivate the entities to implement effectively the actions foreseen in the ENIPC or future integrity policies. Indirectly, the benchmarking can create a yardstick competition between public entities, or, at the territorial level, between municipalities. A central monitoring system then sets incentives for a continuous improvement. These incentives are even stronger when the benchmarking is public.
Several countries are implementing such public monitoring systems (Box 2.1). However, due care must be taken that comparisons make sense and do not penalise smaller municipalities or public entities with less resources and capacities. In addition, the pressure generated by benchmarking could also lead to undesired behaviour aimed at gaming the system and window-dressing (OECD, 2017[4]). To mitigate this risk, monitoring should not be communicated as a control mechanism that aims at naming and shaming those who perform less well. On the contrary, the monitoring exercise should be communicated clearly as a joint and constructive exercise that enables open and transparent conversations amongst stakeholders to overcome possible challenges.
Brazil
The Panel of Public Integrity (Painel Integridade Pública, PIP) allows citizens to check information online about the structure, implementation and monitoring status of public integrity programmes in entities and organisations of the Brazilian Federal Government. The PIP is under the responsibility of the Office of the Comptroller General of the Union (Controladoría Geral da União, CGU).
Since 2017, all public entities of the federal administration are required to implement integrity programmes. The PIP contains several indices that allows understanding the degree to which agencies have adopted them. For example, the PIP contains information on how many entities have implemented integrity management units (Unidade de Gestao de Integridad, UGI), if the agencies have satisfied with all due requirements of UGI designations, if agencies have mechanisms to analyse nepotism or conflicts of interest, whether the agencies have areas responsible for conducting disciplinary proceedings, among others. The PIP also publishes the approved integrity plans of all entities which have submitted it to the platform.
Colombia
The National Anticorruption Index (Índice Nacional Anticorrupción, INAC) analyses the institutional capacities of public entities in the fight against corruption. It is an index of indices that is built using official information of national entities. The INAC evaluates the strengths and weaknesses in terms of transparency, citizen participation, accountability, public integrity and disclosure of public information, including financial, budgetary and contractual information.
The INAC is a project of the Secretariat of Transparency (Secretaria de Transparencia, ST). The ST not only estimates the INAC but provides also several indicators of sanctions regarding crimes against the public administration, such as corruption, an indicator of how much progress there is with the compliance of the Comprehensive Public Anti-corruption Policy, an Open Government Index, as well as results of surveys regarding political culture and performance of public servants.
Peru
The Secretariat of Public Integrity (Secretaría de Integridad Pública, SIP) developed the Integrity Model (Modelo de Integridad) as part of the National Plan of Integrity and Fight against Corruption (Plan Nacional de Integridad y Lucha contra la Corrupción). The Model contains a set of guidelines, mechanisms and procedures to strengthen public entities in their internal capacity to prevent and punish corruption, as well as to strengthen their practices against unethical practices. As part of this programme, the SIP developed an Index of preventive capacity against corruption (Índice de Capacidad Preventiva, ICP) in which the advancement of the Integrity Model is evaluated.
The SIP estimates in the ICP in how far the nine components and its respective 36 subcomponents of the integrity model have been implemented. The main components are Senior Management Commitment; Risk Management; Integrity Policies; Transparency, open data and accountability; Internal and external control and audit; Communication and training; Complaint channels; Oversight and monitoring of the integrity model; and a person in charge of the integrity model.
Source: Compiled by OECD based on the websites from Brazil, Colombia and Peru. For Brazil and Peru, see also (OECD, 2021[12]), (OECD, 2021[13]) and (OECD, 2019[14]).
Costa Rica should establish clear procedures and criteria for regular and independent evaluations of integrity policies that allow for continuous learning and improvement
Policy evaluation is a critical element of sound public governance. Policy evaluation can help ensure public sector effectiveness and improve the quality, responsiveness and efficiency of public policies and services. Evaluation is essential to draw lessons and to provide an understanding of what works, why, for whom, and under what circumstances. It connects policies, policy makers and citizens, helping ensure that decisions are rooted in trustworthy evidence and deliver desired outcomes (OECD, 2020[5]).
The ENIPC foresees an evaluation but does not provide more details. Therefore, Costa Rica could clarify how and when the ENIPC or future integrity policies will be evaluated. In addition to insights provided by the CGR through their external audits, which could consider auditing specific aspects of integrity policies and their performance, it is recommendable to plan for an external evaluation exercise. An independent actor or organisation should carry out this evaluation, while it could be commissioned by the central governing body that is responsible for the central monitoring system recommended above. The evaluation should aim at drawing lessons learnt by evidencing key achievements and weaknesses. In addition, the evaluation process should provide concrete recommendations to inform the choices of policy makers in establishing future strategic steps. For example, Romania recently commissioned the OECD to evaluate the National Anti-corruption Strategy 2016-2020 of the country (OECD, 2021[15]).
The methodology used to evaluate the achievement of the envisaged results of the ENIPC or the future policy and strategies could follow the OECD-DAC evaluation criteria and take into account the following dimensions:
Relevance: Where the ENIPC (or the future policy) designed to respond to country needs and priorities? To what extend are the objectives still valid? Do the stakeholders feel a sense of ownership?
Coherence: Was the ENIPC (or the future policy) coherent with other governance reforms and policies in relevant key areas (external coherence)? Were the different objectives of the ENIPC (or the future policy) designed in a way to reinforce one another and create synergies and were the activities relevant to contribute to the achievement of the results and the objectives (internal coherence)?
Effectiveness: To what degree has the ENIPC (or the future policy) achieved the envisaged goals and implemented the activities (level of implementation)? What were the major factors influencing the achievement or non-achievement of the objectives?
Efficiency: How well were the available resources used to achieve the objectives of the ENIPC (or the future policy)? Where the objectives achieved on time?
Impact: What differences did the ENIPC (or the future policy) make? What were the positive changes and could some unintended consequences be observed?
Sustainability: How did the ENIPC (or the future policy) build on earlier efforts to prevent and combat corruption and how likely are the implemented changes to last over time?
Leverage the data and information from the M&E system of the ENIPC to enable more effective communication strategies
Communicating regularly and clearly about the progress in the achievement of goals can contribute in building trust. Communication also contributes to strengthening accountability processes, to supporting fact driven dialogue between stakeholders and can enhance evidence-based decisions. The data from monitoring and results from evaluations can help policy makers in Costa Roca to develop effective communication strategies. Communication can be stimulated for example through annual or biannual public reports and through dedicated websites.
However, Costa Rica should design these communication strategies carefully. For instance, raising the issue of corruption and the costs related to it may lead to undesired consequences. Especially in a context where corruption is already very present in the public debate and media, awareness raising campaigns on corruption may just increase the already high awareness for an existing problem and thereby confirming the impression that corruption is widespread. Indeed, research has shown that unethical behaviour is contagious and can lead to a “self-fulfilling prophecy” effect, as the perception of corrupt behaviour as a common practice may facilitate rationalising unethical behaviour (Gino, Ayal and Ariely, 2009[16]; Robert and Arnab, 2013[17]; Ajzenman, 2021[18]; Bicchieri and Xiao, 2009[19]; Corbacho et al., 2016[20]; OECD, 2018[21]). Research carried out in Costa Rica confirmed this risk. An information experiment embedded in a large-scale household survey conducted in Costa Rica showed that changes in beliefs about corruption, induced by displaying the increasing percentage of Costa Ricans who have personally witnessed an act of corruption, increased the probability that a respondent would be willing to bribe a police officer (Corbacho et al., 2016[20]).
Such dangers of misleading communication can be prevented by carefully designing relevant campaigns that focus more on the achievements of integrity policies, showing that change is possible. Of course, such results need to be real to avoid promoting cynicism, decaying trust in government and disconnecting citizens from constructive political engagement (Bauhr and Grimes, 2014[22]).
To monitor and evaluate integrity policies, Costa Rica should draw from different data sources and identify gaps for areas where data is not available
Identify a set of indicators to measure progress in implementation and achievement of the goals stated in the ENIPC
As stated in the ENIPC, Costa Rica should focus on identifying a set of indicators that measure the implementation of concrete actions and achievement of desired goals and outcomes. For this, a variety of indicators will be required. Taking into account various indicators from different sources can give the policy maker a more holistic and integrated view of what it is really happening. Table 2.1 presents examples of different data sources that can be used as indicators.
Since the adoption of the OECD Recommendation on Public Integrity, a Task Force of the Working Party of Senior Public Integrity Officials (SPIO) has been developing a framework for a set of indicators (Public Integrity Indicators, PII) to measure the successful implementation of the OECD Recommendation on Public Integrity. The framework establishes standard indicators for the preparedness and resilience of the public integrity system at the national level to prevent corruption, mismanagement and waste of public funds, and to assess the likelihood of detecting and mitigating various corruption risks by different actors in the system. These PII combine sub-indicators establishing minimum legal, procedural and institutional safeguards for the independence, mandate and operational capability of essential actors in the integrity system with more outcome-oriented sub-indicators drawing on administrative data and surveys. The PII apply a mixed methods approach, drawing on both administrative data and big data provided directly by governments and surveys (Box 2.2). Costa Rica, as an OECD member, is part of the data collection for the PII, which enables the country to compare its performance on key integrity issues with other countries. Costa Rica could consider including some of the sub-indicators of the PII into its own M&E framework.
Better indicators require moving away from high-level composite indicators based on expert judgement. As such, the OECD Public Integrity Indicators are moving towards greater use of two other data sources:
Administrative data, including big data and data analytics: Standardisation and better use of administrative data are keystones for better measures of corruption, anti-corruption, and the public integrity system. So far, this has been a largely unexplored frontier at the international level, but national authorities use such data in their own strategies because it is precise, objective and reliable. Several Public Integrity Indicators draw on administrative data, and one uses semantic analysis tools (text mining).
Survey data by national statistics offices and other state administration bodies: The OECD has experience developing public integrity modules for surveys administered by national statistical offices (general population and business surveys) and the central government unit responsible for HRM policy (staff surveys and/or surveys of users and providers of public services). These can be part of larger governance modules or stand-alone victimisation surveys. Such experience-based data is crucial to capture outcomes.
To build the evidence-base for monitoring and evaluating the ENIPC as well as the forthcoming National Anti-corruption (Integrity) Policy, Costa Rica could follow a similar approach based on different data sources. Citizen and staff survey are discussed in the sections below. In addition, Costa Rica can also build on existing indicators in the country, which could be used to measure some of the desired changes, objectives and activities of the ENIPC as well as to identify gaps and inform future strategies and policies.
In particular, the following three sources of information could be used to identify relevant indicators, or, if needed adapted to include additional aspects relevant for the ENIPC:
The new Management Capacity Index (Índice de Capacidad de Gestión, ICG) developed by the CGR (Box 2.3) provides amongst others relevant information on risk management and ethics which could be used to monitor the implementation of related policy objectives in the ENIPC and be aligned with the recommended review and expanded implementation of the Ethics Management Model (Chapter 1).
To strengthen the evaluation mechanisms for the promotion of transparency and accountability of municipalities, the CGR developed the Management Index of Municipal Services (Índice de Gestión de Servicios Municipales, IGSM). The IGSM looks into two broad categories: the Basic Municipal Public Services and the Diversified Municipal Public Services. The former are provided by all 83 local governments, while the latter are provided by a smaller and variable number of municipalities (CGR, 2021[26]).
The Transparency Index (Índice de Transparencia del Sector Público, ITSP), provided by the Ombudsman in co-ordination with the Center for Research and Training in Public Administration (Centro de Investigación y Capacitación en Administración Pública) of the University of Costa Rica, evaluates four different items: access to information, accountability, citizen participation and open government data. The access to information section evaluates the quality and the type of information that it is published on the institutional website. The accountability section evaluates if the published information is accurate and related to the institutional objective, competencies and responsibilities. The citizen participation section evaluates the quality of the channels that citizens have to interact and participate in the institutional planning, control and evaluation process. Finally, the open government data section evaluates if the datasets published in the institutional web page are in compliance with the open data format, allowing their use, reuse and distribution. According to interviews conducted by the OECD for this Integrity Review, the Ombudsman is considering a revision of the ITSP, which could provide an opportunity to tailor it more closely to the related objectives of the ENIPC.
Until 2019, the Comptroller General of the Republic of Costa Rica (Contraloría General de la República, CGR) used the Institutional Management Index (Índice de Gestión Institucional, IGI) to measure some core aspects of public management. The IGI aimed at ensuring that the public sector implements management processes and structures in eight public support processes (planning, financial measures, internal control, procurement, budget, information technologies, user service and human resources of public institutions), aimed at three objectives: efficiency, transparency and prevention of corruption. The results of this index were published through a ranking system, where each assesses institution receives a grading score (CGR, 2019[27]). Although these basic aspects themselves do not guarantee success in the institutional operation, they can determine a minimum threshold in accordance with the regulatory framework, technique and good practices.
After 2019, the CGR determined that the public sector had reasonably advanced in meeting these formal aspects and turned towards promoting more effective practices. Together with a new framework, the Integrated Public Management Model (modelo integrado de gestión pública, MiGPS), this led to the Management Capacity Index (Índice de Capacidad de Gestión, ICG). The new ICG measures practices in four dimensions: Strategy and structure; Leadership and culture; Processes and information; Competencies and equipment. All dimensions aim at strengthening the institutional management capacity, which refers to the articulation and preparation of the available resources of each entity to fulfil its functions, its objectives and achieve the envisaged results. The ICG was applied for the first time in 2021, after a pilot carried out in 2020 to test the tool and the models. The CGR plans to carry out the measurement every two years. While all dimensions and several practices are relevant from the public integrity perspective, two aspects from the 2021 report are worth emphasising (Table 2.3).
Source: Based on information provided by the Office of the Comptroller General of Costa Rica, (CGR, 2019[27]) and (CGR, 2021[28]).
Data from surveys of public officials could provide input on how integrity policies contribute to a culture of integrity in Costa Rica´s public sector
Staff surveys allow policy makers to know if integrity policies change perceptions, experiences, attitudes and behaviours of public officials and contribute to measure the policy goal of ensuring a culture of integrity within the public sector. Surveys of public officials are also useful to conduct diagnostic assessments that precede and inform the design of integrity public policies. A centrally administered public sector staff survey that covers various aspects of public employment has the advantage that the data that it collects can be correlated and compared across entities.
Many OECD countries monitor their integrity policies using such staff surveys (Table 2.3). In the Netherlands, for example, a comprehensive staff survey is at the core of agenda setting for future integrity policies (Box 2.4). In the United Kingdom, the Civil Service People Survey yearly surveys around 300 000 respondents from 98 organizations. This survey provides a benchmark across different public entities. Among the several aspects covered, employee engagement, trust in leadership and fair treatment can be highlighted. A significant variation among these components could imply an integrity risk. Moreover, the overall score of the answers can indicate not only a general picture of the UK Civil Service, but also could highlight the challenges within individual organisations. Finally, the survey allows cross sectional analysis driven by the repetition of questions in regular intervals. Similar information is collected in Colombia, where the National Statistical Office (Departamento Administrativo Nacional de Estadística, DANE) carries out an annual Survey on National Institutional Environment and Performance (Encuesta de Ambiente y Desempeño Institucional, EDI) that integrates questions related to specific integrity initiatives.
Since 2004, the Dutch Ministry of the Interior regularly observes the state of integrity in the Dutch public sector. To this end, political office holders, secretaries-general, directors and civil servants are surveyed in central government, provinces and municipalities using mixed methods, including large-sample online surveys and in-depth interviews.
The Integrity Monitor supports Dutch policy makers in the design, implementation and communication of integrity policies. The results of each Monitor are reported to Parliament. The Ministry of Interior uses the Monitor to raise ethical awareness, detect implementation gaps and engage decentralised public administration in taking responsibility for integrity regulations. Insights from past Monitor waves have helped to identify priorities for anti-corruption efforts and shift integrity policies from prohibition to creating an organisational culture of integrity.
Source: Presentation by Marja van der Werf (Dutch Ministry of Interior and Kingdom Relations) given at the meeting of the OECD Working Party of Senior Public Integrity Officials (28 March 2017, Paris). Lamboo T. & De Jong, J. (2015): Monitoring Integrity. The development of an integral integrity monitor for public administration in the Netherlands. In Hoekstra, A. & Huberts, L. Gaisbauer, I. (eds.), ‘Integrity Management in the Public Sector. The Dutch Approach’.
Costa Rica could therefore consider conducting a periodic, centrally administered survey of public officials throughout the national public administration. The MIDEPLAN could administer this survey on a periodic basis to all national public officials working in the public administration. Alternatively, the National Institute of Statistics and Census of Costa Rica could administer the survey. The survey could include several questions relevant to public sector human resource management in addition to questions related to integrity. The results of the survey could provide a benchmark and be used to inform integrity risk assessments in the national public administration.
Either to complement or instead of a centrally administered survey, Costa Rica could also conduct more limited, ad hoc staff surveys in the whole national public administration, in specific sectors or in specific public entities to inform integrity policy making. However, while they can be relevant for purposes of policy design or communication, for example, such ad hoc surveys lack the advantages of a centrally administrated and regular survey that can be used for benchmarking purposes and for evaluating the longer-term progress in integrity goals (OECD, 2019[29]).
In fact, first steps have been taken in the implementation of staff surveys in Costa Rica. The CGR has been conducting, with no systematic periodicity, the National Corruption Prevention Survey (Encuesta Nacional de Prevención de la Corrupción, ENPC), a measurement instrument that surveys public servants and citizens. The survey asks respondents about their opinion and personal experience related to actions to prevent corruption, their perception related to procedures susceptible to corruption, culture of prevention and general perception of corruption. This survey contains two different modules each aimed at different audiences (see Box 2.5 for public officials, Box 2.7 in the next section for citizens).
The public official module inquires about the organisational ethics culture and the values by measuring variables related to the control environment. However, the CGR expressed that they do not collect or analyse the data from the ENPC survey for monitoring purposes. Rather, each institution is responsible for monitoring its control environment. The CGR uses the collected data to comply with its external oversight mandate. Nonetheless, in the future, questions today contained in the ENPC could inform the monitoring and evaluation process of the ENIPC.
In February 2020, the Comptroller General of the Republic (Contraloría General de la República, CGR), conducted the National Corruption Prevention Survey (ENPC - 2020), to explore the opinions of citizens (questionnaire 1) and public officials (questionnaire 2) on the prevention of corruption in the public sector. The information was obtained through a telephone interview, based on sampling frames aimed at citizens and public officials.
The following results from the module applied to public officials can be highlighted:
87.0% of public officials consider that corruption harms them in their daily lives, mainly due to the misuse of resources (12.5%), the impact on their personal finances (11.2%) and the decrease in job opportunities (8.1%).
Of the total number of respondents, 49.1% indicated that they were aware of actions in their institution to prevent corruption, the main ones being education and promotion of values (23.4%), the application of controls (17.2%) and the application of laws and regulations (7.2%). Compared to the results obtained in 2016, there is an increase in the number of public officials surveyed who indicate that they know about the actions taken by the institution in which they work to prevent corruption (46.0% in 2016).
Regarding the culture to prevent corruption, 58.3% of the civil servants indicate that the citizenry is the main responsible for preventing corruption, followed by the public sector (24.1%) and private companies (0.8%). In addition, the most relevant values when undertaking preventive actions are perceived to be honesty (45.4%), ethics (11.3%) and probity (10.9%).
Regarding knowledge of acts of corruption, 30.7% reported having witnessed a case of corruption in their institution; of these, 72.1% filed a report. Fear of reprisals (45.5%), not seeing change (18.2%) and distrust in the system (11.4%) are the main reasons for not reporting.
Source: https://cgrfiles.cgr.go.cr/publico/docsweb/enpc-2020/perc-fp.html
Data from citizen interactions with government and citizens surveys could help to understand how integrity policies affect awareness for integrity in the whole of society and encourage social accountability
In addition to public servant surveys, citizen surveys are another tool that can inform policy making and be used for monitoring and evaluation purposes. Some existing studies that surveyed citizens in Costa Rica (e.g. Corruption Perception Index, Global Corruption Barometer, Latinobarómetro, Barómetro de las Américas) provide useful insights on the prevailing attitudes and opinions towards corruption. Despite the evidence that these surveys provide, which allow for international comparison, they rather do not provide detailed assessment of integrity within the country context.
Citizen surveys are a flexible tool that provide relevant information depending on how the data that they provide is used, analysed and processed. OECD countries have included three core elements in their citizen surveys and use their results for different purposes. Box 2.6 provides core elements that have been included in citizen surveys in OECD countries and how they might inform integrity policy making. A citizen survey could include questions on perception of government officials of different public institutions. It could ask citizens about the roots of their distrust in government and the attitudes and values they connect with public office. A random sample of citizens could, for example, be presented with a Semantic Differential Scale to express their associations with Costa Rica’s public sector. Repeating a similar measurement on the same or a comparable sample after the implementation of the policies could be a test for an attitude changing effect.
The citizen surveys are a valuable measurement tool for gathering evidence on the design, implementation and communication of integrity policies. This tool can be applied for several purposes. The following elements could be included in an integrity survey:
Values and attitudes: A values and attitudes survey is particularly useful as an ex-ante diagnostic tool for awareness and behavioural change policies. To design an awareness campaign with effective appeal, a survey can be conducted to find out what integrity-related values matter to large groups of citizens.
Experience, awareness and perception of corruption: Corruption is strongly embedded in social interactions. Transparency International's Global Corruption Barometer and other international surveys can provide a brief impression of how common bribery is in Costa Rica, where and when a citizen experiences bribery, and how strongly corruption is perceived by citizens in different sectors. A survey targeting only Costa Rica citizens could assess experiences, awareness and perception of corruption in more detail with respect to the country context.
Dilemmas and justifications: Strengthening a culture of integrity throughout society means enabling citizens to identify and react to an integrity violation. Situations can be identified in which citizens participate in or further justify/tolerate certain types of integrity violations. Confronting citizens with practical ethical dilemmas in survey questions could help integrity policymakers understand what integrity violations are commonly accepted by society, to whom they assign responsibility, and how citizens take this based on their general dislike of corruption.
Source: (OECD, 2019[29]).
As already mentioned, Costa Rica’s National Survey on Corruption Prevention, has a module that surveys citizens regarding their knowledge about actions to prevent corruption, administrative procedures susceptible of corruption, experience of acts of corruption, culture of prevention and in general about their perception of corruption prevention in the public sector (Box 2.7).
In February 2020, the Comptroller General of the Republic (Contraloría General de la República, CGR), conducted the National Corruption Prevention Survey (ENPC - 2020), to explore the opinions of citizens (questionnaire 1) and public officials (questionnaire 2) on the prevention of corruption in the public sector. The information was obtained through a telephone interview, based on sampling frames aimed at citizens and public officials.
The following results from the module applied to citizens can be highlighted:
85.7% of citizens consider that corruption harms them in their daily lives. In relation to this, 15.3% indicate that corruption causes insecurity, 15.2% consider that it affects their personal and the country's economy, and 11.2% believe that it causes tax increases.
Similar to the results obtained in the previous survey, the procedures perceived with the highest level of corruption are: the application for a driver's license (71.7%), the procedure for the passage of merchandise through customs (68.0%), traffic fines (64.7%) and construction permits (62.3%). On the other hand, the procedures indicated as the most complicated or complicated are the request for a medical appointment (15.7%), request for construction permits (8.4%) and procedures at the CCSS (7.6%), which were also mentioned previously.
Regarding the culture to prevent corruption, 64.7% indicate that citizens are the main responsible for preventing corruption, followed by the public sector (23.6%) and private companies (2.2%). In addition, it is perceived that the most relevant values when undertaking preventive actions are honesty (43.8%), honesty (8.8%) and respect (7.2%).
In general terms, citizens perceive that 38.1% of institutions prevent acts of corruption from occurring, which is an increase compared to 2016, when 29.3% of respondents said so. Finally, 70.5% of respondents consider that Costa Rican society is very tolerant of corruption, which shows a slight drop compared to 2016, when 71.1% of respondents indicated a high tolerance of corruption.
Source: https://cgrfiles.cgr.go.cr/publico/docsweb/enpc-2020/perc-cuid.html
Citizen surveys are a thermometer to measure citizen perception towards the public sector and can indicate the level of citizen trust, identify in which areas this trust is particularly weak and where actions should be focused to improve this trust. Citizen surveys generate data that help to nurture the bilateral conversation between government and citizens. They are considered as one of the most valuables sources for the formulation of integrity policies, especially when they also measure trust levels. Trust in public institutions is the core issue of public integrity. Lack of trust compromises the willingness of citizens and businesses to react to policies and contribute to public integrity. Moreover, integrity is one of the core five political dimensions that drive public trust (OECD, 2017[30]).
Therefore, to have comparable data over time, Costa Rica could consider including questions or modules to existing longitudinal surveys conducted by the National Institute of Statistics and Censuses. These questions could be developed based on international good practice and fine-tuned together with the rector institution of the country integrity system to fit the country context. The OECD has recently implemented the OECD Survey on the Drivers of Trust in Public Institutions (OECD Trust Survey) in 22 OECD countries, which monitors people’s trust across different institutions and levels of government across countries (OECD, 2022[31]). Costa Rica was not part of this first exercise, but the country could consider implementing the survey in the future. In addition, more in depth case study on trust where conducted in Korea (OECD/KDI, 2018[32]), Finland (OECD, 2021[33]), Norway (OECD, 2022[34]) and, forthcoming, in New Zealand and Brazil.
Similar to staff surveys, Costa Rica could also produce ad-hoc citizen or targeted user surveys that serves specific purposes that go beyond the content of regularly conducted surveys. For this purpose, government agencies could collaborate with external actors such as academic research centers, for example, the Center for Research and Training in Public Administration of the University of Costa Rica.
User feed-back from public services could also be collected on a more ad hoc basis. For example, users of public services in Costs Rica could be invited to respond to short satisfaction surveys. Anonymously, respondents could indicate not only the quality of the public service provided, but also how they perceived the integrity of the institution or the public servant with whom they interacted. Especially, as integrity also covers issues related to harassment, for instance. Integrating feedback tools in situations in which citizens and public servants interact can allow policy makers to extract data related to the quality of public service and data that could help in building trust in public institutions. Feedback mechanisms provide citizens with the opportunity not only to legitimately reward a good experience, but also to flag a negative one, theoretically preventing citizens from generalising a bad experience to the entire public sector. In turn, those who respond with a positive experience could support a reconsideration of their existing attitudes towards the public sector (OECD, 2019[29]).
The increase of digital interaction between citizens and the public sector produces a diversity of opportunities to integrate questions into the online procedure that could later be used for evaluating the impact of integrity policies. The MIDEPLAN or the National Institute of Statistics and Censuses of Costa Rica could develop a standardised framework for the design and analysis of such opinion questions, with the aim of ensuring the comparability of information across different institutions. Another way of ensuring citizens’ feedback to public officials is though the so-called ambient accountability mechanism: a physical element, e.g. a poster or a screen, placed directly in the public office for citizens to leave comments (Zinnbauer, 2012[35]). The installation of such ambient accountability mechanism in public offices in Costa Rica could be implemented in a randomised fashion and accompanied by an evaluation of their impact.
The chapter provides recommendations to build on the ENIPC and continue working towards a comprehensive and coherent integrity system in the country. However, it is key to ensure that ENIPC’s objective of developing an integrity policy is achieved, that this policy is adopted at the highest level and has clear and measurable objectives, activities and responsibilities.
To achieve grounding the ENIPC and achieve tangible results, Costa Rica could consider in particular the following recommendations:
The MIDEPLAN could play a key role in promoting public integrity through the National Planning System, by ensuring that public integrity is included in the next National Development Plan 2022-2026.
On integrity, the NDP 2022-2026 could prioritise: (1) to improve coherence and co-operation amongst actors of the integrity system through a co-ordination mechanism as recommended in Chapter 1, and (2) the open and participative elaboration of the National Anti-corruption Policy as prioritised by the ENIPC and its incorporation into relevant plans of the National Planning System.
Provide guidelines for subnational levels, to implement the Ethics Management Model and to encourage the development of their own integrity policies, particularly with the aim of creating synergies through the territorial development plans.
The chapter further proposes several avenues to ensure an effective monitoring and evaluation of the ENIPC and future integrity policies. For that purpose, Costa Rica could consider, in particular, the following actions:
Establish a central integrity monitoring system, which produces regular reports on the advances of the implementation of the ENIPC or future integrity policies and that could help to manage and communicate progress towards integrity goals.
Costa Rica should establish clear procedures and criteria for regular and independent evaluations of integrity policies to allow for a continuous learning and improvement and leverage the data and information from the M&E system to enable more effective communication strategies.
To monitor and evaluate integrity policies, Costa Rica should draw from different data sources and identify gaps for areas where data is not available. In particular, a set of indicators are needed to measure progress in the implementation the ENIPC. Data from surveys of public officials and citizens could provide input on how integrity policies contribute to a culture of integrity in Costa Rica´s public sector, how they promote trust in government and how they affect awareness for integrity in the whole of society.
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