In June, 2019, the Government of Georgia approved new Action Plan 2019-2020 for Public Administration Reform (PAR)with the purpose to implement the goals of the Public Administration Reform Roadmap 2020.
EU-Georgia Association Agreement urges the country to carry out comprehensive reforms for building an accountable, efficient, effective, transparent and professional civil service. For implementing this requirement, in 2015 the Government of Georgia approved the Public Administration Reform Roadmap 2020. The document aims at creation of the comprehensive conceptual framework and mechanism for transparent, foreseeable, responsive and effective public administration as well as for meeting the requirements of the society and European standards.
The Public Administration Reform Roadmap consists of six directions: Policy Planning, Civil Service and Human Resource Management, Accountability, Service Delivery, Public Finance Management, Local Municipalities. Reaching these goals was the motivation for adopting Action Plan 2019-2020 for Public Administration Reform. The Action Plan covers all six dimensions but the adequacy and sufficiency of its objectives and activities are dubious. It is worth mentioning that the Government delayed for a few months the adoption of the PAR Action Plan, which is the reflection of serious gaps of policy planning procedures. Even though the Action Plan was approved by the PAR Council in the beginning of 2019, its adoption by the Government was delayed similarly to the Anti-Corruption Action Plan 2019-2020.
As a member organization of the PAR Council, IDFI was involved in the elaboration of the PAR Action Plan. During the discussions held on the draft PAR Action Plan IDFI in a number of occasions underlined the necessity of providing in the policy document more important commitments and reforms. Despite this, the new PAR Action Plan does not provide for ambitious reforms, especially, in terms of increasing transparency and accountability. Instead of determining commitments towards new reforms, the document copies the old commitments from previous policy documents, which have been left unimplemented for a few years now. This includes the objective on implementing Regulatory Impact Assessment (objective 1.4), which was supposed to be implemented by 2018 but this did not happen and the commitment was transferred to the new Action Plan. Lack of ambitiousness of the Action Plan is demonstrated by the objective 3.2 – improving access to the open data system. Only three agencies have been selected as responsible institutions for implementation of this objective (Civil Service Bureau, Ministry of Finance and Municipal Service Development Agency). This makes impossible to achieve the planned objective and demonstrates the unrealistic nature of the commitment. In terms of transparency and accountability one more important commitment is improving the access to public information (objective 3.5) by adopting an Act of Freedom of Information. The objective was to be completed a few years ago. The draft Freedom of Information Act was prepared in 2014 and has been shelved for almost five years despite the fact that it has been renewed several times and scheduled by the Anti-Corruption, Open Governance and Public Administration Reform Policy documents to be adopted in previous years. There are only two objectives foreseen by the PAR Action Plan in the direction of the local self-governance, with the Ministry of Regional Development and Infrastructure of Georgia determined as a responsible agency while municipalities are only referred as partners. This questions the possibility of achieving the objective. Finally, despite the fact that there is no obligation and common rule  on conducting public consultation in the country (as well as quality and publication of monitoring reports), PAR's Action Plan does not determine it as a separate problem and does not set forth increasing the transparency and engagement as a special objective.
In addition to the non-ambitious and unrealistic objectives of the PAR action Plan, there are many other deficiencies:
Poorly-defined risks - in many cases, the risks connected to the achievement of the set objectives of the PAR Action Plan relate to the lack of personnel which constitutes the faultiness of the policy planning process, because in order to meet the criteria of realistic and achievable nature of the Action Plan, it is necessary that planning of each objective and activity is conducted based on the available resources, among them, human resources, otherwise, the policy planning loses its sense. In some cases, the cause of the problem and the risk are mixed up with each other. In particular, it is absolutely unreasonable to determine as a potential risk the non-obligatory nature of the Civil Service Bureau's recommendations because it constitutes the fact that causes problems such as failure to comply with the recommendations of the Civil Service Bureau, which, in turn, interferes with the uniform development of the practice of the civil service. Flaws like these indicate that in the course of the action plan development in-depth situation analysis did not occur, and some problems were left behind.
Absence of risks elimination / risk reduction mechanisms - the purpose of identifying racks in a policy document is to plan relevant steps for their elimination/reduction. Therefore, the risks indicated in the Action Plan should be accompanied by the information on the methods to be applied for risk elimination/reduction. This does not occur in the PAR action plan, which leaves the impression that the risks in the document are defined without proper analysis and/or with the purpose to allow the responsible agencies refer to them in cases when the objectives set forth by the Action Plan are not achieved.
Ambiguous / unmeasurable outcome indicators - although compared to the previous action plan, the indicators have been improved, still there are number of unmeasurable indicators in the document, which means that assessing the achievement of the objectives is actually impossible. For example, the indicator 1.3.4 is presented as follows: "the share of strategic documents and monitoring reports that are filled out by the agencies without any flaw." It is unclear what filling the report without "any flaw" means, specifically what criteria the document prepared by the agency should meet and what will be considered as defective. The same can be said regarding the 5.1.1 indicator, which is presented as "the quality of the country's basic data and direction document (BDD)". In this case it is completely unclear from the Action Plan, what methodology and criteria will measure and evaluate the quality of the document.
Outputs used instead of output indicators - the policy document can determine outputs for activities and output indicators for measuring the activity outputs. With the help of the output indicator, it is assessed whether the expected results for the specific activity set by the document has been achieved. With the help of the output indicator, the outputs of the activity may be measured quantitatively and qualitatively. New PAR action plan mixes the term of output with the term output indicators and under the title of output indicator, it lists what constitutes the output rather than output indicators. The table below provides an example of how output and output indicator should differ from each other:
Inadequate/insufficient objectives for problem resolution - new PAR action plan sets the objectives such as "propose solution for the institutional arrangement of legal entities of public law in order to strengthen the principles of economy, efficiency and efficiency [...]". "Proposing the solution" cannot be considered as an objective because it is overly specific and can only be determined as an activity or sub-activity. The objective of achieving the goal of strengthening the principles of economy, efficiency and efficiency could have been determined as follows: improving the institutional arrangement of legal entities in public law / conforming to [specify] standards.
In order to eliminate the above-mentioned shortcomings, it is necessary for the Government of Georgia to take into account the following recommendations:
1. Strengthening civil society (especially at the regional level) and ensure their involvement in the development of any national or sectoral policy document.
2. Raising public awareness on public civil service reform and ensuring wide public consultations when developing any national or sectoral policy document.
3. Further updating of PAR Action Plan for the purpose of planning more ambitious reforms / commitments and elimination of discussed shortcomings.
4. Expanding the circle of responsible agencies for the implementation of the PAR Action Plan and increasing the involvement of municipalities in it.
 Association Agreement between the European Union and the European Atomic Energy Community and their Member
States, of the one part, and Georgia, of the other part L 261/4 (2014), Article 4.
 The Public Administration Reform Roadmap 2020, p. 5.
 The first Action Plan was adopted in 2015 and the second one – in 2017.
 IDFI's Proposals for the New Anti-Corruption Strategy and Action Plan 2019-2020.
 OECD-SIGMA Baseline Measurement Report: the principles of public administration, Georgia (2018), გვ. 41.
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