The Accord: Bounded or Comprehensive Rationality

Would you rather eat the policy horse or take little mouse nibbles?

I like to think of myself as reasonably smart. I’ve got lots of letters after my name. I’ve got a fancy job title that makes it hard to convey what I do to others outside higher ed, and even to many in higher ed.

In fact, I’m so smart…[how smart?]… I recognise how little I know. I am well aware of the limits of my own cognition, exacerbated by slow mental processing speed, and inability to hold any more than one thing at my mind at once. My rationality is well and truly bounded.

Recognising of the limits of my feeble mind serves as a catalyst in this post to explore the limits of rationality in the Accord consultation process, and potential implementation of Accord recommendations.

Bounded Rationality

Rationality is a significant concept in policy making, with bounded rationality recognising that complex systems, like higher education, are hard to understand. Policy making is more inclined to taking little mouse nibbles from a food platter. Manageable and digestible components of policy rather than eating the whole horse of system transformation. This helps explain why the Accord is such a big deal. It’s an intermittent attempt at eating the horse. It’s big, some bits are hard to chew and digest, and some bits you’d rather not eat at all. I suspect that many on the panel, and the secretariat that provided support to the process at the very least have indigestion, and are probably exhausted.

It’s tempting to think of the panel being a vociferous information processing machine that weighed up all the potential evidence, and were wise enough to integrate this evidence into actionable insight. No doubt panelists were kept very busy, but they too have limits to their cognition. Their rationality was also bounded.

We can see how the panel managed this problem through AusTender reports for the Department of Education in 2023 .

• $136k to RMIT for “Australia Universities Accord Commissioned Work”

• $138k to Nous Group for “Analysis of Submissions to the Accord Interim Report”

• $142k to Bis Oxford Economics for “Technical modelling services to inform the Australian Universities Accord Panel”

• $162k to UTS for “Co-design services with the Department of Education to inform the Australian Universities Accord Final Report on Australia's higher education funding system”

• $165k to Melb Uni for “Provision of co-design to inform and support the Australian Universities Accord Panel on Teaching Quality”

• $336k for RMIT “Services delivered in co-design with the Department of Education to inform and support the Australian Universities Accord Panel on skills and tertiary integration”

• $352k to Nous Group for “Services delivered in co-design with the Department of Education to inform and support the Australian Universities Accord Panel on system governance”

• $710k to Polis Partners for “Project Management for the Universities Accord Implementation”

This list highlights how key tasks of the Accord, like reading and generating insights from submissions, was outsourced to external consultancy services. Other more technical analysis was commissioned for specific purposes, like future jobs growth projections.

It’s natural to do this, and if we left it to the panel to do everything themselves, the bounded rationality problem would have generated a very different report. If anything, what is surprising, is that the amount of tendered outsourced work involved in reviewing the entirety of higher education gave the tax payer change out of $2 million. Obviously much more was spent outside of this tender process, but the tenders give insight into what information processing capacity the panel outsourced.

Comprehensive Rationality

The opposite of bounded rationality is comprehensive rationality, or the rational-comprehensive approach. The policy making process is in this context controlled by elite policy actors whose ideas are translated into policy with the minimum of friction. Policy issues are rationally considered and the best alternative is identified. From here it is a straight forward matter of issuing the policy edict, and having it implemented. No problem.

One might be tempted to see the Accord’s epic culinary adventure as a form of comprehensive rationality. An omnipotent panel parsing the data and issues, diligently weighing up the evidence against its terms of reference to land on its 47 recommendations (and many more if you count recommendation 45.a. as distinct from 45.b.v.). Each recommendation will become law (where necessary), with necessary appropriations (where required), and universities and other tertiary institutions will fall into line.

The reality, well understood by the panel, is more complex. They’ve outlined a staggered approach, with the broad direction dealt with in discrete parcels of work to be undertaken by entities that are yet to exist.

Even with the road map for implementation well described, the policy agenda is likely to be broken into a more complex range of mouse sized constituent policy parts. Some will maintain fidelity to the original intent. Many will be unrecognisable. Many will no longer be fit for purpose once the complex integrated tertiary education system takes shape and evolves. These parts, if reassembled, may look more like an alien mutant than the horse they first carved into.

Australian Tertiary Education Commission

If the panel represents an attempt at eating the horse, The Australian Tertiary Education Commission might be akin to eating an extended family of elephants. TEQSA, the ARC, the Centre for Excellence in Teaching and Research, universities, TAFEs, RTOs, AQF, planning, pricing, ASQA, Regional Commissioners and more are all in frame. This, to me, looks like an attempt at imposing a comprehensive rationality model on a complex system. As ATEC takes shape, and if it takes shape, the bigger and wider its remit, the bigger and more troublesome will be the emergent bounded rationality problems.

We already have plenty of structures that deal with complex systems. Parliament, for example has to grapple with everything, sometimes well, sometimes not so well. DPMC, plays a coordinating role for the whole of government, and its current secretary (Glyn Davis) both wrote the book on ‘public policy processes’ and on the ‘history and future of Australian higher education’.

If my understanding of insights from Glyn Davis’ writings on public policy and higher education flow through to ATEC, it is unlikely that we’ll see it adopt too stringent and interventionist of a model that makes bounded rationality problems bigger than they need to be, nor hubris associated with comprehensive rationality become a defining feature. Glyn is not however, running nor in full control of the process. A change of minister, or government, or cross bench deals in parliament may well see ATEC deviating substantially from the model key proponents have in mind.

My own research highlights that Australian higher education policy has had a dynamic hyper incremental approach with a high frequency of policy reform. The higher education support act is amended on average every 3 months, and spits out a new policy instrument, on average, every two weeks.

This hyper-incrementalism is driven by an inability to devise stable policy mechanisms that can accommodate growth in students and fundamental expansion of what is known of our universe and social realities. I’m hoping the accord and ATEC can chart a new way, but fear the expected return on investment needed to fully fund research and additional student places will come with the quid quo pro of an inordinate fondness for red tape and continued torrent of policy edicts that the sector must comply with.

For clarity - this newsletter represents my personal views informed by my scholarly research and is not to be confused with an official position for any organisation with which I may have an affiliation.