Bureaucratic overload and organizational policy triage: A comparative study of implementation agencies in five European countries

Zink, Dionys; Knill, Christoph; Steinebach, Yves Article — Published Version Bureaucratic overload and organizational policy triage: A comparative study of implementation agencies in five European countries Regulation & Governance Provided in Cooperation with: John Wiley & Sons Suggested Citation: Zink, Dionys; Knill, Christoph; Steinebach, Yves (2024) : Bureaucratic overload and organizational policy triage: A comparative study of implementation agencies in five European countries, Regulation & Governance, ISSN 1748-5991, John Wiley & Sons Australia, Ltd, Melbourne, Vol. 19, Iss. 3, pp. 637-655, https://doi.org/10.1111/rego.12581 This Version is available at: https://hdl.handle.net/10419/330199 Standard-Nutzungsbedingungen: Die Dokumente auf EconStor dürfen zu eigenen wissenschaftlichen Zwecken und zum Privatgebrauch gespeichert und kopiert werden. 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If the documents have been made available under an Open Content Licence (especially Creative Commons Licences), you may exercise further usage rights as specified in the indicated licence. https://creativecommons.org/licenses/by/4.0/ Bureaucratic overload and organizational policy triage: A comparative study of implementation agencies in five European countries Dionys Zink Geschwister-Scholl-Institut für Politikwissenschaft, Ludwig-Maximilians-Universität München, Munich, Germany Christoph Knill Geschwister-Scholl-Institut für Politikwissenschaft, Lehrstuhl für Empirische Theorien der Politik, Ludwig-Maximilians-Universität München, Munich, Germany Yves Steinebach Institutt for Statsvitenskap, University of Oslo, Oslo, Norway Abstract Research on policy implementation traditionally has focused on understanding the success or failure of individual policies within specific contexts. Little attention has been given to the challenges that emerge from the cumulative growth of policy portfolios over time. This paper is addressing this research gap by examining the phenomenon of organizational policy triage, which occurs when implementation organizations face overload and are forced to make trade-off decisions between the implementation of the different policies in their portfolios. We investigate empirical patterns of policy triage across 16 social and environmental implementation agencies in five European countries (Denmark, Germany, Ireland, Italy, and UK). We show that variation in policy triage can be explained by the combination of three central factors: blame-shifting opportunities, the mobilization of external resources, and the commitment to compensate for overload by implementation authorities. Keywords: bureaucratic overload, implementation, public administration, public policy. 1. Introduction Policy implementation is a difficult and complex task, and the complete, timely, and smooth transposition and practical application of policies in line with initially defined objectives is subject to various challenges. The latter have been analyzed by several waves of implementation research inspired by Pressman and Wildavsky’s( 1984) ground-breaking work. As a result, we know a lot about the implementation of specific policies in a given setting that has been more or less successful. We also know a lot on the important role of street-level bureaucrats whose entrepreneurship and discretion plays a crucial role in matching policy requirements with local needs (Cohen & Aviram, 2021; Lowi, 1964). The strong orientation on often case-study based assessments of individual policies, however, implies that implementation research has missed the forest for the trees; that is, it has not developed analytical sensors to capture implementation challenges that emerge beyond the adoption of individual policies, but from aggregate patterns of policy change. In this regard, a particular challenge results from patterns of policy growth or policy accumulation that have been identified as a ubiquitous phenomenon in modern democracies (Adam et al., 2019). The fact that sectoral policy portfolios continuously are growing over time poses a novel—so far unexplored challenge—for policy implementation. As more policies generally translate into an implementation burden, there is the risk of a structural overload of implementation bodies if policy growth is not matched with corresponding Correspondence: Dionys Zink, Ludwig-Maximilians-Universität München, Geschwister-Scholl-Institut für Politikwissenschaft, Oettingenstraße 67, 80538 Munich, Germany. Email: [email protected] *Conflict of interest: The authors report that there are no competing interests to declare. Accepted for publication 16 January 2024. © 2024 The Authors. Regulation & Governance published by John Wiley & Sons Australia, Ltd. This is an open access article under the terms of the Creative Commons Attribution License, which permits use, distribution and reproduction in any medium, provided the original work is properly cited. Regulation & Governance (2025) 19, 637–655 doi:10.1111/rego.12581 expansions of administrative capacities. Consequently, implementation organizations might find themselves unable to handle all of their mandated tasks effectively, implying that not only the respective organization’s implementation performance is affected negatively but also the overall sectoral performance might suffer. The implementation problems potentially resulting from such overload scenarios have been described as organizational policy triage (Knill et al., 2023). This concept captures the fact that overburdened organizations are de facto forced to resort to trade-offs in decisions of various kind when carrying out their implementation tasks. The more such trade-offs have to be made, the worse the implementation performance of the respective organization appears to be. Even though these challenges and resulting policy triage are well-acknowledged in the recent literature (Adam et al., 2019; Knill et al., 2020,2023), we still have limited knowledge about the extent to which these patterns vary across sectoral and national organizations and why this is the case. While the exploration of organizational structures holds a prominent place in implementation research (Sabatier, 1986), the central discourse in this realm ponders about whether public policies primarily manifest through a “single lonely organization” (Peters, 2014, p. 132) or necessitate a “multiorganizational analytic perspective”for a comprehensive grasp of the implementation process (Hall & O’Toole, 2000; Hjern & Porter, 1981, p. 201). The prevailing organizational perspective has predominantly concentrated on delineating and mapping the entities involved in policy implementation, monitoring changes in their composition over time. However, this emphasis has overlooked a fundamental question: how do individual organizations address the challenge of overload and cope with the complexities arising from simultaneous implementation of multiple policies? In this paper, we address this research gap. We study the organizational policy triage in five European countries (Denmark, Germany, Ireland, Italy, and UK) across the sectors of social and environmental policy. To account for empirical variation in triage patterns, we depart from the assumption that the extent to which implementation bodies resort to policy triage results from the configuration and interplay of various factors at the national, sectoral, and organizational level. In view of this constellation, our underlying approach is essentially explorative in nature. We build on a theoretical interpretation of empirical variation that relies on the combination of different causal factors. The latter include (1) blame-shifting opportunities for central policymakers; (2) the implementation authorities’opportunities to mobilize external resources; and (3) the extent to which implementation authorities are committed to compensate for overload. The remainder of this paper is structured as follows: We begin with a brief discussion of the phenomenon of policy growth in order to substantiate the main point of analytical departure of this study (Section 2). In Section 3, we provide an empirical mapping of policy triage in the organizations under study and identify patterns of variation across countries and sectors. In Section 4, we discuss potential theoretical explanations for the empirical patterns observed and analyze the impact of different combinations of causal factors. Section 5concludes. 2. Policy growth and challenges for policy implementation The phenomenon of policy growth has been described and captured from different analytical angles, including the concepts of “policy accumulation”(Adam et al., 2019), “rule growth”(Jakobsen & Mortensen, 2015), “policy layering”(Daugbjerg & Swinbank, 2016), “policyscapes”(Mettler, 2016), or “legislative growth”(Kosti & LeviFaur, 2019). Although these concepts display important differences in their analytical focus, they all observe that governments effectively adopt more rules and policies over time than they abolish. Research has identified various drivers and factors affecting patterns of policy growth. Policy growth is not only driven by vote-seeking politicians who aim to demonstrate their responsiveness to public and interest group demands by addressing the challenges citizens care about (Gratton et al., 2021). Moreover, policies are also governments’main problem-solving tool because they allow them to deal “with issues and problems as they arise” (Orren & Skowronek, 2017, p. 3). However, while there are strong political incentives to produce new policies, it is hardly rewarding politically to dismantle existing policies, even when they have turned out to be ineffective (Bauer et al., 2012; Knill et al., 2020). Political incentive structures, therefore, result in governments typically adopting more policies than they eliminate over time, regardless of the policy sector in question. In order to measure policy growth, we conceive of a policy as a combination of a target (i.e., NOx emission; long-term unemployment) and an instrument that addresses this target (i.e., a ban; a means-tested benefit). Figures 1and 2provide an empirical impression of the dynamics of policy growth over a period of more than four © 2024 The Authors. Regulation & Governance published by John Wiley & Sons Australia, Ltd.638 D. Zink et al. BUREAUCRATIC OVERLOAD AND ORGANIZATIONAL POLICY TRIAGE decades (1976–2020) (Adam et al., 2019,2022). The figures display how the number of environmental and social policies developed on average for the five countries scrutinized in this paper during the observation period. The data presented report policy growth as the result of a continuous addition of new policy elements to existing policy portfolios without the compensatory reduction of already existing policy elements. A policy element is defined by the combination of a policy target and a policy instrument. While policy targets define what or who is being addressed by a new policy, policy instruments define how the target is being addressed. We are not interested in the restrictiveness or generosity of a certain policy since changes in the instrument settings do not affect the size of a policy portfolio. Instead, we are interested in the introduction of new policy instruments and/or the widening of the scope of existing policy instruments to new policy targets. The data collection is based on the coding of relevant national legislation, which allows us to scrutinize changes in the size and properties of environmental and social policy portfolios—the stock of policies a country has at its disposal (Adam et al., 2017). By doing so, we do not only take stock of newly introduced policies but also account for (rare) instances of policy dismantlement. Figure 1 Environmental policy growth in the countries under study. Figure 2 Social policy growth in the countries under study. © 2024 The Authors. Regulation & Governance published by John Wiley & Sons Australia, Ltd. 639 BUREAUCRATIC OVERLOAD AND ORGANIZATIONAL POLICY TRIAGE D. Zink et al. For both policy areas, we see that there has been a constant increase in policies over time. While policy growth is more pronounced for the environmental field, which constitutes a relatively young and dynamic area, it is remarkable that we also observe substantive increases in the more mature and saturated field of social policy. Yet, research on policy growth mainly has focused on the adoption of new programs, rules, and laws. The major share of attention has been to policy outputs. By contrast, systematic investigations of the outcomes and impacts of this output growth have remained rare. The literature acknowledges that policy growth is not a problem per se. The production of (new) public policies often means that problems are addressed, public demands are satisfied, and potentially conflictual situations are regulated if not solved (Rasmussen et al., 2019; Wlezien & Soroka, 2016). The production of environmental policies, for instance, helped to substantially reduce air and water pollution (Steinebach, 2019,2022). However, the literature has also shown that this positive link between policy growth and policy performance is far from straightforward if policy growth is not backed by an expansion of administrative capacities for implementation. Limberg et al. (2022)find that new policies lead to improvements of sectoral policy performance only if they are matched by a simultaneous increase in administrative capacities. Likewise, Fern andez-i-Marín et al. (2022) show that a widening “gap”between the policies up for implementation and available implementation capacities generally leads to a decrease in the effectiveness of public policies, implying that at some point additional policies make no difference whatsoever or even worse, diminish overall sectoral policy performance. 3. Policy growth and organization policy triage: Patterns across countries and sectors It is the main goal of this paper to study in closer detail how the structural challenges emerging from a potentially widening gap between growing implementation burdens and available implementation capacities unfolds at the organizational level. Our analytical point of departure hence deviates from classical implementation research, which is typically concerned with analyzing the implementation effectiveness of individual policies. Instead, we concentrate on the implementation performance of organizations to investigate the consequences of policy growth on implementation activities. In focusing on policy growth, we focus on the extent to which the burdening with new tasks results in a growing mismatch with existing implementation capacities. With this quantitative assessment in changes in the number of tasks, we adopt a rather cautious measure that potentially underestimates overload problems, as more tasks might at the same time increase overall policy complexity and impose conflicting requirements on implementation agencies (Hurka & Haag, 2020). Yet, a mismatch between burden and capacities need not be merely a result of a growth in policies but may also be the consequence of budget cuts. Indeed, such cuts can be observed in some organizations in our sample, for instance in the case of the Irish National Parks and Wildlife Service (NPWS). In such constellations, however, this development took place in the context of parallel burden expansion, implying that the central complaint voiced in the interviews and described in official reports was still focused on the allocation of additional tasks without adequate resource adjustments. We do not dispute the fact that a mismatch between workload and organizational capacity can also be the result of budget cuts. However, given the fact that we only observed budget cuts for organizations that were also affected by policy growth, we cannot make statements about the isolated effect of budget cuts on the extent of policy triage. Furthermore, we also observed overburdening in organizations that were not affected by budget cuts but experienced policy growth. Consequently, policy growth is—at least for the organizations in our sample—a necessary and sufficient condition for policy triage. 3.1. The concept of policy triage To compare variation and change in organizational implementation performance, we utilize the concept of policy triage (Knill et al., 2023). Policy triage refers to the prioritization of implementation tasks related to specific policies over others within an organization. As organizational workload increases, there is a growing need to make trade-off decisions of this nature. The prevalence of policy triage directly impacts an organization’s implementation performance. When policy triage is more prevalent, the organization’s implementation performance tends to decrease, as certain policies and tasks consistently and regularly are neglected in favor of others. Any instance of © 2024 The Authors. Regulation & Governance published by John Wiley & Sons Australia, Ltd.640 D. Zink et al. BUREAUCRATIC OVERLOAD AND ORGANIZATIONAL POLICY TRIAGE policy triage inevitably leads to selective implementation and, consequently, implementation deficits. This remains true regardless of the underlying rationale driving implementation bodies to prioritize certain policies or tasks over others. In other words, when administrative bodies rely on organizational routines that involve policy triage decisions during the execution of their implementation tasks, an increase in implementation deficits is expected to occur consistently. In the course of their day-to-day operations, organizations frequently face the need to make trade-offs, balancing competing priorities and allocating resources accordingly. However, an increase in policy triage indicates that organizations are making increasingly challenging trade-offs, putting them at a higher risk of encountering implementation deficits and failures. In line with this reasoning, the prevalence of implementation deficits is determined by the degree to which triage influences the organizational routines and internal processes of implementation bodies (Bayerlein et al., 2020; Bayerlein, Knill, & Steinebach, 2021; Bayerlein, Knill, Steinebach, & Zink, 2021). Therefore, we define policy triage as an organizational pattern. Our analytical focus lies in identifying triage patterns that become evident in organizational routines (Becker et al., 2005). The level of policy triage can be assessed by considering two key aspects: triage frequency and triage severity. Triage frequency measures how often implementation bodies engage in trade-off decisions. A high triage frequency indicates that policy triage is a regular and integral part of an organization’s routines. On the other hand, low triage frequency suggests that trade-offs occur periodically or in exceptional circumstances rather than systematically being embedded in organizational routines. Triage severity, on the other hand, focuses on the extent of resource reallocation. High triage severity involves significant trade-offs, resulting in the complete abandonment of certain policies or the neglect of important implementation tasks in favor of others. In such situations, policy triage leads to the effective termination of certain organizational responsibilities. Conversely, triage severity is considered low when the trade-offs are less extensive and rather impede but do not completely prevent the execution of specific implementation tasks. To summarize, a high level of policy triage is characterized by frequent trade-off decisions made by implementation bodies that result in significant redistribution of resources among different policies and implementation tasks. Conversely, a low level of policy triage indicates that decisions regarding resource reallocation are infrequent and involve only minor shifts in resources. 3.2. Measuring policy triage: Case selection and data collection To analyze organizational policy triage, we compare implementation bodies in the sectors of social and environmental policy. Studying both environmental and social policy allows us to test our argument across (1) different policy types (regulatory vs. redistributive policies); (2) fields with different degrees of maturity (young vs. old field); (3) quite different requirements for implementation (authorization, inspection, and planning vs. public service provision); and, relatedly, (4) differences in political incentives for engaging in capacity expansions in view of voters’affectedness in case of implementation failures (diffuse matters of environmental quality vs. problems in the delivery of individual services). With regard to the countries under study, we employ a diverse case selection (Gerring, 2008). We focus on five countries (Denmark, Germany, Ireland, Italy, and UK) that constitute advanced industrialized democracies, but substantially vary in the institutional characteristics of their political systems and their administrative traditions (Painter, 2016). This allows us to study organizational policy triage and its determinants across a set of (otherwise) very different institutional conditions and, as such, to increase the generalizability of our findings. For reasons of organizational comparability, we limit our empirical focus to implementation bodies operating at the national level; that is, ministerial bodies and independent agencies. The organizations were selected according to their task load by checking the number of policies within a population of organizations in both policy sectors and then selecting the actors responsible for the largest share of policies (see Supporting Information for more details on this process). We exclude local and regional authorities as arrangements of local government are highly difficult to compare across countries in view of strong differences in patterns of delegation and autonomy. The only exception here is presented by the UK where national policies are implemented by organizations in England, Scotland, Wales, and Northern Ireland as a result of devolution. In this case, we decided to focus exclusively on English agencies in order to avoid skewing our sample. Thus, overall, our sample covers 16 implementation bodies, 8 in each sector (see Table 2). © 2024 The Authors. Regulation & Governance published by John Wiley & Sons Australia, Ltd. 641 BUREAUCRATIC OVERLOAD AND ORGANIZATIONAL POLICY TRIAGE D. Zink et al. To identify the presence of organizational routines of policy triage, we conducted a total of 140 expert interviews (see Table A2 in the Supporting Information). Of those, 41 took place with the organizations’staff. The remaining 99 secondary interviews were conducted with relevant stakeholders such as regional and local administrations and other actors in the respective policy field in order to obtain additional background information and cross-validate accounts provided by the primary interviews. The interviews took place between February 2021 and May 2023, mostly via telephone or video calls. In the Supporting Information, we provide more detailed information on the interview questionnaire, the coding procedure, and the distribution of interviews across organizations as well as a list of the interviews conducted. To complement our findings and to cross-validate information obtained through the interviews, we also consulted secondary sources such as benchmarking documents commissioned by national governments or international organizations like the OECD, as well as media reports that covered the activities of the agencies under study. The implied objective was not only to verify that information obtained via the interviews is factually correct but also to ensure our coding scheme adequately captured the state of policy triage within the organizations. 3.3. Operationalization of policy triage levels Based on the above data from primary and secondary sources, we can identify indications of the severity and frequency of policy triage. In doing so our analytical interest is focused on the extent to which triage frequency and triage severity are embodied in organizational routines. To allow for a direct comparison of the two dimensions, we rate both triage frequency and severity as “low,”“medium,”or “high”(see Table 1). In determining the severity of triage, we consider the nature of the tasks that routinely were neglected in favor of others. Triage severity can be considered “low”if some policies are neglected (partially) to the advantage of others, but this negligence is restricted to secondary implementation tasks (consultation, research activities) that do not directly undermine the effectiveness of a given policy. “High”triage intensity implies that there are farreaching trade-offs between policies, resulting in a situation where organizations completely quit and abandon the implementation of certain policies or central implementation tasks, such as on-spot inspection or the monitoring of emissions of dangerous pollutants. “High”triage intensity also means that implementation tasks requiring accurate analysis and control, such as the certification of industrial plants or the granting of social allowances, are merely “rubber-stamped”by the implementation body instead of being examined thoroughly. The definition of core tasks for a given organization is based on its mandate and on the policies that they are supposed to implement which in turn are again based on legislation (i.e., statutory tasks). There are certain tasks that fall within the mandate but are not statutory. Here we would argue that the neglect is not as severe because implementation of statutory tasks trumps non-statutory tasks. Cases exhibiting high severity indicate implementation deficits in these core areas. Conversely, low severity is assigned to cases where certain measures related to policy implementation, such as additional controls or public outreach, routinely are disregarded, or when certain tasks need to be delegated to other actors on a regular basis. Table 1 Level of policy triage and its constituent dimensions Level of policy triage Policy triage frequency LOW: Triage decisions rarely occur and only imply the reshuffling of resources between a few policies or implementation tasks under the responsibility of a given authority. MEDIUM: Triage decisions occur frequently but are limited to a few policies or implementation tasks under the responsibility of a given authority. HIGH: Triage decisions occur often and affect all policies and implementation tasks under the responsibility of a given authority. Policy triage intensity LOW: Triage decisions are restricted to “secondary”implementation tasks that do not undermine the effectiveness of policies. MEDIUM: Triage decisions involve key implementation tasks. These implementation tasks are delayed but still performed at some point. HIGH: Triage decisions imply that whole policies or central implementation tasks are no longer performed. © 2024 The Authors. Regulation & Governance published by John Wiley & Sons Australia, Ltd.642 D. Zink et al. BUREAUCRATIC OVERLOAD AND ORGANIZATIONAL POLICY TRIAGE The frequency of triage is determined based on statements indicating how often certain tasks typically are neglected in the organization under study. Do organizations display routine behavior that entails regular, occasional, or merely exceptional resort to policy triage? “Low”triage frequency means that triage decisions rarely occur and involve the reshuffling of resources between a few policies or implementation tasks. “High”triage frequency, by contrast, entails that trade-offs in implementation occur often and that almost all policies and implementation tasks under the responsibility of a given authority are subject to triage decisions. We argue that both dimensions, severity and frequency, are equally important in assessing the impact of policy triage. The severity dimension highlights the significance of neglecting core tasks, while the frequency dimension provides insights into the regularity and persistence of triage practices. By considering both severity and frequency, we provide a comprehensive understanding of the level of triage and its implications for policy implementation. Table 2shows how combinations of the different levels of severity and frequency determine either high or low policy triage levels. Whereas a low level of policy triage presumes both low frequency and low severity, the opposite is the case for a high level. Yet, in reality we can also conceive of cases that display hybrid combinations of low frequency and high severity or vice versa. Interviewees of the Italian MET, for example, admitted to a high frequency of triage—“it often happens that we miss some schedules”(IT22012824)—while at the same time attesting a low severity: “we take a week for when normally we could do the same thing in two days”(IT22012824). 3.4. Empirical findings Table 3provides an overview of our empirical findings. Overall, our results reveal considerable variation in the presence of policy triage. Patterns do not only differ across countries, but also across sectors, and to some extent also across sectoral bodies within the same sector. While Denmark stands out as a country of low organizational policy triage in both sectors, the other countries under study display a highly mixed pattern, with triage degrees strongly varying across the different organizations. Pronounced variation also exists even across agencies within the same sector in a country, as it is the case, for instance, with Irish implementation agencies in both sectors and with German social policy agencies. Generally, we observed slightly less pronounced triage levels in the social compared to the environmental sector. Seven out of the 16 bodies under study reveal patterns of low triage. In these cases, available implementation capacities still seem to evolve largely in lockstep with growing implementation burdens emerging from policy growth. In case of Payments Denmark (PD) for example, there are some minor “areas on which (…) [PD] does not have that much attention on”(PD1) at a particular point in time. However, those instances hardly can be described as frequent or severe as they occur only in times of high pressure to implement new legislation on a large scale and do not constitute implementation deficits of any kind. At the most, the agency “runs risk[s] of defocusing (…) [its] managers”(PD2) since the gradually growing legal and administrative complexity in social policy temporarily may entail a few “negative consequences on efficiency”only (PD3). Tasks that are postponed are limited to three kinds of secondary implementation chores; first, adjusting “minor details after the implementation”in case PD’s software specialists “find out that the [IT-]system is not coping 100% with the [new] regulation and need to filter out some problems”(PD1); second, optimizing and simplifying the customer services and communications so that “the [online] journey of the pensioners [in terms of their interaction with the automatized client interaction system] is the best experience possible”(PD3); third, improving the overall functioning and procedural integration of different social benefit branches within the IT-system in order to weatherproof against potential increases of administrative complexity in the future (Interview_PD2; PD3). Interviewees of STAR, the other central implementer of social policy in Denmark and the two environmental agencies reported a Table 2 Dimensions and levels of policy triage Low triage High triage Frequency Low High Severity Low High © 2024 The Authors. Regulation & Governance published by John Wiley & Sons Australia, Ltd. 643 BUREAUCRATIC OVERLOAD AND ORGANIZATIONAL POLICY TRIAGE D. Zink et al. similar setting: STAR’s workload and tasks are “fluctuating, but on a steady level”(LMRA1). In case of the Environment Agency, one interviewee even noted that “we are ahead of time with our own schedules”(EA_2). In similar vein, also the Irish Environmental Protection Agency (EPA) and Pensions Authority (PA) have reported only very limited instances of triage, mostly caused by a lag between task allocation and resource allocation (Knill et al., 2023). In other words: it takes some time before the agency gets what it needs to implement policies. As one interviewee noted, there is usually a period of two to three years when new resources are not available yet, which can be exhausting and stressful (IR21051001). At the same time, however, all interviewees agreed that any overload is generally well-contained. Both agencies very rarely have to resort to policy triage in order to remain operative beyond the fact that some actors occasionally have to wait longer for environmental permits for example (IR21052702; IR21053104; IR21061006). Lastly, the German Bundesagentur für Arbeit (Federal Employment Agency; BA) also reports little to no instances of triage. Generally, interviewees even noted an improvement of conditions over the years: “We no longer have these times where we had to follow the ‘mass instead of class’principle. […] Fortunately, we have moved away from it”(DE210728). Despite an increasing workload—“additional tasks put a strain on the system”—the organization “usually can cope with this and […] keep it at a reasonable level”(DE210708). Again, minor tasks might be delayed occasionally, such as following up on administrative initiatives; however, they do not touch the core mandate of the FEA (DE210708). In five organizations, the need to resort to trade-off decisions is more pronounced, with triage occurring more frequently, albeit in most instances without severe consequences on policy performance. The Irish Department Table 3 Organizational policy triage across countries and sectors Organization Country Sector Triage level Limits to political blame attribution Resource mobilization Overload compensation Environmental Protection Agency (EPA) DK Environment Low High High High Nature Agency (NA) DK Environment Low High High High Payments Denmark DK Social Low High High High Agency for Labor Market and Recruitment (STAR) DK Social Low High High High Bundesagentur für Arbeit (BA) GER Social Low High High High Environmental Protection Agency (EPA) IRL Environment Low High High High Pensions Authority (PA) IRL Social Low High High High Department of Social Protection (DSP) IRL Social Medium Low Medium Medium Ministry of Environmental Transition (MET) IT Environment Medium High Low High Ministry of Labor and Social Policy (MLSP) IT Social Medium High Low High Social Security Institute (INPS) IT Social Medium High Low High Department for Work and Pensions (DWP) UK Social Medium Medium Medium Medium Deutsche Rentenversicherung (DRV) GER Social High Low Low Low National Parks and Wildlife Service (NPWS) IRL Environment High Low Low Low Institute for Environmental Protection and Research (ISPRA) IT Environment High Low Low Medium Environment Agency (EA) UK Environment High Low Low Low Note: The gray shading indicates the level of triage: light gray =low triage; gray =medium; dark gray =high triage. © 2024 The Authors. Regulation & Governance published by John Wiley & Sons Australia, Ltd.644 D. Zink et al. BUREAUCRATIC OVERLOAD AND ORGANIZATIONAL POLICY TRIAGE buy in support. But we want to build that capacity ourselves, build our own muscle up a bit here”(EN23031010). The agency also constantly shifts resources within and between departments to make the most of their internal capacity to “make sure that we efficiently use the resources we’ve got and we deliver”(EN23031010). Similarly, the DSP engages in organizational reform and restructuring, also on the unit level. Senior managers have the power to restructure their subdivision as and when they see fit. For example, as a result of the uneven distribution of workload due to diverging demographics in different counties, support units were restructured and centralized to deal with an increase in tasks (IR21127711; IR21112210). Compensation on the individual level is limited for both the DSP and the DWP. One interviewee noted that mostly the managerial level would engage in excessive overtime in order not to overburden their staff members. Yet, in times of crisis even high-level management helps out on the ground—“everybody is like all hands-on deck”(IR21121711). 4.5. Organizations with high levels of triage Most organizations with high levels of triage display a high vulnerability to be blamed for implementation failures. The ISPRA is affected similarly to other organizations on the Italian central level. In the area of environmental policy in particular, responsibilities for implementation are rather unclear. The formulating level thus effectively is able to avoid taking blame for deficient implementation while at the same time increasing workload more or less constantly, as one ISPRA staffer explained: “They often make a mess that we have to solve. Then you are responsible for solving all these overhead problems and they are not responsible”(IT21042804). Interviewees of the German DRV reported similar issues about blame-shifting: “the pension providers have also warned about the complexity […]. But the cries have gone unheard, and the problems have been assigned to us. […] You don’t always get the impression that politicians, when they want to follow their own path for whatever reason, listen to the experts”(DE210929_1). Also for the English Environment Agency politicians easily are able to dump responsibility for implementation failure onto the organization using its status as independent agency. The formulating level for example regularly argues that due to the EA’s licensing revenue the damage of stagnating—and in case of certain programs—even decreasing resources is not that severe. A textbook example of recent blame-shifting was provided by a former environment secretary commenting on river pollution in certain areas in England: “the former chair of the agency, has attempted to blame ‘cuts’to their budget […] The budget for monitoring license conditions has always been fully cost recovered so it was an agency management failure not a lack of budget”(Adie, 2023). Lastly, NPWS does not suffer significantly from blame-shifting in the traditional sense but more from a general neglect and disregard by policymakers as the organization was not perceived as “politically favorable”to formulators and thus they did not “want to engage with [NPWS]” (IR22052428). Consequently, the agency can be described as an organizational foster child by all means: As a result of what MacCarthaigh and colleagues call “slicing and dicing”of departmental portfolios (2023, p. 19), the organization has changed parent department no less than six times since its creation in 1991. Essentially, the NPWS has been used as a doormat that could be burdened with work without providing the necessary resources. Regarding resource mobilization, again all organizations with high triage level seem to share similar issues. On the one hand, there are little to no opportunities to advocate for more resources. In case of the NPWS, for example, there exists no formal funding obligation as the organization is officially incorporated in its respective parent department. The DRV on the other hand often attempts to advocate for an increase of staffing: “we had too few staff on board. They [the agency’s leadership] mentioned this again and again at their meetings [with the formulating level]”(DE210929_2), yet no increases manifested. In addition, resources also decreased for some organizations. As a result of the economic crisis in 2008, the NPWS’budget was cut by 70 percent. While funding now is at pre-crisis levels again, this was not the result of organizational resource mobilization but rather a force of hand as policymakers increased the budget only after a number of infringement cases were brought against Ireland by the EU. The EA also saw massive budget cuts: the Government more than cut in half the agency’s environmental protection budget from £170 million in 2009– 2010 to £76 million in 2019–2020, while also providing less and less opportunities for temporary funding of projects. 1 With regard to overload compensation, organizations with high triage levels also share a commonality: they almost exclusively engage in compensation on the individual level. As ISPRA interviewees note, for example, © 2024 The Authors. Regulation & Governance published by John Wiley & Sons Australia, Ltd. 651 BUREAUCRATIC OVERLOAD AND ORGANIZATIONAL POLICY TRIAGE D. Zink et al. overload is dealt with through extreme personal sacrifices on behalf of the staff: “the activities are done, but in absurd conditions, in really harsh conditions and with personal sacrifices. For example, two of my colleagues who have a contract were precarious and part-time, they worked for free while waiting for the new contract because the times are long, [and] you can’t stop. […] They worked practically in five years, one year for free without being paid. This is the reality if we talk about a public institution”(IT21042804; see also IT21100609). Similar working conditions were reported in case of the DRV, although in slightly less dramatic terms: “people are frustrated and some push endless overtime and vacation savings, but still struggle”(DE210929_1). Generally, all implementers with high triage activity display a total absence of overload compensation mechanisms that go beyond the individual level and would constitute some kind of organizational strategy: “it’supto us to make the activities run. It’s bottom-up, it is up to us to organize ourselves to complete the work within the deadlines”(IT21100609). In case of the DRV, administrative rules and procedures actively prohibit some of the mechanisms we theorized earlier as being part of compensatory behavior: “You can only work for one team. For procedural reasons, too, you are only approved for that one team. For example, I work on day 10. If there is a crisis in the team of day 9, I cannot jump in, even if I wanted to”(DE211027). In case of the NPWS, overload compensation has also been limited by another aspect: “Communications are poor on many levels: Not enough internal communication or sharing of work plans and priorities and this applies within small units, and at every level, right up to organization-wide. There simply is no culture of communicating and working together. We have no newsletter, no conference, no method whatsoever of communicating across NPWS”(Department of Housing, 2021, p. 5). 5. Conclusion Our paper shed light on the challenges that arise from the cumulative growth of policy portfolios and its impact on policy implementation. While previous implementation research has primarily focused on individual policies, we advocate for the need to consider the broader patterns of policy change and the resulting organizational policy triage. As we have shown, the continuous growth of sectoral policy portfolios poses a significant challenge for implementation organizations, potentially leading to structural overload and impeding effective implementation. To account for empirical variation across implementing organizations, we refined the concept of organizational policy triage which captures the trade-offs that overloaded organizations are compelled to make and ultimately impact their implementation performance negatively. This shift in analytical focus toward organizational performance rather than the effectiveness of individual policies provides insights into the structural challenges arising from policy accumulation. Our paper emphasizes the importance of understanding the variation in policy triage across sectoral and national organizations and the underlying factors contributing to this variation. By examining 16 ministerial bodies and national agencies at the central level in five European countries, we are able to provide evidence of policy triage within the social and environmental sectors. Our findings highlight variations in the degree of policy triage independent of country-specific variables such as administrative tradition, political system, or structural factors such as organizational size. Furthermore, we have shown that the theoretical framework advanced in this study, centrally based on three explanatory factors, blame-shifting opportunities, resource mobilization, and the commitment of implementation authorities is able to account for variation observed in our sample. In general, our findings indicate that the level of policy triage is not only affected by factors that are exogenous to an organization, such as political blame games or an organization’s political leverage to mobilize external resources, but also by endogenous dynamics that determine an organization’s commitment to overload reduction. While political factors are difficult to change in the short term, engagement in organizational reforms might constitute a more appropriate approach to handle bureaucratic overload. The link between organizational reforms and the potential of these reforms to reduce bureaucratic overload are hence a promising area for future research in this field. Recent research has shown for instance, that attempts to strengthen the vertical coordination between bureaucracies in charge of policy formulation and those in charge of policy implementation can help to reduce the potential of administrative overburdening (Fern andez-i-Marín, Hinterleitner, et al., 2023; Fern andez-iMarín, Knill, et al., 2023). Moreover, our findings show that organizations governed by a “silo mentality”could benefit from more cooperative structures to cope with overload. In cases such as the DRV for instance, reforming © 2024 The Authors. Regulation & Governance published by John Wiley & Sons Australia, Ltd.652 D. Zink et al. BUREAUCRATIC OVERLOAD AND ORGANIZATIONAL POLICY TRIAGE the organizational rules and procedures to allow for a more cooperative approach among units and departments most likely will also mitigate overload to some extent. While problems of overload and administrative capacity limitations are often discussed as a general feature of public sector organizations, it is important to emphasize that our analysis refers to a specific class of administrative bodies, namely those bodies for which new tasks typically are permanent in nature. Overload hence emerges from the fact that burden constantly piles up, adding to the number of existing tasks the organization must fulfill. The implementation of public policies is a primary example of such permanent tasks. By contrast, overload challenges resulting from a constant piling up of burden are less likely for organizations that deal with one-off tasks, that is, tasks that are off the table once they are fulfilled such as policy development or policy evaluation. Acknowledgments This work was supported by the European Research Council under Horizon 2020 grant 788941. We thank our three anonymous reviewers for their constructive feedback on the original version of this article. The authors also thank David Levi-Faur for the chance to present an early version at the Theories of Regulation & Governance webinar series as well as all fellow panelists, discussants, and commenters at the CES 2023 and DACH 2023 conferences for their valuable feedback and suggestions. Lastly, we also extend our gratitude to Dionys Zink (medior) for language editing and proofreading. Open Access funding enabled and organized by Projekt DEAL. DATA AVAILABILITY STATEMENT The data that support the findings of this study are available on request from the corresponding author. The data are not publicly available due to privacy or ethical restrictions. ENDNOTE 1See https://hansard.parliament.uk/commons/2022-11-17/debates/29A0035B-708A-4796-8C52-395CA86C7C54/Environment AgencyEnforcementBudget#::text=However%2C%20the%20Government%20more%20than,was%20only%20£94%20million. 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