Review of the effectiveness and validity of operations of the MAIF Agreement:Research Paper

5.3 How efficient, transparent, cost-effective and appropriate are APMAIF processes?

Page last updated: 18 June 2012

Recommendations

12. The APMAIF should include a report card in its Annual Report which could include:
a. reporting of complaints data against new service charter KPIs
b. a summary of APMAIF decisions over the previous 12 months including updated interpretations.

13. The existing level of funding of the APMAIF by DoHA is appropriate given its current functions and powers. Funding levels should be revised if additional functions are added to the APMAIF Terms of Reference. The previous practice of industry co-funding the operation of the APMAIF should not be re-introduced.

5.3.1 Improvements are required to the timeliness of APMAIF communications

Review questionsInsights
What is the timeliness and effectiveness of APMAIF reporting and communication procedures?

What are stakeholder views on improvements in APMAIF processes?

œ There was a divided response amongst stakeholders regarding the timeliness of APMAIF communications.

œ Many stakeholders were unsure about the effectiveness of APMAIF reporting and communication procedures. Some suggested that the APMAIF could communicate more effectively with the community about the complaints handling process and the role of the APMAIF.


As part of this Review, stakeholders were asked about the timeliness and effectiveness of APMAIF reporting and communication procedures. Responses are shown below.

Timeliness

Amongst targeted stakeholders (n=17) there was a mixed response regarding the timeliness of APMAIF procedures. 42% of respondents disagreed/ strongly disagreed and 36% agreed/ strongly agreed that current APMAIF reporting and communication procedures are timely. The range of results from targeted stakeholders is shown in Figure 7 below.

Figure 7: Survey statement: “The APMAIF reporting and communication procedures are timely” – results from targeted survey (n=17)

Figure 7 is a pie chart depicting the results of a statement tested in the survey. Results are that: 24% strongly disagreed; 18% disagreed; 24% agreed; 12% strongly agreed and 24% were unsure.

Amongst general survey respondents, the majority of consumer and health professionals/organisation respondents disagreed or strongly disagreed that reporting and communication procedures are timely. Amongst consumer groups the response was divided, with 20% of respondents disagreeing (8% strongly disagreed; 12% disagreed) and 23% agreeing (19% agreed; 4% strongly agreed) with this statement.

Effectiveness

There was a mixed response both between and within targeted stakeholder groups (n=17) regarding the effectiveness of APMAIF reporting and communication procedures – 41% of respondents agreed (29%) or strongly agreed (12%) and 36% of respondents disagreed (18%) or strongly disagreed (18%) that current procedures are effective (NB: 24% of respondents were unsure of their response to this question).
Top of page
Between 30-40% of respondents from each respective stakeholder group represented in the general survey disagreed or strongly disagreed that APMAIF reporting and communication procedures are effective (NB: more than 50% of respondents from each stakeholder group were unsure of their response to this statement). Stakeholder responses regarding the timeliness and effectiveness of APMAIF reporting and communication procedures indicated that current practices are a good base from which to drive further improvements. Some suggestions for improvements to APMAIF processes identified by stakeholders through free-text responses included:
  • More regular meetings between APMAIF members should be conducted to enable interpretations and guidelines to be revised and updated if required (this may require increased funding). APMAIF members and signatories should also meet on an annual basis to conduct a review of the MAIF Agreement and new interpretations of the MAIF Agreement. This will enable the MAIF Agreement to remain up to date and maintain ongoing industry trust and adherence to the MAIF Agreement.
  • Greater awareness is required amongst community members and health professionals of the complaints process and the role of the APMAIF. Adopting a more proactive approach in raising awareness, disseminating reports and encouraging complaints would raise the profile of issues and increase the accountability of companies.
The APMAIF currently publishes an Annual Report that provides an overview of its activities for the preceding year. The Annual Report outlines complaints statistics for the preceding 12 months, breaches and issues arising from APMAIF business. The Review recommends that the Annual Report could be further strengthened by the inclusion of a ‘report card’ which tracked actual performance against a set of service charter KPIs (ie a mechanism by which APMAIF performance can be measured).

Other than the Annual Report, the APMAIF does not have a strong public presence. Its communication processes could be significantly enhanced through an active campaign to raise the level of awareness and education on the MAIF Agreement. The establishment of a stronger web presence would also enhance the effectiveness of communication and build community awareness.

5.3.2 APMAIF funding should remain independent from industry influence

Review questionInsight
Are there cost recovery options and what is their viability?
  • Stakeholders identified the importance of ensuring that industry is not involved in the funding of APMAIF operations.
  • There is support amongst stakeholders for DoHA to continue providing funding for the APMAIF.

To ensure the APMAIF remains independent and objective, some interviewed stakeholders and respondents to each of the surveys completed identified the importance of ensuring that industry does not fund APMAIF operations. Many stakeholders viewed the partial funding of the Secretariat by industry until 2007 as a conflict of interest which undermined the credibility of the APMAIF complaints handling process. Since that time, stakeholders have welcomed the DoHA initiative to fund all APMAIF operations (including the costs of participation by all APMAIF members.

For many stakeholders, government funding of the APMAIF increases the credibility and integrity of the APMAIF and the complaints handling process. To preserve stakeholder confidence in the effectiveness of the MAIF Agreement and the APMAIF, cost-recovery through industry funding is not considered appropriate.

APMAIF members indicated that APMAIF operations are reasonably cost-efficient and have not been impacted by limited funding. Several stakeholders suggested that better understanding and transparency of the budget and funding arrangements is required. Given its current functions and powers, the existing level of DoHA funding of the APMAIF remains appropriate. Significant changes to the current Terms of Reference may require funding levels to be revised.

5.3.3 Greater transparency and efficiency of APMAIF processes is required

Review questionsInsight
What are stakeholder perceptions of the efficiency, transparency and cost‐effectiveness of APMAIF's processes?

What is the extent to which APMAIF operations are transparent to stakeholders?

What are stakeholder views on improvements in APMAIF processes?

  • Stakeholders identified that the efficiency of APMAIF processes could be improved
  • Some stakeholders suggested that greater clarity is required of the role between the APMAIF and other regulatory bodies, particularly FSANZ
  • There is scope to improve the transparency of APMAIF processes

This Review identified a number of areas for improvement in APMAIF processes. The following sections discuss stakeholder views on the efficiency, transparency and cost effectiveness of APMAIF processes.

Efficiency and cost-effectiveness

Survey results demonstrate that 41% of targeted stakeholders (n=17) were unsure of the efficiency and cost-effectiveness of APMAIF processes. Results amongst remaining stakeholders were divided – 30% either disagreed (12%) or strongly disagreed (18%) and 29% agreed that current APMAIF processes are efficient and cost-effective.

Amongst general survey respondents (n=447), the majority of stakeholders (>65% of respondents for each group), were unsure of the efficiency and cost-effectiveness of APMAIF processes. Amongst remaining stakeholders, there was a general disagreement that processes are efficient and cost-effective. The exception was respondents from consumer groups (n=27), where 16% disagreed and 20% agreed that processes are efficient and cost-effective. These results are shown in Figure 8 below.
Top of page
Figure 8: Survey statement: "The APMAIF’s processes are efficient and cost-effective” – general survey (n=447)

Figure 8 is a chart depicting the results of a statement tested in the survey. The main points of interest in relation to the results of this survey statement are outlined in the text that preceeded the chart.

Interviewed stakeholders identified a number of areas to improve the efficiency of APMAIF processes. Currently, all APMAIF members and the Chair need to be present to make decisions on breaches. This process may be improved through appointment of a Deputy chair or discussions of complaints via teleconference. In the case where there are no complaints for discussion, it may be appropriate for no APMAIF meeting to be held.

Transparency

When asked about the transparency of APMAIF operations:
  • there was a mixed response amongst targeted stakeholders - 47% agreed that current operations are transparent, 18% disagreed and 6% strongly disagreed
  • more than 44% of general survey respondents from each respective stakeholder group were unsure about the transparency of current APMAIF operations. Amongst remaining respondents, the majority disagreed or strongly disagreed that current operations are transparent.
A few stakeholders identified that the role of the APMAIF compared to other regulatory bodies (e.g. FSANZ) needs to be clearer (although some regulatory overlap is inevitable). The Food Standards Code is the primary responsibility of FSANZ and is consistent with the MAIF Agreement. The Scope of the Code is broader, covering composition, labelling, provision of information and advertising. Although FSANZ has regular meetings with staff from both regulatory and nutritional areas of DoHA, further work is required to formalise this relationship. FSANZ are about to begin consideration of a review of Standard 2.9.1, which will include consideration of the complementarity of the Food Standards Code with the MAIF Agreement. This is likely to be a lengthy process of at least nine months duration, providing ample opportunity for consultation with the APMAIF secretariat, DoHA and other stakeholders.

The range of survey responses indicates that there is scope to improve both the efficiency and transparency of the APMAIF processes. The introduction of an APMAIF service charter that includes KPIs on service obligations will promote both efficiency and transparency of operations. Several recommendations proposed through this Review aim to increase the transparency of APMAIF processes (e.g. publication of APMAIF decisions and supporting rationale). Developing and publishing indicative timeframes for different processes will also increase transparency and efficiency.