Evidence of meeting #45 for Access to Information, Privacy and Ethics in the 40th Parliament, 3rd Session. (The original version is on Parliament’s site, as are the minutes.) The winning word was agencies.

A recording is available from Parliament.

On the agenda

MPs speaking

Also speaking

Gary Bass  Executive Director, OMB Watch

3:30 p.m.

Liberal

The Chair Liberal Shawn Murphy

I would like to call the meeting to order. Welcome, everyone.

In the first hour of the meeting we're going to hear from Mr. Gary Bass via teleconference. Mr. Bass is the executive director of OMB Watch, which is the Office of Management and Budget. He has some opening remarks.

Can you hear me fine, Mr. Bass?

3:30 p.m.

Gary Bass Executive Director, OMB Watch

I can hear you just fine.

3:30 p.m.

Liberal

The Chair Liberal Shawn Murphy

That's great. We appreciate that. I think everything is working well.

We certainly welcome you, Mr. Bass, and want to thank you very much for assisting this committee. As the clerk has pointed out to you, we are doing an ongoing study, a fairly extensive study, on open government and the merits of the Government of Canada adopting an open government strategy similar to what the Obama administration has adopted and partially implemented in the United States.

Having said that, I'm going to turn the floor over to you for your opening comments, and then once your comments are concluded, we'll entertain questions from members of the committee.

3:30 p.m.

Executive Director, OMB Watch

Gary Bass

Thanks, Mr. Chair and members of the committee.

As you said, I'm Gary Bass, and I run an organization called OMB Watch. For roughly 30 years we've been focused on trying to promote open government and transparency, so you can imagine that it was with great delight that we heard President Obama, on his first day in office, talk about a theme, a set of principles, that would guide government, which included three points: transparency, participation, and collaboration.

I must say, from the perspective of a non-governmental organization that has been tracking this issue, it is remarkable how much change has occurred in the two years since the President announced those principles. By the same token, I wouldn't be representing an advocacy organization if I didn't say that we have a long way to go still.

What I'm hoping I don't do today is really assess that open government initiative; instead, what I'm hoping to do is to pull from it some lessons that may be helpful to you as you pursue open government initiatives, and they should be reflected as a perspective from a non-governmental organization rather than from an insider of government.

For me, there are three striking things about how the Obama administration has pursued open government. I'll put them into three categories: policy changes, technology changes, and cultural changes. You have my written brief, which goes into much greater detail, so I'll just summarize some of the key points. Then I'll try to conclude with some points I would take out of problems that still have to be addressed with open government, as well as some suggestions about strategies that might be helpful to strengthen open government.

For the Obama administration, one area of approach was to address the policy changes. We have just, in this country, come through a previous administration that held the viewpoint that where you could withhold information, you should. Of course, this occurred in the aftermath of the 9/11 terrorist attacks, and there was a growing increase in secrecy. President Obama came in, and one of the first things he did was set in place a guidance strategy for changing the policy on our Freedom of Information Act laws. In essence, he reversed the “wherever you can, withhold” model to one that said “where you can disclose, you should” and actually had a policy plan that said that to the extent that you can affirmatively disclose—that is, voluntarily disclose—information, the agency should do so. That was a huge policy change.

He put in place many other policy changes. One example would be the change in policy about disclosure of who visits the White House. You can now go online and pull up visitors to the White House to identify who they visited, and by doing that at least get a sense of the general purpose. It doesn't list the purpose of the meeting, but from the identification of the individual you get a sense.

In addition, it isn't just about all the domestic disclosures. The President also changed policy in the area of national security policies. For example, he put in place a new kind of policy on declassification of information, arguing that no information should ever be permanently classified, that ultimately all information should be declassified at some point.

So the policy changes were quite significant, quite important, and quite needed.

The second area they moved on was the technology front. There are lots of jokes that could be made about a government that lives in the 20th century even as we're in the 21st century in terms of technology. The Obama administration came in and couldn't really use very many social media tools; technology was behind the times. It was a struggle, especially for a President who lived with two BlackBerrys on his belt. So they quickly moved on the technology front, and I think the legacy that we live with in the United States—a permanent change in the heavy use of technology—is that public access now always will equal online access. That's a permanent change that we'll never go back on.

This administration jumped in very quickly on the technology front with such things as Data.gov, which was to be a repository of significant data holdings from the agencies. It jumped in with an information technology dashboard, which has yielded savings in the information technology management area whereby the public could look at benchmarks to see whether or not IT performance was really occurring. Today we see agencies moving forward with mobile applications, whereas, as I mentioned, two years ago we were still wrestling in some respects with improving fax technologies.

So there is very rapid change on the technology front, and from the agency's point of view, it is a very exciting time.

The third area includes really the cultural changes, and in fact these are probably the hardest. We all know that even if you have the best of policy changes and they are complemented with the best of technology tools, unless you change the culture or the viewpoint within the government around open government, you're going to be presented with many challenges.

The Obama administration took on the cultural issues in several ways. They immediately moved to create an interagency working group that put the focus on the agencies and their method of implementing some of the open government policy changes. This came through something called the Open Government Directive, which came out December 8, 2009. It was a directive that told agencies to pursue a set of steps to move forward on with creating web pages, creating open government plans, and placing high-priority information on the Internet.

In addition to this kind of interagency working group, the President complemented it with the creation of a leadership team within the White House. It's the first time ever in this government that we have had a White House team focusing on transparency issues. It really has served as inspiration for the agencies, because they see at the highest of levels that the President is serious about these endeavours.

I will say that another very helpful piece is that the leadership team, along with the interagency working group, worked very collaboratively with such groups as OMB Watch and other public interest organizations. That helped to create a very different kind of environment. Complementing all of that on the cultural front, the Office of Management and Budget has issued guidance to the agencies to better maximize awards for transparency—giving rewards, if you will, for that kind of behaviour. At least in this government, for civil servants there is basically only a penalty for disclosure. There's a sort of “gotcha” kind of environment, such that if you put out the wrong information, there is a penalty to pay. Rarely are there accolades or positives for the disclosure. So this idea of presenting awards or incentives was very important.

I will say that one thing missing on this front is the notion of incorporating performance reviews of civil servants and incorporating the notion of disclosure within those evaluations. From our perspective, if it's an important enough issue to be a national mission, then it should be woven into the evaluation of the workers within government.

In any case, these three areas of policy changes, technology changes, and cultural changes are vitally important and work hand in hand in the strategies that the Obama administration brought.

When we move into a more interactive component here, I can go into details on any of those pieces, to describe more in detail what they have done. What I'd like to do, though, is take a few seconds to talk about difficulties within this open government initiative.

I want to mention four examples of challenges. The first is the huge gap between putting in place useful or positive policy and the implementation of those policies.

An example is our Freedom of Information Act. The President, as I mentioned, has shifted gears to say “where possible, disclose information”: have an affirmative disclosure or a voluntary disclosure model whereby agencies should proactively disclose to the public. There's been a huge gap between that policy framework and its actual implementation. We will find out in another month or so the latest data on either problems or the movement toward solutions in dealing with backlogs of requests under the Freedom of Information Act.

But by and large, I think many of us outside of government still see a huge gap between that and the effective implementation of the concepts behind the policy, and that's something that needs to be addressed. That's one type of challenge that will always exist but is vitally important to figure out how to tackle.

A second kind of problem that may exist is that under the open government directive I mentioned, and the emphasis for disclosing information, many of the agencies.... The strength of that model was that it was controlled, by and large, by the agencies, as opposed to the White House. The disadvantage of that is exactly the same, which is that each agency determined what information to be disclosing. The net result of it has been a very heavy emphasis, a much heavier emphasis, on what I'll call mission-driven disclosure. There are specific kinds of disclosures that meet the mission of the agency's fundamental purpose.

What they're not as good at and have not been as prominent on is disclosure about the agencies' activities: things like data and information around accountability and influence of special interests. Those kinds of procedural components have been left largely unattended to, while the focus has been mission driven.

From our perspective, both types of information--the type that's needed for accountability as well as the type that empowers the citizenry--are needed in an open and transparent system. That's the second kind of hurdle.

The third that I want to mention deals with data quality. Obviously, if you have information that is of poor quality, it is going to make the transparency much less valuable. We're fortunate that over the last number of years there has been a much greater emphasis on, say, federal spending transparency, to better track who's getting how much money and for what purposes.

Under our recovery act, which dealt with stimulus spending, we have a Recovery.gov website that has been remarkable in adding disclosure around spending of the recovery act dollars. Similarly, we have a USAspending.gov website that tracks general government spending. The problem is that if the information available through those websites is not accurate and there's no way to verify its accuracy, it diminishes the value of that.

Now, the open government directive knew about this problem and addressed it by having a component that said we have to find ways to improve data quality. This is an ongoing struggle, and one that I would draw to your attention as Canada thinks more about open government initiatives.

There's a last point I would make in terms of a challenge, and that is having the right building blocks for making disclosure really work well. For example, where I was just talking about spending disclosure, what we would ideally want to do in today's Internet age is to be able to mash up disparate data sets so we can bring data from one kind of database, such as regulatory compliance, say, in with spending data.

One ideal would be to know whether government contractors are complying with laws and regulations of the land. Well, to do that, you need to have a key identifier that links data sets. In this country, we do not have, and we haven't employed government-wide, the right kinds of identifiers to make that kind of linkage.

That's what I call a building block. Until you address those fundamental issues—and they're not glamorous issues, by any means, they're very thorny—we will always face difficulties in the transparency arena.

My last comment is to make four points of suggestion as you think about moving forward in Canada on open government issues. I think many of the points I've made should certainly be utilized. I think the Obama administration is an excellent model for moving forward, notwithstanding any criticisms I may have. I think it's a wonderful model. As I said, it was a remarkable achievement within two years.

My first point would be that I think one of the elements that worked extremely well is the collaboration between the government agencies and the non-governmental and private companies as we've moved forward on this openness initiative. That collaboration has bred greater trust. It has created new and innovative approaches, and it has taught us more about the concerns and difficulties that agencies may face in going forward.

The second thing I would say is important to think about going forward is tools for the public to hold the government accountable. Having key benchmarks or measures or metrics are essential to know whether progress is made. It's essential to break down the broad agenda of transparency into discrete sizes so that the public can judge whether or not you have made progress.

The third point I would make in terms of suggestions is to allow for evolution of what you mean by open government and transparency. It's always going to be an evolving tool. As we have better technology, as we have better policies, as we have newer ideas, the notion of what can be done will always change. I think your policies and the structures underlying those policies need to be permissive of an evolving process.

The final point I would make is that I think one of the more successful elements of the Obama administration's effort has been having a leadership that has a dedicated and demonstrated concern for openness. It comes from the President himself. It comes from the White House staff that I was mentioning, the team. It comes from the interagency working group. Demonstrating this leadership is not simply symbolic; it is very real in moving the agenda forward.

With that, I'll stop. I know I've thrown out a number of things. I apologize for throwing so many things out so quickly.

Thank you.

3:50 p.m.

Liberal

The Chair Liberal Shawn Murphy

Thank you, Mr. Bass.

That was extremely helpful.

We're going to go now to the first round. We're going to hear from Mr. Wayne Easter. He's a member of the official opposition, the Liberal Party of Canada.

Mr. Easter, you have seven minutes.

3:50 p.m.

Liberal

Wayne Easter Liberal Malpeque, PE

Thank you, Mr. Chairman.

Thank you, Mr. Bass, for the overview and the papers you've provided as well. It's extremely helpful.

In regard to your last point first, if you're going to go anywhere in open government, you need leadership that is dedicated to openness. We're going to have a tough time getting started here, from where we currently sit.

In any event, these are two different systems of government. You have the White House and the various agencies, the Senate and the Congress. Ours is a parliamentary democracy, a different kind of structure, really, to a great extent. I imagine you understand both. Do you see any difficulties from that perspective in terms of us going to open government here?

3:50 p.m.

Executive Director, OMB Watch

Gary Bass

I think the differences are significant, and in some respects, at a broadest level, no, I don't think there's much difference. That is, to set aside a general thrust and a general belief that the public has a right to know should exist in any form of government, whether in a parliamentary or a bicameral system, as we have.

In specific issues, yes, there are quite large differences--for example, on spending transparency. In the United States, we have a system where the President proposes a budget and then Congress has to dispose of that. So the disclosure system allows for much greater participation by the public in the budget process. It's not simply a transparency issue; it's also a participation issue, to strengthen the democratic process.

In a parliamentary system, that isn't quite a parallel structure, so you would want to probably think through, in a parliamentary structure, where are the opportunities for participation, but also simply where transparency can be useful for an accountability point of view.

One of the ideals in a parliamentary structure as well as in the United States' structure would be if we could tie together the spending data with performance data. Then we could begin starting to talk about not just simply who got how much money but whether or not the money is used wisely. It would be an opportunity to talk about how to make government better. That transforms across all different forms of government structures, I think.

3:50 p.m.

Liberal

Wayne Easter Liberal Malpeque, PE

Thank you. You've kind of indicated, or I thought you did, that under the Recovery Act spending there were some problems with that disclosure. I've looked at that, and from where I sat I thought it was quite informative.

So in terms of information that I could access, I thought it was good. You're saying there's a problem with it. Where are the problems that you see, in terms of the Recovery Act spending that's been posted?

3:50 p.m.

Executive Director, OMB Watch

Gary Bass

I think that's actually a great question. I think what I should do is explain that I'm a huge fan of what we have. It's called, nonetheless, a RAT board. It's a bad acronym, but that's the Recovery Accountability and Transparency Board. I think they've done a great job, and I think Recovery.gov has really been a game changer in how transparency works in this country.

The criticism I have is much more about the implementation phases of that. For example, what I think is a paradigm shift in this country is that through the Recovery Act, for the first time ever, we had the recipients of federal awards report online in a timely fashion around what money they received and what they were doing with it. Under the Recovery Act, the key issue is about jobs. Another key issue involved certain equity issues. So those kinds of data were reported on a quarterly basis for the first time ever from the recipients, and on top of that, if the state received the money and sub-awarded the money to someone else, the sub-recipient had to report. This is a huge change.

The weakness, and our concern, is that it stopped there. The ultimate recipient of the dollar did not have to report. It was only the first two tiers. In addition, there is no check on the data quality. There is only a quick look at whether or not the entity reported and whether or not the numbers looked bad. What we should be doing is tying that data with what the cheques are that the treasury cuts, so that we have an accountable structure.

I'm now at the level of really detailed implementation of what the Recovery.gov site has done, but I think it is a great effort. It is enormously important for long-term agendas in this country I think, and it's also becoming a model in many others right now, at least European countries.

I should add, by the way, just one quick aside. I also had the good fortune, if you will, way back in the days of yore, 2006, of working with then Senator Obama and Senator Coburn to create legislation that required a searchable website of all government spending, which I mentioned is called USAspending.gov. This was, if you will, on our political axis, left and right. I didn't think we could get the legislation done, so we built a website called FedSpending.org that approximated what the bill would have done, and it became a huge success—huge. And in fact the government ended up simply just taking our website and using it as the vehicle for moving forward.

So I'm a huge fan of what the recovery board has done.

3:55 p.m.

Liberal

Wayne Easter Liberal Malpeque, PE

Thank you.

Do I still have some time, Chair?

3:55 p.m.

Liberal

The Chair Liberal Shawn Murphy

You have 50 seconds.

3:55 p.m.

Liberal

Wayne Easter Liberal Malpeque, PE

I have just a quick question. You had talked earlier about the right identifiers that link data, I think you said. What do you mean by that, and how do you suggest it be done? In order to get the information, you have to be talking the same language.

3:55 p.m.

Executive Director, OMB Watch

Gary Bass

It's a complex issue that will quickly devolve into having technology experts supercede all of us in this room and your room.

But let me highlight one of the problems. If we don't have corporate ownership identifiers, we will never know whether the ACME company in database 1 is the same ACME company in database 2. We have to find the tool that ties those together so we know what are the linkages to the same data sets.

Similarly, if we think broader than just in terms of corporate identifier, in many cases, on regulatory kinds of databases, the key compliance issue may not be a company name but may be a geography issue. It may be other kinds of identifiers.

We're all sort of living the Web 1.0 world right now, and social media has moved us into Web 2.0. There is also a lot of discussion of a Web 3.0, which is called the semantic web. That's the place where you get these mashups of data. But that's where you're going to have to have these multiple intersections, and we're going to have to rely on technology experts to help us do that.

To the second part of what you were suggesting, you also implied a very important point about data standards. For example, there are standards like XML, extensible markup language. There is also one for financial called XBRL, for business kinds of relations. These data standards are the essential tools for managing data and distributing data so that we're not in the old school notion of everyone having to replicate a database one by one, but rather having one database and having web services call into that database.

I don't know if that answers your question.

3:55 p.m.

Liberal

The Chair Liberal Shawn Murphy

Thank you very much, Mr. Easter.

The next member of the committee, Mr. Bass, is Madame Carole Freeman. Canada, as you know, has two official languages, and those questions will be posed in French. But I understand you have the English feed there, so you'll be okay.

Mrs. Freeman, you have seven minutes.

4 p.m.

Bloc

Carole Freeman Bloc Châteauguay—Saint-Constant, QC

Good afternoon, Mr. Bass. Thank you for your presentation; I found it most interesting.

You listed the three major aspects: policy and leadership; technology and information; and the culture of transparency. Here, the indication is that we have neither leadership nor policy and, unfortunately, it seems that we have not yet developed a culture of transparency.

You also talked about the problems you had to deal with in terms of the Access to Information Act. As I understand the situation in your country, you are on the verge of having access to data online. That is where you are heading. But when you cannot get information online through the normal channels, you have to make use of your Access to Information Act. But there seems to be a major backlog with it. That being the case, how are you handling the problem? Your managers get performance incentives when they do their jobs well; but, when you don't get information, you realize that there are shortcomings with your Access to Information Act. How can you come to terms with that problem? I see a kind of contradiction.

You say that each agency determines the information it will disclose. Who in the agencies makes that decision?

You also talk about the quality of the data. Could you tell me more about the problems with that?

According to what you are telling us, public participation is key. You have entrepreneurs, private companies, non-governmental organizations like yours, the government, and the public. I would like to know how the American public communicates with the agencies to make the system better.

Those are some questions. I could ask more, but I only have seven minutes.

4 p.m.

Executive Director, OMB Watch

Gary Bass

And they're all outstanding questions, every one of them.

I want to be clear about the backlog issue, to start with. When I was mentioning backlogs, I was really referring to backlogs that exist under the Freedom of Information Act, which is the core backbone for public access in the United States. In some respects, this is an outmoded model whereby the citizen has to file a request to the government, and the government, through appropriate legal channels, determines whether it meets the law's standard for disclosure of the record.

Those requests coming from the public have accelerated over the years, and as a result there is a huge backlog. The agencies were given a mandate by the President to reduce those backlogs by 10% by this year. We will see in another month, based on data coming out, whether the agencies have achieved it. That's what I was referring to by way of backlogs.

But I think your point is still a good one, which is that there is a tendency for government.... If agencies are told to disclose, the natural proclivity is to throw the doors wide open on everything. As a result, having so much may mean that you have nothing, because you can't get through it all; it's just an overwhelming amount of information. The real trick is to get to what I would call high-priority information; that is, the information that key stakeholders of the public as well as Congress—the whole range of stakeholders—have an interest in knowing about.

This is where some of the new social media tools and new technology may prove useful for the interactive process of involving the public and other stakeholders, in helping to determine what the key pieces of information are that agencies should be disclosing voluntarily, without this kind of formal freedom of information request.

The Obama administration tried to move in this direction with something called Data.gov. It has been an extremely useful tool, but it hasn't quite gotten us to that level, because agencies are throwing all kinds of data onto Data.gov. Some of the weaknesses relate to your question about data quality. On Data.gov, it is not unusual, if I open up a file, to have no headers across the row. Think about an Excel spreadsheet without any headers; all you have is numbers. It won't tell you how to use the file. You don't know what the column letters are and you don't get a data dictionary.

If you don't have the metadata and the metadata is sloppy, then the data itself is not all that useful to the public. That's one kind of data quality issue.

The other kind is what I was talking about, cases in which the data itself is just flat out wrong; it just needs to be improved.

Then there's a third kind: missing data. On the Recovery.gov website that I was mentioning, for “place of performance”—where the money was actually spent—sometimes people put in a post office box. That's no place of performance. So there's that kind of data quality.

The last thing I want to mention to you, which is a very exciting prospect that this administration is exploring, is using something called ExpertNet. It's a way of allowing interaction by the public with various experts within the agencies around specific subjects. This is a brand new enterprise that was just proposed by the administration, and they just finished about two weeks ago taking public comments on the structure of this kind of ExpertNet.

That may be a new way. In truth, we are experimenting with ways of engaging in democracy now. We're going to have some failures along the way here.

4:05 p.m.

Liberal

The Chair Liberal Shawn Murphy

Thank you, Mrs. Freeman.

4:05 p.m.

Bloc

Carole Freeman Bloc Châteauguay—Saint-Constant, QC

That's it? I had so many other questions.

Thank you very much, Mr. Bass.

4:05 p.m.

Liberal

The Chair Liberal Shawn Murphy

The next member of the committee is Mr. Bill Siksay, a member of the New Democratic Party.

Mr. Siksay, you have seven minutes.

4:05 p.m.

NDP

Bill Siksay NDP Burnaby—Douglas, BC

Thank you, Dr. Bass.

This has been very helpful, both the information in your brief ahead of time but also what you have presented today.

I want to ask you a little bit about the structure in the Obama administration for driving this. We know that the President gave his strong endorsement of this process. You have mentioned a number of places, both the team in the White House...but I think you also talked about an interagency team. In your brief, you also mentioned the creation of a chief technology office and a chief information officer as well.

Can you tell us a bit about what sort of seniority those people have, how the function is structured, and what their responsibilities are?

4:05 p.m.

Executive Director, OMB Watch

Gary Bass

It's the first time in this country that we have a chief technology officer, CTO, who is Aneesh Chopra. That has made a huge difference, not only again in terms of symbols, but because the President wanted a chief technology officer, it sent a signal all the way through the agencies that this is an important player. So the CTO is part of that White House team, and that person sits in the executive office of the President, sits in the Office of Science and Technology Policy, which is one of the units within the executive office of the President. So they come with a technology and science background, and they're perceived in that vein to be a helpful tool to what are called chief information officers in the agencies. Each agency has a chief information officer.

In addition to that role, the Office of Management and Budget, which is an other office within the executive office of the President, has always had a chief information officer. What the President did was to have that continue but also make that person the chief information officer throughout government. So all those chief information officers within the agencies I mentioned now work through and with...the person is Vivek Kundra.

The combination of having Mr. Kundra and Mr. Chopra has really been a breath of fresh air, if you will, to the agencies. Suddenly all these worker bees in the agencies who felt there was no leadership either on the technology side or on the information policy side have a friend in the White House actively working on this. So again, this was much more than a symbol; this was very real.

The two of them also do not necessarily just control the White House team. If it were so, it would be just a technology-driven enterprise, but instead they've been met with the head of the Office of Information and Regulatory Affairs, who is Cass Sunstein. He sits also within the Office of Management and Budget and does policy work along with.... The President designated—coincidental with your committee's title—the ethics czar, who was the one who also had transparency responsibilities because of the concerns around special interest influence.

So the White House had a policy team to combine with this technology team. That also sent a very big signal to the agencies.

4:10 p.m.

NDP

Bill Siksay NDP Burnaby—Douglas, BC

Thank you for that overview.

There are so many things we want to ask you about. You also mentioned that there was a reward system put in place through the Office of Management and Budget. Can you just expand on what you told us before and tell us a little bit more about that and the intent and what the rewards look like, that kind of thing?

4:10 p.m.

Executive Director, OMB Watch

Gary Bass

The open government directive that I mentioned had multiple parts. One was to try to change the culture of openness in government. One of the items that was expressly identified was to ask the associate director for the Office of Management and Budget, who is Jeffrey Zients, to do a memo to all the executive agencies to identify a reward system. It actually was a financial reward system. Each agency was to nominate various players within its agency for transparency efforts. It is under way now. We haven't actually had this yet. I think it was one of the rare times in government that civil servants were being asked to do something and then told they would get a reward if they did it well.

4:10 p.m.

NDP

Bill Siksay NDP Burnaby—Douglas, BC

Just one other thing that I wanted to ask you to expand on a bit was the absence of performance reviews for public servants who work in this area. Can you just expand on your thoughts there and how that's an ongoing problem?

4:10 p.m.

Executive Director, OMB Watch

Gary Bass

I'm not an expert on personnel management or how to alter the assessment process. It strikes me in general that if something is a national priority, one would expect that your civil service staff is evaluated somewhat on that criterion. Instead the current system is a disincentive structure. That is, if you put something out and it turns out to be inappropriate, you only get penalized. If you put something out and it's really good, you don't get a pat on the back; you get ignored.

So it would strike me that you want to have some kind of structure in terms of pay scales and performance reviews that are also incentives, not just an award system.