Te Rā Whakamana: The Person Behind the Counter is Also Making Policy

20/01/2026

Once a month, Te Rā Whakamana examines a single, deceptively simple question: why do so many policies that look brilliant on paper fail so spectacularly in practice? This series bridges two worlds that too rarely speak to each other: the world of public policy analysis and advice, where ministers receive briefing notes and the Cabinet makes decisions, and the world of implementation, where frontline workers must somehow make those decisions work for real people in real communities. Drawing on international scholarship whilst remaining grounded in the particular challenges and institutional arrangements in Aotearoa, each post explores a different dimension of this persistent gap between intention and reality, between the tidy plans of the centre and the messy truths of delivery. Today, we explore the critical importance of the so-called “frontline” using Nissim Cohen’s work on street-level entrepreneurship. We move beyond the rhetoric.

We comfort ourselves with the constitutional fiction that policy is made by elected ministers, implemented by public servants, and delivered by frontline workers who dutifully follow the rules. If you have been reading this substack for a while, you will know I think that is a fantasy that doesn’t survive even casual observation of how government actually works.

The person behind the counter at Work and Income who decides whether to interpret a rule strictly or flexibly, the nurse who decides which patient to see first when the waiting room is full, the teacher who decides which student needs extra attention, and the engineer who judges that a particular stretch of road requires more than the minimum standard specifies: these public servants are not just implementing policy, they are actively creating it through thousands of daily micro-decisions that collectively define what government does and what it means.

Drawing on Nissim Cohen’s work on street-level entrepreneurship, today’s post invites us to abandon the rhetoric and pretence of central control and finally take the agency of the frontline seriously, not as a problem to be managed through tighter oversight, but as a resource to be cultivated through institutional support, professional development, and genuine active engagement between the centre and the periphery.

Nissim Cohen’s (2024) work on street-level entrepreneurship argues that the person behind the counter makes some of the most important policies in Aotearoa: the case manager at Work and Income, the nurse in the emergency department, the teacher in the classroom and the engineer on-site. These frontline workers are not passive cogs in a machine, dutifully implementing their superiors’ decisions. They are active, creative, and often subversive “policy entrepreneurs” who bend, break, and remake rules to solve the problems at hand.

The intellectual foundation for this argument lies in the work of scholars who have looked beyond formal government structures to understand how policy actually works in practice. Our guide for this exploration is Nissim Cohen, a scholar who builds on Michael Lipsky’s (1980) classic work but takes it in a new direction.

Lipsky first gave us the term street-level bureaucrat to describe the frontline public servants: the police officers, social workers, teachers, and benefit administrators, who interact directly with citizens and exercise significant discretion in their work. Lipsky’s insight was that these workers face impossible demands: overwhelming caseloads, ambiguous rules, inadequate resources, and conflicting expectations from politicians, managers, clients, and the public. To cope with these pressures, they develop informal routines and shortcuts that allow them to get through the day, but which often bear little resemblance to the official policies they are supposed to implement.

Cohen (2024) takes this foundational concept a step further by applying the lens of policy entrepreneurship. Traditionally, policy entrepreneurship was seen as the work of senior leaders, politicians, or well-connected advocates who championed new ideas and pushed them onto the political agenda. It is an idea that comes in and out of vogue in Aotearoa every few years.

These “policy entrepreneurs” were typically understood as operating at the top of the system, using their position, resources, and networks to create windows of opportunity for policy change. Cohen argues, however, that street-level bureaucrats are also entrepreneurs, but of a different kind. Faced with the daily reality of policies that do not work, rules that make no sense, and systems that fail the people they are meant to serve, they do not just passively cope; they actively innovate.

They identify problems that are invisible to policymakers, devise novel solutions that work in their specific contexts, and often build informal networks to spread these new practices to their colleagues. They experiment with different approaches, learn from what works and what does not, and gradually develop new ways of doing things that are more effective than the official procedures.

In short, they do not just implement policy; they actively shape and create it from the bottom up. Their entrepreneurial actions can either support the goals of central decision-makers by finding better ways to deliver services, or they can subvert those goals by creating routines that run counter to the stated intent of the policy.

Cohen’s core argument is that we must move beyond seeing the frontline and street-level bureaucrats as mere implementers and recognise them as a powerful, distributed source of innovation and policy change. The daily choices they make: which cases to prioritise, which rules to follow strictly and which to interpret flexibly, which clients to spend extra time with and which to process quickly, are not just administrative acts; they are political and entrepreneurial acts that define what public policy actually is in practice.

This theory perfectly describes the number 8 wire ingenuity we as a nation so often celebrate, but systematically ignore when it comes to understanding how our public sector actually works.

Every public servant has stories of frontline workers who found clever workarounds to help people in need. The Work and Income case manager who discovered an obscure provision that allowed a struggling family to access emergency assistance. The hospital social worker who developed an informal network of community organisations to provide wraparound support for patients being discharged without family support. The teacher who developed a new approach to engaging disruptive students, later adopted by the whole school. The roading crew who know what mix of asphalt works for a particular stretch of highway. The immigration officer who found a way to expedite applications for refugees facing urgent circumstances. The social worker who uses a GoFundMe so that no child she comes across goes without nappies.

These are not just charming anecdotes about pragmatism; they are practical acts of street-level policy entrepreneurship. They represent the creative adaptation of formal rules to achieve better outcomes for the people the system is meant to serve. They also evidence the gap between policy-as-written and policy-as-experienced, and the crucial role frontline discretion plays in bridging it. Without this constant, invisible work of translation and adaptation, our public services would grind to a halt.

Yet the challenge for our system is treating this vital activity as if it were informal, unofficial, and slightly illicit. We rely on it to function, but we do not legitimise it. A small number of agencies create formal channels for sharing and scaling these frontline innovations across the system. But we do not invest the time, training, and support needed for it to flourish. My evidence for this: look how little investment is made in research, evaluation, and learning. We certainly do not authorise it or give frontline workers the explicit permission to experiment and innovate. Instead, we celebrate the outcomes when they succeed, but we implicitly condemn the rule-bending that was necessary to achieve them.

This leaves our best frontline innovators in a precarious position. They are forced to operate in the shadows, using their own judgment and taking personal risks to do what they believe is right for their clients. They develop informal networks and workarounds that run parallel to the official system but are vulnerable to being shut down by managers who prioritise compliance over outcomes. They become skilled at navigating the gap between what the rules say and what actually works, but they receive no recognition or support for this crucial skill.

Consider the recent experience of the COVID-19 response, where some of the most effective innovations came from the frontline. Public health nurses who developed new ways to reach vulnerable communities. Social workers who created virtual support networks for isolated clients. Teachers who pioneered new approaches to remote learning that were later adopted system-wide. These innovations were not planned by central government or mandated by ministers; they emerged from the creative problem-solving of frontline workers who saw what was needed and found ways to make it happen.

But the system’s response to these innovations was telling. Some were celebrated and scaled up, but many others were ignored or actively discouraged. The default assumption was that any deviation from official procedures was potentially problematic, even when it was clearly producing better results. The system struggled to distinguish between harmful rule-breaking and beneficial innovation, defaulting to a risk-averse approach that stifled creativity and learning.

If we accept Cohen’s argument that street-level bureaucrats are de facto policy entrepreneurs, it forces us to confront a profound accountability problem that goes to the heart of our democratic system. We elect ministers and governments to set policy direction, and we hold them accountable for the results. But Cohen’s work shows that a significant amount of real-world policy is being made by unelected, often invisible, frontline officials on the basis of their personal judgment, professional ethics, and local knowledge. This creates a direct and uncomfortable tension between the principle of democratic control and the reality of professional autonomy.

The traditional response to this tension has been to try to eliminate discretion through more detailed rules, tighter oversight, and standardised procedures. But this approach, as Cohen and others have shown, is both impossible and counterproductive. It is impossible because no set of rules can anticipate every situation that frontline workers will encounter. It is counterproductive because it prevents the kind of adaptive, responsive service delivery that citizens actually need and that makes government effective.

The alternative is to find ways to harness and channel street-level entrepreneurship in directions that support democratic goals and public values. This requires a fundamental shift in how we think about accountability: from compliance with rules to learning for outcomes. It means creating space for experimentation and learning activities, while also ensuring that innovations are shared, evaluated, and scaled appropriately. It means recognising that the creative agency of the frontline is not a problem to be managed, but a resource to be cultivated.

This brings us back to the central theme of this series: the need for robust “interpretive hinges” that can connect the world of policy advice with the reality of implementation. Street-level entrepreneurs are the living, breathing embodiment of these hinges. They are the people who must, every single day, negotiate the gap between the tidy rules of the centre and the messy reality of the front line. They translate abstract policies into concrete actions and feed information on what works and what does not into the system, though often through informal channels invisible to policymakers.

Understanding their world, their dilemmas, and their creative acts is therefore not an optional extra for a policy advisor; it is the absolute core of the craft. To give advice that has any chance of working, a good policy advisor understands the world of the person who will ultimately have to enact it. That means understanding the constraints they face, the resources they have available, and the informal networks and workarounds they rely on. Most importantly, a good policy advisor recognises their front line not as passive recipients of their “wisdom”, but as active partners in the policy process who often know more about what works than they do.

Next month, we will go deeper into the theoretical foundation that allows us to understand their world and take their stories seriously. We will explore the interpretive tradition itself and why it poses such a fundamental challenge to how we typically think about evidence, knowledge, and truth in the public sector.

References

Cohen, N. (2024). Moving beyond traditional policy implementation: Street-level bureaucrats’ policy entrepreneurship. In S. Jann & F. Wegrich (Eds.), Handbook of public policy implementation (pp. 201-218). Edward Elgar Publishing.

Lipsky, M. (1980). Street-level bureaucracy: Dilemmas of the individual in public services. Russell Sage Foundation.