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

20/01/2026

I draw on Nissim Cohen’s work on street-level entrepreneurship to argue that frontline workers make policy every day, and that our system relies on their judgement while doing little to authorise or support it.

Once a month, Te Rā Whakamana takes up a single question that is less simple than it looks: why do so many policies that look brilliant on paper fail so badly in practice? The series sits between two worlds that too rarely speak to each other, the world of public policy analysis and advice, where ministers receive briefing notes and Cabinet makes decisions, and the world of implementation, where frontline workers have to make those decisions work for real people in real communities. Each post draws on international scholarship while staying close to the particular challenges and institutional arrangements of Aotearoa, and explores a different dimension of the persistent gap between intention and reality, between the tidy plans of the centre and the messy truths of delivery. Today I look at the importance of the so-called “frontline” through Nissim Cohen’s work on street-level entrepreneurship, and try to move past 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 that I think this is a fantasy that does not survive even casual observation of how government 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 are all creating policy as well as implementing it, through thousands of daily micro-decisions that together define what government does and what it means.

Drawing on Nissim Cohen’s work on street-level entrepreneurship, today’s post asks us to set aside the rhetoric and pretence of central control and take the agency of the frontline seriously, as a resource to be cultivated through institutional support, professional development, and active engagement between the centre and the periphery, rather than as a problem to be managed through tighter control.

In Cohen’s (2024) account of street-level entrepreneurship, some of the most important policies in Aotearoa are made by the person behind the counter: 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 active, creative and often subversive “policy entrepreneurs” who bend, break and remake rules to solve the problems in front of them, and for the most part they are a long way from passive cogs in a machine dutifully carrying out their superiors’ decisions.

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

The term street-level bureaucrat comes from Lipsky, who used it to describe frontline public servants (the police officers, social workers, teachers and benefit administrators) who deal directly with citizens and exercise significant discretion in their work. His 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 get them through the day, though these often bear little resemblance to the official policies they are supposed to implement.

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

These “policy entrepreneurs” were usually 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 that street-level bureaucrats are entrepreneurs too, though of a different kind. Faced every day with policies that do not work, rules that make no sense, and systems that fail the people they are meant to serve, they do more than cope passively: they actively innovate.

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

In this account frontline workers shape and create policy from the bottom up as well as implementing it. Their entrepreneurial actions can 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.

At the core of Cohen’s argument is a call to stop seeing the frontline and street-level bureaucrats as mere implementers and to recognise them as a powerful, distributed source of innovation and policy change. The daily choices they make (which cases to deal with first, which rules to follow strictly and which to interpret flexibly, which clients to spend extra time with and which to process quickly) are political and entrepreneurial acts as much as administrative ones, and together they define what public policy is in practice.

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

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

I think it sells these stories short to treat them as charming anecdotes about pragmatism, because 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 are also evidence of the gap between policy-as-written and policy-as-experienced, and of the important part frontline discretion plays in bridging it. Without this constant, invisible work of translation and adaptation, our public services would, in my view, grind to a halt.

Yet our system treats 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, and my evidence for this is how little investment is made in research, evaluation and learning. We certainly do not authorise it or give frontline workers explicit permission to experiment and innovate. Instead, we celebrate the outcomes when they succeed while implicitly condemning the rule-bending that was necessary to achieve them.

This leaves our best frontline innovators in a precarious position, operating in the shadows, using their own judgement 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 put compliance ahead of outcomes. They become skilled at working the gap between what the rules say and what works in practice, yet they receive no recognition or support for this important 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, and teachers who pioneered new approaches to remote learning that were later adopted system-wide. Central government did not plan these innovations and ministers did not mandate them; they emerged from the creative problem-solving of frontline workers who saw what was needed and found ways to make it happen.

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 departure from official procedures was potentially problematic, even when it was clearly producing better results, and the system found it hard to distinguish harmful rule-breaking from beneficial innovation, falling back on a risk-averse approach that stifled creativity and learning.

If we accept Cohen’s argument that street-level bureaucrats are de facto policy entrepreneurs, we have 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. Cohen’s work shows, however, that a significant amount of real-world policy is made by unelected, often invisible, frontline officials on the basis of their personal judgement, professional ethics and local knowledge, and 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 supervision and standardised procedures. As Cohen and others have shown, this approach is both impossible and counterproductive. It is impossible because no set of rules can anticipate every situation that frontline workers will encounter, and it is counterproductive because it prevents the kind of adaptive, responsive service delivery that citizens need and that makes government effective.

The alternative is to find ways to 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 while also making sure that innovations are shared, evaluated and scaled appropriately, and it means treating the creative agency of the frontline as a resource to be cultivated rather than a problem to be managed.

This brings us back to the central theme of this series, the need for a robust “interpretive hinge” that can connect the world of policy advice with the reality of implementation. Street-level entrepreneurs are the living embodiment of that hinge, the people who must, every 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 back into the system, though often through informal channels that policymakers cannot see.

Understanding their world, their dilemmas and their creative acts is, in my view, the core of the policy advisor’s craft rather than an optional extra. 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: 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 as active partners in the policy process who often know more about what works than they do, and not as passive recipients of their “wisdom”.

Next month I will go deeper into the theoretical foundation that allows us to understand their world and take their stories seriously, exploring 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 F. Sager, C. Mavrot, & L. R. Keiser (Eds.), Handbook of public policy implementation (pp. 148–155). Edward Elgar.

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