How are problem-gambling prevention policies actually implemented at the street-level? Although policies may appear clear on paper, frontline workers must constantly consider how to apply them in unpredictable, real-world settings. This article further explores these dynamics, specifically examining how policies related to problem gambling prevention were implemented in Turin, Italy, under the 2021 “Time is Money” project. In addition, this article also analyzes how frontline workers develop “policy capacity”, or competencies and skills needed to implement these policies on the ground. To guide this investigation, the authors ask the following questions: How do operators use their margin of discretion to redesign policy during implementation? Does this process imply the development of individual analytical policy capacities at the street level?
Theoretical Expectations
The authors outline the following expectations in their study:
- Street-level bureaucrats (SLBs) prioritize understanding policy problems through direct experience and real-time problem-solving.
- Policy capacities matter in environments wherein frontline workers have high discretion levels and must constantly redesign rules/policies.
Methodology
To gather relevant data, the authors use a three-phase qualitative, longitudinal case-study design in Turin, Italy. First, scientific publications, literature and related documents were reviewed to improve understanding of gambling policies at the local, national, and international levels. Second, the authors conducted semi-structured interviews with key informants involved in the “Time is Money” project to learn more about the creation and implementation of the project. Third, an ethnographic approach was pursued, involving participant observation in at least three gambling venues over the course of four months, to observe the interactions between the operators (SLBs) and gamblers.
Key Findings
An Intensive Process of Policy Divergence and Re-Design
During their time spent observing policy implementation, the authors noticed a series of transformations in the policy. What was written on paper was not exactly how things were going in practice. This phenomenon known as “policy divergence” was highlighting something more: a process of so-called “re-design”. In other words, frontline workers were adapting the “original” policy to concrete, unexpected problems. To do so, they were using their experience and expertise. With small adjustments, trial and error, and reflective effort, the implementers applied small (but important) changes to the policy, trying to achieve a better fit to the goals. The article discusses in detail some of these adaptive strategies (i.e.: hooking, bargaining, termination, conversation) that helped implementers establish relations of shared trust with gamblers, aimed at risk-prevention and damage-control.
The Development of a Distinct Kind of Analytical Capacity at the Street-Level
Observing the process of re-design, the authors noticed that the adaptive strategies didn’t come to be during the early stages of implementation, but later on. At first, frontline workers tried going by the book, but over time they introduced small changes as they gained more experience. The authors interpreted this as evidence of distinct kinds of capacity being developed. Previous studies have shown that designing “on paper” an effective policy requires analytical capacities (the skills to understand a problem and picking the best solution). This article suggests that similar processes occur during frontline implementation. Like policy design, policy “re-design” requires a specific set of skills. Although they take different forms, these frontline skills serve the same purpose: identifying effective solutions to real-world problems. The article illustrates how these capacities develop in practice: workers identify problems and reflect on possible responses, test creative solutions, and evaluate feedback on what works.
Why It Matters
These findings have a series of practical implications for policymaking. First, the article shows that policy divergences do not necessarily indicate inappropriate design, nor excessive discretion among frontline workers. On the contrary, for policies addressing complex social problems (like problem-gambling), divergence is a space for creative problem-solving and an opportunity for learning. Second, leveraging these opportunities requires specific capacities. While the article shows how such skills can be developed autonomously, this process requires an amount of time and effort that is not always granted in every public program. More research is needed on how these capacities can be taught, shared, and transferred. Third, the findings broaden our understanding of the skills and competencies required by policymakers (policy capacities). Some of these capacities (like the analytical ones) can manifest in different, unexpected forms and places. Regardless of where, when, and how they emerge, such capacities appear to complement each other in supporting policy success.
Read the original article in Policy Studies Journal:
Aimo, Niccolò and Federico Cuomo. 2025. “Building Street-level Capacity. Evidence From a Policy For Problem Gambling Prevention.” Policy Studies Journal 53(4): 1045–1064. https://doi.org/10.1111/psj.70005.
About the Article’s Author(s)
Niccolò Aimo acquired a Ph.D. in Urban and Regional Development at the Polytechnic University of Turin following his master’s degree in Political Science at the University of Turin. He is a senior researcher in policy analysis and evaluation for IRES Piemonte and has conducted research abroad at the University of Lisbon (ULisboa). His research focuses on various aspects of sub-national policymaking, with a particular emphasis on the local implementation of European-funded programs, social policies, gambling regulation, sustainability, and workfare.
Federico Cuomo obtained a Ph.D. in Innovation for the circular economy at the University of Turin after graduating in Political Science. At the same time, he worked within the European Funds and Innovation Office of the City of Turin. He carried out research stays at the University of Amsterdam (UvA), the Centre for Social Sciences in Budapest, the Universidad Autonoma de Madrid (UaM) and the University of Antwerp (UAntwerp). His research interests range from the analysis of urban experimentations and collaborative governance arrangements to the evaluation of environmental and healthcare policies. Currently, he is a postdoctoral researcher in policy analysis at the University of Turin and IRES Piemonte.
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