Building Street-Level Capacity: Evidence From a Policy for Problem Gambling Prevention

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:

  1. Street-level bureaucrats (SLBs) prioritize understanding policy problems through direct experience and real-time problem-solving.
  2. 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.

How Street-Level Dilemmas and Politics Shape Divergence: The Accountability Regimes Framework

by Eva Thomann, James Maxia, & Jörn Ege

Conventional thought holds that policies are passed down from policymakers to street-level bureaucrats (i.e., police officers, public school teachers, social workers, etc.) who implement these policies as instructed. However, both anecdotal and empirical data reveal that these street-level bureaucrats can diverge from the formal rules of policies at their discretion. This policy divergence suggests that street-level bureaucrats can become informal policymakers because of their pivotal role in policy implementation. In our paper, we investigate this policy divergence and explore how informal accountability relations influence street-level bureaucrats.

Using the Accountability Regime Framework (ARF), we identify four mechanisms, which can influence the behavior of street-level bureaucrats: political-administrative, professional, participatory/societal, and market. We also suggest the inclusion of a new accountability regime in the ARF: political-ideological. These five accountability relations aim to describe the pressures street-level bureaucrats experience from the formal rules of policies, the norms of their professions, their role in society, their role as economic actors, and their political/ideological beliefs, respectively.

When two or more of these accountability relations create competing demands on a street-level bureaucrat, we call this an accountability dilemma. We argue that actors who experience accountability dilemmas are more likely to diverge from the formal rules of a policy. We also expect divergence to be more likely among actors who prioritize accountability relations inconsistent with the formal rules. We offer the following hypotheses:

Hypothesis 1a: Street-level bureaucrats with political attitudes that contradict with the policy (ideological distance) are likely to articulate a rule-political dilemma.

Hypothesis 1b: Street-level bureaucrats with political attitudes that contradict with the policy are likely to articulate a rule-political dilemma, but only if they also strongly refer to political-ideological pressure.

Hypothesis 2: Stronger reference to an accountability pressure other than rule pressure makes it more likely that the street-level bureaucrat experiences a dilemma of rule pressure with the respective action prescriptions.

Hypothesis 3: The stronger or more numerous the dilemmas expressed by the street-level bureaucrat, the more likely they are to diverge from the policy.

To test our hypotheses, we analyze a case of the UK’s “Prevent Duty” counterterrorism policy. This policy instructs university lecturers to identify and report students they suspect are becoming radicalized. The ambiguity of Prevent Duty’s instructions, its political saliency, and the high degree of discretion that university lecturers enjoy suggest that this case will be useful for our purposes. 

For our analysis, we surveyed social science lecturers in British universities. The survey included measured feelings of accountability and the likelihood of compliance with Prevent Duty. We also conducted qualitative follow-up interviews with lecturers who had experience implementing Prevent Duty. 

In line with H1a, we found that lecturers whose political views contrasted with Prevent Duty were more likely to identify a perceived rule-political dilemma. However, contrary to H1b, the importance one placed on political-ideological accountability did not seem to affect the likelihood of perceiving a rule-political dilemma. In other words, contrasting political beliefs seemed to interfere with the implementation of Prevent Day even among lecturers who separated their work from their political beliefs. 

We also found that the higher priority lecturers placed on an accountability regime, the more likely they were to experience an accountability dilemma, except for market accountability. Perhaps most importantly, we found that stronger accountability dilemmas were associated with higher levels of policy divergence. 

Our findings extend the ARF to include a new accountability regime, political-ideological, which we believe to be an important addition to understanding street-level bureaucrats as “political animals.” We also successfully show that informal accountability relations play an important role in policy implementation. 

You can read the original article in Policy Studies Journal at

Thomann, Eva, James Maxia and Jörn Ege. 2023. “How street-level dilemmas and politics shape divergence: The accountability regimes framework.” Policy Studies Journal 51 (4): 793–816. https://doi.org/10.1111/psj.12504.

About the Authors

Eva Thomann is a full professor of Public Administration at the Department of Politics and Public Administration at the University of Konstanz. She holds a master’s degree in Political Science from the University of Zurich and a Ph.D. in Public Administration from the University of Bern. She specializes in Public Policy and Public Administration; her research focuses on the patterns, reasons, and consequences of how policies are put into practice.

James Maxia is working in the private sector in London, UK. He graduated from the University of Oxford with an MPhil in Comparative Government after completing his undergraduate studies at the University of Exeter. He is interested in studying voting behavior, political violence, and public policy implementation.

Jörn Ege is a permanent lecturer in “Local & Regional Governance” at the ZHAW School of Management and Law in Winterthur, Switzerland. He studies administrative arrangements and their consequences for the governance of societal problems in international(ized), regional, and local contexts.

Find him online:
Website: https://www.zhaw.ch/en/about-us/person/egej/
X: https://twitter.com/EgeJorn
LinkedIn: https://www.linkedin.com/in/jorn-ege/