What Good Policies Does:
In November 2019, I wrote an article here introducing Good Policies which covered our planned activities, why we focus on advocacy and non-communicable diseases (NCDs), and why we believe policy change has the potential to be a leading cause area due to its potentially high cost-effectiveness. As we have made rapid progress in the months since I wanted to follow up on our initial article with updates to our previously planned activities and an updated request for funding. In this article, you’ll get an overview of what Good Policies does, our current thoughts on the direction of the organisation over the next few months, a recap on why this intervention was chosen and our rationale for planned activities.
First, a short reminder of who we are and what we do. We are a small NGO that started in the first cohort of the Charity Entrepreneurship program and are focused on policy-based interventions in low and middle-income countries that have the potential to beat the current top GiveWell recommended charities on a cost per DALY basis. We are starting off our work with a focus on tobacco tax policy in Armenia and Mongolia, specifically aiming to fill a gap we identified in the current field of nonprofits by focusing our work on collaborating with Ministries of Finance and other similar actors (ex. Ministry of Economy, Economic Parliamentary working groups, World Bank, etc.) rather than the standard for the space which is to focus on working with health-related actors like the Ministry of Health and WHO which is mostly covered by large NGOs such as Campaign for Tobacco-Free Kids, Vital Strategies, The Union, and other regional players. For more details on our initial rationale for starting this charity, please refer to our initial blog post (or just ask us in the comments).
As a note, we also want to mention that part of our intention for starting this NGO is to build up policy expertise (and government connections) that can be applied to different fields ranging from alcohol control to AI Safety. From our discussion with stakeholders in a variety of fields ranging from scientists to government officials, we found that tobacco control was broadly a non-controversial field and seemed to be an excellent entry point into policy as it provided a clear wedge to open doors with a relatively straightforward intervention that is well understood by the global health community, unlike x-risks and some of the more niche areas of EA. This should allow us to build expertise and credibility in policy and with governments while still working on a highly cost-effective intervention. For other policies outside of tobacco taxation today, we plan to opportunistically jump on policy window openings (eg. alcohol taxation) when identified and ideally if we see them in a context where we have already made connections and have local credibility to leverage.
Updates Since November 2019:
We think that we have made significant progress in improving our position to influence tobacco tax policy. Our work so far has mostly involved developing relationships with various ministries and civil society organizations to better understand the barriers to increasing tobacco taxes and provide an avenue for changing legislation. We have decided to focus on engaging with fiscal policy actors rather than public health actors (who generally already support this policy) unlike many organisations in the tobacco control community. This is partly because we are probably more focused on a narrow set of policy asks unlike many organisations with slightly more diverse aims. Our main update is adding a second arm to our pilot by working in Armenia as well as Mongolia. We think that this will be beneficial not only from a total impact perspective but also developing our understanding of how we have an impact. We also hope that this will provide a clearer narrative for funders. There is a more detailed explanation of these decisions below.
Focus on Fiscal Policy & Advocacy
We have always been focused on creating a nonprofit that embodied the EA mentality and values and this approach has helped guide many of our decisions, especially regarding intervention choice (being well documented as cost-effective and relatively neglected outside the top 10 largest smoking countries). When looking at the potential for impact, we also looked deeper at the intervention possibilities. While the standard in tobacco taxation NGO work is to focus on the health aspects of the intervention and its benefits, this has left the actual key stakeholders (in most countries the Ministry of Finance and parliamentarians concerned with financial matters) in the dark because of the assumption that they would back taxes based purely on the health benefits and because many of the NGOs in the space were formed or highly influenced by health workers and public health professionals rather than economists or financial professionals.
By focusing on economic issues, we are helping to fill a major gap that only a few NGOs are working in (such as Tobacconomics and the tobacco tax FCTC Hub in South Africa) and that is especially neglected in smaller economies across the world. This is due to a few factors, including the inherent complexity in doing robust economic modelling in a specific country which the average local NGO can’t undertake. This modelling is necessary to demonstrate the effects of tobacco taxes, ranging from approximate government revenue increases to the estimated decrease in the number of smokers. Other factors may be that because of the status of tobacco companies, which in developing economies usually are a major player with money to spend, the local economic think tanks (of which there are usually very few in smaller and poorer countries) are likely to either work for the tobacco companies or to have worked for them in the past, making it hard for local NGOs to hire them to do any economic work. Also, we are targeting the main stakeholders of tax law, the Ministry of Finance and finance-related officials within government who have heard many of the health arguments for tobacco taxes, but not the economic arguments and whose mandate is not focused on the health of the citizenry, but the health of the entire economic system and who generally have a much more “business-friendly” mentality and are wary of taxes that might hurt tobacco companies and other major taxpayers or lead to decreased economic investments. By tailoring arguments towards them and assuaging their fears about causing increases in inflation, job losses, tax losses, etc., we can bring onboard the key stakeholders who are necessary to change tax law.
In December 2019, I went on a scoping trip to Mongolia to meet the National Cancer Council of Mongolia and other civil society organisations. We were able to engage with a broad range of civil society organizations who were supportive of our mission. We believe that it is important to show that our policy asks have broad public support rather than just being aligned with the interest of a niche group. Several groups have agreed to partner with us on our campaign, to help us develop our policy asks and advocacy materials, and champion our policy recommendations. Some groups also had useful connections to key ministries and political parties which our campaign can leverage to make progress more quickly than going through more conventional channels. Generally, we found that civil society organizations were aware that tobacco use is a problem within Mongolia but most were surprised by the scale of the problem. Most groups were supportive of tobacco control policies and were receptive to the idea of increasing taxes on tobacco products.
In the run-up to the parliamentary election in June 2020, we are focused on trying to establish champions within the main political parties in Mongolia. If elected, these champions will be able to support our policy recommendations for parliament and the MoF and push through our proposed strategy on tobacco taxes. We are currently in conversation with a sub-committee in the Mongolia People’s Party (one of the two main political parties) and are hoping that they will put tobacco control within the manifesto that their political campaign runs on. This would show a commitment from the elected parliament to work on tobacco control over the next four years. We are working on establishing connections to the other major political party as well as non-partisan parliamentary groups with compatible agendas to ours.
We are currently hiring staff in-country to help us in coordinating and recruiting campaign partners. I am also planning on going to Mongolia during Q1 of this year to facilitate various meetings including a workshop with a network of young journalists who have shown an interest in publishing material on the tobacco industry or the tobacco problem in Mongolia to increase public knowledge on tobacco control issues within Mongolia. The tobacco control community has been very supportive of our work so far and we are currently exploring partnering with the Campaign For Tobacco-Free Kids (CTFK) and the Tobacco Tax FCTC Hub at the University of Cape Town. We think that by engaging with established players we can make fewer strategic mistakes by drawing upon their experience but also improve our platform for sharing what we have learnt with the wider tobacco control community.
This is one of our larger changes. We think that a multi-pronged intervention that covers several countries at once would be the best strategy, to begin with as it allows us to compare our approach in two different areas and will likely be the closest thing we can get to an RCT given the intervention type. To expand our capabilities to tackle two countries at once, Joel Burke, another member of the first Charity Entrepreneurship cohort who was also researching tobacco taxation as an intervention has joined as a co-founder. Joel has taken the lead on operations in Armenia and has a similar agenda to explore increasing tobacco taxes in Armenia.
In early Nov (2019), Joel went on a research trip to Armenia, a country that has a small total population of ~3m, but where more than 50% of men are smokers leading to an exceedingly high burden of disease on the population from tobacco-related illnesses (~30% of male deaths are from tobacco-related disease according to Tobacco Atlas). Based on the criteria previously set for country selection (there are several, but key criteria include rule of law, current tax rate, the likelihood of a policy window appearing, % burden of disease from tobacco), Armenia ranked as one of the top choices. To further assess this, he met with stakeholders from the MoH, WHO, MoF, and others in the government and private sector to assess the potential for tax increases in tobacco. Based on these initial conversations and other factors, such as the election of a new highly progressive government and the current consideration of a strong tobacco control bill that covers most everything other than tax, Joel decided to focus on Armenia.
We have received strong support for our plans, especially from the MoH, WHO, CTFK, and other traditional health-focused organizations. The Ministry of Finance is more sceptical about tobacco taxes in general but historically they have shown a willingness to raise tobacco and other ‘sin’ or ‘health’ taxes and likely will need to do so again to cover an upcoming budget shortfall.
As we have now pinned down our planned activities, received feedback from local and international stakeholders, and laid the groundwork for 2020, we are switching our focus to fundraising. We aim to be highly cost-effective, but to have an opportunity to create meaningful policy change in Armenia and Mongolia, we need the resources to advocate for our agenda ranging from local support to conducting high-quality economic research that can be provided to our stakeholders and more. We are currently raising a total of $200,000 for activities for the year 2020 that covers all of what we expect to need, including a contingency fund. This is our ideal funding scenario, at the low end we believe we can make do with $100,000, but this will lead to a much lower likelihood of passing new tobacco tax policies in either country during a reasonable time horizon and given the winner take all quality of this intervention, we believe it is better to be slightly over-resourced rather than under-resourced.
We are excited to continue exploring what we believe to be a promising opportunity to improve health outcomes for millions of people. We think that working in Mongolia and Armenia will strengthen our potential for impact not only on each project but on future projects. We are by no means the only organisation working on tobacco control, but we think that we may offer a competitive giving opportunity due to our focus on neglected countries. We believe that we have also differentiated ourselves from some of the more established actors in the tobacco control community by focusing on fiscal policy and building networks that are particularly suited to tobacco tax asks. We are looking to fundraise for our work over 2020, and it is unlikely that without funding we will be able to continue the work that we have been doing. We really appreciate the advice and leads on fundraising within and outside of the EA community. We are looking to raise $200,000 for the next 12 months of work but in a low funding scenario, we think that we could cover essentials with around $100,000.
On a personal note, I would also like to take this opportunity to thank Charity Entrepreneurship and our mentors/advisors from the EA community who have spent time talking through challenges with us and have generally supported us whilst working on this project. If you have any feedback for us or would like to support is in some way you can contact me at firstname.lastname@example.org.