It is clear is that the new system of RPI was not put in place as part of a comprehensive system for measuring regulatory performance. Rather, they were one element in a loosely coordinated set of changes introduced over a period of several years from the later 1990s. The other major changes were: a requirement for annual regulatory plans (the OSB 2003), an improved and somewhat better resourced RIS system (Productivity Commission 1998: 27-8) and the PBS noted above (Department of Finance and Administration 1999). The danger in such a situation is that the information provided by RPI might be considered in isolation from other performance indicators, thereby reducing their value to senior decision-makers, rather than being an important part of an integrated set of indicators enabling more systematic assessments and appropriate, timely, remedial action in relation to regulatory performance. The probability of this occurring was increased with the decision to divide responsibility for the various reform elements among several departments and agencies. Annual regulatory plans were to be developed by departments although, initially, these would be coordinated by the OSB. The annual PBS to be developed by departments, would include appropriate indicators to be reported on in their annual reports. The strengthened RIS was to remain with the ORR. Overall responsibility for the RPI was given to the Office of Small Business, although responsibility for collecting, monitoring and assessing relevant data was split between the ORR (with regard to RPIs 1, 2, 3, 8) and the OSB (RPIs 4, 5, 6, 7, 9), with the ORR providing relevant data to the OSB for collation into an annual report on the RPIs (DITR 2006: 3).

The decision to allocate responsibility for PBS outputs, outcomes and indicators to the departments could hardly have been otherwise, given the extent of the planning task involved and the need for a detailed knowledge of the relevant regulation. However, the decision to split responsibility for RPI between the OSB and the ORR was questionable. On the one hand the ORR was collecting relevant performance data as part of its established RIS process, so it would be inefficient for that to be replicated by the OSB. On the other hand, splitting responsibility for parts of the process increased coordination costs and, possibly, would introduce a degree of friction between the two agencies involved. However, given that the development of RPIs had commenced within the context of small business policy and pressures from small business, it might have been felt that it was politically appropriate to vest at least partial carriage of responsibility for the reform of regulatory systems with the Department of Industry — the department with responsibility for small business policy at the federal level. It is instructive to note that, following a further review of business regulation in 2006, responsibility for RPI was moved from the OSB to a reorganised and renamed ORR, in the shape of the Office of Best Practice Regulation.