The National Rural Employment Guarantee Act, providing wage employment security in the poorest districts of the nation, is about to enter its implementation phase. Throughout the last few months, various arms of government - the Central ministries of Rural Development and Panchayati Raj, the corresponding state-level ministries, the National Advisory Council, and the Administrative Reforms Commission have all considered various details of the implementation, and their many views and recommendations will probably be reconciled as the program rolls out.

There is little doubt that the Act is of great significance, committing the government to an enormous spending program, as well as assuring the minimum welfare of tens of millions of households. But will the Act work as envisaged, or will this effort too be derailed by the poor implementation that followed so many other plans? The risk of derailment is very real; our governments at various levels are not geared to manage the tremendous complexity of the Act - Hundreds of millions of beneficiaries, and funds flow between three levels of government, at a minimum. Moreover, with the passage of the Right to Information Act as well, it has now become imperative that the NREGA be implemented in a manner that is consistent with the demands of the RTIA. This requires information management through technology on a scale that is completely new to administration in the country.

The complexities and novelties can be bridged only if the implementation is managed or overseen by an agency that has both the authority and the responsibility for the program - the current shape of government is too distributed to possibly account for the functioning of the NREGA. A National-level autonomous body should be created solely for implementing the NREGA.

The NREG Agency

The body, called, say the NREG Agency, should be fully empowered with financial and implementing authority. This will finesse the problem of coordinating between so many Government agencies and Departments. Officers deputed to this agency should have a five year term. Such officers should be deployed and transferred by the head of this body in consultation with a Governing Board, and not by the Government. Selection to the Agency should be the sole prerogative of the Agency. Such officers selected cannot be recalled by their parent departments until their tenure is over. However the Agency can choose to return any of its officers back to the parent department.

Selection to the Agency should be the sole prerogative of the Agency. Such officers selected cannot be recalled by their parent departments until their tenure is over.

 •  Gearing up for entitlements
 •  The 200 districts chosen

The Governing Council should consist of both Government and non Government representatives. Non government representatives should not include retired bureaucrats. This has already caused a lot of problems in the RTI, as seen with the appointment of Information Commissioners from retired government servants. The Government should fully fund this Agency, and appoint the Chairperson and the Board at inception. Later, the Board itself should be empowered to appoint new members as older members retire. The Board should have the sole authority and responsibility to select the MD or CEO. The logic behind this approach is that implementation has several challenges that are best left to an autonomous Agency dedicated to it, and that managerial roles for different arms of government alone are simply unlikely to overcome these challenges.

In addition to creating such an Agency, we need a complete strategy for social mobilization. Ideally, this should be in the form of labour associations at the Panchayat level, with scope for Federations at the Block or even District levels. This mobilization should not be conducted either by the Government or the Agency, but by civil society, people's movements and organizations, and by NGOs. None of these should be funded by the Government. It is not in the long term interests of the Government to organize the poor that might question the Agency or the Government itself. Similarly, NGOs or any other civil society organization will have to compromise themselves if they are funded by the Government. However, such a process of social mobilization should be formally recognised by the Governing Board of the Agency and the board could even include elected representatives of the labour associations.

The structure and roles proposed here are an adaptation of the model used for the National Dairy Development Board (an autonomous agency) which turned India from a milk deficit nation to the world's largest producer of milk. This was achieved not by line departments of the Government. The resistance to the employment guarantee will likely come from local large farmers and wage employers. There will be resistance or apathy from the bureaucracy and from some of the politicians aligned to land-owning interests. To counter these, we need social mobilisation independent of the proposed Agency, which is a creature of the Government.

Around the country, activists, academics, development professionals and others are likely to keep a keen watch on the early stages of NREGS implementation. But while our alertness can point to problems in the implementation, without an over-arching agency responsible for correcting the problems, it will remain unclear who in government is to respond to - or even gather - each concern. The national government should recognise the many pitfalls that lie ahead, and act now to ensure that the optimism behind the new legislation does not become buried in a mountain of government-as-usual.