A/HRC/38/33 protection, the position of IMF on universal access to and targeting of social programmes and collaboration with other institutions. The strategic framework would also provide guidance on effective programme design, covering both the General Resources Account Arrangements and concessional lending. The latter would draw on a June 2017 IMF policy paper, 72 a guidance note to be issued in the first half of 2018 and the 2018 Review of Conditionality and the Design of IMF-Supported Programmes. 32. The report of the Independent Evaluation Office and the response of the Executive Board drew mixed reactions from external stakeholders. Some special procedure mandate holders, as well as a group of 53 economists, academics and development experts, were strongly critical.73 IMF has committed to consult with civil society on the development of its new social protection strategy, but that process has to date been relatively opaque74 and formalistic, reflecting the culture of control at IMF and the relatively few civil society organizations that focus on scrutinizing its activities. 33. The report of the Independent Evaluation Office, along with its annexes and background papers, is nonetheless very helpful and informative. Its main shortcomings are its acknowledged failure to address two key issues: (a) the impact of IMF interventions on the welfare of vulnerable groups; and (b) whether social protection has increased or decreased as a result of IMF-supported programmes.75 By way of justification, the Office claimed that the first would have required a much larger study and the second was not feasible due to “conceptual and attribution problems”. And IMF officials with whom the Special Rapporteur spoke argued strongly that there were too many variables at play for that analysis to be done meaningfully. However, comprehensively avoiding such central issues calls into question the certainty with which IMF makes various policy prescriptions. Some attempt to evaluate impact is essential if it is to be seen to be acting responsibly and in an evidence-based manner.76 Defining social protection 34. The report of the Independent Evaluation Office defines social protection as a variety of policy instruments providing cash or in-kind benefits to vulnerable individuals or households, including: (a) social insurance (such as public pension schemes); (b) social assistance (such as government transfers to the poor); and (c) labour market interventions for the unemployed (such as unemployment insurance and active labour market policies). The report also addresses food and energy subsidies, but not broader development or poverty reduction policies, such as education and health policy.77 Its annex lists different definitions of social protection used by IMF and other organizations. 78 Work currently under way to identify a uniform definition for the purposes of IMF is essential since the Special Rapporteur’s interviews confirmed considerable uncertainty and disagreement within IMF about what social protection means. 35. The most important issue is the overall philosophy underpinning social protection. The main debate in defining social protection has been between a “social safety net” approach and a human rights or “social citizenship” approach.79 The definition of a social 72 73 74 75 76 77 78 79 IMF, “Social Safeguards and Program Design in PRGT and PSI-Supported Programs”, Policy Paper (June 2017). See www.ohchr.org/Documents/Issues/Development/IEDebt/Open_Letter_IMF_21Dec2017.pdf; www.networkideas.org/news-analysis/2017/12/53-economists-write-to-imf-directors-on-approach-tosocial-protection/; and www.brettonwoodsproject.org/2017/09/ieo-finds-imf-follows-nebulousstandard-social-protection-engagement/. In strong contrast to the World Bank’s lengthy consultations over the updating of its social safeguard policies in 2016. IMF, The IMF and Social Protection, pp. 23–24. On the importance of evaluation, see M. Ravallion, “The World Bank: Why it is Still Needed and Why it Still Disappoints”, in Journal of Economic Perspectives, vol. 30, No. 1, Winter 2017, pp. 82– 84. IMF, The IMF and Social Protection, p. 4. Ibid, annex 1. See report of the Special Rapporteur on extreme poverty and human rights (A/69/297), para. 21. 11