+++ NGOs and Accountability in China PDF

NGOs and
Accountability
in China
Child Welfare Organisations
Jude Howell, Xiaoyuan Shang, and

Karen R. Fisher
NGOs and Accountability in China
Jude Howell · Xiaoyuan Shang
Karen R. Fisher
NGOs and
Accountability
in China
Child Welfare Organisations
Jude Howell Karen R. Fisher
Department of International Social Policy Research Centre
Development University of New South Wales
London School of Economics Sydney, NSW, Australia
and Political Science
London, UK
Xiaoyuan Shang
Social Policy Research Centre
University of New South Wales
Sydney, NSW, Australia
ISBN 978-3-319-90220-3 ISBN 978-3-319-90221-0 (eBook)

https://doi.org/10.1007/978-3-319-90221-0
Library of Congress Control Number: 2018939754
© The Editor(s) (if applicable) and The Author(s), under exclusive license to Springer
International Publishing AG, part of Springer Nature 2019
This work is subject to copyright. All rights are solely and exclusively licensed by the
Publisher, whether the whole or part of the material is concerned, specifically the rights
of translation, reprinting, reuse of illustrations, recitation, broadcasting, reproduction
on microfilms or in any other physical way, and transmission or information storage and
retrieval, electronic adaptation, computer software, or by similar or dissimilar methodology
now known or hereafter developed.
The use of general descriptive names, registered names, trademarks, service marks, etc. in this
publication does not imply, even in the absence of a specific statement, that such names are
exempt from the relevant protective laws and regulations and therefore free for general use.
The publisher, the authors and the editors are safe to assume that the advice and
information in this book are believed to be true and accurate at the date of publication.
Neither the publisher nor the authors or the editors give a warranty, express or implied,
with respect to the material contained herein or for any errors or omissions that may have
been made. The publisher remains neutral with regard to jurisdictional claims in published
maps and institutional affiliations.
Cover image: © Photography by Bobi

Cover design by Emma J Hardy
Printed on acid-free paper
This Palgrave Macmillan imprint is published by the registered company Springer

International Publishing AG part of Springer Nature
The registered company address is: Gewerbestrasse 11, 6330 Cham, Switzerland
Preface and Acknowledgements
This book is the latest result of over three decades of research on

Chinese child welfare, civil society, and NGOs. We were inspired in this
journey by the seminal research and writing of Professor Gordon White
of the Institute of Development Studies, Sussex University, who sadly
passed away in 1998. We worked closely with Professor White through
our Ph.D. research and later joint research projects. His enthusiasm for
China was contagious, as was his passion for social justice. This guided
him in his approach to research and the issues he chose to investigate.
He pioneered the way in research on social welfare and civil society,
informed always by an astute sense of the importance of politics. The
spirit of his work has continued to influence our own research.
Our research on China’s children and child welfare systems work
started with the situation of abandoned children in state child welfare
institutions in China, and expanded to cover other orphaned children,
children with disabilities, children who experienced abuse, and now any
children in disadvantaged situations. Our focus has turned to the actions
of Service-providers in China and how to improve the effectiveness of
the system to provide quality welfare services to all children in disadvan-
taged situations. In China’s current child welfare system, which is mov-
ing towards a mixed welfare system, non-governmental organisations
(NGOs), both international and domestic, play increasingly important
roles.
Our work on NGOs traces its roots back to the pioneering project
on civil society in China led by Professor White. Since then we have
v
vi Preface and Acknowledgements
traced the development of civil society through its many shifts and turns,
exploring in-depth child welfare NGOs, women’s organisations, labour
groups, and health NGOs. Through these empirical investigations we
have observed the changing Party/state approaches to NGOs and the
development of a welfarist incorporation strategy towards civil society.
This seeks to harness the instrumental benefits of NGOs in the transition
to a mixed welfare system, whilst containing rights-based groups and
advocacy organisations that the Party/state deems threatening.
In this book, we examine the making of accountability and legiti-
macy in China’s child welfare organisations. Most of these NGOs went
through a difficult journey to achieve their goals. During the research,
we not only observed their efforts to build their accountability and legit-
imacy but we also witnessed their development over the years. As they
moved towards a mature organisation, they overcome many unexpected
difficulties, struggling to become registered, obtaining a legal status, and
facing financial and technical pressures, social discrimination and exclu-
sion. They needed the support from people in all walks of life to sur-
vive. During the process, their accountability proved to be their most
important capital, on which they built the foundation for their sustaina-
ble development, connecting them with their donors and services users.
As a result, many of the successful non-government child welfare service
organisations paid particular attention to building their accountability
and legitimacy. It seemed to be an explanation for their survival and con-
tinued development in the highly marketised and politically authoritarian
environment of today’s China.
This project would not have been possible without the support of
many people. First and foremost, we acknowledge the funding provided
by the Australian Research Council, which provided us with a three year
grant to conduct the fieldwork, process the data and analyse our find-
ings. We wholeheartedly express our thanks to Wei Wei, the national
director of the Right To Play at the time of the research, for all the
organisation’s financial and research support to the project. Both the
University of New South Wales, Australia and Beijing Normal University,
China played a pivotal role in aspects of research management. We are
also grateful to the London School of Economics, UK, for its role in
research management as part of the linked arrangement between the uni-
versities.
Preface and Acknowledgements vii
Any research project relies always on a team of dedicated researchers.

Here we thank in particular, Zhang Wen, Wang Fang, Chen Lining,
Wang Qingfen for their support in the field-work, and Zhao Yi, Lin
Su, Yu Jie, Cui Yawen, Li Jing, Zhu Zhaonan, Wang Xiafei, Fang Qian,
Zhong Ling, Ryan Gleeson, and Max Alston for their contribution to
the research. We appreciate very much the incisive and constructive com-
ments by anonymous, international peer reviewers. Their suggestions
were invaluable in shaping the final manuscript. We also thank Alina
Yurova of Palgrave Macmillan for her enthusiasm and support in the
writing of the book and Mary Fata for her careful work in steering the
manuscript through to final production.
London, UK Jude Howell

Sydney, Australia Xiaoyuan Shang
Sydney, Australia Karen R. Fisher
Contents
1 Introduction 1
Clearing the Conceptual Path 5
Aims and Research Questions 9
Why China? 15
Why Child Welfare Groups? 19
Methods 22
Structure of Book 26
References 29
2 Setting the Theoretical Scene 33

What Is Accountability? 34
Accountability and NGOs 39
Accountability and User Participation 42
Accountability in Authoritarian Regimes 43
Accountability in China 45
Accountability and Institutional Change 49
Framework of Analysis of Accountability 52
References 62
3 Welfare Reforms, Child Welfare NGOs,

and Accountability 69
Welfare Reforms 70
Background on Development of NGOs in China 74
ix
x Contents
Challenges of Accountability for NGOs in China 83

Child Welfare NGOs 85
Children’s Services Characteristics 86
Legal Status 87
Accountability of Registered Child Welfare Organisations 89
References 91
4 Making Accountability—Liming Family 95

Liming Family: Origins, Purpose, and Activities 96
Operating in the Interstices of Legality 99
Struggle for Legitimate Registration 101
Seeking Government Funds for Shared Responsibilities 105
Extracting Benefits to Secure Children’s Rights 106
Reputation and Trust as Accountability Capital 110
Organisational Accountability 111
Financial Accountability 112
Professional Accountability 115
Conclusion 117
References 119
5 Accountability and User Participation—The Case

of Angel House 121
Background 123
Accountability Through Building Capacity
and Professionalism 132
Leading Role of Professionals 132
Staff Training and Support 134
Open Rehabilitation and Parents’ Education 134
Accountability to Funders 136
Using Mass Media as Surrogate Accountability 136
Accountability to Users 137
Conclusion 138
References 140
Contents xi
6 Changing Accountabilities—Children’s
Hope Foundation 141
Background to Children’s Hope Foundation 142
Dual Accountability 146
New Actors and New Accountability Arrangements 147
Accumulating a Stock of Accountability Capital on the
Path to Separation and Independence 152
Auditing 155
Financial Accountability to the General Public 156
Professional Accountability 157
User Accountability 158
Conclusion 160
References 162
7 Accountability of a Mixed Child Welfare Organisation 163

Background to the Mixed Welfare Institution 164
Children in the Institution 165
International Co-operation 167
Development of Resource Centres Targeted at Communities 169
Accountability to Government 170
Financial Accountability to International Partners 176
Managerial Accountability to Staff 178
Accountability to Children and the Community 180
Conclusion 183
References 185
8 Conclusion 187
Key Findings 190
Accumulating Stocks of Accountability Capital 190
Hierarchies of Accountability 192
Politics of Building Accountability and Legitimacy 193
Institutional Change 198
Making Accountability but Far from Perfect 200
Theoretical Contribution 202
xii Contents
Policy Implications 206

Future Research 209
References 211
Appendix 213
Glossary 217
Index 219
List of Figures
Fig. 7.1 Children in the Mixed Welfare Institution 1985–2009 166

Fig. 7.2 Children adopted from the Mixed Welfare
Institution 2000–2009 167
Fig. 7.3 Annual income generated by the welfare institution
(Source Annual work reports of Mixed Municipal Welfare
Institution 2001–2009) 175
xiii
List of Tables
Table 1.1 Characteristics of child welfare organisations 24

Table 2.1 Legitimacy and accountability of NGOs 58
Table 5.1 Annual income and expenditure of Angel House
(2006–2014) (′000 RMB) 129
Table 7.1 Children in the Mixed Welfare Institution 1985–2009 166
Table 7.2 Children adopted from the Mixed Welfare Institution
2000–2009 167
xv
CHAPTER 1
Introduction
From the sunny spring day that the Wang’s son was born in Tianjin,
the whole family started searching for treatment for his developmental
disabilities. A few years later, they were exhausted financially and psy-
chologically. Looking at his despairing son and patient grandson, the
grandfather reflected: “I finally realized that, if my disabled grandson was
to live as a person, there must be an adult who does not live as one too”,
because they must devote all their time to care for him. Instead of giv-
ing up, he established the Qizhi Child Rehabilitation and Care Home
with the support of Tianjin Disabled Persons’ Federation in a rundown,
small shed, to provide services to children with developmental disabilities
and their families. Six years later, as he lay dying, the grandfather held
his son’s hand and unable to speak, used the other hand to point to his
grandson. His son agreed, “I’ll do it, I’ll take care of the children at the
care home for the rest of my life”.
Non-governmental organisations (NGOs) often start from citizens’
initiatives such as the example of the grandfather in Tianjin, even in
authoritarian states like China. These citizens experience or observe gaps
in state provision and sometimes are driven to remedy them by setting
up NGOs. It is often argued that authoritarian regimes provide public
welfare services as a means to enhance their legitimacy in the eyes of cit-
izens and maintain their rule (Cassani 2017; Dukalskis and Gerschewski
2017; Huang 2015; Gandhi 2008; Bueno de Mesquita et al. 2003, pp.
29–30; Wintrobe 1998). In capitalist authoritarian regimes, the state is
not the sole provider of welfare services; rather there is a mixed welfare
© The Author(s) 2019 1

J. Howell et al., NGOs and Accountability in China,
https://doi.org/10.1007/978-3-319-90221-0_1
2 J. HOWELL ET AL.
system where the private sector and non-governmental sector play a com-
plementary role. In authoritarian contexts where there are tight restric-
tions over civil society groups, service-delivery NGOs are subject to strict
controls and monitoring which can hamper their approach to service
delivery, the scale of services provided and their organisational develop-
ment. For authoritarian regimes, there is the perennial risk that service-
delivery NGOs serve as fronts for political opposition groups and that
their very existence could stimulate the development of more politically
oriented civil society groups demanding rights and political change. Such
regimes often look with suspicion upon service-delivery NGOs that adopt
a rights-based approach to their work and that seek to influence govern-
ment policy. Added to this, authoritarian governments fear that external
agents working on behalf of foreign powers seek to bring about regime
change through their support to civil society groups. These perceptions
of regime threat can limit the potential role of NGOs in delivering wel-
fare services and shaping the direction of welfare policy, not least by fos-
tering a restrictive regulatory, political and social environment for NGOs.
Post-socialist authoritarian states, such as China, Vietnam, and the
former Soviet Republics face particular challenges in reforming their wel-
fare systems. Under the political economy of planning, markets were vir-
tually eliminated and civil society groups were sharply curtailed. Though
some welfare-oriented civil society organisations may have been incor-
porated into the planning system, they were limited in number, served
mainly as intermediary conduits between generic groups of citizens and
the Party, and had minimal room for innovation. Following the collapse
of state-planned socialist systems and their respective welfare structures
in the early and late 1980s, reforming post-socialist states have moved
towards mixed welfare systems for the financing and delivery of welfare
services. However, they do not preside over a pre-existing supply of pri-
vate and non-governmental service providers that could be harnessed in
welfare reform. These have to be grown by creating incentives, building
their capacity, and developing an enabling regulatory environment of rel-
evant laws, policies, and regulations, and fostering public confidence in
their work. Whilst laws, policies, and regulations may endow alternative
welfare providers with legal legitimacy, the provision of adequate, qual-
ity welfare services entails much more than this. Competencies, respon-
siveness to user needs, professionalism, efficient management, effective
governance, and financial and moral probity are vital ingredients for an
adequate, quality mixed welfare system. Ensuring that welfare service
1 INTRODUCTION 3
providers have these crucial components hinges on putting in place

effective institutions of accountability that can facilitate their broader
legitimacy as legal, professional, and responsive providers of services.
Accountability and legitimacy thus go hand in hand.
However, in authoritarian regimes, ensuring accountability of gov-
ernment officials, bureaucrats, and welfare services providers, whether
state, private, or non-governmental, becomes much more difficult than
in liberal democratic mixed welfare systems. This is especially so in post-
socialist ones, where a robust legal system, an independent civil society,
media, independent watchdogs, independent courts are constrained and
weakly developed, These governments are moving towards mixed welfare
systems where NGOs play a role. They can put in place legal processes
of accountability such as registration and licencing, but NGOs too have
to invest in creating institutions of accountability. This is not just to sat-
isfy government requirements for accountability but also to gain public
trust and confidence in their operations, without which it would be hard
to attract funds and clients. The process of ‘making accountability’ is
an essential part of building their legitimacy, which in turn can facilitate
their scaling-up and organisational development. This involves navigat-
ing relations with an often fragmented state serviced by suspicious local
state officials and riven by the contending goals and interests of different
departments. It also entails changing the sometimes negative public per-
ceptions of non-governmental service-delivery providers.
The politics of how service-delivery NGOs in post-socialist states craft
accountability and legitimacy is thus the central theme of this book. We
explore this through the case of post-socialist, authoritarian China which
has been gradually reforming its welfare provision towards a mixed sys-
tem involving non-governmental providers and the private sector. A key
dilemma facing the Chinese government was that the regulating environ-
ment for NGOs was overly restrictive, resulting in very few NGOs actually
registering as social organisations. If the government sought to subcon-
tract services to NGOs and expand the supply of non-governmental ser-
vice providers, then NGOs needed to be legal entities registered with the
Ministry of Civil Affairs (MOCA) as social organisations. In the light of
this from 2008 onwards the Hu Jintao and Wen Jiabao administration
(2002–2012) (hereafter referred to as the Hu-Wen administration), ini-
tiated experimental pilots in several cities and provinces. Local authorities
were given permission to experiment with the relaxation of registra-
tion requirements for NGOs to facilitate the growth in the number of
4 J. HOWELL ET AL.
service-delivery NGOs eligible to bid for governmental welfare services

contracts. The subsequent Xi Jinping administration (2012 onwards)
(hereafter referred to as the Xi administration), built on these initiatives
and within a year of assuming office had rolled out the subcontracting of
welfare services to NGOs across the country. These regulations have since
been accompanied by a raft of directives, orders, and local regulations
aimed, amongst other things, at ensuring the accountability of NGOs,
their professionalism, effectiveness, competency, and financial probity,
thereby bolstering their legitimacy as providers of services in the eyes of
local government officials and the public.
However, NGOs do not gain legitimacy in the eyes of the public
overnight or merely by registering with MOCA, or by grafting on for-
mal accountability systems. Although registration sets in train various
accountability processes, these alone cannot guarantee public confidence
in the competence, probity, and effectiveness of NGOs. Accountability
and legitimacy have to be earned, particularly for NGOs that start life
as unknown quantities. Given that most NGOs were not able to register
and gain legal status, not least because of the reluctance of government
departments to act as sponsors as required by the regulations, it was even
more crucial that NGOs developed other forms of legitimacy as well.
Though some NGOs registered as companies in order to have some legal
status and a bank account, technically they were always at risk of being
closed down on the grounds of not being genuine companies that exist
to make a profit. Registering as a company was a second-best option next
to gaining full legal status as a social organisation through registration.
Not being registered at all left an NGO constantly vulnerable to harass-
ment and to potential closure.
Nevertheless, many NGOs have been able to develop their work pro-
viding services and pursuing rights issues despite not being registered.
The reasons for this are complex and clearly in an authoritarian state,
pursuing a rights agenda is much more sensitive than providing services.
For some local government officials, the kind of services provided by
NGOs is seen as filling gaps, providing services that they do not have
the funds to do, or would not be able to do for reasons of outreach or
legal constraints. Furthermore, NGOs working at the grassroots level are
a useful source of information for local government officials about citi-
zens’ preferences and views. Insofar as NGOs appear to be harmless and
providing useful services to disadvantaged groups and communities, local
government officials often tolerate their activities, and in some cases,
even openly recognise their achievements through awards and taking
1 INTRODUCTION 5
government delegations to visit their services. This tolerance is not just

a reflection of rational local government officials recognising the benefits
of NGO-provided services, but also encapsulates considerable ‘accounta-
bility work’ carried out by NGOs to achieve public and government rec-
ognition and enhance their legitimacy. In this way, they not only protect
themselves against governmental harassment but also strengthen their
possibilities for legal registration with the MOCA. This may have posi-
tioned well some NGOs to apply for welfare services contracts that were
later rolled out during the Xi administration.
As post-socialist governments move towards mixed welfare systems
involving a plurality of funders and service providers, state-run wel-
fare institutions, too, have become pressured to raise extra funds from
non-governmental sources. This has pushed them to seek additional
funding from fee-raising activities, raising funds from international
organisations and the general public and engaging with a wider range
of actors, including NGOs, community groups, and international agen-
cies. Whilst state-run service providers already enjoyed legal status and
were endowed with much stronger legitimacy than unregistered NGOs,
they also became subject to different accountability demands as they plu-
ralised their sources of support. State-run welfare institutions, too, are
having to learn the craft of ‘second-order’ accountability-making aimed
at other funders and service users. Compared to NGOs, however, they
start from a more privileged position as legally sanctioned institutions.
Nevertheless, they face particular systemic and organisational constraints
that make them less adept at becoming mixed welfare institutions.
But what is accountability and what kind of accountability do NGOs
build? Here we have first to clear the conceptual path.
Clearing the Conceptual Path

As a first step, we need to clarify the key questions that analysing
accountability demands, whether in relation to governments, NGOs, or
companies. These are:
(1) Who can demand accountability?

(2) From whom is accountability demanded?
(3) For what is accountability sought?
(4) How is accountability sought?
(5) What sanctions can be brought to bear on the person/organisa-
tion held to account?
6 J. HOWELL ET AL.
Conceptually, the notion of accountability is complex, contested, and

elastic. In its most basic incarnation, accountability refers to a relation-
ship between two parties, A and B, where A is usually the citizen and B
the government. In this relationship, A demands that B provides reasons
for their behaviour. Accountability is essentially a relationship of power
between two parties. The parameters of accountability are thus never
given but have to be worked out through formal and informal processes
of contestation and negotiation.
Various approaches to accountability add a further layer of complex-
ity to the concept. Different emphases may be given to different types
of accountability, such as financial accountability, managerial accounta-
bility, image accountability, and democratic accountability that involve a
multiple matrix of actors. Underlying the priority given to any of these
different types of accountability are relationships of power between prin-
cipal and agent, that is account-holders and account-givers. Seeking
accountability requires the empowerment of users to press for enhanced
participation and the right to redress and thus for a broader, substantive
democratisation of society.
Given the issues of empowerment and participation, accountability to
users can prove particularly difficult in authoritarian contexts where insti-
tutions of checks and balances, open media, and organised civil society
are severely constrained. Moreover, alternative options of welfare provi-
sion, whether provided by the state, market, or NGOs, remain very lim-
ited in formerly state-planned economies, so users cannot readily exercise
choice by exiting and finding an alternative provider. Instead, voice is the
prime vehicle through which they can express their (dis)satisfaction. Yet
even with voice, the lack of alternatives as well as the limits on expression
in authoritarian states can make users cautious about exercising voice.
The choices of exit and voice that Hirschman (1970) first drew attention
to are thus heavily bracketed in post-socialist states. These constraints
in turn exacerbate the effects of the tight regulatory environment in
authoritarian contexts that limits the scale, depth, and approach to ser-
vice delivery.
Set against this context NGOs have developed what we call ‘second-
order accountability’ as a means to build and enhance their reputation
and legitimacy. Crafting second-order accountability involves accumulat-
ing a stock of accountability capital. Accountability capital includes such
‘inputs’ (Nathan 2003) as positive media exposure, governmental awards,
transparency of finances, professional expertise, reports to donors, and so
1 INTRODUCTION 7
on. These are pieces of evidence that can be used to justify claims that
are made by NGOs and enhance the legitimacy of the NGOs. The more
stock of accountability capital that an NGO can accumulate, the greater
its chances of tacit government recognition, minimising harassment, and
ensuring its survival. It also enables it to attract funding from different
sources and gain the trust and confidence of government officials, poten-
tial donors, and the general public, thus contributing further to its sur-
vival and development. An expanding constituency of support increases
the legitimacy of NGOs and provides a protective veil against unwarranted
governmental harassment. Accountability and legitimacy are thus closely
related (see Chapter 2 for fuller discussion). Accountability is the means
through which account-holders can demand accountability from agents or
account-givers that make claims about how they govern, or in our case
how they provide services. Where account is seen to be given, the  agent,
in this case NGOs, gains legitimacy, and this legitimacy in turn can be
used as in input for accountability. Making accountability and legitimacy is
thus a crucial part of an NGO’s strategy for survival.
As a second step, we need to clarify the term ‘NGO’, which is a rel-
atively new term in the Chinese context, though widely used across the
world and in the literature on organisation by citizens. Though the con-
cept of an NGO is deployed globally in academe, politics, and policy, it
can, like many social science terms, be defined in a variety of ways and
with varying degrees of analytic rigour, differing in terms of its empiri-
cal referents, its political connotations, its range of activities, its assumed
values and organisational features, and appropriated politically for differ-
ent ideological purposes. In general, the term NGO refers to an organ-
isation that is neither governmental nor profit seeking and has a public
benefit purpose. In practice, however, such neat boundaries prove to
be messy and fudged, as some NGOs receive government funding and
some are even set up by government (government-organised NGOs or
GONGOs). NGOs may be more or less formalised, with some formal
NGOs having a clear legal basis, a body of staff and volunteers, a consti-
tution, mission statement and goals, a structure of governance such as a
board of trustees or directors, and a source of revenue that is neither tax-
ation nor profit. NGOs can engage in a range of activities including ser-
vice provision, advocacy on behalf of particular causes and social groups,
rights work, humanitarian work, and action research and policy influ-
ence. The term NGO is often used interchangeably with other terms,
such as non-profit organisation, grassroots organisation, voluntary sector
8 J. HOWELL ET AL.
organisation, or third sector organisation (Bebbington et al. 2008; Lewis

2007; Hilhorst 2003, pp. 3–5; Howell and Pearce 2001; Salamon and
Anheier 1992). It is distinct from social movements such as the environ-
mental or women’s movement, which are looser, more fluid, and more
intermittent ways of organising, though NGOs may be important con-
stituents of such movements. It is also distinct from a membership group
such as a trade union or business association.
In socialist states such as China or in state-dominated authoritarian
regimes, there may be little space for independent organising. In such
contexts, the concept of an NGO may not be part of public, policy, aca-
demic, or political discourse. Moreover, the idea of a non-governmen-
tal organisation is likely to be threatening, being viewed as a potential
channel for destabilising authoritarian regimes. In the case of China,
as more independent organisations emerged in the reform period from
1978 onwards and researchers became exposed to the literature on civil
society and NGOs, there were political concerns about how to translate
these ideas, which mattered for how the government might then deal
with these new organisational entities. The key stumbling block was the
idea that the ‘non-’ in NGO might mean anti-government, suggesting
that these organisations were potential channels of dissent and opposi-
tion (Ma 1994).
For the first two decades of reform the Chinese term of ‘social organ-
isation’ (shehui zuzhi), which derived from its usage in Soviet Russia,
was used to describe newly forming social groups in the reform period.
Technically, a social organisation was an organisation registered with the
MOCA. However, as will be discussed in further detail in Chapter 3,
registration proved to be a cumbersome affair, riddled with constraints
and barriers that ultimately discouraged registration. As more foreign
NGOs began to operate in China, particularly from the millennium
onwards, the usage of the term NGO became more current and was
generally translated literally as ‘fei zhengfu zuzhi’. In Chinese, the term
NGO (fei zhengfu jigou) is used interchangeably with other terms, such
as social organisation, charity, grassroots organisation, association, and
registered non-profit enterprise.
With the proliferation of Chinese NGOs from 2000 onwards, the
concept of NGO began to be used loosely to refer to all more inde-
pendently organised groups, whether registered or not. The book thus
starts with a definition of NGO that is not contingent on its legal sta-
tus. As will be seen in the case-studies, most child welfare NGOs were
1 INTRODUCTION 9
unregistered due to the considerable difficulties obtaining registration.

The newness of the organisational structure of an NGO coupled with the
challenges to registration have in turn affected the organisational devel-
opment of NGOs in China. Without the legitimacy accorded through
registration along with the policy constraints on domestic revenue-
raising, most NGOs in China are best characterised as ‘proto-NGOs’,
rather than fully fledged NGOs that would be more widely found in
liberal democracies. They are proto-NGOs in that their organisational
structures and systems, governance arrangements, practices, principles,
and channels for fund-raising are often weakly developed. As a result,
most NGOs are very small in scale, with few staff and volunteers, and
short-term funding sources that render sustainability and long-term
planning distant goals. Added to this, as will be discussed in Chapter 3,
government suspicion of independent citizen organising through NGOs
and foreign funding has further hindered the development of a thriving
civil society, of which NGOs are often a key part.
Aims and Research Questions

This book sets out to address the conceptual, structural, and political
issues around the making of accountability and legitimacy by NGOs in
an authoritarian regime where different service providers, including
NGOs, are playing an increasing part in developing welfare services. It
pursues this through the lens of child welfare NGOs during the Hu-Wen
period of administration (2002–2012) when numerous initiatives were
adopted to address issues of poverty and inequality, and the first five
years of the Xi era (2012–2017), when new laws, regulations, and pol-
icies governing NGOs were further developed and extended across the
country. Its broad aims are first, to enhance understanding theoreti-
cally and conceptually of accountability and legitimacy in authoritar-
ian states, focusing on the case of China. In doing so, it develops the
concepts of ‘second-order accountability’ and ‘stock of accountability
capital’. Second, it aims to understand empirically how NGOs develop
second- order accountability by accumulating a stock of accountability
capital as a means to build their reputation and legitimacy. It considers
the implications of this for service user participation and the hierarchy
of accountabilities that emerges. Third, the book considers more broadly
how these findings on the crafting of accountability in China shed light
on processes of institutional change in authoritarian contexts.
10 J. HOWELL ET AL.
The key research questions investigated are:

First, what combination of accountability capital inputs do NGOs
draw on to build their second-order accountability and legitimacy? This
in turn generates a number of sub-questions:
• What kind of links has the NGO nurtured with local and national
media to publicise its work and what kind of exposure has it
received?
• How has it tried to cultivate good relations with local government?
• Has it been recognised by local government in any way for its
achievements?
• To what extent is the NGO developing professional networks,
strengthening its professional expertise through training and
absorbing latest scientific knowledge?
Second, what hierarchy of accountabilities does this lead to, such as the
prioritisation of financial accountability over say organisational accounta-
bility, and how does this in turn affect user participation in accountabil-
ity? This also leads to a number of sub-questions:
• What processes of accountability has the organisation established

in terms of organisational accountability, managerial accountability,
financial accountability, and child welfare accountability and why?
• What pressures do funders exert on the NGO in terms of account-
ability? How does this affect financial reporting procedures, trans-
parency and auditing processes, procedures to avoid conflicts of
interest, and how does this ensure probity and appropriate use of
resources?
• What is the organisational structure of accountability, including
the role of board members, external auditors, members and users,
management and establishment history? What are the processes of
decision-making?
• What factors have pushed NGOs to develop professional expertise,
such as governmental requirements, international funders, profes-
sional peer expectations, training, and parental demands? What are
the technical and professional qualifications, experience, and prac-
tices relevant to child welfare services and to what extent does the
NGO manifest these?
1 INTRODUCTION 11
• How do users participate in the organisation and how is informa-

tion fed back to users? What are the systemic biases against users
that hinder them from seeking accountability? How does user
participation in child welfare service provision affect child wel-
fare accountability? What is the responsiveness to user preferences,
assuming these are known?
• What sanctions can different stakeholders deploy to ensure account-
ability and change?
Third, what are the politics shaping the process of making accountabil-
ity and legitimacy in NGOs in an authoritarian state? Sub-questions here
include:
• What are the power relations between those demanding account-

ability and those giving account and what are the sources of this
power, such as funding, professional standing, and knowledge?
• What are the power relations between NGOs and the state and how
do these affect the strategies and tactics NGOs use to survive?
• How do these state-NGO relations affect how NGOs set about
making accountability and establishing legitimacy? How do pro-
cesses of institutional change in the state create opportunities or
constraints for NGOs?
• How do social divisions along the parameters of age and profes-
sionalism affect the power of children to hold service-providers to
account?
In exploring these key research questions, the book draws on three bod-
ies of literature, namely theories of accountability, institutional change,
and user participation. As these are discussed more fully in Chapter 2,
we provide here a brief overview of their relevance and application
in the book as well as how this research contributes to their develop-
ment. Theories of accountability have been developed primarily in rela-
tion to liberal democratic states. This book draws on these theories but
adapts these to apply to an authoritarian context. For example, it applies
Mattei’s (2009) multidimensional conceptual framework as a tool for
analysing accountability by service provider organisations (user-initiated
NGOs, other NGOs, government and private organisations) to service
users, the wider public, and the state in the empirical setting of child
12 J. HOWELL ET AL.
welfare in China. In particular, it examines accountability to these three

groups in terms of accounting for financial expenditure including pub-
lic and private funds (financial accountability); operating an efficient and
legally compliant organisation (organisational accountability); follow-
ing best practices (professional accountability) and achieving the child
outcomes and intended goals of social services (child welfare accounta-
bility). The analysis of empirical data identifies how Chinese child wel-
fare organisations manage, avoid, or ignore conflict between these four
accountability dimensions as certain dimensions become prioritised over
others and the implications of this for different account-holders. The
multidimensional framework provides a useful entry point for tracing the
development of accountability in child welfare groups in China and for
analysing the emerging hierarchy of certain types of accountability.
The second strand of literature that informs the book’s conceptual
and theoretical framework concerns processes of institutional change.
Theories of accountability developed in relation to liberal democratic
states focus more on the outcomes of accountability-making processes,
that is, the types of accountability processes that exist such as financial
accountability and managerial accountability. They reveal little about
the processes that lead to the making of accountability processes. To
understand this, the book builds upon theories of institutional change.
Institutions refer to the rules, procedures, and norms that govern pro-
cesses of change (North 1990). Historical institutionalism reminds us
that institutional change has a past, present, and future, that cannot be
fully grasped through a static approach. Similarly, attempts to modify
institutionalist theory have highlighted the role of informal processes of
change and the importance of social structures in shaping change (Hall
and Taylor 1996). Institutional change can be prompted by exogenous
events such as new trade relations, or through endogenous processes of
change such as a change in political regime, or through sudden events
such as a global financial crash. Alternatively, there is also a growing
body of work which points to the gradual nature of institutional change.
The accountability work done by NGOs in China exemplifies grad-
ual institutional change that enhances the resilience and survival of the
organisation. This in turn relates to a sub-literature in the field of Chinese
governance where the starting point has been the adaptive capacities
and resilience of the Chinese Community Party (CCP). Andrew Nathan
(2003, 2009) identifies a gamut of input institutions used by the CCP
to shore up its legitimacy and adapt to a citizenry that has become less
1 INTRODUCTION 13
accepting of state propaganda and able to organise through the Iinternet.

These input institutions include measures to enhance government trans-
parency, efforts to include citizens in local decision-making processes,
community elections, and introducing new processes of accountability
beyond the traditional ones of petitioning and leveraging personal con-
nections. NGOs in a similar way have also developed adaptive inputs to
enhance their legitimacy, resilience, and survival. The research thus high-
lights not only the gradual process of institutional change by NGOs in
response to a highly controlling state but also the processes of adapta-
tion by leveraging various combinations of inputs that make up a stock of
accountability capital in an authoritarian context.
The development of NGOs and their accountability work also high-
lights the way that NGOs operate in the crevices of gradual state institu-
tional change. Particularly relevant here is the idea of ‘drift’ in theories of
gradual institutional change, whereby the rules governing the system do
not change in line with circumstances. In this context, local officials have
opportunities to change rules informally and discretely. The rules gov-
erning the registration of NGOs in China are a good example of rules
that no longer correspond to changed circumstances. This then leads
to a process of drift, whereby local officials ignore these rules and allow
NGOs to continue to operate because there are advantages to them in
doing so such as filling gaps in service provision and gaining informa-
tion about citizens’ preferences, priorities, and opinions. For their part,
NGOs use the spaces and opportunities that open up because of this
process of drift to develop their activities, accountability, and legitimacy.
The third strand of literature informing the book relates to user par-
ticipation and democratic accountability, one aspect of which is the
participation of people who use services in the way the organisation
operates. User participation in social services sits along a spectrum of
user-focused power devolution consistent with theories of the democ-
ratisation of social service provision (Shier 2010; Cornwall and Gaventa
2000). Participation theory argues that accountability, quality of service,
and user outcomes can be linked by empowering people who use ser-
vices. As Kilby (2006, p. 951) underlines, without downward account-
ability to users through semi-formal or formal arrangements, NGOs
cannot be effective in empowerment. Participation has intrinsic and
instrumental purposes—enabling people’s control over the services they
use and influencing practice in child welfare organisations. Processes
range from feedback about services to the full co-production of services
14 J. HOWELL ET AL.
(Bovaird 2007; Douthwaite et al. 2006; Kilby 2006). In services for chil-
dren, this involves families, advocates, or representatives and the direct
participation of children to influence service delivery, resource allocation,
and governance practices to maximise children’s agency (Shier 2010;
Cavet and Sloper 2004). As of yet, user participation in social services
in China is rare (Zhong and Fisher 2017). The research thus explores
cases of enhanced participation through user-initiated NGOs to achieve
accountability in child welfare groups in China.
The book makes a number of contributions at the theoretical and
empirical level. First, it deepens understanding about how NGOs make
accountability and legitimacy in an authoritarian context. In doing so, it
puts forward the concepts of second-order accountability and accounta-
bility capital to describe, capture, and explain the politics of the process
of accountability-making. It also contributes by thinking about account-
ability as a dynamic process rather than merely an outcome. This way
of approaching accountability and legitimacy has particular salience in an
authoritarian context where there are strict state controls over basic free-
doms such as freedom of organisation and where achieving legal status is
particularly difficult.
Second, by taking a dynamic, processual approach to accountability-
making, it illuminates how exogenous factors such as external funders
both domestic and foreign as well as endogenous factors such as atti-
tudes to users can lead to certain types of accountability being prioritised
over others. In particular, it reveals the power relations that underpin
systemic biases against marginalised and vulnerable groups in pursuing
accountability. It provides a basis for understanding the implications of
moving from a state-dominated mode of welfare provision to a mixed
welfare model of provision.
Third, it contributes to understanding how institutional change and
adaptation occurs in authoritarian contexts. It focuses not on the CCP
or state as much of this literature has done, but on NGOs. Their resil-
ience and survival in authoritarian contexts depends on NGOs’ ability to
adapt and navigate often contradictory relations with the different parts
of the state. By emphasising the gradual and dynamic nature of change,
the book thus challenges depictions of China that suggest an unchang-
ing form of authoritarianism. It contextualises NGO survival strategies,
particularly those seeking to leverage accountability and legitimacy as
tactics in viability and organisational development, in the context of an
adaptive dynamic between state and NGOs. Just as the CCP uses input
1 INTRODUCTION 15
institutions to enhance its survival and resilience, so too, the book sug-
gests, NGOs use accountability capital to ensure their continued exist-
ence and development. At the empirical level, the book provides the first
in-depth study of accountability for welfare provision in an authoritarian
regime, with a specific focus on child welfare groups.
Finally, the book contributes to accountability theories by bringing
politics back into the discussion. These politics relate to the way cer-
tain hierarchies of accountability emerge and become consolidated.
Whether in China or elsewhere, the common tendency is for financial
and organisational hierarchy to become prioritised over other dimen-
sions, particularly accountability to users. This cannot be reduced to
some technical inevitability about organisational development processes;
rather, it reflects the power relations between those demanding account-
ability and those providing account. These power relations in turn
connect closely to the politics around whose demands get heeded and
prioritised. As seen in this book, sociocultural attitudes including issues
of deference to age and expertise work against considering the views
and voices of children. Politics is evident in the way NGOs navigate the
restrictive environment within which they operate and manage their rela-
tionships with government to ensure survival. Their navigation is not just
a matter of reducing government suspicion towards them but also of gar-
nering public confidence so as to raise funds and extend their client base.
Having clarified the meaning of accountability adopted here and its
multidimensional nature, we need to consider also why the book focuses
on China and on child welfare groups and the methods used in the
research.
Why China?
The case of China is particularly pertinent for several reasons. First, fol-
lowing the introduction of market reforms in December 1978, social
organisations in China have proliferated in number across the country,
engaging in issues ranging from environmental protection to the welfare
of the children of prisoners. They enjoyed a significant spurt in growth
after China entered the World Trade Organisation at the end of 2001,
though most of them have not been able to register under the highly
restrictive regulatory framework for registration. Government officials,
particularly in the public security agencies have tended to view NGOs
with suspicion, tolerating some, keeping an eye on others and in some
16 J. HOWELL ET AL.
cases, harassing and closing them down. The Chinese case illustrates
well the impact of bureaucratic fragmentation on the progress of wel-
fare reform and civil society development. In particular, we can observe
the gradual crafting of a welfarist incorporation strategy towards civil
society groups through the Hu-Wen and Xi eras, whereby certain ser-
vice-oriented NGOs with instrumental value to the Party-state in wel-
fare reform are encouraged and licensed, whilst most other civil society
groups remain in an institutional limbo of non-registration (Howell
2015). The imperative of advancing welfare reform through the diversifi-
cation of service providers using a strategy of welfarist incorporation has
to some extent diluted the impasse between welfare-focused departments
and security agencies. This impasse centred around the risk that ena-
bling NGOs to develop so as to provide welfare services might provide
an opportunity for civil society organisations perceived as threatening to
emerge and grow.
Second, the CCP experimented with new forms of accountability in
the government–citizen relationship during the Hu-Wen years. The pro-
cesses of marketisation and commodification have not only led to ris-
ing income, gender, and regional inequalities but also increasing social
protests both in rural and urban areas concerning corruption, widening
inequalities, maltreatment in the workplace, displacement, and social
injustice. Existing methods of providing accountability such as the peti-
tioning system (xinfang) are unable to cope with the volume of com-
plaints and are deliberately undermined by local officials so as to avoid
criticism and coming under the scrutiny of higher levels of author-
ity. Local citizens have increasingly bypassed local petition offices and
appealed to higher levels. Some have even encamped in Beijing out-
side relevant government ministry buildings to pursue their grievances.
Whilst central and local government officials have generally responded
with coercion to protests, demonstrations, and similar ‘mass incidents’,
in the last decade they have also turned to ‘softer tactics’ of appeasement,
engaging in dialogue, and experimenting with new methods of account-
ability. To this end, they have sought to improve the calibre of govern-
ment officials through competitive entrance examinations; introducing
systems of performance evaluation of government cadres accompanied
by a system of rewards (promotion) and sanctions (demotion); through
anti-corruption initiatives; through the introduction of competitive
village elections; and through indirect elections within the Party.
1 INTRODUCTION 17
The Party has also experimented with and then extended new chan-
nels through which citizens can hold government to account, such as
public hearings, consultation with experts, and participatory budgeting.
They have introduced new legislation and regulations such as the 1989
Administrative Litigation Act and 2007 Open Government Regulations,
which endow citizens with the means and authority to seek redress.
The Party has also tolerated the print and broadcasting media play-
ing more of a watchdog role over companies and government officials,
though this is still subject to constraints, government censorship, and
vulnerable to intermittent government interference. Such experimenta-
tion implicitly acknowledges the need to give citizens greater space to
air their grievances and provide them with a wider range of opportuni-
ties to participate in governance processes. It provides another way of
gauging citizens’ preferences and concerns, assisting the government in
addressing an information and feedback deficit that bedevils authoritar-
ian states without liberal democratic institutions, such as an independent
media, independent civil society, and electoral politics that can play this
role. It is also a useful soft tactic to stave off discontent and bolster Party
legitimacy. It has thus provided a more amenable context within which
local officials have often turned a blind eye to NGOs providing services
to marginalised and vulnerable groups and tolerated groups that seek to
advise aggrieved parties on their rights. The need for government offi-
cials to be more accountable and responsive has come more firmly onto
the Party agenda, particularly since Xi Jinping, General Secretary of the
CCP, came into office in 2012.
Simultaneously, frustrated with government officials’ incompetence,
impropriety, and corruption, particularly at a local level, Chinese citizens
have artfully deployed social media and mobile phones to expose mis-
conduct and injustices. Incidents where government officials have been
found to spend extravagantly, engage in illicit affairs, or behave above
the law have rapidly gone viral on Chinese social media, such as WeChat,
blogs, and chat rooms.
Third, China is shifting from an export-oriented, labour-intensive
model of development to a more capital-intensive model that privileges
industrialisation and urbanisation over rural development. This has
entailed changes in welfare provision for both rural and urban residents.
The acceleration of state enterprise reforms from the mid-1990s along
with the opening up of a housing market has undermined the former
18 J. HOWELL ET AL.
system of welfare provision that centred on the work unit (danwei).

Similarly in rural areas, land reform has dispossessed rural residents and
undermined their core source of livelihood security. With these changes,
providing welfare to rural migrant workers, who increasingly depend on
their waged labour for sustenance, has become increasingly important for
the government. Providing welfare is a way to stave discontent and main-
tain support from key constituencies.
In its efforts to reform the welfare system, the Chinese government
has turned to the private sector and NGOs to assist with welfare reform.
It is thus moving away from an entirely state-led system of welfare pro-
vision to a mixed welfare system. Given the limited supply of NGOs,
the government has to not only improve incentives for these agencies
to deliver services but also ensure their capacity and professionalism.
This requires it not least to amend the regulatory framework govern-
ing NGOs to make it less cumbersome for them to register, thus ena-
bling them to apply for government contracts to provide services. As a
result, issues around the professionalism, capacity, accountability, and
governance of NGOs have come to the fore. The exposure of and alle-
gations of fraudulent activities in three large GONGOs in 2011, namely
the Chinese Red Cross, the China Youth Foundation, and the China
Charities Foundation, spurred a drive amongst non-governmental foun-
dations to improve the governance and accountability of NGOs and
by the MOCA to explore routes to improving governance. Addressing
welfare issues matters to the CCP as a way of allaying social discontent
and bolstering its legitimacy. There is thus an instrumental, stability
driver underpinning the Party’s turn in the millennium towards courting
NGOs as partners in welfare provision. To this end, the Party is keen to
establish a more enabling institutional framework for the registration of
NGOs that can contribute to the alleviation of poverty and inequality
through provision of welfare services.
Finally, as an example of an authoritarian regime, and specifically
a post-socialist authoritarian regime,1 a focus on China provides a way
of filling a yawning gap in the research and literature on accountability,
which, as will be discussed in greater depth in the next chapter, has been
primarily preoccupied with accountability in liberal democratic regimes.
Whilst there is a burgeoning body of literature on civil society and NGOs
in China, particularly in the last decade, scant attention has been paid
to accountability and legitimacy issues and the particular challenges that
authoritarianism poses. One of the few such empirical studies revealed
1 INTRODUCTION 19
that local NGOs complied with financial accountability to funders but

were less aware of accountability to service users or the public or about
other accountability dimensions or concepts of user participation in
NGOs processes (Fisher et al. 2011). Apart from this, there are few stud-
ies that address the issue of NGO accountability and legitimacy in China.
The growing body of research about Chinese NGOs has concentrated
on legal structures, political barriers and managerial systems (Fisher et al.
2011; Howell 2009; Unger 2008; Edele 2005; White et al. 1996) and
does not include empirical evidence about accountability for social ser-
vices (Lu 2009).
Why Child Welfare Groups?

More than eight million disadvantaged children increasingly rely on sup-
port from Chinese child welfare NGOs. There are two groups of disad-
vantaged children in China according to whether or not their guardians
are absent or present. One type refers to those whose birth parents as
guardians are absent for different reasons, such as orphaned or aban-
doned children, street children and prisoners’ children, or those whose
birth parents are deprived of guardianship due to domestic violence
against children. The other group are those who have their birth parents
as guardians but have special needs, such as children with disabilities or
serious diseases or children from poverty-stricken backgrounds.
Disadvantaged children are a small and vulnerable group that does not
have the power to protect itself. These children need specialised, pro-
fessional services because of the additional needs in their development.
Given their specialised needs, the private sector is reluctant to enter this
field, whilst the price of market-supplied services is not affordable for
most parents. As a minority group, disadvantaged children and their car-
ers do not have enough political voice to influence policy-making, result-
ing in a lack of investment in public services catering for their needs in
most of the country. In the context of insufficient market supply, the lack
of state investment, and poor quality of government support, the organi-
sations that provide services in this field are typically NGOs and charities
(Shang et al. 2005).
Child welfare NGOs started to emerge in the 1990s and their growth
accelerated from 2000 onwards during the Hu-Wen administration. By
child welfare NGOs, we include registered foundations, social organisa-
tions, and non-profit organisations that provide child welfare services and
20 J. HOWELL ET AL.
child protection so as to improve the welfare of disadvantaged children

as well as unregistered child welfare NGOs. Some NGOs are initiated by
families and communities to develop services for their own children in
the context of shortages of public services. Some employ workers and
others rely on volunteers. There are also international NGOs, chari-
ties, and faith-based groups providing child welfare services. They sus-
tain their service provision by charging at cost price for services rather
than seeking to make a profit, attracting charitable donations and using
volunteers as well as paid staff. Already as the mixed welfare system is
emerging, many state-owned child welfare organisations now also receive
greater financial, technical, and staff support from non-governmental
sources than from the government.
Despite over two-thirds of child welfare NGOs emerging from 2000
onwards, the vast majority remain unregistered, not least because of the
complex and demanding registration procedures and the additional diffi-
culties of registering for such groups.
The requirement to work closely with governmental departments
became more stringent following a tragic incident where seven children
in the care of an unregistered child welfare NGO died in a fire in January
2013. The woman running the NGO, a cleaner, had cared for more than
100 abandoned children since 1986, including children sent by the local
state child welfare institution, though she did not have legal guardian-
ship of any of them. The courts ruled that the children had died from
neglect (China Youth Newspaper 2013, January 1). In the wake of this,
seven government departments,2 including the MOCA, jointly issued a
document requiring that civil affairs departments at the county level or
above should provide direct protection for all orphans and abandoned
infants and that child welfare NGOs should not be run independently.
Following this incident, the MOCA investigated all NGOs involved in
caring for abandoned children without legal guardianship and prohibited
them from taking on any new children.
This incident highlighted the risks of leaving child welfare in a
limbo realm of non-registration where even basic accountability incum-
bent on registered organisations was not regulated. Registered organi-
sations must abide by clearly defined responsibilities and duties as well
as detailed and specific operational procedures. Registered child wel-
fare organisations are accountable legally, politically, and economically
to the competent business unit supervising them and cannot refuse to
comply without risking the loss of their business licence.3 Apart from
1 INTRODUCTION 21
maintaining their legal accountability, they also have to be politically and

economically accountable, that is, they must not threaten state security
and must ensure that their assets are legitimately sourced, that there is no
fraud or embezzlement, and that they account to donors for how they
use those resources. Though registered organisations are accountable
to the government, there are no requirements or processes for ensuring
accountability in terms of professional competence, the protection of the
rights and welfare of children, or for service users.
As a result of the difficulties in registering, the majority of child wel-
fare NGOs remain unregistered or register as for-profit enterprises, even
though they are not-for-profit. Indeed, some child welfare organisations
have existed for years without registration (Shang et al. 2005). In gen-
eral, neither the civil affairs administration nor the police intervenes in
these organisations, despite the fact that technically they are ‘illegal
organisations’. Nor do they actively encourage them to register. As long
as they do not have any political or religious purpose, do not intention-
ally commit any activity against the government, do not threaten the
safety of children, or are in any other way illegal, then the authorities do
not monitor their activities, intervene in or support their operations, and
commonly do not enforce the accountability requirements of registered
NGOs (Fisher et al. 2011; Lu 2009; Edele 2005). Such tolerance is an
effect of the yawning gap in government services for disadvantaged chil-
dren and an implicit recognition that the child welfare NGOs to some
extent fill this gap and reduce the resource pressure on government
agencies. The consequences for some children supported by unregulated
NGOs can be extreme, as seen in the 2013 incident where the seven chil-
dren died in the fire. Furthermore, even when some child welfare NGOs
have operated for more than three decades, their practices are so lax that
some children reach adulthood without formal education or a legal status
because the NGO could not register their birth (Shang et al. 2005).
In the wake of several NGO scandals in 2011, the MOCA faced
intense public criticism about the poor quality and quantity of child wel-
fare provision and came under increasing pressure to change the way it
monitored child welfare NGOs. Building the accountability of NGOs
through regulation and support has become a priority for the Chinese
state and civil society. As the government has relaxed registration
requirements for NGOs operating in the field of child welfare so as to
increase the supply of good quality support to disadvantaged children,
the accountability of such NGOs has become a salient issue.
22 J. HOWELL ET AL.
Thus, a situation of both over-regulation and under-regulation pre-

vails, with the vast majority of child welfare NGOs remaining unreg-
istered and at greater risk of potential closure,4 but also exposing
children to greater risks of poor quality care and potential abuse. The
lack of registration does not mean, however, that unregistered child
welfare NGOs do not develop processes of accountability. As will be

seen in the subsequent chapters, some NGOs are required by exter-
nal donors to respond to accountability demands, whilst others create
second-order forms of accountability to gain the trust and confidence
of government departments, service users, and the general public.
Moreover, some have developed ways of being accountable that go
beyond that required from registered organisations, such as seeking to
develop their professional expertise, making public their accounts, and
proactively inviting government officials to witness their activities.
The focus of the book on child welfare groups is thus highly rele-
vant and appropriate. First, child welfare is a main reform priority of the
MOCA. Due to the vulnerability of children, it is a social service that
is perhaps less politicised than services for other social groups and has
drawn less political attention. Second, there are important child safe-
guarding issues at stake that call for improved accountability, whether
of registered or unregistered organisations. Third, due to the complex-
ity of registering and difficulties of identifying a supervisory department,
many unregistered NGOs are not subject to basic legal accountability,
let alone other dimensions of accountability, which potentially puts chil-
dren’s safety and rights at risk. Fourth, state-run child welfare institu-
tions have also been pressured to diversify sources of funding, rendering
them subject to accountability demands from new actors such as inter-
national organisations. Through these new funding arrangements, they
have become exposed to international practices and pushed to focus on
quality of services, not just quantitative, state-driven targets. Finally, as
this research shows, some child welfare NGOs have been attempting to
establish better processes of accountability, some of which go beyond
basic legal accountability.
Methods
The research for this book was carried out between 2007 and 2017. The
project used mixed methods, including analysis of policy documents,
preliminary analysis of a data-set of 188 child welfare organisations,
1 INTRODUCTION 23
semi-structured interviews with key informants, and process tracing

through case-studies of organisations (Collier 2011; Bennett 2010; Van
Evera 1997). Documentary analysis of the MOCA policies covered the
laws, regulations, and policies about child welfare organisations, NGOs
and accountability. The data-set was collected between 2008 and 2009
through online research, personal communications, and discussions with
relevant agencies. The data-set of 188 child welfare organisations reflects
those we were able to trace during the research period and it is likely that
some were missing. Up until 2013, some new organisations might have
been established, but after 2013 new ones could only register as disa-
bility organisations, not child welfare organisations—see Chapter 5. The
characteristics of these organisations as revealed by the data-set of 188
organisations are likely to continue to reflect the larger group of current
NGOs (Table 1.1).
Two-thirds of these organisations were established after 2000. They
provided services for disadvantaged children to access education, chil-
dren with disabilities, and children without the care of their parents
(orphaned or parents in prison). Most of the organisations did not have
registration information, and were thus highly likely to not be registered.
Of the 56 organisations that were registered, 48 were registered with a
Civil Affairs Bureau. The registered organisations were initiated by com-
munity members, parents, or entrepreneurs and professionals. Most of
the founders were from China but eight organisations were established
by international organisations. They relied mainly on public donations
and service fees, with only two organisations receiving any government
money and six using funds of the founder.
Fieldwork was conducted in Beijing City, Guangxi Zhuang Autonomous
Region, Yunnan, and Hebei provinces between 2008 and 2010, with
follow-up site visits, interviews, online and documentary research up
till 2017. These sites were selected because they had a sufficient diver-
sity of child welfare organisations, had children and families in need,
and exemplified a range of socio-economic and policy contexts. As the
political and cultural centre of China, Beijing is home to both interna-
tional and domestic child welfare NGOs. Guangxi was one of the pilot
regions reforming the management system of social organisations and
has a variety of child welfare organisation types with multiple sources
of funding. Yunnan exemplifies a province where child welfare organ-
isations are active because of the concentration of disadvantaged chil-
dren, due to disability, HIV/AIDS, and orphaned children. Historically,
24 J. HOWELL ET AL.
Table 1.1 Characteristics of child welfare organisations
Number Percent
All organisations 188 100

Established after 2000 125 66
Provide services for Disadvantaged children, mainly education 57 42
Children with autism, cerebral palsy or 36 26
intellectual disabilities
Orphaned and abandoned children 15 11
Children with parents in prison 12 9
Children with hearing and vision 12 9
impairments
Registration All registered 56 30
Civil Affairs Bureau 48 26
Non-profit enterprise 3 2
Not registered 17 9
No registration information 115 61
All registered organisations 56 100
Founders Community members 25 44
Parents 17 30
Other—Entrepreneurs and professionals 14 26
International founders 8 14
Main funding source Public donations 27 48
Service fees 21 37
Founder’s own funds 6 11
Government funds 2 4
Source Public information collated from the Internet and direct contact with the organisations
2008–2009
Hebei province has been home to many orphanages run by churches

and thus provided an ideal site for observing child welfare organisations
run by religious groups. A participatory approach to research informed
the design of the research and the fieldwork. Young people, families and
NGOs initiated by families were involved in the design of methods, col-
lection of data, comments, and analysis of the findings and dissemination.
Fieldwork in each site included semi-structured interviews, focus
groups, and observation with families and young people who used ser-
vices when they were children, with child welfare organisations that pro-
vided services to them, and with professionals who supported them. The
professionals were from education, disability, health, civil affairs, labour,
social security, social work and the disability and women’s federations.
1 INTRODUCTION 25
In addition to the detailed research in these four sites, social policy post-
graduate researchers from Beijing Normal University carried out further
research nationwide on child welfare NGOs in their home towns across
15 provinces and autonomous regions. As a result, this study has much
wider coverage than the four sites where intensive research was carried
out. Altogether research was conducted through semi-structured inter-
views on 88 organisations, including 68 non-governmental child welfare
organisations and 20 state child welfare organisations.
The sampling framework was a minimum of seven child welfare
organisations at each location. Specifically, this involved one govern-
ment child welfare organisation that operated at each location; at least
two NGOs initiated by families, two other NGOs, and two private child
welfare organisations. This yielded a total sample of 28 child welfare
organisations. As most of the child welfare NGOs had been set up for
only a couple of years, their systems of administration, governance, and
management were not yet fully developed. As a result, their processes of
accountability were often rudimentary. In the light of this, we focused
on cases with a longer trajectory of operations, that illustrated different
types of child welfare organisations, and that were willing to be inter-
viewed for more detailed analysis of their accountability processes. These
types included religious NGOs, which were particularly vulnerable to
government suspicion and potential harassment and were thus likely to
encounter more difficulties in gaining legitimacy; NGOs set up by par-
ents, which had to work hard at raising funds, establishing their expertise
and achieving credibility; and mixed state welfare institutions that were
under pressure to diversify their sources of funding and had to respond
to new demands for accountability from a wider range of actors. The
development of the four cases analysed in this book was thus studied
closely for more than ten years.
In addition to these various methods and a participatory approach,
the research also used a case-study method to examine in-depth four
child welfare organisations and the processes by which they crafted
accountability and legitimacy. The four cases were selected for more
detailed analysis in this book because they had relatively well-developed
accountability processes. This meant the processes could be analysed
from the multiple dimensions. The four organisations are diverse in
terms of their registration status, focus, and development path. On a
practical level for the feasibility of in-depth research, they were also
26 J. HOWELL ET AL.
all willing to participate in more detailed interviews, interactions, and

observation opportunities.
A case-study method is particularly appropriate here as it allows for
capturing texture, depth and nuance and complex and shifting processes
within an organisation over time (Gerring 2007; George 2005; Mason
2002; Yin 1998). Process tracing enables us to track how policies, reg-
ulations, and processes emerge over time. Specifically, through pro-
cess tracing, we can follow how certain types of accountability begin to
emerge, how hierarchies of accountability develop over time, and how
power relations shape those hierarchies (Collier 2011; Bennett 2010;
Van Evera 1997). The analysis brought together the data produced with
the mixed methods, triangulating findings from the fieldwork, the data-
sets, and the documentary analysis. The case-studies form the structure
for empirical chapters, with additional data from the other organisations
included in the discussion where relevant.
Structure of Book
Chapter 2 sets out the theoretical and conceptual framework that
informs the research and analysis of accountability and participation in
child welfare organisations in China. It begins by providing a review
of relevant literature on accountability and legitimacy, noting the pre-
dominance of research related to democratic states and to government–
citizen relations. It then explores the existing literature, albeit limited,
on accountability in authoritarian states and on non-state actors such
as NGOs, noting the particular conceptual, political, and methodologi-
cal challenges that research in these political and organisational contexts
entails. In particular, the chapter highlights and combines theories that
address the multidimensional nature of accountability, theories that link
accountability with participation, and theories that throw light on sys-
temic biases against the marginalised, vulnerable, and poor in accounta-
bility. More broadly, the chapter locates the discussion of accountability
within a broader theoretical framework around processes of institutional
change in authoritarian contexts, notably China.
Chapter 3 examines the background of welfare reforms and NGO
development in China. It hones in on the particular accountabil-
ity issues facing NGOs in China, drawing attention to some of the key
institutional and political constraints. This provides the context for a
more detailed look at the particular situation of child welfare NGOs.
1 INTRODUCTION 27
We sketch the development of policies, laws, and regulations governing

child welfare NGOs, underlining some of the particular challenges in
this field, providing contextual background to the subsequent case-study
chapters.
Chapters 4–7 provide case-studies of the making of accountability
and legitimacy amongst different types of child welfare service providers.
Each chapter highlights the emerging patterns of accountability and the
pressures that push an organisation to prioritise certain types of account-
ability over others and the implications of this for reproducing organ-
ised bias against weaker and marginalised social groups. The chapters
trace the process of how the organisations accumulate stocks of capital,
enhance their legitimacy, and how power relations between principals
and agents, that is, those demanding account and those giving account,
shape the combination of accountability capital that is developed.
Chapter 4 examines the case of Liming Family, a religious-based,
non-governmental child welfare organisation based in a rural county of
Henan province. This case illustrates in depth the processes of making
accountability to gain a national reputation, public trust, and govern-
ment confidence. Despite the difficulties of being a religious institution
in a secular, authoritarian state, Liming Family was able to gain the con-
fidence of local government and managed to operate for over 30 years
without being able to register as a child welfare institution with the Civil
Affairs Bureau. In 2013, it finally gained legal registration as a disability
services organisation. The chapter draws attention to the various inputs
that contributed to building up a stock of accountability capital, such as
publicising its work, attracting positive media attention, receiving higher
level governmental delegations, attracting public donations and devel-
oping its professionalism and expertise. Though it had developed some
internal formal processes of financial and managerial accountability, its
professional accountability was weak and it had not put in place any pro-
cesses for ensuring accountability downwards to users.
Chapter 5 takes the case of Angel House, a well-established NGO that
is distinct in the cases in that it was initiated by users, namely parents. It
built its reputation and legitimacy by developing stocks of accountability
capital. To this end, it adopted various strategies, such as developing its
capacity and professionalism, allying professionally with other civil society
organisations, and setting up its own processes of internal governance,
including accountability, to govern its affairs. During this period, govern-
ment policies on child welfare and social organisations changed several
28 J. HOWELL ET AL.
times. Though the local government and Disabled Persons’ Federation

played a role in its development, especially at the start, its close relations
with international professional organisations were a key factor in ena-
bling it to develop its professional expertise and services. It adopted an
open approach towards informing parents about the rehabilitation meth-
ods used. Although it was user-initiated, it had not yet extended the idea
of user accountability downwards to the children.
Chapter 6 examines the case of Children’s Hope Foundation in
Shandong province, and its complex relations with the semi-governmental
Association B, from which it eventually separated to establish an independ-
ent non-governmental foundation. This process of separation provided an
ideal lens through which to observe first, the process by which the organ-
isation built a stock of accountability capital as a second-order form of
accountability, and second, how Children’s Hope Foundation prioritised
financial and organisational accountability over user accountability.
Chapter 7 analyses the case of a state child welfare institution that
changed from a state-funded institution to one financially linked to local
and international organisations. The diversification of funding sources
had implications for expanding their scope of accountability to a range
of people and organisations. The case-study raises questions about man-
aging competing accountabilities, prioritising certain dimensions of
accountability, and about how to take advantage of the potential addi-
tional legitimacy from these new accountability relationships. It illus-
trates how state-run institutions, too, are having to develop second-order
accountability capital to extend their legitimacy beyond the state to other
audiences. It also reveals how state institutions can come under particular
political pressures as reflected in the reluctance of the organisation to be
re-interviewed in the period since Xi Jinping came into office.
In Chapter 8, we pull together the key findings of these case-studies,
relating these to the research questions laid out in the introduction. We
consider the process of making accountability in child welfare organisa-
tions in China to enhance legitimacy and secure organisational survival.
We reflect on how institutions change in the authoritarian context of
China, and specifically how NGOs can capitalise on state institutional
change to advance their own positions. The chapter discusses the gener-
alisability of the research findings and reflects on the broader theoretical,
methodological, and policy implications and outlines a path for future
research.
1 INTRODUCTION 29
Notes
1. There are various typologies of authoritarian regimes (see, e.g., Linz’s
1970 pioneering work on this; O’Donnell 1979; Perlmutter 1981;
Huntington and Moore 1970). Post-socialist regimes are a distinct subtype
of authoritarian regime (Diamond 2002; Brooker 2000).
2. These were the Ministry of Civil Affairs, National Development and
Reform Commission, Ministry of Public Security, Ministry of Justice,
Ministry of Finance, National Health and Family Planning Commission,
and State Administration of Religious Affairs (2013).
3. If they refuse to accept supervision and inspection or refuse to follow the
rules of supervision and inspection, they risk their business license being
cancelled, or could risk more serious punishment including “ceasing activ-
ities within a designated period” and “revocation of registration”; if the
case constitutes a crime, the criminal liability shall be investigated accord-
ing to law (Article 25).
4. According to Article 27, ‘unregistered or deregistered organisations that
carry out activities in the name of non-profit enterprises shall be banned
by the registration administration and their illegal properties shall be con-
fiscated; if the case constitutes a crime, the criminal liability shall be inves-
tigated according to law; or if the case does not constitute a crime, public
security punishment shall be given according to law’.
References
Bebbington, A., Hickey, S., & Mitlin, D. (2008). Introduction: Can
NGOs make a difference? The challenge of development alternatives. In
A. Bebbington, S. Hickey, & D. Mitlin (Eds.), Can NGOs Make a Difference?
The Challenge of Development Alternatives (pp. 3–37). London: Zed Books.
Bennett, A. (2010). Process tracing and causal inference. In H. E. Brady &
D. Collier (Eds.), Rethinking Social Inquiry: Diverse Tools, Shared Standards
(2nd ed., pp. 207–219). Lanham, MD: Rowman and Littlefield.
Bovaird, T. (2007). Beyond engagement and participation: User and commu-
nity coproduction of public services. Public Administration Review, 67(5),
846–860.
Brooker, P. (2000). Non-democratic Regimes: Theory, Government and Politics.
New York: St. Martin’s Press.
Bueno de Mesquita, B., Smith, A., Siverson, R. M., & Morrow, J. D. (2003).
The Logic of Political Survival. Cambridge, MA: MIT Press.
Cassani, A. (2017). Social services to claim legitimacy: Comparing autocracies’
performance. Journal of Contemporary Politics, 23(3), 348–368.
30 J. HOWELL ET AL.
Cavet, J., & Sloper, P. (2004). The participation of children and young peo-
ple in decisions about UK service development. Child: Care, Health and
Development, 30(6), 613–621.
China Youth Newspaper. (2013, January 1). Mass media reporting the death of seven
orphans in Henan: Abandoned when they were alive, and death because of neglect.
Collier, D. (2011). Understanding process tracing. PS: Political Science and
Politics, 44(4), 823–830.
Cornwall, A., & Gaventa, J. (2000). From users and choosers to makers and shap-
ers: Repositioning participation in social policy. IDS Bulletin, 31(4), 50–62.
Diamond, L. (2002). Elections without democracy: Thinking about hybrid
regimes. Journal of Democracy, 13(2), 21–35.
Douthwaite, M., Hammer, M., & Mayhew, S. (2006). Balancing protection and
pragmatism: A framework for NGO accountability in rights-based approaches.
Health and Human Rights, 9(2), 180–206.
Dukalskis, A., & Gerschewski, J. (2017). What autocracies say (and what citizens
hear): Proposing four mechanisms of autocratic legitimation. Contemporary
Politics, 23(3), 251–268.
Edele, A. (2005). Non-governmental Organizations in China. Geneva: Centre
for Applied Studies in International Negotiations (CASIN). Retrieved from
http://www.casin.ch/web/pdf/chinafinal.pdf.
Fisher, K. R., Li, J., & Fan, L. (2011). Barriers to the supply of nongovernment
disability services in China. Journal of Social Policy, 41(1), 161–182.
Gandhi, J. (2008). Political Institutions under Dictatorship. Cambridge:
Cambridge University Press.
George, A. L. (2005). Case Studies and Theory Development in the Social Sciences.
Cambridge, MA: MIT Press.
Gerring, J. (2007). Case Study Research: Principles and Practices. New York:
Hall, P. A., & Taylor, R. C. R. (1996). Political science and the three new insti-
tutionalisms. Political Studies, XLIV(5), 936–957.
Hilhorst, D. (2003). The Real World of NGOs: Discourses, Diversity and
Development. London: Zed Books.
Hirschman, A. (1970). Exit, Voice and Loyalty: Responses to Decline in Firms,
Organisations, and States. Cambridge, MA: Harvard University Press.
Howell, J. (2009). Government-organised nongovernment organisations. In D.
Pong (Ed.), Encyclopedia of Modern China. New York: Charles Scribner’s Sons.
Howell, J. (2015). Shall we dance? Welfarist incorporation and the politics of
state-labour NGO relations. The China Quarterly, 223, 702–723.
Howell, J., & Pearce, J. (2001). Civil Society and Development: A Critical
Exploration. Boulder: Lynne Rienner.
Huang, X. (2015). Four worlds of welfare: Understanding subnational variation
in Chinese social health insurance. The China Quarterly, 222, 449–474.
1 INTRODUCTION 31
Kilby, P. (2006). Accountability for empowerment: Dilemmas facing non-

governmental organisations. World Development, 34(6), 951–963.
Lewis, D. (2007). The Management of Non-governmental Development
Organisations (2nd ed.). London: Routledge.
Linz, J. (1970). An authoritarian regime: Spain. In E. Allardt & S. Rokkan
(Eds.), Mass Politics: Studies in Political Sociology. New York: The Free Press.
Lu, Y. Y. (2009). Non-governmental Organisations in China: The Rise of
Dependent Autonomy. London: Routledge.
Ma, S. (1994). The Chinese discourse on civil society. The China Quarterly, 137,
180–193.
Mason, J. (2002). Qualitative Researching. London: Sage.
Mattei, P. (2009). Restructuring Welfare Organizations in Europe, from
Democracy to Good Management? London: Macmillan.
Nathan, A. J. (2003). Authoritarian resilience. Journal of Democracy, 14(1), 6–17.
Nathan, A. J. (2009). Authoritarian impermanence. Journal of Democracy, 20(3), 37–40.
North, D. C. (1990). Institutions, Institutional Change and Economic
Performance. Cambridge: Cambridge University Press.
O’Donnell, G. (1979). Modernisation and Bureaucratic Authoritarianism:
Studies in South American Politics. Berkeley: California University Press.
Perlmutter, A. (1981). Modern Authoritarianism: A Comparative Institutional
Analysis. New Haven: Yale University Press.
Salamon, L., & Anheier, H. (1992). In search of the non-profit sector, I: The
question of definitions. VOLUNTAS: International Journal of Voluntary and
Nonprofit Organizations, 13(2), 125–152.
Samuel, P. Huntington., & Clement, H. Moore, eds. (1970). Authoritarian
Politics in Modern Society: The Dynamics of Established One-Party Systems. New
York: Basic Books.
Shang, X., Wu, X., & Wu, Y. (2005). Welfare provision to vulnerable children:
The missing role of the state. The China Quarterly, 181, 122–136.
Shier, H. (2010). Children as public actors: Navigating the tensions. Children
and Society, 24(1), 24–37.
Unger, J. (Ed.). (2008). Associations and the Chinese State: Contested Spaces.
Armonk: M. E. Sharpe.
Van Evera, S. (1997). Guide to Methods for Students of Political Science. Ithaca:
University of Cornell Press.
White, G., Howell, J., & Shang, X. (1996). In Search of Civil Society: Market
Reform and Social Change in Contemporary China. Oxford: Clarendon Press.
Wintrobe, R. (1998). The Political Economy of Dictatorship. Cambridge:
Yin, R. K. (1998). Case Study Research: Design and Methods. London: Sage.
Zhong, L., & Fisher, K. R. (2017). Participation and Chinese non-government
organization accountability. International Journal of Sociology and Social pol-
icy, 37(13/14), 743–754.
CHAPTER 2
Setting the Theoretical Scene
In exploring the issue of accountability and legitimacy of non-governmental

organisations (NGOs) in China, three sets of literature have been par-
ticularly useful. These relate to the rich body of writing on accountability,
participation, and institutional change. Much of this work has focused its
attention on liberal democratic states and the government–citizen relation-
ship, yielding an array of theories and incisive debates about the conceptual-
isation of accountability. The global proliferation of NGOs from the 1990s
onwards led to mounting concerns about the legitimacy and accountability
of NGOs, sprouting a concomitant new layer of research and writing on
these issues. This led to a more comprehensive understanding of account-
ability that recognised its multiple forms, developed typologies of account-
ability and linked accountability to issues of participation, power, and
empowerment. The focus on forms of accountability was useful for NGOs
seeking to strengthen their accountability systems. However, there was
little attention given to the politics around the making of accountability,
why certain hierarchies of accountability emerged or why demands of some
account holders were given priority over others, or the relationship between
accountability and legitimacy.
Compared to the breadth of writing on accountability in liberal
democratic regimes, there was a dearth of research on accountability
or institutional change in authoritarian regimes. Studies of NGOs in
authoritarian contexts tended to focus on their relations with the state

https://doi.org/10.1007/978-3-319-90221-0_2
34 J. HOWELL ET AL.
and issues of repression, rights, and resistance (Chen and Tang 2013;
Chan 2012; Lee and Shen 2011; Froissart 2011; Cheng et al. 2010;
Chen 2003, 2004). Questions of institutional change were centred on
the prospects of regime change and eventual democratisation rather than
understanding how authoritarian institutions could undergo gradual
institutional change to survive. Moreover, broader normative studies on
civil society linked the emergence of NGOs with processes of democra-
tisation. In the last decade there has been growing interest in why some
authoritarian regimes survive, stimulating research also on China and
the adaptive features of the Chinese Communist Party (CCP). Given
the difficulties for international researchers in doing field-research in
authoritarian contexts, empirical studies of NGOs, and other civil society
organisations were limited.
This chapter reviews the extensive work on accountability, participa-
tion and institutional change in liberal democratic regimes, and the more
limited body of research on authoritarian regimes. It builds upon these
bodies of literature to develop a framework for analysing the politics of
making accountability and legitimacy in NGOs in authoritarian contexts.
It begins by exploring ideas about accountability, the extension of these
concepts and analyses to NGOs and the links between participation,
and accountability. It reviews approaches to accountability in authoritar-
ian regimes, and specifically in China. It then applies concepts used in
theories of gradual institutional change in liberal democratic regimes to
the context of authoritarian China. Finally, it develops a framework for
analysing the crafting of accountability and legitimacy by NGOs in an
authoritarian context. In particular it underlines the salience of the mak-
ing of second-order accountability in Chinese NGOs, where the diffi-
culties in achieving first-order accountability through registration, hence
legal status, prove to be a significant barrier to their further development
and legitimacy. It queries not only static and rigid notions of authoritari-
anism but also assumptions about the power of the state to singly set the
terms of NGO development.
What Is Accountability?
Whilst few would dispute the need and importance of holding govern-
ments, NGOs, or corporations to account, there are conceptual, theo-
retical, and practical reasons why operationalising this can prove tricky
and complex. Conceptually, accountability is a contested term that is
2 SETTING THE THEORETICAL SCENE 35
stretched in multiple ways and used for different purposes. Like other
social science concepts such as civil society, rights, and democratisation,
the concept of accountability bears a halo of righteousness, justice, and
sanctity. It becomes appropriated by different actors for different pur-
poses, endowed with multiple and often conflicting meanings, given
different empirical referents and operationalised in a variety of ways. It
litters political and policy discourse around politics and governance and
is common currency in international development institutions, be they
governmental, multilateral or non-governmental. Bovens (2007, p. 449)
describes its usage in less savoury terms as resembling ‘a dustbin filled
with good intentions, loosely defined concepts and vague images of
good governance’, whilst Pollitt and Hupe (2011) refer to it as a ‘magi-
cal concept’ that is broad, hard to resist, and widely used, yet can only be
usefully applied when doused with a large jug of cultural and contextual
content.
As introduced in Chapter 1, accountability is not just a simple issue
of who can demand accountability, but who has the capacity, power, and
authority to do so. This inevitably then leads to questions about whether
the right to demand accountability is formally guaranteed through laws,
constitution, or regulations and what other informal sources of rights or
moral authority enable the less powerful to demand accountability. For
accountability to be effective, it is not sufficient that the government
provide adequate reasons for their behaviour, but citizens should also
be invested with the power to enforce sanctions, when the organisation
held accountable falls below the agreed performance bar. The ability,
possibility, and power to express voice, deliberate, participate, be con-
sulted and have access to information are important ingredients in real-
ising accountability. As such, they are essential ex-ante elements in the
accountability process.
The bulk of theoretical literature on accountability has arisen in the
context of democratic states and has thus been classically concerned
with political accountability, that is, the accountability of government
to elected officials and of politicians to citizens (Norris 2014). In dem-
ocratic states the prime mechanism for operationalising accountability
between politicians and citizens is through regular elections that ena-
ble citizens to remove governments. Senior civil servants are answer-
able for their work to ministers, who in turn are vertically accountable
to parliament and elected politicians (Mattei 2007, p. 366). Democratic
regimes deploy not only vertical forms of accountability such as citizens
36 J. HOWELL ET AL.
demanding accountability from their governments through the courts or

voting system or politicians demanding bureaucratic accountability from
their civil servants, but also horizontal structures of accountability such
as checks and balances between the executive and the legislature, organs
that are relatively equally positioned. Such powers are enshrined in laws
that guarantee and protect the rights of citizens to demand accountabil-
ity whether through the ballot-box or through the courts. Furthermore,
the media and civil society play an essential role in democratic regimes
in exposing government incompetence, abuse, and improprieties, and in
lending support to citizens demanding accountability.
Over time the complexity of accountability has increased in response
to the growth of the state, the expanding role of non-governmental
actors and globalisation. As state functions have expanded, the
importance of bureaucratic accountability, that is the accountabil-

ity of lower-level officials to higher levels in the government, has risen.
In particular the development of welfare states in the post-World War
II era and the accompanying volumes of expenditure have increased
the demand for bureaucratic or administrative accountability. Since the
1970s the role of non-governmental actors in welfare service provision,
campaigning, policy advocacy, and rights-based work both domestically
and globally has grown exponentially (Hilhorst 2003; Howell and Pearce
2001; Van Rooy 1998; Hulme and Edwards 1997). The participatory
approaches often adopted by non-governmental actors have fostered
research on accountability to users or downward accountability (Norris
2014, p. 206).
The rise of new public management approaches to public service
provision involving decentralisation, managerialisation, privatisation,
and contractualisation, has led to the pluralisation of service providers,
extending to not just the for-profit sector but also not-for-profit organ-
isations, variously known as NGOs, voluntary sector organisations, and
charitable organisations.1 Moreover, relationships of procurement and
subcontracting have focused attention on financial accountability over
and above other types of accountability. The rapid development of new
communications technologies and means of transport has underpinned
the increasing globalisation of economies and societies, with goods,
peoples, ideas, and services increasingly enmeshed in multiple layers of
relationships that complicate the processes of accountability (Scholte
2005, 2011; Charnovitz 2007; Ebrahim 2003, p. 814; Najam 1996). As
Mattei (2007, p. 367) notes, the results-oriented managerial approach
of new public management coupled with the delegation of authority to

autonomous non-governmental or quasi-governmental agencies has led
to tensions between different types of accountability. In particular, the
ascendancy of financial accountability has begun to overshadow the con-
tinuing relevance of political accountability, and specifically of civil serv-
ants in quasi-governmental agencies to ministers.
The expansion of the welfare state, the rise of new public management
approaches, the development of non-governmental public actors and
global processes have extended research on accountability both in rela-
tion to the range of potential actors demanding accountability and being
held to account and the different types of accountability. Accountability
has been sliced into a number of pieces. Financial accountability, for
example, requires government officials and NGOs to justify their use of
budgets, and has come to particular prominence in results-based new
public management. Organisational or managerial accountability empha-
sises accountability for the outcomes and processes of government agen-
cies and NGOs, including the use of finances, the delivery of outputs,
the efficiency and effectiveness of the organisation. Societal or down-
ward accountability refers to the actions of civil society groups, social
movements, individual citizens, and the media in holding government
agencies to account, raising public issues, and exposing injustices and
wrongdoings (Norris 2014, p. 206; World Bank 2005; Ackerman 2004;
Smulovitz and Peruzzotti 2000). User accountability, that is, the practice
of users holding providers of services to account, is a type of downward
accountability (Kilby 2006). In the context of new public management
approaches to service delivery, the discourse of user accountability tilts
towards ‘client’ or ‘customer’ accountability, terms reflective of mar-
ket principles. Democratic accountability requires citizens, the public,
and service users to hold government agencies and NGOs to account.
Where the exercise of accountability leads an actor to change behaviour
in response to new information gained through monitoring, policy eval-
uation, data, or peer review and to be sanctioned for ignoring such infor-
mation that might otherwise have improved performance, accountability
is reflexive (Norris 2014, p. 207).
These different types of accountability do not, however, garner a sim-
ilar amount of attention, either in practice or in research, with greater
emphasis increasingly placed on financial accountability and to a much
lesser on user accountability. Furthermore, they can also be in ten-
sion with each other. Apart from financial accountability and political
38 J. HOWELL ET AL.
accountability as noted above (Mattei 2007), there are also tensions

between user accountability and financial accountability, societal account-
ability and political accountability, horizontal and user accountability.
In organisations receiving multiple sources of funding, hence numerous
principals, juggling the diverse deadlines, reporting formats, financial
categories, and other reporting requirements can lead to administrative
overload and the prioritisation of delivering account upward to funders
over downward to users. Willems and Van Dooren (2007, pp. 1032–
1033), however, contend that multiple accountabilities need not be
negative as they increase the chance that a person or organisation is held
to account for their actions, provided the costs thereof can be reduced.
There are also disparities of power between funders and recipients of
funding, where accountability lines flow vertically upward but not down-
ward from funder to recipient (Bendell and Cox 2006). Similarly, the
increasing pressure from civil society organisations on governments and
global institutions has provoked criticism from governmental represent-
atives and within academe about the representativeness and legitimacy of
civil society groups to make claims on behalf of others (Anderson 2009;
Kovach 2007; Peruzzotti 2007, pp. 43–60; Fox and Brown 1998).
Professionals such as therapists, social workers, doctors may render
account horizontally to other professionals, often through professional
associations, but may be reluctant to ‘renounce their expert power’ to
facilitate open accountability from their ‘clients’ (Leung 2008, p. 534).
Furthermore there can be issues around the mutual dependency
between donors and recipients which can compromise the monitoring
and enforcement of accountability. Institutional donors need to demon-
strate to their own funders and supporters successful implementation of
their programmes to justify their partnerships and activities, whilst donor
recipients need the financial and other support from donors. They thus
have a mutual interest in overlooking some aspects of accountability to
ensure the continuation of their partnership and achievement of their
goals.
These different types of accountability are premised on the assump-
tion that certain preconditions exist that can make them realisable.
These include open information, equal and ready access to informa-
tion, and knowledge of the processes for demanding accountability.
They assume not only that channels for the expression of accountabil-
ity demands exist but that citizens, the public, and service users also
are empowered to make such demands in the first place and formally or
informally summon sanctions to alter behaviour. Legal or regulatory

requirements for an organisation to be accountable strengthen the posi-
tion of account-holders. However, often there are no such requirements
for downward accountability to users (Kilby 2006, p. 952).
This assumption of empowerment and equality of access to account-
ability is fundamental to understanding how accountability processes
unfold on the ground. Marginalisation, poverty, stigma, and social differ-
entiation, be it in terms of gender, ethnicity, disability, class, or age, can
bias processes of accountability to the favour of more powerful groups
in society and to the prioritisation of different types of accountability.
Efforts to foster greater user participation in accountability processes
can be crucial in realising genuinely equal access to democratic account-
ability, as will be discussed later in this chapter. Furthermore, equality
of access and empowerment of citizens, the public, and service users are
particularly challenging in authoritarian contexts where the channels of
interest expression, the extent and power of civil society, access to open
information, and the independence of the media are severely limited.
In brief, the shifts in the institutional landscape of states, markets, and
societies have required a reworking of the notion of accountability to
recognise the multiplicity of actors, levels, power relations, and degrees
of complexity. It has stimulated research into the tensions and practical
difficulties of managing multiple accountabilities and into the impact of
the pluralising web of those to be held to account and those demanding
accountability (Edwards and Hulme 1995). As non-governmental actors
and user participation are an important part of the story woven in the
case-study chapters of this book, it is worth reflecting on the particu-
lar challenges that accompany seeking accountability from NGOs and
in empowering citizens, the public, and service users to participate in
accountability processes.
Accountability and NGOs

As discussed above, most conventional theoretical treatments of demo-
cratic political accountability posit a binary relationship between two par-
ties, A and B, with A usually referring to the government and B to the
citizen. Once the notion is extended to non-state actors such as com-
panies or NGOs the relationship becomes more muddied and complex.
For NGOs the questions of ‘who is to be held accountable and who
can demand accountability’ is much more complicated than the simple
40 J. HOWELL ET AL.
formula of A and B. Whilst governments in liberal democratic regimes

are accountable to an electorate and companies to their shareholders,
NGOs are potentially accountable to a variety of domestic and external
donors, the public, central and local governments, the staff employed
in the organisations, and the beneficiaries of NGO activities, services,
and campaigns. There is accountability upward to funders, accountabil-
ity downward to beneficiaries and accountability horizontally to other
organisations in the non-governmental sphere and to professional bod-
ies. Moreover, NGOs are often required to be accountable to a variety
of donors, including individual donors, domestic governmental and
non-governmental funders, international development and financial insti-
tutions, and international foundations, which have different sources of
power and leverage. This problem of ‘many cooks’ begs the question as
to whether purportedly value-driven NGOs are any more accountable to
their users than say governments to their citizens or firms to their share-
holders and consumers.
When we consider different types of accountability and the empha-
ses these are given, then the application of the concept of accountabil-
ity to NGOs becomes more diffuse and multilayered. This complexity
can encourage a tendency to simplify and reduce the areas of account-
ability granted attention, leading to hierarchies of accountability, with
financial accountability at one end and user accountability at the other.
The amenability of different types of accountability to quantitative meas-
urement is one factor in shaping the hierarchies that emerge. It is much
easier to account for the number of schools built or appointments with
physiotherapists provided than to assess the effects of interventions
on the empowerment or confidence of users, or on their capacities to
learn or express voice. The latter are qualitative outcomes that may not
immediately manifest themselves and are difficult to measure or quan-
tify. Managerial and financial accountability require NGOs to answer to
their boards and trustees, multiple donors and staff about the honest and
appropriate use of funds, outcomes, and processes of the organisation,
such as the delivery of outputs and the efficiency and effectiveness of the
organisation. Democratic accountability requires NGOs to be answera-
ble to staff, beneficiaries, members, and users for the degree of demo-
cratic openness, transparency, and participation in the organisation and
assumes the availability of channels of participation that allow users to
hold NGOs to account and means of imposing sanctions. Unlike gov-
ernments NGOs have had to become increasingly accountable for the
images they create about the social groups and issues they work for.
Image accountability requires NGOs to be responsible to the general
public, its members and donors about the way it portrays issues, its use
of images of say children or of victims of disasters, or famines to raise
funds (Fehrenbach and Rodogno 2016; Dogra 2012).
The multiplicity of actors that are potentially involved in hold-
ing NGOs to account not only complicates the issue of accountability
(Najam 1996, p. 350), but also lays bare the underlying power relation-
ship that infuses accountability relations and leads to certain types of
accountability becoming privileged over others. Who has ultimate power
and authority to demand accountability from NGOs and enforce it?
What incentives drive principals to demand account? What institutional
rules exist to govern processes of accountability and how do NGOs nav-
igate competing rules, obligations, and authorities? Who has access to
information? This raises questions around whose accountability should
be and actually is prioritised, and whether users are empowered to seek
redress and justification of NGOs’ behaviour and actions.
Where users of services are relatively marginalised and disadvantaged
social groups, accountability processes can have built-in biases based on
assumptions of lack of capability and professional expertise that serve to
exclude such groups. Moreover, asymmetries of information between
users and service providers render users less able to voice their concerns
and seek account. Such ‘bounded rationality’ reflects the influence of
power relations and social biases (Brett 1993, p. 287). NGOs, like other
organisations in society, are culturally embedded organisations that are
infused with and constituted by social norms, values, expectations, and
power relations which work to privilege certain voices and interests
over others. The absence of laws and regulations requiring NGOs to be
accountable to their users means that in practice downward accounta-
bility is a matter of discretion. This also raises issues for NGOs about
how best to navigate multiple accountabilities, whether their systems of
accountability contain embedded biases against disadvantaged groups,
and who and how they determine the standards and norms against which
they may be held to account.
At the practical level there are issues around the systems and meth-
ods of enabling accountability, how effective these are, whether they
can be applied, how they are assessed, and the source of their authority.
As indicated above, in democratic regimes, there are constitutional and
42 J. HOWELL ET AL.
legal frameworks shaping the accountability relationship between citizen

and government. However, in the case of non-governmental actors the
sources of authority, processes, and systems for holding these to account,
and the potential range of sanctions may be only partially institution-
alised. Moreover, the power relations between the account holder and
the account provider may lack any legal basis, making the operationali-
sation and outcomes of such relations even more contingent on the play
of power and therefore the possibilities for systemic bias against mar-
ginalised groups even greater. There are also practical matters around
enforcement. Whilst penalties for financial impropriety can be assigned
through regulatory bodies or courts, it is less clear how beneficiaries
could enforce penalties for incompetence in project management or for
the use of images that characterise a country simplistically as poverty-
stricken and deserving of charity. Large donors are better equipped
than individual donors to hold NGOs to account and implement sanc-
tions through the withdrawal of funding as they have the authority and
resources to initiate monitoring and evaluation processes. Individual
donors like users have bounded rationality due to asymmetries of infor-
mation. Moreover, individual donors to NGOs are not members and
cannot avail themselves of the formal processes of accountability that a
membership structure provides. These issues around institutionalisation
are even more acute in authoritarian regimes where channels for citizens,
the public, and users to hold government, let alone NGOs, to account
are sharply limited.
Accountability and User Participation

Underlying the amount of emphasis given to any of these different
types of accountability are relationships of power between principal and
agent, that is between account-holders and account-givers. In many
democratic regimes procedural rather than substantive democracy
prevails. As a result the degree of democratisation of different organ-
isations can vary. Thus whilst citizens may have the democratic power
to vote out a government, their capacity to hold different kinds of
organisations to account such as hospitals, schools, and transport ser-
vices can be sharply circumscribed for cultural, institutional, and his-
torical reasons. Seeking accountability requires the empowerment of
users, and downward accountability, to press for enhanced participa-
tion ex-ante and ex-post, and the right to redress and thus for a broader,
substantive democratisation of society. Without addressing unequal

power relations, participation may be reduced to a pathetic ‘sham ritual’,
as Najam (1996, p. 346) observed.
Participation theory argues that accountability, quality of service,
and user outcomes can be linked by empowering service users so that
they are able to influence practice and policy through processes rang-
ing from feedback to user participation in the design of service (Speer
2012; Martin 2011; LeRoux 2009). However, as Brett (2003) argues, it
is important to recognise that in practice participation often falls short of
the claims made for it by participation enthusiasts. Participation is a spec-
trum with weak participation such as consultation and providing infor-
mation at one end and strong participation that involves empowering
beneficiaries to partake in policy design, planning, and decision-making
at the other (Brett 2003, p. 5). Even where an organisation may lie more
towards the strong end of the spectrum, participation alone cannot bring
about social transformation, nor would direct control lead to greater effi-
ciency and effectiveness.
There is also the matter whether different types of issues such as child
welfare, environmental protection, labour rights, or humanitarian assis-
tance involve different sets of actors and power relations that lead to dif-
ferent systems and hierarchies of accountability and particular types of
systemic biases that Goetz and Jenkins (2005) allude to. Moreover, to
what extent does the empowerment of users and beneficiaries for differ-
ent domains such as labour or child welfare invoke specific political, cul-
tural, and social challenges. For example, empowering workers to seek
redress from employers might involve new regulations and laws, the
implementation of which might run counter to government investment
policies. Similarly, giving children voice to demand accountability from
service providers can challenge fundamental social hierarchies and power
relations between adult and child, old and young and lead to outcomes
that ultimately disadvantage and disenfranchise children.
Accountability in Authoritarian Regimes

Compared to research on accountability in liberal democratic regimes,
there is relatively little written about accountability systems in authori-
tarian regimes, particularly in relation to NGOs. Nevertheless, just as in
liberal democracies, accountability is important to monitor and alter gov-
ernment behaviour and to curb excess, abuse, and injustices arising from
44 J. HOWELL ET AL.
misuse of power (Bovens 2007, p. 462). It is also important as a means

for improving the effectiveness and quality of public administration and
thus ultimately enhancing the legitimacy of the regime. In newly democ-
ratising regimes, where the institutional scaffolding of democracy is frag-
ile and incomplete, or in authoritarian regimes where the right of citizens
to vote out or challenge their government is seriously constrained, the
capacity of citizens to demand accountability is likely to be severely com-
promised. In authoritarian regimes the limits on demanding account-
ability and the garnering of information about citizens’ preferences and
priorities create particular challenges for scrutiny, for curbing the concen-
tration of power and for learning from policy mistakes. Furthermore, in
the absence of a vibrant and plural civil society, an independent media and
electoral systems for changing governments, authoritarian regimes face
an information deficit about the views, priorities, and preferences of cit-
izens (Cassani 2017; Dukalskis and Gerschewski 2017; Wintrobe 1998).
In China the intermediary institutions during the planning era that pro-
vided some means of gauging citizens’ needs and views such as the mass
organisations—All-China Federation of Trades Unions or the All-China
Women’s Federation—are no longer able to reach out to an increas-
ingly diverse population. Finding new ways of gathering information
about citizens’ concerns such as through opinion polls, public hearings,
or through NGO activity is important for keeping government informed
and able to adjust policies so as to mitigate discontent that could oth-
erwise affect regime stability. Theories of accountability thus need to be
adapted to describe and explain formal and informal processes of account-
ability, to identify the constraints and enabling factors, and to elucidate
the variables that combine to enhance citizens’ power to demand and
enforce accountability in weakly democratic and in authoritarian contexts.
Whilst authoritarian states vary in their degree of control, sources of
authority and power, party structures and historical trajectories, they
have in common a pattern of governance that restricts the spaces for
civil society organisations, controls the media, limits the avenues for cit-
izen participation, and curbs the freedom of expression and association
(Diamond 2002; Brooker 2000; Wintrope 1998; Linz 1970). This in
turn affects the ‘who, from whom, how and about what’ dimensions of
accountability. In other words, in an authoritarian regime, be it a mili-
tary or one-Party state, the capacity and powers of citizens to formally
demand accountability is constrained by the lack of guaranteed and pro-
tected rights, the limited mix of structures and processes that can be
deployed to pursue accountability, the standards and norms that may be

leveraged, and the range of issues that can be challenged without incur-
ring repression. In some authoritarian contexts appealing to international
norms and standards may invoke suspicion and hostility on the part of
government officials, thus pushing citizens to find imaginative and politi-
cally acceptable ways of framing their grievances against the government.
However, this paints a somewhat static picture of governance in
authoritarian regimes. External factors such as increasing engagement
in the global economy and international institutions can put greater
and new demands on authoritarian regimes. Processes of urbanisation,
industrialisation, and marketisation change the social fabric of society and
reconfigure the social constellations of power in enduring authoritarian
regimes. Denser global links between civic actors in authoritarian regimes
and external non-governmental players can alter the dynamic of civil
society-state relations, strengthening, the hand of civil actors and shap-
ing new demands. In enduring socialist states such as China and Vietnam
(less so in Cuba), processes of globalisation, marketisation, and industri-
alisation have in the last three decades fundamentally altered the struc-
ture of the society and economy, changed social norms and values, and
have been accompanied by some, albeit limited, changes in governance.
In China, for example, the CCP has proved adept at altering its structure
and processes of governance to accommodate socio-economic change
and co-opt new actors who could potentially challenge its authority. In
the absence of contested multi-party elections the Party has introduced
new forms of public participation in policy processes, new laws to enable
citizens to hold government officials to account, and new policies and
measures to improve the transparency of governance, potentially impor-
tant ingredients in realising meaningful accountability.
Accountability in China
Recognising the dynamic and adaptive nature of authoritarianism
in China, how then have accountability processes changed or not?
Compared with research into accountability systems in democratic
regimes, far less attention has been paid to accountability in China.
This is in part because of the absence of competitive national elections
as a procedural mechanism of accountability and in part because of the
black box nature of elite Chinese politics. Research into accountabil-
ity has thus focused on other parts of the political system, in particular
46 J. HOWELL ET AL.
village elections, the cadre responsibility system, intra-Party elections,

the petitioning system, new forms of rights-based protest and new pro-
cesses for ensuring accountability of the state. Most of the literature on
village elections has centred on election procedures, their transparency,
manipulation by higher-level officials, corruption and their potential role
in developing democracy (Landry et al. 2010; Luo et al. 2010; Howell
2007). The focus has been on procedural accountability at the expense
of substantive accountability. Compared to writing on election proce-
dures, there has been relatively less research on post-election account-
ability processes, the effectiveness of accountability processes such as
village assemblies, or the informal means by which villagers seek redress
on an everyday basis (Jacka and Wu 2015; Looney 2015; O’Brien and
Han 2009; Yao 2009).
Following the introduction of the cadre responsibility system, there
has been a growing interest in intra-Party/state accountability, whereby
cadres are held responsible to higher levels for the performance of their
work. Certain tasks such as economic development and stability are given
particular priority and recognised in the points-based reward system that
feeds into the promotion process. This type of vertical accountability
facilitates control by higher levels of government over lower levels in a
context of economic and administrative decentralisation. Work in this
area has focused on describing and analysing the different reward systems
(Tan 2014; Edin 2003a, b). It is no mean task given the opacity of elite
politics and the Party machinery, the goals, functions, and priorities of
the evaluation system (Heimer 2006), the effectiveness of this mecha-
nism in maintaining Party rule (Whiting 2004), and issues of corruption
(Burns and Wang 2010). The system does not, however, provide any way
of evaluating public perceptions of cadre performance on an everyday
basis (O’Brien and Li 1999, pp. 174–175), except in so far as instability
leads to protests and riots.
Other forms of bureaucratic accountability have also emerged. Ma
(2009), for example, explores the feasibility of financial accountability
in a non-electoral system. His research highlights the impact of budget-
ary reforms in China in reducing the opportunities for corruption. Such
reform has included centralisation of financial budgets, laying down the
rules governing authority to distribute funds, the drawing up of budg-
ets and detailing of revenue and expenditure, and enhancing horizontal
accountability through the National People’s Congress in its role of scru-
tinising and approving budgets.
The petitioning system has long been used as a formal mechanism

whereby citizens can demand accountability from local cadres and seek
redress for perceived injustices (Minzner 2006; Cai 2004; O’Brien and
Li 2004). Dating back to imperial times, the petitioning system has
undergone numerous modifications in the reform period aimed at mak-
ing it more efficient and effective. It is a key form of ‘societal account-
ability’, that is, a vertical mechanism whereby individuals and social
groups can raise awareness of public issues, report on local officials and
expose government malfeasances (Smulovitz and Peruzzotti 2000).
It involves by-passing lower levels of government to seek redress from
higher-level authorities. This may be done in parallel to, as well as, or as
a substitute for legal channels, though the source of authority for redress
lies not in the legal system but with the Party/state. In the post-1949
period it mainly takes the form of citizens going to the ‘letters and visits’
offices in different levels of government and Party organs, including local
people’s congresses, courts and discipline commissions (Minzner 2006,
p. 103; Cai 2004, pp. 431–432).
Petitioning remains a more common way than the law courts for
seeking redress, resting as it does on the principle of rule by man rather
than rule by law, or appeal to personal intervention by leaders rather
than assertion of law-based rights (Minzner 2006, p. 160). Despite its
long trajectory the petitioning system is by no means smooth, leading
to endless cat-and-mouse games between citizens and different levels
and branches of government (Thireau and Hua 2003). When citizens
become frustrated for justice at local levels, they take their grievances
upward to Beijing, often living in peripheral, run-down suburbs of the
capital to press higher-level authorities on a daily basis for redress of their
grievances. In some extreme cases petitioners have been known to com-
mit self-immolation as their final act of seeking redress (Minzner 2006,
p. 104). Despite the popularity of petitioning as a redress mechanism,
it is not a sure means to success. In a survey cited by Minzner (2006,
p. 106) only 0.2% of petitioners surveyed had had success in address-
ing their grievances. As Minzer (2006, p. 107) contends, this is partly
explained by the fact that petitioning serves as a ‘multipurpose tool of
governance’ aimed not only at resolving disputes and monitoring local
officials’ behaviour but also at feeding information upward about social
stability and managing legitimacy.
Since the 1990s the Communist Party has been experimenting with
new ways of enabling citizens to hold government to account and
48 J. HOWELL ET AL.
strengthening its procedural legitimacy by demonstrating responsive-

ness (Dukalskis and Gerschewski 2017). These include public hearings
(Ma 2012; Zhong and Mol 2008), deliberative polling and consultation
(He and Warren 2011; Fishkin et al. 2010), regulatory changes such as
the Regulations on Open Government Information of 2007 (effective
from 2008), citizen surveys (Yu 2010), online governance sites (Ma
2012) and citizen participatory budgeting (Duckett and Hua 2013; He
2011; Fishkin et al. 2010; He and Thogersen 2010). Such experiments
relate to a broad notion of accountability where input processes such as
deliberation seek to stimulate greater responsiveness on the part of the
actor being held to account. In this way it has added new layers of for-
mal accountability processes in an effort to bolster legitimacy without
incurring the risks of regime change. As Nathan (2003) argues, innova-
tion in input institutions is a form of adaptive governance that enables
regime resilience. It was dynamic political entrepreneurs who lay behind
the experiments in citizen participatory budgeting that were carried out
in Wenling County and Wuxi City, Zhejiang province, and Harbin City
in Heilongjiang Province (Yan and Ge 2016; Ma 2009). However, no
other local governments in China have sought to replicate these mod-
els of participatory budgeting, and their continuity has been vulnerable
to changes in leadership (Ma 2009, p. 171), underlining the importance
of institutionalisation for the longer-term replication and success of such
innovations (Wu and Wang 2012, p. 276).
Similar efforts to promote greater transparency through the 2007
Open Government Information Regulations have also been thwarted
by local officials who are reluctant to disclose information and interpret
the regulations in such as a way as to hinder citizen access to informa-
tion. Illustrative of this is the case of environmental campaigners who
used these regulations to request the Ministry of Agriculture to release
an investigative document concerning an endangered fish reserve at
Xiaonanhai Dam in Chongqing. Their request was refused on the
grounds that such regulations did not cover procedural information
(Geall 2012). Indeed such instances of failure to gain requested infor-
mation is the norm rather than the exception. Vague clauses in the
regulations that exempt the requirement to disclose information pro-
vide cautious local officials with the key to refuse any citizen requests.
Specifically, Article 8 of the regulations states that disclosure should
not be given if it endangers ‘state, public or economic security or social
stability’. Moreover, as Yan and Ge (2016, p. 226) note, even where
there are serious innovative efforts to enhance transparency, as with the

Jiaozuo City model of budget information transparency, these tend to
be top-down, one-way initiatives with limited room for citizen participa-
tion in monitoring and feedback. Furthermore, the ability to access such
information may depend also on education levels and availability of social
media technology, creating an in-built bias against those with lower
socio-economic status (Yan and Ge 2016, p. 228). Such transparency
efforts as in Jiaozuo and participatory budgeting as in the case of Wuxi
have not served to empower citizens in a meaningful way, thus limiting
the effectiveness of innovative experiments in improving governance and
accountability (Wu and Wang 2012, pp. 275–277). The existence and
development of formal accountability processes is no guarantee that they
will be effective or enforced.
As Ma (2012) observes, the above-forms of accountability are state-
led. New forms of societal accountability have also emerged in the
reform period. These include citizens exposing through social media
various incidences of government corruption, social movements around
local environmental issues such as the slow walk protest in Xiamen
against the location of a polluting industry, collaboration between NGOs
and the media in exposing the risks of policies that threaten the envi-
ronment, such as around the extensively reported campaign against the
Nujiang Dam in Yunnan Province (Ma 2012, p. 114). Other forms are
the emergence of watchdog NGOs around issues of government trans-
parency, NGOs exposing rights issues (such as the organisation, Yi
Renping) and NGOs leveraging personal relations with local and central
People’s Congress delegates to advocate policy changes. As will be seen
in the case-studies, NGOs, too, deploy the new opportunities created
through the Internet and social media to promote their visibility, build
their reputation, and invite accountability.
Accountability and Institutional Change

These efforts at enhancing transparency, developing new forms of for-
mal accountability and encouraging citizen participation have been dis-
cussed within the broader framework of Party adaptation. Writers such as
Heilmann (2009), Heilmann and Perry (2011), Nathan (2003, 2009)
and Shambaugh (2008) have highlighted the Party’s ability to adapt itself
to changing circumstances as a key reason for its durability and resil-
ience, as compared to other socialist states such as the Soviet Republic.
50 J. HOWELL ET AL.
In addressing the issue of enduring authoritarianism they also implicitly

draw attention to the importance of gradual rather than sudden, abrupt
institutional change. Scholars of gradual institutional change in lib-
eral democracies such as Mahoney and Thelen (2010), Hacker (2010),
Campbell (2004) and Pierson (2000) have identified key ways in which
this happens, including concepts such as drift, conversion, and layer-
ing. Particularly relevant in this book is Hacker’s concept of ‘drift’ and
Mahoney and Thelen’s concept of ‘layering’. Drift refers to rules that
remain the same but may not be acted upon despite changing exter-
nal circumstances, creating opportunities for informal changes to rules.
Layering refers to the within-system adjustment or revision of existing
rules (Mahoney and Thelen 2010, pp. 16–17).2
Gradual institutional change is evident in the reaction to NGO reg-
istration practices in China. As discussed in Chapter 3, the registration
requirements for NGOs proved in practice too onerous for NGOs with
the result that most NGOs did not attempt to register and the num-
bers of unregistered NGOs far exceeded that of registered NGOs. On
the one hand local government officials were often reluctant to register
NGOs because of the risk that they might pose threats to social stability
and thus tarnish their career prospects under the cadre appraisal system.
On the other hand, some local government officials also recognised the
instrumental benefit to the state of NGOs that effectively took on gov-
ernment functions, met unaddressed local needs, and provided a source
of information about citizens’ concerns, needs, and opinions. By tolerat-
ing NGOs and even rewarding those deemed to provide worthy services,
local government officials partook in institutional change. In this way
the actual rules did not change but local government officials informally
instituted new rules. This created opportunities for NGOs to develop
their organisations and expand their activities. The idea of layering also
is of relevance to our analysis. The adjustment of the registration regula-
tions that permitted certain types of NGOs to register directly with the
Civil Affairs Bureau and forgo the need to find a government sponsor
began with experiments in pilot sites from 2008 onwards and was rolled
out nationwide in 2013 under the Xi administration. This adjustment
was a process of gradual institutional change through layering.
Institutional change is not confined to state institutions. The child
welfare NGOs that have emerged since the millennium have been
engaged in continual processes of institution-building, including in the
realm of accountability and legitimacy. Though formal accountability
processes in China are weak, this does not mean that accountability is
not practised or achieved in NGOs and governmental institutions. As
Tsai (2007) cogently argues, accountability without democracy is possi-
ble. Her work is instructive here in that she draws attention to the role of
informal rules in exercising accountability in quasi-governmental institu-
tions at village level.
Tsai sets out to explain why villages with similar levels of economic
development can differ in their provision of public goods and services.
At the core of her thesis is the role of informal institutions in political
systems such as authoritarian regimes with weak formal institutions of
accountability. She proposes that villages with solidary groups, such as
temples, that are both encompassing and embedding, are more likely to
have better governmental provision of public goods than villages without
such solidary groups. Solidary groups are based on shared ethical stand-
ards and moral obligations (Tsai 2007, p. 94). They are encompassing
when they include all citizens in a given governmental jurisdiction and
embedding when they involve local government officials in their activi-
ties (Tsai 2007, p. 96). Such solidary groups provide opportunities for
people, including local government officials, to acquire moral standing,
to demonstrate this and to be rewarded for this. Moral standing thus
creates incentives for local government officials to respond to citizens
and provide public goods and services that they value. It also provides
a resource of leverage for solidary groups to hold local government offi-
cials to account. Informal institutions such as solidary groups that are
encompassing and embedding can be ‘functionally equivalent’ (Tsai
2007, p. 269) to democratic institutions that enable accountability and
allow for rules to change.
Regardless of whether it be formal or informal institutions of account-
ability, the degree of user participation and democratisation of social
services in authoritarian regimes remains relatively circumscribed com-
pared to democratising, developing countries. In the greater Chinese
context Hong Kong policy already mandates user participation processes
for management accountability in NGOs and other providers of social
services (Leung 2008); in contrast mainland China lacks such man-
dates. Understanding the accountability of NGOs and other welfare
service providers in authoritarian contexts has thus to be located within
a broader analysis of the changing context and dynamics of authori-
tarian regimes and the scope for citizen participation. Norris (2014,
p. 214) notes two key limitations of downward and particularly user
52 J. HOWELL ET AL.
accountability. These are, respectively, the lack of citizen groups able to

push for accountability from above and the reluctance of government
officials to tolerate the influence of non-governmental groups. Both
these limitations are highly pertinent to authoritarian regimes and are
particularly prevalent in the case of China where countervailing power
is limited. This weakness renders top-down and horizontal accounta-
bility important, not just to ensure vertical and horizontal accounta-
bility but also to put pressure on governmental and non-governmental
account-givers to heed downward accountability.
Framework of Analysis of Accountability

This critical review of accountability theories in general and China spe-
cifically points to a number of gaps in the literature. There is a substan-
tial body of work on the theoretical dimensions of NGO accountability
as well as general, opinion-led statements on NGO accountability.
However, there are very few empirical studies of accountability in
Chinese NGOs, and how the institutions of accountability emerge,
how it is practised, and what aspects of accountability are prioritised.3
Furthermore, whilst there is a burgeoning literature on accountability
between higher and lower levels of government in China, there is a pau-
city of studies pertaining to NGO accountability and the impact of for-
eign funding on accountability. Although there is a substantial body of
empirical research on petitioning and increasingly on citizens’ recourse
to legal rights as ways of demanding government accountability, there
is little empirical research on the accountability of government officials
and NGO directors to users of services. Similarly, there is hardly any
empirical or conceptual research on accountability to users or beneficiar-
ies and clients demanding accountability in relation to services provided
by NGOs in China. There is also a yawning gap in general, and specif-
ically in studies of accountability in China, regarding the biases inher-
ent in particular forms of accountability. The vast majority of studies of
accountability, both generally and with regard to China, tend to privi-
lege the study of a certain type or types of accountability (Norris 2006,
2014).
Finally, most studies of accountability emphasise the achievement
of various formal dimensions of accountability as the starting point of
accountability. Such an approach masks the more subtle, hidden, and
dynamic informal processes of building accountability and legitimacy
that pre-empt the arrival of achieved formal processes and procedures of

accountability. In authoritarian states restrictive regulations govern inde-
pendent organising and limit the registration and legalisation of NGOs
that would allow formal procedural accountability to develop. In the
absence of ‘first-order’ legal status, ‘second-order’ accountability comes
to assume a particular salience in paving the way to more institutional-
ised accountability, and hence the survival, development, and legitimacy
of NGOs. Unmasking these processes of how institutions of accounta-
bility emerge is crucial in understanding how some NGOs in China are
able to survive and develop organisationally, attracting clients, funds and
public confidence in their work.
This book thus seeks to address some of these gaps in two ways. First,
it develops a theoretical framework for analysing the making of account-
ability and legitimacy by NGOs in China, contributing the concepts of
accountability capital and second-order accountability. These concepts
build from related ideas of social capital (Putnam 1993). They assume
that making accountability is a dynamic process that has to be rehearsed
and performed repeatedly to build, maintain, enhance, and restore legit-
imacy, as will be discussed later. Accountability is thus not about a static,
unchanging outcome. It also assumes that accountability and legitimacy
are culturally embedded, with norms, values, and cognitive understand-
ings varying across social contexts. We thus consider the broader context
underpinning different types of accountability such as the availability of
and access to information, opportunities and channels for user participa-
tion, consultative processes and capacity-building of account-givers and
account-holders, as well as the informal norms and values that shape the
development of NGOs. Deliberation, transparency, participation, and
consultation are thus key inputs into the different types of accountability
that can condition the relative effectiveness of accountability.
Second, in analysing the making of accountability, we draw on a
multi-dimensional framework that recognises a multiplicity of accounta-
bilities premised on relationships that vary in terms of power and status
and on instrumental means for demanding accountability. We use this as a
heuristic device to analyse the different types of accountability that com-
mand attention in NGOs and how certain types of accountability come
to be prioritised and emphasised at the expense of others. We thus con-
sider not only financial accountability but also managerial accountability,
horizontal accountability between agencies that are equally positioned
such as inter-county or inter-NGO accountability, vertical accountability
54 J. HOWELL ET AL.
between lower and higher levels of government, societal accountability

between government and citizen bodies, social movements and media,
and user accountability between users and providers of services. Adopting
a multi-dimensional framework has the advantage that it compensates for
the limitations of a uni- or bi-dimensional focus on one or two types of
accountability, which can miss vital elements of broader accountability
dynamics (Norris 2014, p. 206). Furthermore, it starts from the prem-
ise that realising accountability is not a simple, rational exercise but is a
dynamic relationship of negotiating power in a context where there are
often systemic biases against poor, marginalised, and disadvantaged
groups. The book thus considers not only the problems in operational-
ising different types of accountability, but also contributes ideas for facil-
itating the conditions that would lead to improved accountability and
thus outcomes.
As discussed in the introduction to the book, accountability refers to
a relationship between two actors (whether individuals or organisations),
whereby one demands accountability from the other, accompanied by
a system of rewards and sanctions. It is a power-laden, negotiated rela-
tionship, in that demanding accountability and responding to demands
for accountability is shaped by structures and processes of inequality. At
the core of the development of accountability is the imperative to gar-
ner trust, recognition, and confidence from the other, be the other
an organisation, the state, individual, or the general public. The pro-
cess of garnering trust, recognition, and confidence is thus the pro-
cess of developing accountability. Being responsive to others enables an
organisation to gain trust, confidence, and recognition in their capabil-
ities and operations, and ultimately to strengthen their legitimacy. This
involves the establishment of rules, both formal and informal, that link
the demand for accountability with the demonstration of being account-
able. Demonstrating formal accountability to a funder or governmental
body might include submitting regular reports, auditing of accounts,
or receiving inspections. These various inputs create a stock of account-
ability capital. For an NGO service provider to become accountable to
others, it first needs to identify for what and to whom it should be held
responsible, that is, who is entitled to demand accountability about what.
A service provider may thus be required to be accountable to a variety
of potential account-holders such as users, funders, government, the
general public (if the service it provides involves public interests), pro-
fessional bodies and its peers. The service provider can be legally and/or
morally obliged to respond to account-holders’ demands for account

ability. By demonstrating accountability, it can gain the trust and confi-
dence of account-holders such as government, users, funders in its work,
and competencies. Developing organisational accountability requires
developing processes and mechanisms that not only clarify who should
be responsible for what, but also who can demand accountability and for
what.
In an authoritarian state such as China where the regulatory frame-
work is restrictive, making it difficult to gain legal registration as a social
organisation, creating a stock of informal accountability capital is vital
too for gaining the trust and confidence of various account-holders
such as government, funders, and users. Given that NGOs can attract
government suspicion, are new forms of organisation, and are often
unfamiliar entities to the general public, NGOs have to work hard to
have their organisation and services understood, recognised, valued, and
trusted. Accountability work is an important means to build reputation,
allay suspicions and enhance legitimacy.
As stated in the introduction accountability and legitimacy go hand
in hand. However, in the literature on legitimacy, accountability and on
NGOs, they are often treated as separate, discrete concepts that have
produced contained bodies of literature on one or the other, or greater
emphasis on the one at the expense of the other (Gleiss 2014; Atack
1999). The links between legitimacy and accountability in NGOs are
under-theorised. As a result there is a lack of analysis and empirical stud-
ies of how NGOs develop processes of accountability providing evidence
of their claims of legitimacy. We argue that accountability and legiti-
macy cannot be so neatly separated but that are each constitutive of each
other in that legitimacy can be an outcome of strengthening account-
ability whilst also a resource for accountability, and accountability can
provide the material inputs for demonstrating and supporting claims to
legitimacy.
Legitimacy has been variously defined predominantly in relation to
governments, but common to most definitions is the notion of the ‘right
to rule’. Weber’s (1964) classic work on legitimacy delineates different
sources of legitimacy such as charismatic and bureaucratic legitimacy.
In the 1970s and 1980s a body of work developed that focused on the
issue of organisational legitimacy, that is, the perception that an organi-
sation’s rightful claims to pursue certain goals through particular means.
Definitions tended to emphasise either the evaluative dimension of
56 J. HOWELL ET AL.
legitimacy, that is the congruence between the values of the organisation

and broader social norms in society (Dowling and Pfeffer 1975) or the
cognitive aspects, that is, whether organisations were ‘understandable’
(Suchman 1995). Suchman went one step further in combining these
two dimensions in his definition, that is, ‘Legitimacy is a generalised per-
ception or assumption that the actions of an entity are desirable, proper,
or appropriate within some social constructed system of norms, values,
beliefs and definitions’. This definition is a useful starting point for our
framework as it emphasises ‘perceptions’, which are particularly relevant
in relation to the government’s and public’s understanding and approach
towards newly emerging NGOs. It also allows us to recognise the shift-
ing context of social norms, values and beliefs that prevails in the rapidly
changing socio-economic context of China and the socially constructed
nature of legitimacy, wherein NGOs have to demonstrate their right to
be social actors in the terrain of social welfare.
As strategic legitimacy theorists emphasise (Ashforth and Gibbs
1990; Pfeffer and Salancik 1978; Dowling and Pfeffer 1975), legiti-
macy has to be constantly remade, maintained, and sometimes restored,
if an organisation is to extract resources from funders and ultimately to
survive. Such processes are shaped by wider social norms, value, and
beliefs. Demonstrating accountability is an important part of reinforcing
and maintaining legitimacy, which in itself is a vital resource for attract-
ing funding (Ashforth and Gibbs 1990, p. 177) and for demonstrating
accountability. As Hilhorst (2003, p. 128) observes in her ethnographic
study of a local NGO in the Philippines, accountability is a ‘device for
legitimation’. This is particularly important in China where the trust
deficit between the public and government and NGOs fosters suspicion,
the risk of repression renders the stakes of gaining legitimacy high, and
where shifting, norms, and values in a context of rapid change make
legitimisation more complex and contested.
In liberal democracies citizens hold their government to account for
their claims to rule through elections. Elections are a key accountability
mechanism yielding substance to their claims in the form of votes. NGOs
and their leaders, like firms, are not elected. NGOs make claims to jus-
tify what they do, which are usually articulated in mission statements,
annual reports, constitutions, and public statements. These claims are
typically that they are well governed, upright, professional, efficient, and
value-based organisations. As they are not elected entities, they develop
other ways of being held to account. Gleiss’ (2014) careful study of the
legitimation strategies of Chinese NGOs focuses on legitimation as a

form of communication involving distinct discursive elements. We argue
that demonstrating accountability and building legitimacy involve not
just processes of discursive communication, but also concrete material
inputs and processes that create a stock of accountability capital that can
be leveraged to justify legitimacy claims.
The accountability processes that NGOs use (see Table 2.1) might
include seeking legal status, inviting and receiving government bodies,
seeking and accepting opportunities for media coverage and enhancing
public visibility, reporting to donors, demonstrating transparency. These
accountability processes give substance to the claims made through vari-
ous inputs that make up the stock of accountability capital. These inputs
can be formal or informal. Formal inputs include auditing and reports,
governance structures such as boards of trustees, and managerial systems
of leadership and human resources. Informal inputs include evidence of
professional expertise, positive media coverage, events to publicise the
work of the NGO in the community, evidence of donated funds and
grants, evidence of an expanding client base, government approval seen
in awards and public recognition, and proof of declared values such as
humane care and love. Accountability processes thus involve perform-
ative acts of inviting scrutiny which provide testimony in the form of
a stock of accountability made up of formal and informal inputs. This
stock of accountability gives substance to legitimacy claims.
These inputs thus together make up the stock of informal and formal
accountability capital of an organisation that can bolster the accounta-
bility and legitimacy of an NGO. The accumulation of donor funding
sends a signal that a donor has sufficient confidence in the organisation
to provide it with funds and thus in itself becomes an input of accounta-
bility. Similarly, having clear structures of governance, professional skills
development, and managerial systems that lay down standards and obli-
gations indicates to funders, users, and government that the organisation
has capacity and established formal processes of accountability. An NGO
with a large range of clients and the ability to secure clients through
referral likewise signals a degree of trust in the receiving NGO on the
part of the sending organisation, usually a government department.
Attracting prominent figures in society and government officials to be
on the board of an NGO also bolsters public and governmental trust
in the accountability and legitimacy of the NGO (Ashforth and Gibbs
1990, p. 181).
58
Table 2.1 Legitimacy and accountability of NGOs
Stock of accountability
Legitimacy claims Examples of informal inputs Examples of formal inputs Examples of processes
Efficiency Evidence of professional exper- Mission statements, constitution Seeking or accepting opportu-
Effectiveness tise such as training, practices, Audit reports nities for media coverage
J. HOWELL ET AL.
Good governance membership of professional Reports to donors, government Developing transparency and
Professionalism networks Governance structures in place good governance practices
Values such as care, love, Positive media coverage such as boards, staff job specifi- Creating websites and organ-
participation Open days for public and cations and M&E systems, and ising public events around the
public events in community clear lines of authority NGO
Governmental recognition of User feedback processes Inviting public into the NGO
work seen in visiting govern- Receiving government
ment delegations, government delegations
awards and honours and con- Joining professional bodies
tinued existence despite lack of Delivering reports and accounts
legal status Establishing formal channels for
Transparent website and other user participation
public information such as
newsletters
Evidence of expanding funding
Evidence of growing client base
and domination of a specific
service sector
Evidence of care and love seen
in staff behaviour and attitudes
Evidence of participation of
users in providing feedback and
running organisation
Accumulating a stock of informal accountability capital comprised

of various inputs serves to create second-order, informal processes of
accountability that substitute for and complement formal institutions of
accountability. They constitute important ingredients in a longer term,
historical process of building the formal institutions of accountability.
These accountability inputs mirror the inputs that Nathan discusses in
relation to the government, whereby efforts to improve public participa-
tion in decision-making and enhance transparency are a means of adapta-
tion aimed at boosting the government’s legitimacy and ensuring regime
survival. In a similar way these inputs and the efforts to create stocks of
informal and formal accountability capital are also a way for NGOs to
boost their legitimacy, ensure their survival, and develop organisationally
in an authoritarian context.
By using the media to publicise achievements, the NGO can ‘offer up’
accountability to potential account-holders where formal accountabil-
ity institutions are weak and/or non-existent. These informal stocks of
accountability capital can exist alongside formal institutions of account-
ability in the organisation. An NGO that receives external funding, for
example, may be obliged to deliver annual reports stating how its funds
were used, receive annual auditing and be subject to regular monitor-
ing and inspection visits from the funder. It may also develop other for-
mal institutions of accountability such as job specifications that lay down
standards and obligations and requirements for skills training. Given that
these formal institutions of accountability are still weakly developed in
NGOs, creating second-order accountability becomes particularly impor-
tant as a way of developing a reputation of competency and probity,
creating trust and building legitimacy. By exploring the accumulation
of accountability capital, we can analyse the development of accounta-
bility and the power relationship between resource holders and resource
users in the development thereof. In the process, too, being seen to be
accountable can itself become an important resource in achieving further
accountability and alters in turn the power relationship between resource
holder and resource user.
An NGO may also continue its attempts to register officially as an
NGO, thus conforming to a government’s definition of legitimacy, as
such first-order accountability signifies government trust and can inspire
public confidence in the legitimacy and capabilities of the organisation.
Whilst registering as a social organisation endows legal status and clearly
signals recognition by the state, it cannot alone suffice to secure trust and
60 J. HOWELL ET AL.
reputation and ultimately resources through sub-contracting or dona-

tions. The numerous scandals involving GONGOs such as the Chinese
Red Cross and others are testimony to this (Xu 2012). These more
informal ways of making and demonstrating accountability are comple-
mentary to formal processes of accountability such as accountability
in law or formal accountability to donors. However, the formal institu-
tions of accountability in both government and NGOs in China remain
weak. In such a context, particularly where an NGO lacks state-sanc-
tioned, registration status as a social organisation, informal institutions of
accountability acquire particular importance in developing second-order
accountability. Nevertheless, building substantial second-order account-
ability capital does not guarantee any automatic or unproblematic legal
registration. In authoritarian states NGOs focused on rights, controversial
public affairs or issues deemed to be regime-threatening, are often still
refused registration, as seen in Russia (Dauce 2014), Egypt and Hungary.
The theoretical framework adopted here thus distinguishes between
‘first-order’ accountability that is premised on legal institutions of
accountability and ‘second-order’ accountability that includes the infor-
mal and formal institutions of accountability made through accumu-
lating stocks of accountability capital. To some degree the framework
draws inspiration from Tsai’s (2007) work on informal institutions but
differs in some fundamental ways. Whereas Tsai’s study focuses on sol-
idary groups in rural villages and accountability between government
officials and citizens, this framework is concerned with the urban set-
ting, where social diversity makes it less likely that solidary groups exist
(Tsai 2007, p. 264) and the relationships of accountability are between
NGOs and the state, public and users, rather than rural citizens and the
state. Compared to solidary groups such as temples, NGOs are relatively
unfamiliar types of organisation that arouse governmental and public
suspicion rather than confidence, trust, and legitimacy. NGOs that seek
to provide welfare services cannot automatically command recognition
or trust; building processes of accountability becomes an important
element in nurturing and earning recognition and trust and gaining
legitimacy. Whilst moral standing is central to Tsai’s informal accounta-
bility institutions, reputational standing is at the core of NGOs’ informal
accountability institutions. The focus of our study is thus on how NGOs
create institutions of accountability by accumulating stocks of accounta-
bility capital and ‘offer up’ accountability as part of a broader process of
legitimisation to ensure organisational development and survival.
This is not to say that NGOs do not also have formal accountability
institutions, nor that they may also be developing formal accountability
institutions as a way to strengthen their stock of accountability capital.
These might include, for example, putting in place managerial forms of
accountability such as job descriptions that specify qualifications, skills,
and standards. Where they have external funders, they may also be sub-
ject to formal accountability institutions such as regular reporting and
monitoring to donors, auditing of use of funds, inspections, and visits by
the funder. However, these formal accountability institutions are likely
to be weak and far from adequate to ensure full accountability along all
dimensions. Moreover, shared interests between international donors
and NGOs in demonstrating effectiveness of operations to ensure the tap
of funds continues can also weaken the enforcement of accountability.
Even if NGOs do have registered status, the type of upward accounta-
bility to the state that is required is limited. Generally, it would require
writing annual reports, presenting accounts, receiving random inspec-
tion visits. There is no guarantee that this bureaucratic accountability
would be effective in ensuring good performance; nor would it require
any obligation to be accountable to users of services; nor would it ensure
legitimacy.4
In an authoritarian state such as China where state approval is valued
by the public, NGOs, and service users, especially when there is public
distrust of NGOs, this second-order stock of accountability capital serves
as a form of accountability that can be harnessed to demonstrate legiti-
macy. This accountability reflects a dynamic process of changing sources
of funding, the development of social media, and changes in the regu-
latory environment governing foundations and social organisations.
Moreover, it enables an organisation to attract funding and develop
further. Second-order accountability does not escape the general trend
towards a predominantly upward relationship of accountability such as
to new funders rather than to children and users per se. Moreover, it is
not the outcome of moral obligations of solidary group members, as Tsai
discusses, though some NGOs may be value-driven, but rather the active
initiative of NGOs to offer up accountability as a way to earn reputa-
tional standing in the eyes of the state, public, funders, and other NGOs,
enhancing their legitimacy and ultimately their organisational survival.
In the subsequent chapters we observe and analyse the making of
accountability and legitimacy in the field of child welfare through the
creation and leveraging of informal and formal accountability capital.
62 J. HOWELL ET AL.
We analyse how these processes of accountability-making create particu-

lar hierarchies of accountability that can reinforce or potentially challenge
seemingly fixed power relations. We demonstrate how NGOs’ processes
of institution-building interlock with gradual state institutional change,
where NGOs capitalise on processes of drift and layering to advance
their development and survival. In this way, our study highlights the
dynamism and fluid nature of institutional change in China that defies
assumptions of the institutional rigidity of authoritarian states.
Notes
1. The term ‘not-for-profit organisation’ is commonly used in the USA,
whilst ‘NGOs’ is used more widely in Europe. ‘Voluntary sector organisa-
tions’ is a specific term used in the UK.
2. Conversion refers to the strategic deployment of existing rules to achieve
change.
3. See, for example, Gleiss (2014) in-depth analysis of legitimation strategies
of Chinese labour NGOs. See also Hasmath and Hsu (2008).
4. As Dowling and Pfeffer (1975, p. 124) note, legitimacy cannot be solely
defined by what is legal, and even less so in an authoritarian state.
References
Ackerman, J. (2004). Co-governance for accountability: Beyond “exit” and
“voice”. World Development, 32(3), 447–463.
Anderson, K. (2009). What NGO accountability means and does not mean. The
American Journal of International Law, 103(1), 170–178.
Ashforth, B. E., & Gibbs, B. W. (1990). The double-edge of organisational legit-
imation. Organisation Science, 1(2), 177–184.
Atack, I. (1999). Four criteria of development NGO legitimacy. World
Development, 27(5), 855–864.
Bendell, J., & Cox, P. (2006). The donor accountability agenda. In L. Jordan
& P. V. Tuijl (Eds.), NGO Accountability: Politics, Principles and Innovations.
London: Earthscan.
Bovens, M. (2007). Analysing and assessing accountability: A conceptual frame-
work. European Law Journal, 13(4), 447–468.
Brett, E. A. (1993). Voluntary agencies as development organisations:
Theorising the problem of efficiency and accountability. Development and
Change, 24(2), 269–303.
Brett, E. A. (2003). Participation and accountability in development manage-
ment. The Journal of Development Studies, 40(2), 1–29.
Brooker, P. (2000). Non-democratic regimes: Theory, government and politics.

New York: St. Martin’s Press
Burns, J., & Wang, X. (2010). Civil service reform in China: Impacts on civil
servants’ behaviour. The China Quarterly, 201, 58–78.
Cai, Y. (2004). Managed participation in China. Political Science Quarterly,
119(3), 425–451.
Cassani, A., (2017). Social services to claim legitimacy: Comparing autocracies’
performance. Journal of contemporary Politics, 23(3), 348–368
Campbell, J. L. (2004). Institutional Change and Globalisation. Princeton:
Princeton University Press.
Chan, C. K. (2012). Community-based organisations for migrant workers’
rights: The emergence of labour NGOs in China. Journal of Community
Development, 48(1), 6–22.
Charnovitz, S. (2007). Accountability of non-governmental organisations in
global governance. In L. Jordan & P. Van Tuijl (Eds.), NGO Accountability:
Politics, Principles and Innovations (pp. 21–42). London: Earthscan.
Chen, Feng. (2003, April). Industrial restructuring and workers’ resistance in
China. Modern China, 29(2), 237–262.
Chen, F. (2004). Legal mobilization by trade unions: The case of Shanghai. The
China Journal, 52, 27–45.
Chen, Feng., & Mengxiao, Tang. (2013, April/June). Labour conflicts in China.
Typologies and their Implications, Asian Survey, 53,(3), 589–583.
Cheng, J., Ngok, K. L., & Zhuang, Y. (2010). The survival and development
space for China’s labour NGOs: Informal politics and its uncertainty. Asian
Survey, 50(6), 1082–1106.
Dauce, F. (2014). The government and human rights groups in Russia: Civilised
oppression? Journal of Civil Society, 10(3), 239–254.
Diamond, L. (2002). Elections without democracy:Thinking about hybrid
regimes. Journal of Democracy,13 (2), 21–35.
Dogra, N. (2012). Representations of Global Poverty: Aid Development and
International NGOs. New York: I.B. Tauris.
Dowling, J., & Pfeffer, J. (1975). Organisational legitimacy: Social values and
organisational behaviour. The Pacific Sociological Review, 18(1), 122–136.
Duckett, J., & Wang, H. (2013). Extending political participation in China: New
opportunities for citizens in the policy process. Journal of Asian Public Policy,
6(3), 263–276.
Dukalskis, A., & Gerschewski, J. (2017). What autocracies say (and what citizens
hear): Proposing four mechanisms of autocratic legitimation. Contemporary
Politics, 23(3), 251–268.
Ebrahim, A. (2003). Accountability in practice: Mechanisms for NGOs. World
Development, 31(5), 813–829.
Edin, M. (2003a). Remaking the communist party-state: The cadre responsibility
system at the local level in China. China: An International Journal, 1(1), 1–15.
64 J. HOWELL ET AL.
Edin, M. (2003b). State capacity and local agent control in China. China
Quarterly, 173(March), 35–52.
Edwards, M., & Hulme, D. (Eds.). (1995). Non-governmental Organisations—
Performance and Accountability: Beyond the Magic Bullet. London: Earthscan.
Fehrenbach, E., & Rodogno, D. (2016). ‘A horrific photo of a drowned Syrian
child’: Humanitarian photography and NGO media strategies in historical
perspective. International Review of the Red Cross, 1, 1–35.
Fishkin, J. S., He, B., Luskin, R. C., & Siu, A. (2010). Deliberative democracy
in an unlikely place: Deliberative polling in China. British Journal of Political
Science, 40(2), 1–14.
Fox, J. A., & Brown, L. D. (Eds.). (1998). The Struggle for Accountability: The
World Bank, NGOs and Grassroots Movements. Cambridge, MA: MIT Press.
Froissart, Chloe. (2011). NGOs' defending workers’ rights: Semi-union organisa-
tions contribute to the regime’s dynamic stability. China Perspectives, 2, 18–25.
Geall, S. (2012, May 13). The Yangtze’s latest dam construction shows
the hollowness of China’s ‘breakthrough’ FoI legislation. Guardian
Comment Network. Retrieved from https://www.theguardian.com/
commentisfree/2012/may/13/china-freedom-of-information-yangtze-dams.
Gleiss, M. S. (2014). How Chinese labour NGOs legitimate their identity and
voice. China Information, 28(3), 362–381.
Goetz, A., & Jenkins, R. (2005). Reinventing Accountability: Making Democracy
Work for Human Development. Basingstoke: Palgrave Macmillan.
Hacker, J. S. (2010). Policy drift: The hidden politics of US welfare state
retrenchment. In W. Streeck & K. Thelen (Eds.), Beyond Continuity:
Institutional Change in Advanced Political Economies (pp. 40–82). Oxford:
Oxford University Press.
Hasmath, R., & Hsu, J. (2008). NGOs in China and issues of accountability.
Asia Pacific Journal of Public Administration, 30(1), 1–11.
He, B. (2011). Civil engagement through participatory budgeting in China:
Three different logics at work. Public Administration and Development,
31(2), 122–133.
He, B., & Thogersen, S. (2010). Giving the people a voice? Experiments with
consultative authoritarian institutions in China. Journal of Contemporary
China, 19(66), 675–692.
He, B., & Warren, M. E. (2011). Authoritarian deliberation: The deliberative
turn in Chinese political development. Perspectives on Politics, 9(2), 269–289.
Heilmann, S. (2009). From local experiments in national policy: The origins of
China’s distinctive policy process. In A. Kipnis, L. Tomba, & U. Jonathan
(Eds.), Contemporary Chinese Society and Politics (pp. 183–211). Abingdon:
Routledge.
Heilmann, S., & Perry, E. J. (2011). Mao’s Invisible Hand: The Political
Foundations of Adaptive Governance in China. Cambridge, MA: Harvard
University Press.
Heimer, M. (2006). The cadre responsibility system and the changing needs of
the party. In K. E. Brodsgaard & Y. Zheng (Eds.), The Chinese Communist
Party in Reform (pp. 122–138). London: Routledge.
Hilhorst, D. (2003). The Real World of NGOs. London: Zed Books.
Howell, J. (2007). Village elections in China: Recent prospects, new challenges.
Etudes Rurales, 179(January–June), 213–234.
Howell, J., & Pearce, J. (2001). Civil Society and Development: A Critical
Exploration. Boulder, CO: Lynne Rienner.
Hulme, D., & Edwards, M. (Eds.). (1997). NGOs, States and Donors: Too Close
for Comfort? New York: St. Martin’s Press.
Jacka, T., & Wu, C. R. (2015). Village self-government and representation in
southwest China. Journal of Contemporary China, 46(1), 1–24.
Kilby, P. (2006). Accountability for empowerment: Dilemmas facing non-gov-
ernmental organizations. World Development, 34(6), 951–963.
Kovach, Hetty. (2007). Addressing accountability at the global level: The chal-
lenges facing international NGOs. In L. Jordan & P. Van Tuijl (Eds.), NGO
Accountability: Politics, Principles and Innovations (pp. 195–210). London:
Earthscan.
Landry, P. F., Davis, D., & Wang, S. (2010). Elections in rural China:
Competition without parties. Comparative Political Studies, 43(6), 763–790.
Lee, C. K., & Shen, Y. (2011). The anti-solidarity machine? Labor nongovern-
mental organizations in China. In S. Kuruvilla, C. K. Lee, & M. E. Gallagher
(Eds.), From Iron Rice Bowl to Informalization: Markets, Workers, and the
State in a Changing China (pp. 173–187). Ithaca and London: ILR Press and
Cornell University Press.
LeRoux, K. (2009). Paternalistic or participatory governance? Examining oppor-
tunities for client participation in nonprofit social service organizations. Public
Administration Review, 69(3), 504–517.
Leung, T. T. F. (2008). Accountability to welfare service users: Challenges and
responses of service providers. British Journal of Social Work, 38(3), 531–545.
Linz, J. (1970). An authoritarian regime: Spain. In E. Allardt & S. Rokkan,
(Eds.), Mass politics: Studies in political sociology. New York: The Free Press.
Looney, K. E. (2015). China’s campaign to build a new socialist countryside:
Village modernisation, peasant councils and the Ganzhou model of rural
development. The China Quarterly, 224, 909–932.
Luo, R., Zhang, L., Huang, J., & Rozelle, S. (2010). Village elections, pub-
lic goods investments and pork barrel politics, Chinese-style. Journal of
Development Studies, 46(4), 662–684.
Ma, J. (2009). The dilemma of developing financial accountability without elec-
tions. Australian Journal of Public Administration, 71(2), 111–121.
Ma, J. (2012). The rise of social accountability in China. Australian Journal of
Public Administration, 71(2), 111–121.
66 J. HOWELL ET AL.
Mahoney, J., & Thelen, K. (Eds.). (2010). Explaining Institutional Change:

Ambiguity, Agency and Power. Cambridge: Cambridge University Press.
Martin, G. P. (2011). The third sector, user involvement and public service
reform: A case study in the co-governance of health service provision. Public
Administration, 89(3), 909–932.
Mattei, Paola. (2007). Managerial and political accountability: The widening
gap in the organisaiton of welfare. International Review of Administrative
Sciences, 73(3), 365–387.
Minzner, C. F. (2006). Xinfang: An alternative to formal Chinese legal institu-
tions. Stanford Journal of International Law, 42, 103–179.
Najam, A. (1996). NGO accountability: A conceptual framework. Development
Policy Review, 14(4), 339–353.
Nathan, A. J. (2003). Authoritarian resilience. Journal of Democracy, 14(1), 6–17.
Nathan, A. J. (2009). Authoritarian impermanence. Journal of Democracy, 20(3),
37–40.
Norris, J. (2014). Rethinking accountability in new governance. The European
Journal of Social Science Research, 27(3), 199–219.
O’Brien, K. J., & Li, L. (1999). Selective policy implementation in rural China.
Comparative Politics, 31(2), 167–186.
O’Brien, K. J., & Li, L. (2004). Suing the local state: Administrative litigation in
rural China. The China Journal, 51, 75–96.
O’Brien, K. J., & Han, R. (2009). Path to democracy? Assessing village elections
in China. Journal of Contemporary China, 18(60), 359–378.
Peruzzotti, E. (2007). Civil society, representation and accountability: Restating
current debates on the representativeness and accountability of civic associ-
ations. In L. Jordan & P. Van Tuijl (Eds.), NGO Accountability: Politics,
Principles and Innovations (pp. 43–60). London: Earthscan.
Pfeffer, J., & Salancik, G. (1978). The External Control of Organisations: A
Resource Dependence Perspective. New York: Harper and Row.
Pierson, P. (2000). The limits of design: Explaining institutional origins and
change. Governance: An International Journal of Policy and Administration,
13(4), 475–499.
Pollitt, C., & Hupe, P. (2011). Talking about government: The role of magic
concepts. Public Management Review, 13(5), 641–658.
Putnam, R. (1993). Making Democracy Work: Civic Traditions in Italy.
Princeton: Princeton University Press.
Scholte, J. A. (2005). Globalisation. A Critical Introduction (2nd ed.).
Basingstoke: Palgrave Macmillan.
Scholte, J. A. (2011). Building Global Democracy? Civil Society and Accountable
Global Governance. Cambridge: Cambridge University Press.
Shambaugh, D. (2008). China’s Communist Party: Atrophy and Adaptation.
Washington, DC: Woodrow Wilson Centre Press.
Smulovitz, C., & Peruzzotti, E. (2000). Societal accountability in Latin America.

Journal of Democracy, 11(4), 147–158.
Speer, J. (2012). Participatory governance reform: A good strategy for increas-
ing government responsiveness and improving public services? World
Development, 40(12), 2379–2398.
Suchman, M. C. (1995). Managing legitimacy: Strategic and institutional
approaches. The Academy of Management Review, 20(3), 571–610.
Tan, X. (2014). Constructing a performance-based accountability system for the
Chinese government. Journal of Public Affairs, 14(2), 154–163.
Thireau, I., & Hua, L. (2003). The moral universe of aggrieved Chinese work-
ers: Workers’ appeals to arbitration committees and letters and visits offices.
The China Journal, 50, 83–103.
Tsai, L. (2007). Accountability Without Democracy. Cambridge: Cambridge
University Press.
Van Rooy, A. (Ed.). (1998). Civil Society and the Aid Industry. London:
Earthscan.
Weber, M. (1964). The Theory of Social and Economic Organisation. New York:
The Free Press.
Whiting, S. (2004). The cadre evaluation system at the grassroots: The paradox
of party rule. In B. Naughton & D. Yang (Eds.), Holding China Together.
New York: Cambridge University Press.
Willems, T., & Van Dooren, W. (2007). Coming to terms with accountabil-
ity: Combining multiple forums and functions. Public Management Review,
14(7), 1011–1036.
Wintrobe, R. (1998). The Political Economy of Dictatorship. Cambridge:
World Bank. (2005). Societal Accountability in the Public Sector. Washington,
DC: World Bank.
Wu, Y., & Wang, W. (2012). Does participatory budgeting improve the legit-
imacy of the local government? A comparative case study of two cities in
China. Australian Journal of Public Administration, 71(2), 122–135.
Xu, X. (2012). On the new model of public participation models in the micro-blog
era: Take Guo Meimei as an example. Lanzhou Academic Journal, 2(1), 66–71.
Yan, X., & Ge, X. (2016). Participatory policy-making under authoritarianism:
The pathways of local budgetary reform in the P.R. of China. Policy and
Politics, 44(2), 215–234.
Yao, Y. (2009). Village elections and redistribution of political power and collec-
tive property. The China Quarterly, 197, 126–144.
Yu, X. D. (2010). Citizen participation and its impacts on people’s wellbeing.
Zhejiang Social Science, 1, 34–51.
Zhong, L. J., & Mol, A. P. J. (2008). Participatory environmental governance in
China: Public hearings on urban water tariff setting. Journal of Environmental
Management, 88(4), 899–913.
CHAPTER 3
Welfare Reforms, Child Welfare NGOs,

and Accountability
Before moving on to the case-studies, we first need to situate

accountability processes in the historical-institutional context. The chal-
lenges that Chinese child welfare NGOs face have their roots in the
major transformations in child welfare since 1949. Leung and Xu (2015)
identified three turning-points in the historical trajectory of post-1949
social welfare. The first refers to the Maoist period when socialist egal-
itarian principles underpinned the creation of a basic system of social
protection; the second to the post-1978 era when the turn to a market
economy led to the disintegration of the welfare system under planning;
the third refers to the period under Jiang Zemin when from the mid-
1990s reforms to the welfare system were initiated. This third turn, we
argue, is given added impetus during the Hu-Wen administration as the
shift towards technological upgrading of industrial and agricultural pro-
duction call for new forms of social protection.
In this chapter, we locate our analysis of making accountability and
legitimacy in child welfare organisations within the broader historical-
institutional context of welfare reforms and the development of NGOs.
We then reflect on the particular challenges that NGOs and accounta-
bility face in authoritarian China. Finally, we provide an overview of the
specific regulatory environment governing child welfare NGOs and the
sector-specific challenges they encounter.

https://doi.org/10.1007/978-3-319-90221-0_3
70 J. HOWELL ET AL.
Welfare Reforms
During the Maoist decades, welfare provision was organised through the
urban work-unit and the rural communes, with households continuing
to play a role in the care of family members. State-owned enterprises
provided workers with cradle-to-grave welfare, including kindergartens,
schooling, medical care, and pensions, as well as an ‘iron rice bowl’ of
secure employment (Dreyer 2000; Lieberthal 1995). Though the extent
and quality of welfare varied according to the relative size and wealth
of state enterprises, workers in state enterprises fared relatively better
than those employed in street factories or collective enterprises (Walder
1986).
In rural areas child-care arrangements such as creches and kindergar-
tens enabled women to participate more easily in collective production,
whilst basic health care and schooling ensured that basic needs were met
(Dreyer 2000; Brugger and Reglar 1994). A rural co-operative health
system, where farmers made minimal contributory payments through
the commune system, enabled basic health needs to be met and access
to hospital care ensured for more serious illnesses (Lieberthal 1995). An
exception to this was the period of the Great Leap Forward (1957–1961),
when overly rapid collectivisation along with inadequate flows of infor-
mation, leftist politics and poor weather resulted in one of the largest
famines in history. Over 30 million people in rural areas died as a con-
sequence (Williams 1986). After readjustment of agricultural policies in
the early 1960s welfare arrangements were resumed in a similar vein as
before.
However, there was considerable variation in provision across rural
areas and the quality and extent of provision did not match that provided
in urban contexts. Health-care facilities were far less available and acces-
sible in rural areas, whilst the quality of school buildings, teacher, and
overall education fell behind that in urban areas. Rural residents did not
benefit from pensions so that the care of the elderly fell primarily upon
the household. Welfare provision during the Maoist decades was sharply
divided between rural and urban areas. Strict controls on internal migra-
tion through the residence permit system, known as ‘hukou’, rendered
access to superior facilities in urban areas impossible for rural residents
(Huang et al. 2010).
With the introduction of market-oriented economic reforms under
the leadership of Deng Xiaoping in 1978, China embarked upon a new
3 WELFARE REFORMS, CHILD WELFARE NGOS, AND ACCOUNTABILITY 71
export-oriented, labour-intensive model of development. This led to

the disintegration of the former social welfare fabric. Rapid decollectiv-
isation in rural areas in the early 1980s brought with it the collapse of
rural communes and the concomitant structures of welfare provision. As
the new household contract system returned agricultural production to
households, collectively provided creches and kindergartens melted away
(Croll 1994), whilst provision of basic medical facilities and care dissi-
pated in the 1980s. In urban areas, the gradual opening up to foreign
investment in the 1980s through the Special Economic Zones, the devel-
opment of the private sector, and the streamlining and closure of state
enterprises from the mid-1990s onwards led to the breakdown of the
urban work-unit, the gradual eradication of job security, and the collapse
of the accompanying system of welfare provision.
It was during the 1990s that the effects of the disintegration of urban
and rural welfare systems became evident and captured the attention of
Party leaders eager to deepen labour markets and privatisation of the
state sector. From the mid-1990s onwards under the administration of
General Secretary Jiang Zemin and Premier Zhu Rongji, policy reforms
were introduced in the areas of social security, medical care and pensions,
marking the third turning-point in post-1949 social welfare reform. The
main approach adopted was to put in place insurance systems, where
employees, employers, and the local state made monetary contributions,
which together could be pooled and used to support employees if unem-
ployed, ill or upon retirement (Chan et al. 2008; Bland and Yu 2004).
During the 1990s welfare reforms were piecemeal and uneven, concen-
trated solely on urban areas (Saich 2008). Furthermore, they offered
little protection to migrant workers who did not enjoy urban resident
status and who were generally reluctant to contribute to private insur-
ance schemes when the transferability of such funds across provinces was
not guaranteed (Huang et al. 2010; Li 2006).
It was under the leadership of Hu Jintao and Wen Jiabao, who
came into office in spring 2002, that a more comprehensive and uni-
fied approach towards welfare reform was undertaken, building upon
the achievements already made in the Jiang Zemin era. China’s entry
into the World Trade Organisation (WTO) in December 2002 opened
up new global economic opportunities and gave a significant boost to
production and growth. During this decade of economic boom, at least
up till the global economic recession of 2008, growth rates continued
at double-digit pace, reserves of dollars spiralled as export-production
72 J. HOWELL ET AL.
expanded, and the national economic coffers burgeoned. Compared to

the Jiang-Zhu administration when industrial development was privi-
leged over agriculture and urban areas over rural, Hu Jintao and Wen
Jiabao addressed more systematically the needs of rural areas and migrant
workers (Huang 2008). Growing unrest in rural areas, often violent
and directed against local government officials, was a major source of
instability. Added to this, the growing number of strikes, protests, and
demonstrations by migrant workers demanding unpaid wages, safer
working conditions, overtime bans caused considerable concern amongst
central Party leaders around the stability of production and ultimately of
the Party (Chan 2001).
To address these issues the Hu-Wen leadership adopted a policy
and political discourse around ‘people-centred development’ and ‘har-
monious society’ that placed rural issues and the injustices of migrant
workers more squarely onto the policy and political agenda (He 2015;
Zhao 2012). This created the political context for a more concerted
effort to establish a comprehensive and unified welfare system that took
into account the welfare needs of rural residents and migrant workers.
Building on the legacy of Jiang and Zhu, the new leadership set out to
institute a series of welfare reforms that would shrink the gap between
rural and urban areas, address the issues facing migrant workers in the
workplace and pluralise the financing and delivery base of welfare.
Over the next ten years, serious efforts were made to lessen the
burdens on farmers, improve access to and quality of schooling, and
unify the system of welfare across rural and urban areas. With one fell
swoop, the abolition of agricultural tax in 2006 reduced the burden of
fees and taxes that local governments extracted from farmers (Kennedy
2007). Schooling up to 14 years old was made compulsory, leading to
improvements in enrolment and attendance of schoolchildren in rural
areas. Drawing on the advice of experts, local experiments, and interna-
tional experiences, steps were taken to unify the system of welfare pro-
vision across urban and rural areas. In 2008 pensions and social relief
(dibao) were extended to rural areas, albeit at a lower level (Li 2014).
Regulatory changes aimed at enabling social insurance payments to be
transferred from place to place promised to increase migrant workers’
access to and take-up of social insurance benefits.
These moves were crucial if China was to upgrade from an export-
oriented, labour-intensive model of development to a more high-tech,
capital-intensive model, requiring a higher skilled labour force. Land
reforms and mass migration to urban areas had weakened rural residents’
ties to the land. Land no longer served as a security asset for rural
migrants. Welfare reform was crucial in addressing the welfare gap for
dispossessed rural migrants and for appeasing migrant workers who were
increasingly concerned about social protection.
As well as reforming the system of welfare provision, reforms were
initiated to pluralise the system of financing welfare and service deliv-
ery. During the Hu-Wen administration various initiatives were adopted
to enable the involvement of the private sector and non-governmental
organisations in the financing and delivery of welfare services, going
beyond the work on insurance schemes carried out during the Jiang era.
To this end the government encouraged corporate social responsibil-
ity, experimented with the private sector provision of welfare, including
child-care, and introduced legislation to promote foundations as alter-
native sources of welfare funding and provision. From 2001 the legal
basis for procurement to the private sector was already being laid, with
the passing of the Contract Tendering Law 2001 and the Procurement
Law 2002, a year later (Jia and Su 2009). Though there were no specific
laws or regulations on the subcontracting of welfare services, only
‘guiding opinions’ (zhidao yijian), these two laws paved the way for sub-
contracting welfare services later to NGOs, as will be discussed in the
section on NGO development.
These were followed in 2008 with various pilot experiments in key
cities such as Shenzhen, Beijing, and Guangzhou, to adjust the regu-
latory environment governing NGOs to make it easier for them to bid
for government welfare services contracts. In this way, the government
could expand and diversify the supply of welfare services providers.
These experiments built upon the work already done by NGOs, which
in the absence of such governmental initiatives, had already been supply-
ing services without any government support or encouragement in the
past. Indeed, NGOs had already been filling gaps in services in a range
of domains, including migrants, child welfare, disability, and HIV/AIDs.
However, diversifying providers of services to NGOs faced numerous
barriers, related not only to the limited supply, capacity, and professional-
ism of NGOs but also the regulatory environment governing NGOs, the
politics surrounding the reform of this, and public perceptions of NGOs.
Government officials at the MOCA, academic advisers and research-
ers were well aware that for NGOs to play a role in welfare provision,
the supply needed to be significantly increased and capacity-building,
74 J. HOWELL ET AL.
professionalisation, and governance needed to be nurtured and devel-

oped. The legitimacy of NGOs mattered both to the state and NGOs.
If welfare was to be a means for justifying authoritarian rule through a
mixed welfare system, then NGOs had to be seen to be competent and
professional agencies, accountable and legitimate in the eyes of govern-
ment officials and the public. Without this, they risked undermining
public confidence in the government and ultimately a key justification to
rule.
Background on Development of NGOs in China

The historical development of civil society in China is now well covered
in the literature and requires no further rehearsing in detail here. We
thus highlight some major landmarks in the trajectory of civil society and
NGOs since 1978 and focus our attention on the regulatory environ-
ment governing NGOs. With the shift in direction towards the market
post-1978 new forms of social organising were encouraged to develop so
as to facilitate the process of market development. In the 1980s, trades
associations such as the Silk Trade Association, agricultural production
associations such as the Duck-breeding Association, manufacturing pro-
ducer associations such as the Cement Producers’ Association, entre-
preneurs’ associations and professional associations such as the Lawyers’
Association were the main type of social organisations to flourish (White
et al. 1996). These quasi-governmental associations played a crucial role
in lubricating market development, acting as intermediaries between the
state and producers, and taking on tasks that might otherwise have been
carried out by the state. They were organisations whose members and
clients benefited in various ways from economic reform.
Welfare-oriented social organisations were limited in number dur-
ing this period, being mainly GONGOs such as the Disabled Persons’
Federation. Mass organisations such as the All-China Federation of
Trades Unions and the All-China Women’s Federation also carried out
various welfare tasks to alleviate poverty (Pringle 2011; Taylor et al.
2003; Howell 1996; Davin 1976). The Regulations on the Registration
of Social Organisations 1950 were the key regulatory instrument gov-
erning the newly emerging social organisations. This required social
organisations to register with the MOCA at the corresponding admin-
istrative level and identify a sponsoring governmental agency to oversee
their work. Apart from this, the General Principles of the Civil Law of
the P.R. China 1986, stated that a social organisation could be qualified
as a legal person, thereby giving legal legitimacy to social organisations.
Nevertheless, in the 1980s there was little oversight over the develop-
ment of social organisations and associations which registered with a
myriad of different government departments (White et al. 1996).
It was following the crackdown on the Democracy Movement
in June 1989 that the Party took steps to tighten up control over the
emergence of social organisations. Groups seen as hostile to the regime
such as democracy groups, autonomous students and workers’ unions
were quickly banned, whilst other groups perceived as harmless were
required to register under the revamped Regulations on the Registration
and Administration of Social Organisations 1989 (White et al. 1996).
These regulations changed the former NGO administrative system into
a pattern of registration at different levels and dual administration. Thus
local civil affairs departments were put in charge of the registration and
administration of social organisations, whilst each social organisation
became subject to the management of a competent business unit, or
supervisory unit. Thereafter, the MOCA issued relevant administrative
regulations and other administrative provisions, whilst the supervisory
governmental departments also issued their own relevant administrative
provisions. For foundations, the administrative system became one of
“registration at different levels and triple administration”, whereby banks
also became an additional third part of the examination and administra-
tion system.
The 1989 Regulations introduced several stringent articles that con-
stricted the development of social organisations. Relevant articles here
were Article 3 preventing there being more than one organisation per
field sponsored by a government department, limiting the pluralisa-
tion of the emerging civil society.1 There could thus be only one NGO
working on say environmental education or HIV/AIDs sponsored by
the relevant bureau. Article 19 preventing the formation of branches
across the country hindered the development of horizontal links between
NGOs and the co-ordinated, cross-provincial development of a service-
delivery NGO sector. Apart from this, requirements such as having a cer-
tain level of bank deposit, offices and governance structures proved too
onerous for most NGOs, which held back from seeking formal registra-
tion. Local government bureaus were often reluctant to act as sponsors
to social organisations, not only because these were unknown entities but
also because they feared they might have political agendas, be fraudulent,
76 J. HOWELL ET AL.
or lack competency, and would thus jeopardise the promotion pros-

pects of local leaders (Hildebrandt 2013). As Su et al. (1999) and Wu
(2001) note, the fundamental principles and guiding ideology of the
system sought to limit the development of NGOs rather than protect
the civil right of freedom of association as provided by Article 35 of the
Constitution.
The 1989 Regulations were amended again in 1998 in response to
the activities of the Falun Gong that had been able to mobilise follow-
ers across China to surround the Zhongnanhai, the central power-house
of the Party, and ongoing concerns about the ‘unordered’ development
of social organisations (Ostergaard 2004). These regulations retained the
constraining clauses concerning branch formation and only one organi-
sation per field. There was a growing concern amongst security authori-
ties that foreign agencies were attempting to destabilise China by setting
up and/or manipulating foreign-funded social groups. Many of the more
independent women’s organisations that had sprouted during the Fourth
World Summit of Women hosted in Beijing in 1995 were supported and
often financed by foreign foundations, embassies and aid agencies, open-
ing up opportunities for international exposure to alternative ideas and
ways of organising, and drawing Chinese groups into international net-
works (Kaufman 2012; Howell 1997).
However, whilst the 1998 regulations imposed restraints on social
organisations, they were also accompanied by other new regulations that
sought to strengthen the regulatory environment for non-governmental
actors in the field of welfare. These were regulations relating to p
eople’s
run non-profit organisations (minban feiqiye danwei, 民办非企业单
位) that provided welfare services, foundations, and public donations.2
In this way, the government sought to capitalise on the new sources of
entrepreneurial wealth as well as promote public confidence in dona-
tions. Up till this point, Chinese foundations were few and far between,
with most being government-founded, government-run institutions,3
along with a handful of foreign foundations. By increasing the number
of corporate or private foundations, the government sought to attract
an alternative stream of finance and fill gaps in service provision around
areas such as poverty reduction and disability welfare.
It was from the millennium onwards that civil society groups con-
cerned about emerging social problems and minority interests began
to take off. Whilst most social organisations founded in the 1980s and
1990s were trade, academic, business, and professional associations,
from the millennium onwards, there was a rise in the number of social
organisations engaged in rights work, service delivery, and advocacy on
behalf of poor and marginalised groups (Howell 2003; Pei 1998). This
was in part because the socio-economic effects of two decades of rapid
market reform were becoming increasingly visible by 2000 and in part
because the new leadership under Hu Jintao and Wen Jiabao shifted the
political discourse to ‘balanced development’, ‘people-centred devel-
opment’, and ‘harmonious society’, metaphors for the widening gap in
income equality. It was also because citizens were already forming social
organisations in response to gaps in government support, such as early
intervention for children with autism. However, it was the response of
citizens and NGOs to the Wenchuan earthquake in 2008 that contrib-
uted to a more favourable outlook amongst government officials towards
service-delivery NGOs and brought home the potential utility of NGOs
as supplementary agencies to the government in welfare provision and
humanitarian relief (Schneider and Hwang 2014; Shieh and Deng 2011;
Simon 2009; Teets 2009).
During the Hu-Wen era, various initiatives were taken to foster the
development of non-governmental actors in financing and delivering
welfare services, including revised regulations on foundations and exper-
iments in relaxing the registration requirements for service- focussed
NGOs. The 1998 regulations on the administration of foundations
were revised in 2004 to make it easier for wealthy entrepreneurs, phi-
lanthropists and corporations to provide an alternative source of wel-
fare financing and to establish non-public fund-raising foundations.
Two years later, the MOCA promulgated the Measures for the Annual
Examination of Foundations 2006 and the Measures for Release of
Information of Foundations 2006. The implementation of these Measures
was crucial in laying the basis for the future transparent development of
non-public fund-raising foundations and thus raising the level of public
confidence in donating funds to foundations. As well as strengthening
processes of transparency and governance, these new measures and reg-
ulations also clearly delineated public fund-raising foundations, mainly
government-organised foundations, from private or corporate philan-
thropic foundations, which were not permitted to raise public funds.
These measures were followed by the Law of Enterprise Income Tax 2007,
which stipulated that “public benefit donations made by enterprises can
be exempted from income tax due, with a ceiling of 12% of the annual
profit”, thus encouraging businesses to donate to philanthropic causes.
78 J. HOWELL ET AL.
In 2010 the launch of the China Foundation Centre, a non-

governmental, sectoral information service website marked the first time
that foundations were self-regulating their affairs rather than subjecting
themselves only to government regulation. This marked an important
step in instilling public confidence in foundations, particularly in the
wake of the various scandals engulfing government foundations that year.
In contrast, other types of social organisations, such as NGOs, had still
not established any independent, self-regulating bodies.
This suite of new regulations improved the environment for com-
panies to undertake philanthropic activity and gave the green light for
the expansion of private foundations. The number of private foun-
dations increased threefold from 892 in 2004 to 3,029 in 2012 and
reached 3,198 in 2015 (MOCA Statistical Yearbook 2012, p. 155; China
Statistical Yearbook 2013, p. 783). Thus by 2015 governmental or
public fund-raising foundations were in the minority, standing at 1,548.
Whilst most new foundations required national-level approval, in the
summer of 2009 Shenzhen municipal government, a leading site for gov-
ernance reform, was granted the power to approve public fund-raising
foundations, enabling the One Foundation to register in January 2011 as
an independent public fund-raising foundation (Yin 2011).
However, some Party leaders harboured growing suspicion about the
role of external actors in the wake of the Colour Revolutions in Georgia
(2003), Ukraine (2004), and Kyrgyzstan (2005). The security agencies
such as the Ministry of Public Security were concerned that foreign gov-
ernments and foreign-financed NGOs were behind apparent attempts to
destabilise and overthrow the government. Though the MOCA for many
years had been urging a relaxation of the regulatory environment to ena-
ble service-delivery NGOs to play a greater part in welfare provision, the
security agencies persisted in hindering any such reforms, suspicious not
only of foreign NGOs and foundations and the groups they financed and
supported, but also of other domestic groups that might harbour opposi-
tional tendencies (Howell 2015).
Two new initiatives in 2009 sought to strengthen government control
over foreign agencies. The first was the Notice on Issues Concerning the
Administration of Foreign Exchange Donated to or by Domestic Institutions
2010 by the State Administration of Foreign Exchange. Stipulations requir-
ing donated funds to be paid into a special foreign exchange bank account
and documentation to be notarised sought to tighten control over foreign
funding and were likely to add to the administrative burdens of NGOs.
The second was a new MOCA regulation piloted in Yunnan province—

the Yunnan Province Provisional Regulations Standardizing the Activities
of Foreign NGOs. The intent here was again to strengthen control over for-
eign funding and activities in China and was a precursor to the eventual
passing of a new law in April 2016 on foreign NGOs, namely, the Law of
the People’s Republic of China on the Management of Activities of Overseas
Non-governmental Organisations in Mainland China, (hereafter referred to
as the Foreign NGOs Law). Foreign NGOs Management Law 2016.
Nevertheless, it is important to underline that NGOs were not restricted
or contained as they had been in the pre-reform era. Many were allowed to
exist as unregistered organisations, partly because of the lack of state capac-
ity to monitor them and control them, partly because local government offi-
cials viewed some as harmless, and partly because they were instrumentally
useful to local officials. NGOs assisted the government by filling gaps in ser-
vices and providing feedback on citizens’ priorities and preferences. There
was nevertheless suspicion and concern about such groups being opposition
groups or front agencies for anti-regime activities, especially amongst public
security agencies. Though NGOs existed in a limbo registration situation,
they were always under threat of potential surveillance, harassment, and clo-
sure which made organisational development and expansion difficult.
It was in the context of welfare reforms aimed at pluralising the
financing and delivery of services and the more favourable governmental
stance towards NGOs after the Wenchuan earthquake that the MOCA
was given the go-ahead in 2008 to experiment with relaxing regulations
governing certain types of NGOs in certain cities and provinces such as
Shenzhen, Beijing, and Guangdong so that they could apply for gov-
ernment service contracts. In fact, sub-contracting welfare to NGOs
had started earlier with Asian Development Bank support for tender-
ing to NGOs for poverty reduction projects in Jiangxi province in 2005
but was very limited (Jia and Su 2009). In the experimental locations
identified in 2008, social organisations for public welfare and public ser-
vices could get registered directly with local civil affairs departments, and
approval by a competent business unit was no longer required (Zhou
2012; Wei 2011). The MOCA released the Measures for the Evaluation
and Management of Social Organisations 2010. This was the first time
the MOCA had attempted to regulate the evaluation of civil society
organisations using ministerial regulations, reflecting the moves afoot to
institutionalise and professionalise the role of NGOs in China’s welfare
system. The need for such professionalisation was an emerging theme
80 J. HOWELL ET AL.
within China in studies of NGOs and amongst policymakers (Li and

Hou 2009; Liu 2008; Deng 2003; Li 2003).
Encouraged by the results of these pilots, the MOCA issued a doc-
ument in the summer of 2012 effectively endorsing this change in reg-
istration regulations across the country. According to this, certain types
of social organisations such as charities, industrial associations, and pub-
lic interest groups could register directly with the relevant level of the
MOCA. As potential supervisory units were usually reluctant to take on
responsibility for a social organisation, this new regulation potentially
could make registration easier for social organisations in the welfare field.
This then enabled government departments concerned with welfare
issues to expand more easily their pool of service providers, and specifi-
cally non-governmental welfare organisations.
Building upon the experimentation with sub-contracting and NGOs
in the Hu-Wen era, the newly installed Xi administration (2012 onwards)
issued a raft of legislation, regulations, and policies in the first five
years of office that were to shape the further development of NGOs in
China. Significant here were the various national and local level regula-
tions extending subcontracting to NGOs across the country, the Foreign
NGOs Law 2016, with effect from January 2017, and the Charity Law
2016. The Charity Law had been severely delayed during the Hu-Wen
eras for a variety of reasons. The passing of this law was significant
because it strengthened the legislative and regulatory basis for non-gov-
ernmental service providers and legitimised their role in the field of
welfare provision. Academics and practitioners viewed it as an enabling
law, though with some caution (Shieh 2016). In terms of child welfare
NGOs, the most directly relevant reforms in the Xi era were the rolling
out of the new registration requirements needed for sub-contracting and
the Foreign NGOs Law 2016.
Soon after Xi Jinping came into office, the State Council indicated
in March 2013 that its plan for state restructuring and transfer of gov-
ernment functions would foster the development of social organisations
(He 2013). This plan sought to permit four categories of NGOs, namely,
industrial associations, charities, community services, and science and
technology associations, to register directly with the relevant level of the
civil affairs bureau, without the need to identify a sponsoring agency.
In July 2013 Guangdong, one of the earlier pilot sites for the change,
issued regulations for eight types of NGOs to register directly. The
Making Innovations in the Social Governance System 2013 Decision at the
3rd Plenum of the 18th Central Party Committee further endorsed this
direction, affirming that selected organisations such as charities, philan-
thropic organisations, and community organisations could ‘directly apply
for registration’ and that ‘social organisations should be commissioned to
provide public services’.4 By 2015, local governments across the country
had issued local regulations for implementing this new direction in their
particular contexts (Shen and Ma 2013).
Although the intent of the sub-contracting arrangements was to diver-
sify the supply of service providers, the policy has encountered numer-
ous teething problems as it has been rolled out. For example, although
the tendering system was ideally competitive, in practice local govern-
ment officials have tended to favour NGOs that they were already famil-
iar with (Jing and Chen 2012). There have been issues around ignoring
the scoring results to award the contract to a favoured candidate, as well
as concerns about the potential for corruption without careful monitor-
ing procedures being put in place (Shen and Ma 2013). The opportu-
nities for departmental gains has reportedly led to some departments
creating their own NGOs to win contracts and expand the resources of
the department (Wu 2013). Furthermore, though the removal of the
requirement to find a supervisory governmental agency was meant to
facilitate registration, in practice some risk-averse local level civil affairs
bureau have been hesitant to become responsible for NGOs previously
unknown to them (personal communication 2017).
From the perspective of service-focused NGOs this strategy of wel-
farist incorporation provided an opportunity to access government funds,
gain legal legitimacy as players in the field of social welfare, extend client
markets, develop the organisation, and scale up activities. To the extent
that service-delivery NGOs had built up their accountability and legit-
imacy and gained governmental and public trust and confidence, the
better positioned they were to win such government contracts. For child
welfare NGOs these policy changes opened up the possibility of gain-
ing legal status through registration and strengthening their stock of
accountability capital, and ultimately legitimacy.
Whilst these new policies on registration and subcontracting point
to strong support for a service-oriented civil society, it has also been
counter-balanced by an intensive clampdown in 2015 and 2016 on the
Internet, lawyers, labour NGOs, feminists, and other rights-based groups
and individuals. Already introduced in the late Hu-Wen era, the require-
ment to set up a Party cell in NGOs has been more stridently pursued
82 J. HOWELL ET AL.
under Xi’s office. In this way the Party can use NGOs as a source of
information about the concerns and priorities of citizens, enabling it to
adjust policies, and ultimately to maintain support. The relaxation of the
regulatory registration regulations aimed to expand the supply of welfare
services providers but also formed part of a broader strategy of crafting
a tamed civil society that was wholly service-oriented and supportive to
governmental interests.
The Foreign NGOs Law reflected this doubled-edged nature of pol-
icy reforms related to social organisations. Foreign NGOs had grown
substantially during the Hu-Wen era. The only regulations that had
applied previously to foreign agencies were the Provisional Regulations
on the Administration of Foreign Chambers of Commerce 1989 and the
Regulations on Administration of Foundations 2004, so that foreign
NGOs effectively were outside the legal system. Although the Law
sought to strengthen the legal basis of foreign NGOs in China and
bring legal order into their registration process, it also was a way to
limit international influence in China, particularly in light of the Colour
Revolutions and the 2011 Arab Spring. It is not insignificant that the
new Law requires foreign NGOs to register not with the MOCA, but
rather with the Ministry of Public Security. Various clauses in the leg-
islation such as Articles 41 and 42 of the Foreign NGOs Law, which
allow the police to enter NGO offices or project sites, copy documents,
seize property and freeze bank accounts, have caused considerable con-
cern amongst foreign NGOs (Shieh 2016, 2017). Effective from 2017,
foreign NGOs remain uncertain about their legal status as registration
processes have proven cumbersome and they have yet to establish their
room for manoeuvre in practice.
From the standpoint of Chinese NGOs, the Foreign NGOs Law also
raises concerns about their financial sustainability, as international donors
have been an important lifeline for their organisational sustenance and
development. The implications for child welfare NGOs of the tighter reg-
ulatory framework governing foreign NGOs relate not just to issues of
financial sources but also to more discrete benefits such as access to profes-
sional expertise, support for organisational development, opportunities for
training, and learning about international best practice. The new Foreign
NGOs Law has changed the context within which NGOs, and child welfare
NGOs, have to craft accountability and legitimacy. With the uncertainty
and risks around receiving foreign funds, child welfare NGOs in receipt of
foreign funding will more than ever need to orient their accountability and
legitimacy efforts to garner the support of the general public and govern-
ment. The politics of the processes whereby NGOs ‘make accountability
and legitimacy’ is thus important for understanding how they can survive
and develop, despite the shadow of government suspicion and surveillance
and despite a shifting regulatory environment that brings both opportuni-
ties as well as risks and constraints.
Challenges of Accountability for NGOs in China

The authoritarian context of China poses particular challenges for
NGOs in developing systems of accountability. First, as an authoritar-
ian regime, accountability systems for government officials, let alone
non-state actors, are poorly developed. Citizens have limited rights to
redress, though as discussed in the previous chapter, the CCP has initi-
ated new ways of improving the accountability of government officials to
citizens. Nevertheless, the systems of accountability remain fragmented
and inadequate to the shifting range of actors and demands. Democratic
accountability remains circumscribed and the notion of users of services
demanding accountability, regardless of the type of provider, is novel.
Second, as the regulatory environment governing NGOs is restrictive
and demanding, many NGOs do not have legal status. They have either
registered as for-profit companies or operate in a state of legal limbo.
They exist in a context of uncertainty, often subject to suspicion, harass-
ment, and closure whilst simultaneously being tolerated and sometimes
courted by some branches of government which see the benefit of their
work in terms of service provision, providing information about citizens’
needs and concerns, and social stability. As they are legally outside the
system, they do not fall under the accountability requirements stipulated
in the relevant supervisory policies for registered groups. The question-
able legal status of these NGOs poses particularly grave risks to children
who use their services and in the worst cases remain unregistered, with
no recourse to the rights of other citizens. Given that many NGOs will
not meet the criteria for sub-contracting services due to capacity, size,
or relations with local government officials, or indeed may not wish to
do so for fear that this could affect their independence, it is likely that
unregistered welfare-oriented NGOs will continue to occupy the spaces
of legal limbo.
Third, for a variety of reasons such as the restrictions on NGOs set-
ting up branches and organising across the country, the fragmentation
84 J. HOWELL ET AL.
of and competition amongst NGOs, as well as the lack of a developed

sectoral identity and support infrastructure, NGOs have not established
systems of self-regulation that would strengthen their accountability to
users, funders, and the public. There are no effective independent watch-
dog governing NGOs, no self-organised systems of mutual, horizon-
tal accountability, no umbrella groups that coordinate and preside over
standards, no voluntary codes of conduct that apply to NGOs, or par-
ticular domains of NGO activity. NGO staff do not necessarily expect
that the organisation will be run in a democratic and open way, either
in relation to their own participation in decisions in the organisation or
in relation to users being able to hold the organisation to account. As
in many contexts where civil society organisations are newly emerging,
the pioneers of NGOs are often, strong charismatic leaders, who staff
and beneficiaries may feel in awe of and be reluctant to challenge their
authority and power. As a result, most NGOs have few regularised chan-
nels through which staff can hold leaders to account or through which
users and beneficiaries can hold NGO staff to account.
Fourth, existing accountability systems of NGOs such as direct super-
vision by a government agency for registered NGOs or accountability to
funders prioritise upward, managerial accountability rather than down-
ward, democratic accountability. Even within managerial accountabil-
ity, the emphasis tends to be on financial accountability rather than on
outcomes and the impact of NGOs’ work on the supposed beneficiar-
ies. Given that citizen participation in governance processes in relation to
government are sharply circumscribed, there is little expectation that the
users of services or beneficiaries should have a role in governing NGOs.
Added to this, entrenched cultural values and biases along the lines of
gender, age, education foster deference to those with authority and
power and a reluctance to call for accountability, unless there are coun-
tervailing pressures for social change. Furthermore, government super-
vision of NGOs is driven not just by issues of managerial accountability
and reducing the risks of malfeasance and poor practice, but also by the
potential risk that the government perceives NGOs might pose to regime
stability.
Finally, the situation in China is less about the process of reinventing
accountability in a democratic environment as Goetz and Jenkins (2005)
describe, but more about a process of adaptation and innovation in an
authoritarian context where few examples of doing accountability exist,
particularly democratic accountability. Accountability systems between
citizens and state in China have been limited, partly because of structural
factors such as the absence of independent oversight institutions such as
ombudsmen, the lack of independent civil society organisations and the
absence of an independent media. As noted in Chapter 2, the CCP has
been adapting its systems of accountability in response to an expanding
arena of more autonomous civil society organisations, the emergence of
a more independent and investigative media, the rise of social media and
the need to appease dissatisfied, and more vocal citizens. This process of
institutional innovation by the government opens up spaces for NGOs,
too, to experiment with and grow different ways of doing accountability
that are not limited to managerial accountability but that can also poten-
tially embrace democratic accountability. It allows us to observe the pro-
cesses of gradual institutional change through the lens of accountability.
Having provided a background to the developmental trajectory of
NGOs in China and the challenges for accountability and legitimacy, the
next section focuses on the specific situation of child welfare NGOs. It
provides an overview of the legislative, policy and regulatory environ-
ment governing child welfare NGOs. This environment creates particular
sectoral challenges to child welfare NGOs compared to other types of
NGOs, with implications for their development.
Child Welfare NGOs

Child welfare NGOs are important contributors to the Chinese mixed
welfare state and offer a useful lens to understand service-delivery
NGOs. Their development is closely related to the larger development
of the Chinese civil society, non-governmental and non-profit sector. The
child welfare NGOs discussed in this book include foundations, social
organisations, and non-profit organisations that provide child welfare
and child protection services. Like other social organisations in China
that call themselves NGOs, these organisations include those with a for-
mal and legal registered NGO status (foundation, social organisation, or
registered people’s run non-profit enterprise (minban feiqiye danwei 民
办非企业单位); formal and legal registered status as a for-profit enter-
prise, carrying out non-profit service activities; and organisations with-
out any registered legal status, which may refer to themselves as NGOs
or people’s run non-profit unit (minban feiyingli danwei, 民办非营利单
位).5 In practice, a range of terms are used interchangeably, with NGOs
referring to themselves using different terms in the same conversation.
86 J. HOWELL ET AL.
Added to this, there was an ongoing debate at the time of writing

around whether the term non-profit organisation (minban feiyingli dan-
wei, 民办非营利单位) should be applied more broadly to include social
organisations, foundations and social service organisations. Indeed, the
MOCA was considering introducing a new regulation for a new category
of ‘social service organisations’ and was no longer using the registration
category non-profit enterprise (minban feiqiye danwei, 民办非企业单
位).6 How organisations were named and categorised was thus subject to
considerable flux and contestation, leading to confusion in nomenclature
both in regulations and everyday usage.
State institutions are also important players in the field of child welfare
and many increasingly rely on more financial, technical, and manpower
resources from non-governmental sources than from the government.
We argue that these state institutions have also become a type of mixed
child welfare organisation themselves that rely not just on state fund-
ing but also international NGOs, public, and corporate funds. In terms
of accountability processes, such organisations already differ from ones
that fully depend on government funds and so we include them in the
analysis.
Children’s Services Characteristics

Child welfare organisations generally deliver services to children who
have specific support needs. One type of service is for children liv-
ing with their families and who have additional needs, such as children
with disabilities, serious diseases, or living in extreme poverty. The sec-
ond type of service is for children whose birth parents are absent, such
as children who are orphaned or abandoned, street children, children
of prisoners, or children who have been removed from their birth par-
ents due to abuse. The need for these services has gradually diminished
over the last 20 years. Most children left in state care are now children
with disabilities and most of them are now fostered or adopted within
China (Shang and Fisher 2014). On the other hand, the number of chil-
dren who have been removed from their birth parents due to abuse and
neglect is increasing (Katz et al. 2011).
The children typically require professional services specific to their
needs. As a relatively small proportion of children, they do not have
enough political voice to influence policymaking, and so state-provided
public services do not usually meet their needs. Market services are
usually inadequate because even if the services are available, they are spe-
cialist and expensive compared to other child care and education. These
factors mean that public and private provision of these children’s services
is insufficient in most locations. In this context, the organisations that
provide the services are often non-profit organisations and charity organ-
isations. Their service costs are sustained through charging fees at cost to
families who can pay, charity donations and volunteer services. In these
circumstances, the accountability of the organisations is particularly sen-
sitive because the children rely on the goodwill of the organisations to
provide adequate quality services necessary for their quality of life.
According to a 2013 survey conducted by the Ministry of Civil Affairs
(MOCA), there were 878 private institutions run by individuals or
organisations taking in 9,394 orphaned and abandoned children. Most
of these had not registered and thus did not have legal status. Of the 878
non-governmental adoption institutions, 583, that is more than 60%,
had religious affiliations. Whilst after 1949 churches were prohibited
from operating in China, including in the sphere of social welfare, with
the opening up of the economy from 1978 onwards, churches were per-
mitted to operate again, though within a tightly controlled environment.
Some church property that had been confiscated in the early 1950s was
also restored. The scale of unregistered institutions points not only to
the lack of state capacity both in terms of implementing registration reg-
ulations and in providing adequate welfare but also to the degree of tacit
complicity in ensuring the survival of these organisations so as to meet an
urgent and expanding child welfare need.
Legal Status
In addition to the laws and policies for other NGOs described ear-
lier in this chapter, children’s services face additional regulation due to
the vulnerability of children, including the Law of the People’s Republic
of China on the Protection of Minors 2006, and Interim Measures for the
Administration of Social Welfare Institutions (MOCA 1999, 2012).
These laws include provisions on the establishment, functionality, and
management of child welfare organisations (Shang 2007). Child welfare
NGOs must comply with the general registration requirements for social
organisations and they also must meet the specific conditions of child
welfare institutions. For example, educational organisations that pro-
vide services for children with disabilities must meet relevant stipulations
88 J. HOWELL ET AL.
on private schools issued by the educational department. Child welfare

organisations or individuals that provide services for children not in the
care of their birth parents must be jointly run with state-owned child
welfare institutions:
Social organisations and private social welfare organisations that pro-

vide services for orphans and abandoned infants must be run jointly with
civil affairs agencies of the local government at the county level or above.
(MOCA 1999, 2012)
Such a regulation where the state administers adoption is commonplace

in many countries. In practice, however, this regulation in China was
ignored due to the shortage of services from state child welfare institu-
tions. Many child welfare NGOs operated without registration and were
not forbidden (Shen and Shang 2015, January 28). It is likely that more
child welfare organisations were unregistered than registered. These
organisations were under-regulated, whilst the registered ones were
over-regulated, yet both were not accountable for quality of services
standard.
In 2013, after the fire event described in Chapter 1 (China Youth
Newspaper 2013, January 1), seven government departments includ-
ing MOCA jointly issued a document reiterating strict administration
of child welfare NGOs that care for abandoned children.7 The MOCA
investigated all NGOs involved in caring for abandoned children with-
out legal guardianship and prohibited them from taking on any new
children. Following the 2013 survey, the MOCA also issued the Notice
on Regulating the Adoption of Orphaned and Abandoned Children by
Religious Organisations 2014, which stated that “Organisations that are
initiated by religious organisations and take in orphaned and abandoned
children must be run jointly with civil affairs agencies of the local gov-
ernment at the county level or above”. This notice would bring private
orphanages under closer state scrutiny. Both regulations meant that
unregistered child welfare NGOs faced difficulties continuing to oper-
ate. Closing the organisations could have negative consequences for the
children already in their care, so the government faced the choice of
strengthening their accountability, knowing they may be forced to close
if they do not meet the higher standards, or supporting them to improve
their standards, including assisting them to register.
Accountability of Registered Child Welfare

Organisations
The MOCA policy goal on child welfare NGOs is to keep children safe,
requiring that civil affairs departments at local levels provide direct protec-
tion for all children not in the care of their birth parents, and  requiring
that child welfare NGOs cannot be run independently. The government’s
accountability requirements for these NGOs are highly concentrated on
meeting basic registration standards as competent business units, rather
than considering the quality of their child welfare services.
The uneven accountability between organisations registered as NGOs,
registered as businesses or not registered will remain until the govern-
ment addresses the barriers to registration. This includes enabling all
eligible child welfare organisations to become legal and establish direct
legal relations with the government, making it possible for civil society
and the state to supervise and support their work and for children and
families to demand quality services to meet their needs.
The current administrative system for social organisations and people’s
run non-profit units (minban feiyingli danwei, 民办非营利单位) directly
influences the accountability of child welfare NGOs. The accountabil-
ity is to the local civil affairs department, the competent business units,
and the multiple government departments relevant to child welfare. The
government’s top-down accountability demand for child welfare NGOs
is based on clearly defined responsibilities and duties as well as detailed
and specific operational procedures. The response of child welfare NGOs
to the accountability demand is a mandatory requirement. Refusal to
respond to the accountability requirements for supervision and inspec-
tion may result in the cancellation of the NGO’s business license or lead
to more serious punishment including ceasing activities within a des-
ignated period and revocation of registration; if the case constitutes a
crime, the criminal liability will be investigated according to law.
Full compliance by child welfare NGOs with the regulations is
unlikely and the consequences are compromised because, in spite of the
strict registration system and deterrence, the social demand for children’s
services is so high that many child welfare NGOs remain unregistered
or do not comply with regulations. As the government’s accountability
under the authoritarian political regime is focused on legal accountabil-
ity, political accountability, and economic accountability, there is a con-
siderable lack of accountability in other areas concerning child welfare,
90 J. HOWELL ET AL.
such as the professional competence of organisations and the protection

of the rights and welfare of children.
The current administrative system for social organisations and NGOs
is focused on constraining the development of political organisations.
The civil affairs administration, as a department that is in charge of the
welfare of children, is well aware that for years state investment in the
welfare of children has been insufficient and that the existence of child
welfare NGOs reduces the burden on the civil affairs administration. The
civil affairs administration supports in most circumstances the develop-
ment of alternative providers for child welfare services. Moreover, there
are many pressures on the civil affairs administration and in Chinese soci-
ety to reform the administrative system for social organisations and non-
profit organisations, allowing more non-governmental contributors to
enter this field and address welfare gaps that the state is unable or unwill-
ing to fill.
This chapter located the analysis of accountability-making and legit-
imacy in child welfare organisations within the broader historical-
institutional context of welfare reforms and the development of civil
society, including NGOs. It then reflected on the particular challenges
that NGOs seeking to enhance their accountability to the public, donors,
government, and users face in authoritarian China. Finally, it provided an
overview of the specific regulatory environment governing child welfare
NGOs and the sector-specific challenges they encounter.
The next chapters move on to explore in-depth how this context
shapes accountability processes in four case-studies of child welfare
organisations. In this way, the chapters look through a fine lens at the
constraints and opportunities that the child welfare organisations face,
how they craft accountability and legitimacy and how differential power
relations shape a hierarchy of accountabilities and the reproduction of
social biases. The next four chapters explore the cases of Liming Family,
a religious-based, child welfare organisation with a trajectory of over
30 years; Angel House, a user-founded child welfare NGO; Children’s
Hope Foundation, which transited from a quasi-governmental organisa-
tion to an independent NGO; and a mixed welfare institution, a state
institution under pressure to diversify its sources of funding. All four
cases exemplify the politics of the processes of accountability making and
establishing legitimacy.
Notes
1. See also State Council (1998a, b).
2. These regulations were the 1998 ‘Provisional Regulations for the
Registration and Administration of People’s Run Non-Profit Enterprise’,
the ‘Administrative Regulations on Foundations’, the ‘Provisional
Regulations on Foundations’, and the 1999 ‘Law of Donations on Public
Welfare’.
3. There were only 8. See China Development Brief (2004).
4. See Decision of the 3rd Plenum of the 18th Central Committee of the
CCP, Section XIII Making Innovations in the Social Governance System.
5. It should be noted that some researchers object to the term ‘people’s run’
as it can evoke associations with the Maoist period when 5% of the people
were considered enemies of the people.
6. At local level, the Civil Affairs Bureau were continuing to register organi-
sations as non-profit enterprises (minban feiqiye danwei, 民办非企业单位).
7. These were the MOCA, National Development and Reform Commission,
Ministry of Public Security, Ministry of Justice, Ministry of Finance,
National Health and Family Planning Commission, and State
Administration of Religious Affairs.
References
Bland, D., & Yu, K. M. (2004). A long financial march: Pension reform in
China. Journal of Social Policy, 33(2), 267–288.
Brugger, B., & Reglar, S. (1994). Politics, Economy and Society in Contemporary
China. Basingstoke: Macmillan Press.
Chan, A. (2001). China’s Workers Under Assault: The Exploitation of Labour in a
Globalising Economy. Armonk: M.E. Sharpe.
Chan, C. K., Ngok, K. L., & Phillips, D. (2008). Social Policy in China:
Development and Well-Being. Bristol: The Policy Press.
China Youth Newspaper. (2013, January 1). Mass media reporting the death of
seven orphans in Henan: Abandoned when they were alive, and death because
of neglect. China Youth Newspaper.
Croll, E. (1994). From Heaven to Earth. London: Routledge.
Davin, D. (1976). Woman-Work: Women and the Party in Revolutionary China.
Oxford: Clarendon Press.
Deng, G. (2003). Build up and accountability mechanism for Chinese non-profit
organisations. Chinese Public Administration, 3, 28–29.
Dreyer, J. T. (2000). China’s Political System: Modernisation and Tradition.
Basingstoke: Macmillan Press.
92 J. HOWELL ET AL.
Goetz, A., & Jenkins, R. (2005). Reinventing Accountability: Making Democracy

Work for Human Development. Basingstoke: Palgrave Macmillan.
He, D. (2013, April 17). New rules for NGOs to improve operations. China
Daily.
He, Z. (2015). Governance and Adaptation of the Chinese Communist Party: A
Comparative Perspective. Beijing: China Compilation and Translation Bureau.
Hildebrandt, T. (2013). Social Organisations and the Authoritarian State in
China. Cambridge: Cambridge University Press.
Howell, J. (1996). The struggle for survival: Prospects for the women’s federa-
tion in post-Mao China. World Development, 24(1), 129–144.
Howell, J. (1997). Post-Beijing reflections: Creating ripples but not waves.
Women’s Studies International Forum, 20(2), 235–252.
Howell, J. (2003). New directions in civil society: Organising around margin-
alised interests. In J. Howell (Ed.), Governance in China (pp. 143–171).
Boulder, CO: Rowman and Littlefield.
Howell, J. (2015). Shall we dance? Welfarist incorporation and the politics of
state-labour NGO relations. The China Quarterly, 223, 702–723.
Huang, Y. (2008). Capitalism with Chinese Characteristics: Entrepreneurship and
the State. New York: Cambridge University Press.
Huang, Y., Guo, F., & Tang, Y. (2010). Hukou status and social exclusion of
rural-urban migrants in transitional China. Journal of Asian Public Policy,
3(2), 172–185.
Jia, X., & Su, M. (2009). Final Report on Government Procurement of Public
Services, P.R. China. Manila: Asia Development Bank.
Jing, Y., & Chen, B. (2012). Is competitive contracting really competitive?
Exploring government-nonprofit collaboration in China. International Public
Management Journal, 15(4), 405–428.
Katz, I., Shang, X., & Zhang, Y. (2011). Missing elements of a child protection
system in China: The case of LX. Social Policy and Society, 10(1), 93–102.
Kaufman, J. (2012). The global women’s movement and Chinese women’s
rights. Journal of Contemporary China, 21(76), 585–602.
Kennedy, J. J. (2007). From the tax-for-fee reform to the abolition of agricul-
tural taxes: The impact on township governments in north-west China. The
China Quarterly, 189, 43–59.
Leung, J. C. B., & Xu, Y. (2015). China’s Social Welfare: The Third Turning
Point. Cambridge and Malden, MA: Polity Press.
Li, H. (2003). On construction of the public accountability of non-profit organ-
isations. Journal of Shanghai Jiaotong University (Edition of Philosophy and
Social Sciences), 11(1), 32–36.
Li, B. (2006). Floating population or urban citizens? Status, social provi-
sion and circumstances of rural-urban migrants in China. Social Policy and
Administration, 40(2), 174–195.
Li, B. (2014). Social pension unification in an urbanising China: Paths and con-
straints. Public Administration and Development, 34(4), 281–293.
Li, S., & Hou, J. (2009). Problems in the accountability of Chinese non-profit
organisations and countermeasure. Journal of China National School of
Administration, 6, 49–53.
Lieberthal, K. (1995). Governing China: From Revolution Through Reform. New
York: W.W. Norton.
Liu, J. (2008). Complete the accountability mechanism of Chinese non-profit
organisations. Hubei Social Sciences, 5, 42–44.
Ministry for Civil Affairs (MOCA). (1999). Interim Measures for the
Administration of Social Welfare Institutions, http://www.mca.gov.cn/article/
zwgk/fvfg/zdshbz/200711/2007110003485.shtml. September 1, 2015
Ministry of Civil Affairs (MOCA). (2012). China Civil Affairs Statistical
Yearbook 2012. Beijing: National Statistical Press.
National Bureau of Statistics, China. (2013). China Statistical Yearbook 2013.
Beijing: National Statistical Press.
Ostergaard, C. S. (2004). Governance and the political challenge of the Falun
Gong. In J. Howell (Ed.), Governance in China (pp. 207–225). Lanham,
MD: Rowman and Littlefield.
Pei, M. (1998). Chinese civic associations: An empirical analysis. Modern China,
24(3), 285–318.
Pringle, T. (2011). Trade Unions in China: The Challenge of Labour Unrest.
Abingdon: Routledge.
Saich, A. (2008). Providing Public Goods in Transitional China. New York: Palgrave.
Schneider, F., & Hwang, Y. (2014). The Sichuan earthquake and the heavenly
mandate: Legitimising Chinese rule through disaster discourse. Journal of
Contemporary China, 23(88), 636–656.
Shang, X. (2007). Impacts and Revolutions. Beijing: China Social Sciences
Publishing House.
Shang, X., & Fisher, K. R. (2014). Caring for Orphaned Children in China.
Lanham: Lexington Books.
Shen, X., & Ma, S. (2013). Government service-purchasing: From “paper” regula-
tions to on-the-ground implementation. China Social Organization, 2, 12–15.
Shen, Y., & Shang, S. (2015, January 28). Dilemma for identity of private child
relief organisations. Procuratorial Daily. Retrieved from http://newspaper.
jcrb.com/html/2015-01/28/content_177973.htm.
Shieh, S. (2016). Charity Law FAQs. Retrieved from http://ngochina.blogspot.
co.uk/search?q=Charity+Law.
Shieh, S. (2017). The origins of China’s new law on foreign NGOs. China File.
Retrieved from http://www.chinafile.com/reporting-opinion/viewpoint/
origins-of-chinas-new-law-foreign-ngos.
Shieh, S., & Deng, G. (2011). An emerging civil society: The impact of the 2008
Sichuan earthquake on grassroots associations in China. The China Journal,
65, 181–194.
94 J. HOWELL ET AL.
Simon, K. W. (2009). Regulation of civil society in China: Necessary changes

after the Olympic Games and the Sichuan earthquake. International Journal
of Civil Society Law, 8(2), 60–89.
State Council 1998a, Regulations on registration and administration of social
organisations. http://swshzz.chinanpo.gov.cn/6036/62166.html. 2015.6.21
State Council 1998b, Provisional regulations on registration and administration
of private non-profit entities. http://swshzz.chinapo.gov.cn/6036/62170.
html, 2015.6.21
Su, L., Ge, Y., Zhang, S., & Gao, B. (1999). Regulations and Development: The Third
Sector’s Legal Environment. Hangzhou: Zhejiang People’s Publishing House.
Taylor, B., Chang, K., & Li, Q. (2003). Industrial Relations in China.
Cheltenham: Edward Elgar.
Teets, J. C. (2009). Post-earthquake relief and reconstruction efforts: The emer-
gence of civil society in China? The China Quarterly, 198, 330–347.
Walder, A. (1986). Communist Neo-traditionalism: Work and Authority in
Chinese Industry. Berkeley: University of California Press.
Wei, M. (2011, November 24). A Parent-unit is no longer required for social
organizations to get registration in Guangdong. Beijing News. Retrieved from
http://news.xinhuanet.com/society/2011-11/24/c_111190021.htm.
White, G., Howell, J., & Shang, X. (1996). In Search of Civil Society: Market
Reform and Social Change in Contemporary China. Oxford: Clarendon Press.
Williams, J. (1986). A tragedy of good intentions: Post-Mao view of the great
leap forward. Modern China, 12(4), 419–458.
Wu, J. (2001). Government Reform and the Development of the Third Sector.
Beijing: China Social Sciences Publishing House.
Wu, H. (2013). Model study of Xuzhou city government procurement of resi-
dential services for the elderly. Commercial Economy, 10, 29–31.
Yin, P. (2011, August 4). A new dawn for NGOs. Registration requirements
relaxed for charity work. Beijing Review. Retrieved from http://www.bjre-
view.com/nation/txt/2011-08/01/content_380902.htm.
Zhao, S. (2012). Looking back three decades. In New Destiny of Peasants (pp.
377–385). Beijing: Shangwu Yinshuguan.
Zhou, H. (2012). Suggestions on Revision of ‘‘Interim Regulations on
Registration Administration of Private Non-Enterprise Organisations’’ and
Improvement of the Registration Administration System for Social Service
Organizations. Retrieved from http://www.hongyu-online.com/showinfo.
asp?id=9061.
CHAPTER 4
Making Accountability—Liming Family
This chapter is the first of the case-studies that explore accountabil-

ity within child welfare organisations.1 Liming Family existed in legal
limbo for over 30 years as a non-governmental orphanage run by a
religious organisation in a rural county in Hebei province (Shang and
Fisher 2014). In 2013, it was finally able to register with the Civil Affairs
Bureau for its disability services, but not as a child welfare institution for
its support to orphaned children. It achieved this partial registration by
capitalising on the changing regulatory environment from 2008 onwards
and by strategically accumulating stocks of accountability capital, such
as fostering a reputation in the community for a professional and caring
approach, displaying the work of the NGO to the public, and developing
positive relations with government officials. Such performative acts to
build accountability and credibility were thus an important precursor to
procedural legitimacy through registration that provided a legal bedrock
for accountability. Gaining legal status was important not only because it
endowed a measure of governmental and public confidence in the organ-
isation and triggered certain governmental accountability procedures and
inspections as described in Chapter 3, but also because it enabled the
organisation to improve the welfare of children by providing certain ser-
vices and opportunities for the children in its care.
Despite its lack of legal status as a child welfare organisation, Liming
Family was still subject to formal financial and organisational account-
ability procedures required by higher levels of the church. After regis-
tering as a disability social organisation in 2013, it became subject also

https://doi.org/10.1007/978-3-319-90221-0_4
96 J. HOWELL ET AL.
to governmental procedures and inspections. Nevertheless, this was not

sufficient for providing account to the public, users, or government,
whether through formal or informal means. In their efforts to accumu-
late stocks of accountability capital, Liming Family’s accountability sys-
tems along multiple dimensions remained biased upward towards vertical
authorities, with little attention paid to user accountability and limited
professional accountability. Furthermore, there were no clear systems of
accountability between the fostering parents and the church or state.
The chapter begins by briefly describing the nature of Liming Family,
its origins, the care it provides, and its target groups. In the next sec-
tion, it goes on to trace the difficulties Liming Family faced in achieving
legal status through registration. It examines its strategies for accu-
mulating accountability capital and legitimacy, its tactics in highlight-
ing government failure to provide fully for orphaned children, and its
efforts to extract policy benefits to secure children’s rights. In doing so
it also explores the performative acts to foster reputation and trust from
the government and community and accumulate accountability capital.
The last section examines the dimensions of accountability pursued by
Liming Family, including organisational, financial, and professional.
Liming Family: Origins, Purpose, and Activities

Liming Family is one of many religious organisations that runs orphan-
ages and carries out work on adoption. Liming Family is illustrative of
the difficulties facing unregistered organisations, and particularly those
with religious affiliations, in achieving legal accountability. As discussed
in Chapter 3, 60% of non-governmental adoption institutions were
faith-based organisations. The policy returning some church property
that had been confiscated in 1949 created the opportunity for Liming
Family to set up an orphanage and develop other children’s services.
Its expansion and eventual registration for disability services in 2013
has in part been due to its ability to develop second-order accountabil-
ity through nurturing public confidence and governmental trust in its
activities.
Liming Family’s roots date back to 1985, when some children with
disabilities were abandoned near the villages where converts congre-
gated together. The parents of these children expected that the church
or converts would take in their children. Acting according to their
beliefs, converts endeavoured to take care of these children, with families
4 MAKING ACCOUNTABILITY—LIMING FAMILY 97
taking turns initially to care for the children. As the effects of the ‘one
child, one family’ planning policy intensified, converts in each of the
neighbouring villages were soon caring for several children. The situa-
tion eventually became untenable. In 1988, Bishop Wang Chonglin in
Xingtai Parish set up an orphanage using the property returned to the
church by the government and commissioned Sisters of Teresa in the
parish to manage the orphanage.2 Since then, the number of children
taken in by Liming Family increased rapidly. Generally, Liming Family
received seven or eight children per week and sometimes even two chil-
dren per day but could not admit all of these. By 1994, Liming Family
had admitted over 80 children into its care.
These children came to Liming Family through three different chan-
nels. First, some children were abandoned around the villages where
converts regularly gathered. Second, occasionally local policemen or
urban residents would send abandoned children or street children they
found to Liming Family. Usually, they did so by hiring a taxi to send the
newly identified abandoned children to Liming Family. For instance, a
child who lost both parents due to his father’s long-term imprisonment
was without food and began to steal food in town. Seeing this, some
policemen who were concerned about the risk of juvenile crime pooled
money to send the child to Liming Family. Liming Family then raised
the child until his father was released from prison. The third channel was
through the church. Liming Family admitted children sent by Catholic
churches from other cities and provinces.
For years, Liming Family was overwhelmed by a large number of
abandoned children it took in. It then put up posters in neighbouring
villages, requesting local villagers to stop sending abandoned children to
it. Meanwhile, Liming Family also called on the villagers to check for any
woman bearing a child who might be at risk of abandoning it to inform
Liming Family as soon as possible. Subsequently, local residents immedi-
ately informed Liming Family of cases of suspected child abandonment,
whenever they saw anyone with a sick baby. Then, the nuns would usu-
ally host the parents and child for one night at Liming Family, cover-
ing their travel expenses, and attempt to persuade the parents to return
home with the child. During festivals, Liming Family staff might visit the
families of such adults, providing clothes and other help. From then on,
the number of children abandoned in the local area decreased. However,
children abandoned in other areas and then sent to Liming Family con-
tinued to increase.
98 J. HOWELL ET AL.
As the work of Liming Family expanded, it gradually set up three

specialised units, the orphanage, and two rehabilitation centres. Only
the rehabilitation services were able to obtain registration. The three
units were located in Ningjin County in Xingtai City and Gaoyi County
in Shijiazhuang City, both in Hebei province. The first unit was the
orphanage established in early 1988 and renamed as the Biancun Liming
Family Nursing Centre, Biancun being a village near Ningjin County in
Hebei. It has not been able to register with the Civil Affairs Bureau. The
orphanage was followed in 2005 by the Gaoyi County Liming Family
Rehabilitation Station in Hebei province, which provides rehabilitation
treatment for children with cerebral palsy within or outside the orphan-
age. It registered as a people’s run non-profit unit (minban feiyingli dan-
wei, 民办非营利单位) engaged in disability services with Gaoyi County
Health Bureau and Gaoyi County Civil Affairs Bureau in 2005.
As the children in the orphanage grew up, the need emerged to pro-
vide them with skills for employment. To this end the third unit, the
Ningjin County Liming Vocational Training and Rehabilitation Centre
was set up in 2013, providing vocational training and protected employ-
ment to orphaned children and young people with disabilities aged over
14 years. It also registered in 2013 with the Civil Affairs Bureau as a peo-
ple’s run non-profit unit (minban feiyingli danwei, 民办非营利单位).
By May 2015, the three units in the Liming Family had taken in and
assisted over 600 orphaned children and children with disabilities, most
of whom had physical or intellectual disabilities, with conditions such as
cerebral palsy, cleft lip and palate, developmental delay, and congenital
heart disease. Over 20 nuns and 12 full-time staff were responsible for
taking care of the children and running the institution. It also recruited
long-term volunteers to assist with providing care for the children.
Biancun Nursing Division of Liming Family houses approximately
50 orphaned children and children with disabilities, most of whom
need 24-hour care. The Ningjin Liming Vocational Training and
Rehabilitation Centre caters for 30 people aged 14 years to 30 years. The
centre provides adults in the orphanage with independent living space
and vocational skills training according to their abilities. It also provides
vocational training to young people from other orphanages or families.
Gaoyi County Liming Family Rehabilitation Station assisted around 150
children with cerebral palsy per year.
Liming Family had thus developed at a phenomenal rate, expanding
into three specialised units and meeting an urgent and growing welfare
need. Given its scale and its welfare-orientation, particularly towards

marginalised children, it is surprising that all this could be achieved
despite the lack of legal status for the orphanage. As will be seen in the
next subsections, nurturing good relations with government and gain-
ing public confidence were vital steps in ensuring the sustainability of
the organisation. The lack of official legal status through registration
with the Civil Affairs Bureau for most of its existence was matched by
accumulating stocks of accountability capital, such as a reputation for
care and professionalism, positive media coverage, governance processes,
reporting requirements, and developing government and public trust,
and confidence. However, robust and comprehensive, multidimensional
accountability processes were weakly established.
Operating in the Interstices of Legality

As with many NGOs in China, there were no independent evaluations by
a third-party of the accountability systems in Liming Family. The actual
processes in place for the various dimensions of accountability were
thus extrapolated during the field-work from the interviews, reports,
and website of Liming Family. The legal status of an organisation is an
important precondition for accountability in that it triggers the applica-
tion of relevant laws, regulations, and procedures. This, of course, does
not mean that all dimensions of accountability are covered; rather, that
those required by certain laws, regulations, and procedures should at
least be followed. Furthermore, given the weakness of the non-profit sec-
tor in China and the lack of public knowledge and confidence in it, legal
registration endows the organisation with a legitimate status and some
degree of public confidence. This is not to say that having legal status
automatically guarantees public trust, particularly given the various scan-
dals in 2011 involving GONGOs. However, given the very strict crite-
ria for registering, it suggests a certain ‘jumping of hoops’ that feeds a
degree of public confidence. Legal status also reduces the risks for local
government officials that endorsing or engaging with an unknown NGO
might bear, particularly if it turned out to be a criminal organisation or
politically risky group. There were thus strong incentives for Liming
Family to persist with trying to gain legal registration.
Many NGOs encounter considerable difficulties in attaining legal sta-
tus, not because they are criminal organisations or are regime-threatening,
but because the dual management requirements combined with the cadre
100 J. HOWELL ET AL.
appraisal system make government officials wary of taking responsibility

for supervising an NGO. NGOs thus have to engage in considerable infor-
mal ‘accountability-building’ work to move towards this goal. Important
ritualistic elements of this accountability-building work are cultivating
good relations with local governments officials, publicising3 or publicly
displaying the work of the NGO to the local community and government
institutions, building contacts with the media to create a favourable public
image of their work, opening up their institutions and activities to pub-
lic and/or official view, building relations with influential individuals, and
inviting influential people onto their boards or as advisors. Establishing
processes of governance such as a council and delivery of reports to donors
were important formal elements in giving account. As we will see, Liming
Family has engaged in all these accountability-making rituals, building
stocks of accountability capital, to acquire eventually legal status.
As the founding of Liming Family predated the Regulations on the
Registration of Social Organisations 1989, neither the founding church
nor the government realised or mentioned that Liming Family would
need to register. Though the local government supported the work of
Liming Family, it was in 1994 when Liming Family began to cooperate
with a German charitable organisation that it realised the importance of
being registered with a relevant government agency for the legitimacy
of the child welfare organisation. It was at this point that Liming Family
began its ‘accountability work’ to try to obtain registration as a child
welfare organisation. However, this was not an easy way to go and for
many years bore no fruit. It was not until two decades later that it was
able to register all its divisions, except the orphanage.
Though the registered rehabilitation services enabled Liming Family
to have some legal status and thus made it subject to the various regu-
lations and procedures governing a particular type of NGO, it still left
many unresolved issues from the perspective of children’s services. The
most immediate issues related to the residential registration of the chil-
dren and the qualifications of the organisation in the sphere of adoption
and fostering. The local government had never prevented Liming Family
from receiving children with disabilities and providing care for them.
However, after the local government established its own child welfare
institution in 2014, abandoned children were assigned to this new gov-
ernment-owned child welfare institution rather than to Liming Family.
For well over 20 years the orphanage at Liming Family has oper-
ated in the interstices of legality, neither registered nor prohibited.
As the director of Liming Family repeated on many occasions, it enjoyed

good relations with the government despite the fact that its application
to register as a child welfare organisation able to take on guardianship
and added responsibilities had been refused. The tolerance of local gov-
ernment officials towards Liming Family was partly because it filled a
service gap but also because of the considerable accountability-building
work done by Liming Family. This work included a relentless effort to
gain legal status, access government funding, and achieve residence sta-
tus for the children to receive benefits such as education and the minimal
living allowance. These moves of achieving performative legitimacy such
as through displays of informal governmental approval, open reporting
of goals, activities and approach, displays of professional care suggest that
establishing credibility and trust are key forms of accountability capital
in moving towards procedural legitimacy. In other words, accumulat-
ing stocks of accountability capital is an important preliminary step on
the path towards legal status that would, in turn, trigger certain formal
accountability processes laid down in law. This is particularly the case in
China, an authoritarian regime, where government officials have long
harboured suspicions about the motives of NGOs, especially religious
organisations, and thus tended to be risk-averse in terms of granting any
form of legal registration.
Struggle for Legitimate Registration

Since 1994 the director of Liming Family has presented about a hun-
dred petition letters to many government departments at different lev-
els including the Civil Affairs Bureau, the Religious Affairs Bureau, the
United Front Work Bureau, the Public Security Bureau, the Political
Consultative Conference, and the People’s Congress. Most of these
government departments received her visits in a friendly manner and
expressed sympathy for her efforts. Illustrative of the good relations it
was carefully nurturing, the provincial Religious Affairs Bureau regarded
Liming Family as a patriotic education base, even advising those who were
considering suicide to visit this organisation for counselling. However,
none of these bureaux were ready to act as sponsors of the orphanage so
that it could be registered as a child welfare institution. The reasons were
multifold. Local government officials eager to gain promotion were often
unwilling to become responsible for a non-governmental entity about
which it had limited knowledge. In addition, there were also economic
reasons for this reluctance. Liming Family accepted children with disabil-
ities from across the country. Yet, the welfare costs for their care would
lie with the local government, if the children became local residents.
Furthermore, Liming Family was a religious organisation, which again
raised sensitivities for local government officials. Unable to gain registra-
tion, the director tried another tactic of proposing that the government
take over the care of the children itself. This, however, also came to no
avail, at least until 2014 when the government set up its own organisa-
tion to care for abandoned children, after which Liming Family could no
longer receive abandoned children.
After years of effort for registration that were unsuccessful, Liming
Family considered its future options. As it had not been able to register
as a child welfare organisation for orphaned children, it decided to build
on its work providing services to children with disabilities living in the
community with their families. The rehabilitation services in Gaoyi and
Ningjin counties  registered as people’s run non-profit units for disabil-
ity services in 2005 and 2013 respectively. This process proved relatively
easy as Liming Family had been providing rehabilitation services for chil-
dren with disabilities for many years. As the director commented,
Our service reaches more than 100 families every year. We have not car-
ried out any promotional activity. The parents came to our rehabilitation
station through word-of-mouth. Every year many parents from the south
part of Hebei Province and some even from Baoding, Tangshan, Tianjin
and Handan bring their children here for rehabilitation. Most of these chil-
dren have cerebral palsy.
As Liming Family had by then over a decade of experience in rehabili-

tation services, families were aware of their work on a word-by-mouth
basis and local government officials were not concerned that the organ-
isation was a risky venture that might have consequences for their own
positions. The local Disabled Persons’ Federation provided them with
funding for the services for three years after they gained registration
(RMB 12,000 per person per year).
With the children in its care growing older and increasing in num-
ber, Liming Family decided in 2013 to build new houses in Ningjin
to provide more living space for the children and also set up a ded-
icated rehabilitation centre to provide vocational training and pro-
tected employment. To this end, local entrepreneurs provided funding,
whilst the construction work was done by a group of church converts.

However, the provincial and municipal governments deemed the con-
struction to be illegal as it had not been reported in advance and ordered
it to be halted. Despite this government order, they persisted with con-
struction. In response, the provincial and municipal level governments
gave way to the construction of new houses but insisted that they get
registered as a business, but not as an orphanage. As Liming Family
refused to register as a business, local government officials made an alter-
native proposal of registering as a people’s run, non-profit enterprise
(minban feiqiye danwei, 民办非企业单位) to provide disability services.
The Liming Family accepted this offer, submitted the necessary docu-
ments for registration in 2013, and within a week its registration was
approved, again as a disability services organisation but not as a child
welfare one that could take on orphaned children.4
This still left the orphanage work of Liming Family without any legal
registration status. Some progress was made towards this in 2013, fol-
lowing the tragic deaths of fostered children in the fire in Henan. In the
wake of this tragedy, the central government issued two policy docu-
ments, namely, the Notice on the Further Improvement of Relevant Work
for Abandoned Infants and the Notice on Regulating the Adoption of
Orphaned and Abandoned Children by Religious Organisations. As stated
in Chapter 3, the former requires that any individuals or social organ-
isation running social welfare institutions for orphaned and abandoned
children have to run these jointly with the local Civil Affairs Bureau at
county level or above. Such a practice where the state administers adop-
tion with other agencies is usual in many countries. It also prohibits any
unauthorised adoption of abandoned infants. The latter similarly requires
that any religious organisation engaged in the adoption of orphaned
children and abandoned infants must also be run jointly with the local
Civil Affairs Bureau at county level or above. These two Notices trig-
gered a formal process of negotiation between the Civil Affairs Bureau
of Ningjin County and Liming Family, culminating in a decision to sign
a joint foster agreement with the director. She obtained formal guardian-
ship of the abandoned children in her care, although the orphanage itself
was still not able to formally register.
This formal recognition of the director as the guardian for the chil-
dren at Liming Family had immediate benefits for the residential chil-
dren. First, the Civil Affairs Bureau provided an orphan’s allowance of
about RMB 700 per month for every child under 18 years old. It also
changed the status of those who were 18 years or above from the origi-
nal low-income family members, which had only entitled them to a few
tens of RMB of monthly living allowance, to the five guaranteed mem-
bers, which granted them a monthly living allowance of over RMB 300.
Despite having this joint fostering agreement, the director of Liming
Family remained concerned about shortcomings in the agreement. First,
the policy documents provided a very ambiguous specification of how a
joint fostering agreement should be operationalised. Second, the agree-
ment did not address longer term policy issues. As the director stated,
“[The government department] can solve our immediate problems only
but cannot solve our problems on a policy basis”. So whilst the agree-
ment enabled children to continue living in Liming Family, it did not
address future issues such as receiving children, sending them to foster
families, and ensuring their residential registration, matters which would
probably require action at higher levels of government.
Although even after almost 30 years, Liming Family still did not enjoy
legal status as a non-governmental child welfare institution with respon-
sibilities for orphans, it nevertheless attained a degree of formal recog-
nition through its careful and strategic management of its relations with
the state. Were this not the case, local government officials would not
take higher-level delegations to visit Liming Family. In 2014, for exam-
ple, local government officials took a central investigation team con-
sisting of Chinese People’s Political Consultative Congress (CPPCC)
officials to visit Liming Family, effectively claiming credit for its achieve-
ments. As the director commented,
Because we’re doing well, the central government people are always led
to us for investigation instead of any other worse orphanages. They always
visit us, and they have come here for two or three times. They think that
both our facilities and services are good.
The reputation and legitimacy already achieved locally paved the way for
visits by higher-level governmental officials, which added to the Liming
Family’s stock of accountability capital.
Though the disability units of Liming Family had gained legal sta-
tus as a people’s run, non-profit enterprise, the lack of legal status as an
orphanage registered with the Civil Affairs Bureau continued to con-
strain the work of Liming Family. For this reason, the director astutely
used these official visits to put forth the case for granting the orphanage
legal registration and gain policy extensions for the children. These
efforts reaped benefits after Xi Jinping rolled out the policy of sub-
contracting welfare services to NGOs across the country from 2013
onwards. This policy shift enabled Liming Family to capitalise on the
stock of accountability and legitimacy it had built up over many years
to finally negotiate a joint fostering agreement between the director as
guardian and the local government.
In the next subsection, we trace how Liming Family put pressure on
the local government around its governmental obligations to strengthen
its own legitimacy and to extract policy benefits for the children in its
care.
Seeking Government Funds for Shared Responsibilities

During the Spring Festival season Liming Family would approach gov-
ernment departments for financial support to provide children in its
care with additional benefits. During traditional festivals in China, gov-
ernment departments will visit vulnerable people such as the elderly and
poor, distributing food and clothes to express government concern for
them. As Liming Family was not a government-run institution, govern-
ment officials did not visit the abandoned children in their Family. The
director of Liming Family used this festive occasion to claim resources
from the local state to extend such gifts to the children in their care,
effectively taking on a governmental obligation. As one of the employees
at Liming Family commented, “[This is to] let the government know at
least that fostering orphaned children is the government‘s business, not
completely ours”. When Liming staff challenged local government offi-
cials about their lack of attention to the abandoned children at Liming
Family, the staff were rebuffed and criticised for taking on a task for
which they lacked the proper resources. As the interviewee recounted,
The government visits the elderly without any family during traditional
festivals. Why don’t they visit these children without any family? Or, do
they not know they exist? When we began to talk to them [government
officials], they ignored us completely, not casting us a single look. They
even made sarcastic comments such as `we told you not to take in these
children, but you insisted in getting involved in this business. Now you are
not able to manage the trouble this brings and now bring it to us. Where
can we get the money? We have to take the money out from our own
pocket.
Despite these rebuffs Liming Family continued to put pressure on the

government to provide them with funds of around RMB 2000–3000 per
year, reminding and shaming them into meeting government responsibil-
ities to take care of abandoned children.
Extracting Benefits to Secure Children’s Rights

Though both the government and the church knew that Liming Family did
not have the legal status to care for the orphaned children, the local gov-
ernment had no intention of shutting down or taking over this child wel-
fare organisation. Instead, the local government provided as much support
as possible in many areas of the organisation’s operations, demonstrating its
recognition of the important service gap Liming Family filled. In this way,
the local government added to the organisation’s stock of accountability
capital through informal government approval of its work. Before 2000, for
example, the children in Liming’s care could not be registered as perma-
nent residents because Liming could not gain authority as a legal guardian
and the government would not take that responsibility either. This meant
that the children did not have legal rights to go to public schools. The local
government conceded to the requests of Liming Family  and allowed the
children in their care to attend local schools without paying any extra fees
for temporary schooling.
Indeed, after six years of persistent effort and using the 2000 pop-
ulation census as an opportunity to push harder on the rights of the
children to citizenship registration, Liming Family managed to secure
collective residential registration for all the children. However, this
still did not entitle the children in their care to enjoy the then house-
hold-based social security benefits because the government would not
appoint Liming Family as guardian. Another concession that the gov-
ernment made was that when Liming Family found adoptive parents for
the children under its care in line with the requirements of the Adoption
Law, the Civil Affairs Bureau would often treat these children as special
cases. It would then let them go through adoption formalities and per-
mit adopted children to acquire registration as permanent residents.
Through persistence, threats, and direct action, Liming Family was
also able to secure other policy benefits for the children such as mini-
mum living allowance, rural medical insurance, and a special guarantee
of permanent residence for adopted children. The success in extracting
such policy benefits could be traced back to the requested visit of a for-
eign priest who sponsored children at Liming Family and who was
invited by the China Disabled Persons’ Federation to China for the 2008
Paralympic Games. The priest wished to visit Liming Family during his
stay in China so the director lodged his request with the relevant gov-
ernment department, but was politely refused. The director argued that
it was inappropriate to refuse him a visit given that he had sponsored
the children, underlining at the same time that the government failed
to provide proper support to the abandoned children. The government
official conceded and allowed him to visit the county town but refused
adamantly to permit any visit to Liming Family.
Faced again with this refusal, the director drew attention to the inter-
national dimension of the case and the potential negative impact it would
have on China. She continued to press for his visit and even carried out
a sit-in demonstration together with dozens of children outside the gov-
ernment building. Such direct action immediately galvanised government
officials, who feared that any social unrest would attract the attention
of higher levels, reflect badly on them, and affect their promotion
prospects. As a result, a county co-ordination meeting involving relevant
departments such as the Civil Affairs Bureau, the Financial Bureau, the
Religious Affairs Bureau, and the Disabled Persons’ Federation was held
to discuss the issue of registration and what policies at the county level
could be applied in the meantime to the benefit of Liming Family.
This led to a favourable outcome in that the children at Liming
Family were to be covered by the minimum living allowance system with
RMB 60–70 of monthly living allowance provided for each child. The
county government also agreed to pay the insurance expenses for the
New Rural Cooperative Medical System. Each of these initiatives aimed
at extracting policy benefits through tactics of embarrassment, threat,
direct action and demonstrable gap-filling services, and led to govern-
ment officials granting policy benefits and changing their behaviour in
relation to abandoned children. In the words of the director,
From then on, the minimum living allowances have always been provided
and during every Spring Festival since 2009, government officials from the
township government and/or the civil affairs bureau come to visit these
children and send them gifts. No matter what the gifts are, say a few cans
of cooking oil, this means that the government is now aware of the exist-
ence of these children.
After the 2014 visit of CPPCC officials, the CPPCC investigation team
gave a positive evaluation of the work done by Liming Family, adding to
Liming Family’s stock of accountability, and asked whether there were
any problems. The director mentioned the issue of registration, point-
ing out that, without registration as a child welfare institution, Liming
Family could not qualify to send children to adoptive families. She also
mentioned the fact that there were 18 children who had already found
proper adoptive families but who could not go there because they could
not be registered as permanent residents. This then put pressure on the
provincial government, which agreed to handle these children as special
cases. As a result, the children who were sent to adoptive families within
the county and within the province could from then on be registered as
permanent residents. Though this may be deemed a successful outcome,
it is still limited in that it is but a temporary, discretionary solution for
particular children in the absence of a formal policy.
Nevertheless, the persistent and determined attempts by Liming
Family to leverage opportunities to attain legal status as an orphanage
reaped some benefits in terms of the extension of certain policy bene-
fits to the resident children, and the relatively easy process of register-
ing dedicated disability service divisions of Liming Family as a people’s
run non-profit enterprise. Each of these gains deepens the accountabil-
ity obligations of Liming Family to the state and reflects, in turn, the
positive reputation of Liming Family in the eyes of many government
officials. Enjoying positive relations with government officials is viewed
by funders and users of the services as a proxy measure of legitimacy in
the absence of registration. By providing account informally to local gov-
ernment officials, Liming Family accumulated second-order accountabil-
ity that fed into officials looking upon them with approval, albeit it with
some caution, and helped to establish reputation and legitimacy.
Full legal registration would have introduced certain accounta-
bility processes in relation to the state but as seen from the efforts
of Liming Family, the rigidity of the registration system ultimately led
to mutually beneficial, long, drawn-out ritualistic games of advance
and retreat that ate away at the fraying edges of obstructive registra-
tion requirements and to the concomitant granting of gradual conces-
sions and ‘giving way’ moves on the part of government officials. Such
concessions illustrated how the process of institutional drift created
opportunities for child welfare NGOs to negotiate the rules around the
benefits they could claim for the children in their care as an unregistered
organisation. Local officials had some interest in this too because they
could demonstrate that the government cared for children and because
the child welfare NGO was filling a service gap.
Unable to register as a non-governmental child welfare institution,
the second-best option for Liming Family was to register parts of the
organisation as a people’s run non-enterprise disability services organi-
sation, which still took, as seen above, considerable effort to obtain.
Nevertheless, whilst this second-best option offered some legal legiti-
macy, it still constrained the development of Liming Family in various
respects. First, Liming Family is not legally entitled to send children to
families for adoption. In 2000, however, the local government helped
some of the children to go through the adoption procedures as part of
the specially streamlined adoption arrangements. When the official in
authority changed later, these informal arrangements were no longer
possible. This underlines the importance of cultivating ties with a sym-
pathetic high-level government leader who can assist an organisation in
achieving its goals. However, it also runs the risk that sooner or later top
government leaders will be rotated to other positions, leaving the organ-
isation vulnerable to the priorities and predilections of a new incoming
leader and the need to invest more time and energy in cultivating a new
‘patron’.
Second, Liming Family was not able to resolve the residential status of
adopted children and as a result, the adopting families had to address this
by themselves. Consequently, some parents tried to transfer the residen-
tial registration of the children through other means such as by present-
ing falsified certificates or parental test reports to prove that the children
were theirs by birth. Altogether there were 18 families which could not
secure residential registration for the children. As related above, follow-
ing the visit of officials from the CPPCC in 2014, the government of
Hebei province agreed to complete the intra-provincial residential reg-
istration transfer procedures for the 18 children. Nevertheless, such
arrangements were still regarded as ‘special cases’ and were discretionary,
rather than institutionalised in policy. The lack of policy support for child
adoption not only hampered the adoption work of Liming Family but
also meant that children could not enjoy family life, which is profession-
ally understood to be a better option than growing up in an orphanage.
Third, in 2014, the local government established its own child wel-
fare institution, which meant that Liming Family could no longer take in
abandoned children. This, in turn, prompted Liming Family to re-orient
and transform its work, mainly looking after children with disabilities and
the children it took in before 2014.
In the next subsections, we examine more closely the process of build-
ing accountability and legitimacy. We start by looking at how Liming
Family deployed performative displays to build trust and reputation and
then move on to examine dimensions of accountability such as organisa-
tional, financial, and professional.
Reputation and Trust as Accountability Capital

Proxy validation through enjoying good relations with the government
offers some reassurance to a sceptical public. To ensure a wider reputa-
tion, Liming Family has also adopted strategies to bolster its credibility
in the local community and amongst potential donors. In doing so it had
to counter suspicion on the part of both the government and the local
community because of their unfamiliarity with NGOs and its religious
background. The first step in its accountability work was thus to reduce
the level of suspicion, which it tried to achieve by enhancing its visibil-
ity, demonstrating openness, and inviting government officials into the
organisation. In this way, it gained increasing respect and trust of villag-
ers and government workers. As the director stated,
They have found that we are providing such good care for the children and
that we are not proselytising when we do this… When we need help, we
tell the villagers, and many of them will come to help, for example, to do
cleaning work, to repair houses for us and to make dumplings for the chil-
dren at the Spring Festival.
The villagers’ willingness to help was an informal indicator of the level

of trust in the institution. Moreover, through their encounter with
Liming Family, whether daily or less regularly, the villagers were exposed
to living and working conditions there and the approach of Liming
Family to their work, providing a degree of openness and information
as well as opportunities for comment and feedback that is necessary for
accountability.
The reputation built up by Liming Family through the performative
displays of openness, informal government approval, and professionalism
was not limited to the immediate community. As the only public welfare
organisation dedicated to the care of orphaned children and children with
disabilities in Ningjin County or even in Xingtai City, its existence and
reputation was quick to spread by word-of-mouth. By establishing part-

nerships with many businesses and institutions in the surrounding area
for public benefit activities and by providing a base for society-focused,
practical activities for many university students, Liming Family was able
to consolidate its reputation. A series of news reports by the local media
on Liming Family such as ‘Provincial Medical Experts Provide Voluntary
Services for Liming Family Orphaned children and Children with disabili-
ties’, ‘Teachers and Students of Shijiashuang Railway Technology College
Visit Liming Family Orphanage’, or ‘Hebei Economic Management
School Holds Launch Ceremony of “Love Our Children with disabilities
at Liming Family”—A Charity Donation Campaign’ put a positive spot-
light on Liming Family, enhancing its local reputation.
Furthermore, in the last ten years, Liming Family has organised activ-
ities on the Help-the-Disabled Day each year, using this to do public
advocacy work around the integration of people with disabilities into
society. It also opens Liming Family every year on an appointment basis
to various visitors from other child-care institutions, to field delegations
of leaders from municipal, provincial, and central government and to
the public, thus building its stock of accountability capital. It has also
disseminated its work through a regular print publication that provides
information about events and activities. These steps towards public open-
ness were a crucial element in accumulating stocks of accountability cap-
ital and enhancing legitimacy. However, though Liming Family was able
to secure the registration of the disability divisions as people’s run, non-
profit enterprises, it was not able to achieve registered legal status as a
non-governmental orphanage. This was problematic in that such legal
status was a precondition for the application of child welfare-related reg-
ulations pertaining to the care of children. Falling outside of this, Liming
Family had no legal obligation to comply with the conditions, criteria,
and accountability demands laid down for state-run orphanages, however
limited these might be. The children in their care had no access to the
resources and status afforded to children in state care, except by discre-
tion of government officials.
Organisational Accountability
The key internal structure for accountability within Liming Family was
the council. The council had nine members from higher levels of the
church, enterprises, academics, social worker, and staff of Liming Family.
Every year Liming Family reported to the council meeting, providing

information about the financial position, the quality of its professional
services and other items. One of the council members was designated to
gather information about the conditions of the children, their opinions
and needs and report these back to the council. At the annual meeting,
the council made comments for Liming Family based on the information
obtained.
Apart from providing internal accountability to the council, Liming
Family also had to provide external accountability to church author-
ities. Every year it submitted an annual work report, annual financial
statement and financial budget, and operational plan for the following
year to its immediate administration, the Mother Teresa’s Missionaries
of Charity, and to the next higher authority, Xingtai Parish. Apart from
this, there was no line of accountability to the villagers’ committee or to
local government until recently. Prior to obtaining registration in 2013
for the disability services, Liming Family was not required to be account-
able to the local government and the church was the main institution
to which it was organisationally accountable. After registration, the local
government carried out an annual audit of Liming Family every year.
Furthermore, since the Civil Affairs Bureau began providing part of the
living costs for the children in the form of orphan allowances or mini-
mum living allowances, Liming Family was required to report to it on
its finances and operations. However, the government did not carry out
any supervision of Liming Family or provide any guidance around child
welfare. There was also no formal line of organisational accountability
downward to the children. Accountability was an upward, vertical pro-
cess only.
Financial Accountability
Liming Family relied almost exclusively on non-governmental resources
because the government provided very limited material support. In
addition to the fund of RMB 10,000 granted by the provincial Civil
Affairs Bureau upon its establishment, Liming Family only received sev-
eral discretionary allowances (from less than RMB 1,000 to over RMB
3,000) or grains and edible oil from the government during the Spring
Festival. Apart from this, the Disabled Persons’ Federation donated
RMB 5,000 and ten wheelchairs and some other rehabilitation tools.
Up until the Gaoyi County Liming Family Rehabilitation Station was

registered as a people’s run non-profit enterprise in 2005, Liming Family
had no legal status at all and so could not issue tax-free invoices to
funders. This affected its fund-raising activities, and so it could only turn
to local churches and converts for financial support. After it registered
the disability units as people’s run non-profit enterprises, Liming Family
had to apply to the Financial Bureau for permission to issue invoices for
donations because certain policies had not been effectively put in place in
the county.
Liming Family also faced additional challenges as a result of not
having a legal status. For instance, the children in care were not enti-
tled to the minimum living security allowance for urban residents or the
five guarantees allowance (wubao) for rural residents. However, Liming
Family was entitled to apply to the government for allowances for chil-
dren with disabilities or diseases such as medical allowances. At the same
time, children at Liming Family would be expected to pay for the educa-
tional services provided by local government. As described above, some
of these financial blockages were finally addressed through discretion-
ary decisions by officials as a result of the persistence of Liming Family’s
efforts, the monthly orphan allowance of RMB 700 for children under
18 years, the five guarantees allowance (over RMB 200 monthly) for
children over 18 years, and the new rural co-operative health care insur-
ance being cases in point.
The survival of Liming Family owed much in the initial years to the
support of the local church community. First, Liming Family used the
house of the church rent-free and congregation members assisted with
house repairs. Second, most of the food consumed at Liming Family
was donated by the local congregation. Since most converts were farm-
ers, they were willing to donate grains after the harvest. In addition,
Liming Family bought a piece of land, which the nuns farmed to grow
vegetables. Any additional food requirements were purchased in the local
market. Third, the local parish and some Buddhist organisations and
charitable organisations donated funds and second-hand clothes. This
support enabled Liming Family to operate on a daily basis, but for larger
expenditures, it had to rely on fund-raising. For instance, when money
was needed for a child’s surgery, or for building new accommodation or
repairing heating equipment, then Liming Family would solicit contribu-
tions locally or on the Internet.
In addition to the donations from the local congregation and several

foundations, the local communities also provided substantial support to
Liming Family. For instance, an entrepreneur in Ningjin County had a
child with cerebral palsy and received rehabilitation therapy at Liming
Family. As the rehabilitation outcome was very satisfactory, the entre-
preneur provided a large sum of funding to Liming Family to show his
gratitude and also mobilised other entrepreneurs to support the organ-
isation. Many individuals also donated and provided substantial support
to the organisation. Liming Family occasionally received donations
from people in Hong Kong and Taiwan or overseas, such as the above-
mentioned foreign priest. If there was a severe funding gap, Liming
Family could as a last resort seek help from the church community,
which would leverage its extensive network and resources to help Liming
Family tide over the difficulties.
With its multiple sources of funding, how then did Liming Family
provide financial accountability to its donors? Liming Family was
required to report financially to its own council and parent church
through an annual, year-end financial report. Any expenditure over 20%
of the annual budget had to be justified and accounted for. Its finan-
cial accountability was thus upward-looking, with financial reporting
and annual auditing reports being provided to the church, council, and
donors.
However, according to the director, donors tended not to scruti-
nise the organisation or demand detailed accountability and trusted
that Liming Family was run well. In recounting the visit of the One
Foundation, which had provided considerable support through the
Ocean Heaven Program, the director commented that they came to
“visit with a mind of appreciation”, rather than seeking detailed explana-
tions. Similarly, a number of local entrepreneurs, who were major donors
to Liming Family, visited mainly to make donations and often did not ask
for any donation invoice, or for any report about how their money was
used.
Whilst Liming Family had opened its facilities to the public, media,
and government officials, its systems for financial accountability related
internally to the council and externally to the church. There was no
downward accountability around revenue and expenditure to staff, vol-
unteers, parents, or children. Moreover, the lack of interest from donors
to demand accountability ultimately weakened the process of financial
accountability.
Professional Accountability
In the last two decades in China, the approach to caring for orphaned
and abandoned children has undergone significant changes. Indeed, it
was only in the late 1990s in China that social work began to emerge
as an academic field of study, as a topic of vocational training and as a
professional body that could provide training and set professional
standards (Chan et al. 2008; Hutchings and Taylor 2007). Civil affairs
departments have tried to standardise the welfare services provided to
vulnerable children. In doing so, they have started to implement the
practices of high-income countries to transform institutional care at
state-run child welfare institutions and move towards family-based mod-
els, particularly fostering and adoption. Approximately 50% of the chil-
dren previously raised by government have been placed into families in
the community. Nevertheless, since Liming Family had no legal status,
the government did not monitor its child welfare practices or provide it
with technical or funding support.
When Liming Family began its work in the late 1980s, it faced formi-
dable obstacles in terms of professionalising its workforce. In the absence
of any professional support structures and the lack of information about
the latest policies and child care practices, Liming Family sought to iden-
tify opportunities to improve its professional capacity. Through the accu-
mulation of experience and the development of a mutual help network
amongst peer organisations, the knowledge, expertise, and profession-
alism of Liming Family increased, adding to its stock of accountability
capital.
In the first two decades of its work, most children at Liming Family
were collectively raised within the institution. When Liming Family was
established, institutional care was viewed in China as the best alternative
care for orphaned children. Through its encounter with a UK child char-
ity organisation, Liming Family came to hear about changes in the foster
care policies in China. Although Liming Family was not directly under
the supervision and administration of the government, Liming Family
changed its operational model accordingly. It arranged for some nuns to
permanently take care of  specific children. This allowed the children to
have the chance to establish a stable attachment relationship with their
carers. When an extra house became available, the director arranged for
care groups to reside together, like a family. In this way, the director of
Liming Family still tried to follow governmental policies in child welfare
practice, even though they were not supervised by the government. In

addition to this institutional care, Liming Family started to place some
young children in foster care families from the congregation. Similarly,
although Liming Family could not send children for adoption through
governmental channels, as it lacked a legal status as a child welfare insti-
tution for orphans, it tried to find adoptive parents for children within
the church community.
The change in direction towards family-based care also meant the
nuns and carers needed to acquire new skills, professional knowledge,
and exposure to new practices. Liming Family thus arranged for staff
members to visit well-developed peer institutions in China, Taiwan,
Singapore, and elsewhere for training and exchange. In 2010, they
arranged for a study-tour in South Korea. Nuns involved in early reha-
bilitation and medical treatment for children with cerebral palsy partic-
ipated in numerous training sessions, including specialised, short-term
training courses at schools in China, visits to other institutions, and
informal training, advice, and knowledge provided by visiting external
experts to Liming Family. Through this on-the-job training, these nuns
built up considerable professional expertise so that they are now invited
to other institutions to work as trainers of rehabilitation nursing.
As the children got older, their futures as adults and their employment
prospects also became an issue for Liming Family. Liming Family designed
occupational therapy exercises for children over 14 years old according to
their individual talents and capacities, such as painting, handicrafts, entre-
preneurial talents, academic skills, and computer skills. In the absence of
any available disability employment, the children could then sell handi-
crafts to the public or run the second-hand shop at Liming Family.
Liming Family has become the leading institution amongst state-run
and non-governmental peer institutions in China. For this reason, it has
played an important role in building professionalism in the field of child
welfare in China, which added to its stock of accountability capital that
could be leveraged to justify legitimacy claims. In 2007, supported by the
private Chinese One Foundation, the heads of Liming Family and three
other peer institutions5 jointly initiated the China Non-Governmental
Network Alliance of Rehabilitation Institutions for children with cer-
ebral palsy.6 Its purpose was to build a platform for learning, exchange
and resource sharing, to facilitate the common development of all insti-
tutions, and to advance the development of rehabilitation and educa-
tion in China. By September 2017, 51 social organisations dedicated to
providing services for the rehabilitation of children with cerebral palsy

in China had joined this network. Drawing on years of experience and
accumulated resources, the director of Liming Family identified experts
to provide training and long-term technical support to institutions
within the Network Alliance. Similarly, Liming Family together with
Nanjing Amity and Shijiazhuang Jinde Foundation jointly initiated the
Non-Governmental Orphan Relief Union, which included child wel-
fare NGOs as well as experts and scholars. Whenever there was any pol-
icy change or news event, institutions within the Alliance communicated
with each other to exchange ideas, reactions, and experiences. The build-
ing of this network alliance and union was an important step in devel-
oping the professionalism of NGOs in this field in China. The focus was
on information and experience exchange, training and facilitating connec-
tions. However, the alliance had yet to establish professional standards or
principles of accountability for the emerging sector of non-governmental
child welfare institutions.
In brief, Liming Family began as an organisation with minimal pro-
fessional expertise, knowledge, supervision, or guidance in the realm
of child welfare. Through engagement with international child welfare
organisations it was exposed to international child welfare policies and
practices. Furthermore, as it gained legal status as a people’s run non-
profit enterprise for the disability services, it also became subject to some
government supervision processes, though it remained constrained in its
ability to advance fostering and adoption. After 30 years of practice in
the field of child welfare, Liming Family accumulated experience, knowl-
edge, and expertise to the extent that it became a child welfare NGO
to be visited by other institutions and indeed by central level govern-
ment officials. Furthermore, it took the lead in establishing a network of
non-governmental child welfare providers with the goals of professional-
ising the field, creating opportunities for information and exchange, and
providing knowledge about latest practice. Nevertheless, there remained
weaknesses in its systems of accountability, not least the lack of down-
ward accountability to children, carers, and staff.
Conclusion
Unlike many other NGOs which mainly rely on foreign resources,
Liming Family has drawn primarily on Chinese resources for the past
three decades. As of May 2015, it provided for the welfare of over 600
children, the majority of whom were children with disabilities. This is

not an easy accomplishment for a non-governmental child protection
agency without foreign support. It also points to growing social aware-
ness in China concerning those losing out in the reform process, and
particularly vulnerable children. There are many other child welfare insti-
tutions operated not only by the church, but also by businesses, individ-
uals, and organisations that have made similar strides. However, it would
be naive to assume that a faith-based organisation delivers high-quality
child welfare by default of its values of love and care, as seen in the expo-
sure in the West of numerous cases of abuse in faith-based social service
institutions.
In terms of accountability and legitimacy, the case of Liming Family
illustrates some of the challenges in being unregistered or being regis-
tered as a disability services organisation rather than as a child welfare
organisation, both for the kind of welfare that can be provided and the
development of the organisation. The energy and persistent efforts put
into attaining registration as a disability services people’s run non-profit
enterprise and in extracting policy benefits despite not being registered
suggest that developing trust, confidence, and informal legitimacy were
important preliminary steps towards achieving legal status. Courting
informal government approval, positive media exposure, and earn-
ing a reputation for good practice and professional expertise were part
of building second-order accountability and legitimacy. However, the
direction that accountability took in terms of upward/downward and
vertical/horizontal were not random processes. Liming Family had in
place some internal and external formal processes for organisational and
financial accountability. Pressures from above in relation to the church
and later towards local government meant that upward accountability
trumped downward accountability and that the dimensions of organisa-
tion and finance trumped professional and user accountability.
From the perspective of users, children and staff, there were no for-
mal processes in place to provide organisational or financial accountabil-
ity. Professional accountability was even weaker, not only due to the lack
of professionally focused inspections or professional guidance provided
by the government, but also because the network of non-governmental
child welfare providers had yet to develop professional codes of conduct
that specified principles, goals, and obligations. The lack of downward
accountability to children and users reflected not only notions of defer-
ence to professionals and higher authorities, and differences in power
relations, but also the objective situation that Liming House had, in fact,
a monopoly of provision. There were no formal channels for voice, and
in any case if voice was used, there was no exit option for clients apart
from relying on Liming Family as there were no nearby alternatives.
Finally, in terms of institutional change, the case of Liming Family
illustrated well how rules can change informally. The process of institu-
tional drift created negotiation opportunities for Liming Family and local
government officials to achieve shared goals of child welfare. Rules were
thus ignored and effectively changed, though with local government dis-
cretion, so that Liming Family was able to extract policy benefits for the
children in their care despite being unregistered.
Notes
1. The analysis in this chapter builds on field-work over ten years, Liming
House documentation and website, and the case-study field report. It
also draws on a preliminary investigation in Shang and Fisher (2014),
Chapter 14, which was about the impact of the type of care on the chil-
dren, rather than the accountability of the organisation.
2. As the names of the people and organisations are publicly available on their
webpage: www.limingfamily.cn/about, they are included here.
3. See for example, Network of State-Owned Assets (2015), Shijiazhuang
Child Protection and Education Centre (2003), Xingtai City Government
Network (2013).
4. Although both Gaoyi and Ningjin rehabilitation units were already reg-
istered, the construction of the houses was not included in the activities
they had registered for, thus they had to register another people’s run non-
profit enterprise for these new houses.
5. These three institutions are: Angel House in Nanning, Life Tree in Beijing,
and Family of Love in Shanxi Province.
6. Later, China Non-Government Network Alliance of Rehabilitation
Institutions for CP Children set up its office in Beijing and was renamed as
National CP Rehabilitation Social Collaboration.
References
Chan, C. K., Ngok, K. L., & Phillips, D. (2008). Social Policy in China:
Development and Well-Being. Bristol: The Policy Press.
Hutchings, A., & Taylor, I. (2007). Defining the profession? Exploring the inter-
national definition of social work in the China context. International Journal
of Social Welfare, 16(4), 382–390.
Network of State-Owned Assets Supervision and Administration Commission at

Hebei Provincial People’s Government. (2015). Hebei economy management
school held a ceremony to solicit contributions for ‘caring for children with disa-
bilities and supporting liming family’. Retrieved from http://www.hbsa.gov.
cn/GuoSiYaoWen/2015-04-20-237809.html.
Shijiazhuang Child Protection and Education Centre. (2003). Putting Up a Blue
Sky for Street Children. Shijiazhuang: Hebei Education Press.
Xingtai City Government Network. (2013). Free diagnosis for orphaned children and
children with disabilities in liming family by provincial medical experts. Retrieved from
http://info.xingtai.gov.cn/content.jsp?code=000721684/2013-00254&name.
CHAPTER 5
Accountability and User Participation—The

Case of Angel House
Whilst the dimensions of financial and organisational accountability

occupy considerable time and energy of non-governmental organisa-
tions (NGOs), much less attention is given to user accountability. This
is the case amongst NGOs internationally as well as in China. In recent
years there have been efforts in some countries to develop and apply
processes for improving user accountability, though much of this has
been devoted to adult users. User accountability towards children and
marginalised groups has been slower to develop, let alone put into prac-
tice. Children rarely have a voice around the services they are provided
with. In China the idea of accountability to users is novel, especially
accountability to children. In a society where deference to adults is
expected and Confucianist social traditions reproduce hierarchies around
age and gender, the idea that children should be asked their views on ser-
vices provided by adults would seem highly unusual. Moreover, there is a
paternalistic assumption that adults ‘know best for’ and ‘know better than’
their children. However, failure to seek the views of users runs the obvi-
ous risks that the services provided are not tailored to the needs of the
person or even the target group, leading not only to inefficient and inef-
fective use of resources but also the loss of opportunities to improve the
situation of users.
In the last two decades there has been increasing academic and prac-
tical interest in the issue of downward accountability, user participation,
and rights-based approaches to service provision. The absence of such
downward accountability has been closely linked to the more general

https://doi.org/10.1007/978-3-319-90221-0_5
absence of both user participation in project and organisational planning,

implementation, and evaluation, and of a rights-based framework guid-
ing policy and practice. In a rights-based approach to service provi-
sion, users of services are empowered to demand the realisation of their
rights and to challenge inequities and discrimination (Mayhew et al.
2006). Some writers such as Mayhew et al. (2006) and Kilby (2006) have
argued cogently that enhancing user participation is a way of empow-
ering users and thus increasing downward accountability towards users.
Involving users in the design of services, governance, implementation,
evaluation would lead to better use of resources, services that are bet-
ter tailored to the needs of users, and ultimately greater accountability
(Cavet 2004; Narayan 1999). In practice, however, many NGOs claim-
ing to pursue rights-based approaches to service provision still fail
to ensure user accountability, particularly for marginalised groups.
This is  for a variety of reasons such as lack of knowledge about interna-
tional human rights laws or how to implement such an approach in practice
or paternalistic attitudes towards vulnerable groups, or competing account-
ability obligations (Mayhew et al. 2006, p. 182; Kilby 2006, p. 952).
Whilst the links between participation and accountability and argu-
ments for this coupling have been well rehearsed by academics and prac-
titioners, there is relatively little evidence demonstrating that this is the
case. This chapter thus bridges this gap between the normative and the
empirical by examining the case of a child-welfare NGO that has been
initiated and run by the parents of children living with disabilities. As
indicated in the introduction, 30% of all registered child welfare organ-
isations we surveyed were founded by the parents. Angel House has
become well-known throughout China for its support to children with
disabilities.1 Compared to the other case-studies, Angel House bears a
close descriptive likeness to its constituents as it is set up by carers who
have proximity to the beneficiaries (their children). We would thus
expect that legitimation would be easier and that accountability to users
of services would be more subtle, informal, and developed than when
compared to organisations established ‘on behalf of’ target groups
(Gleiss 2014). In this case, the users are the parents or guardians of the
children, rather than the children themselves. We would expect that a
user-initiated and user-run organisation would involve users more in the
design of services, governance, implementation, monitoring, and evalu-
ation, leading to better accountability. However, as seen in this chapter,
its initial reliance on external funding enhanced its upward accountability
5 ACCOUNTABILITY AND USER PARTICIPATION … 123
and the dimensions of organisational and financial accountability but

at the expense of it developing downward accountability to users and
children.
This chapter begins with some preliminary background informa-
tion about Angel House. It then goes on to examine different dimen-
sions of accountability, such as organisational, financial, professional,
and user. It examines the different strategies used to build accountabil-
ity and legitimacy such as developing the professional capacity of staff,
putting financial and auditing procedures in place, ensuring transparency
of information to users, and leveraging the media to publicise the work
of the House. It reflects on the emphasis given to communicating with
users and ensuring user participation as a way of breaking down power
relations between parents, staff, and managers. It argues that the prox-
imity of organisational staff to users was a positive factor in promoting
participation and strengthening reputation and accountability to users.
However, it also notes how downward accountability still did not extend
to the children and young people with cerebral palsy.
Background
Angel House was founded by Wang Fang,2 whose daughter, Baobao,
one of a twin, was found to have cerebral palsy. She embarked upon
a long and arduous journey to find a cure. However, all the expensive
treatments and surgical procedures for correction failed to make any
significant improvement. When Baobao was five years old, Wang Fang
sent her daughter to a rehabilitation centre run by the city Civil Affairs
Bureau and to Gui Gang Mother’s House for rehabilitation therapy. In
2001, Wang Fang attended a special rehabilitation training session for
children with cerebral palsy, which aimed to promote conductive educa-
tion. There she learned that cerebral palsy currently could not be cured,
and that the only treatment was to alleviate its symptoms through reha-
bilitation as early as possible. She also had the opportunity to visit an
organisation in Hong Kong that had been initiated by parents. This
experience made her realise that it was the parents who knew the chil-
dren best and that the development of the children needed to begin as
soon as possible. This inspired her to take action in the absence of any
nearby rehabilitation services that were socially inclusive.
When Baobao reached school age, Wang Fang found that neither the
local nor special schools in Nanning were willing to accept children with
cerebral palsy, who had usual intelligence but difficulties in moving and
speaking. The only available school was Pei Zhi, a school for children
with intellectual disabilities, which was under the supervision of Nanning
Civil Affairs Bureau. This school provided nine years of education for
each child, with about a dozen children in each class. However, the chil-
dren had no opportunity for inclusion with other children. She learned,
too, that the educational challenges her daughter faced were common
for most children with cerebral palsy.3 Faced with these challenges, and
the lack of understanding of the rehabilitation needs of children with
cerebral palsy, Wang Fang realised that she had to rely on her own efforts
to create a developmental path for Baobao and other children so that
they could be included within their communities.
In June 2002 she founded the Angel House Centre for Rehabilitative
and Educational Activities (hereafter known as Angel House), in
Nanning City, Guangxi. The organisation was registered as a people’s
run non-profit enterprise unit (minban fei qiye danwei, 民办非企业单
位) providing disability services with the Civil Affairs Bureau of Jiangnan
District, Nanning city, Guangxi province and operated under the admin-
istration of the Disabled Persons’ Federation of Jiangnan District. The
main activity of Angel House was to provide rehabilitation services for
children with cerebral palsy, many of whose parents were of below aver-
age income and some of whom were living in poverty. Unable to obtain
relevant rehabilitation services because of the very limited availability of
these provided by government, or indeed the market, parents of children
with cerebral palsy have had to create such services themselves. Having
legal status was beneficial to Angel House but was insufficient to develop
multi-dimensional accountability and to establish its legitimacy as a pro-
fessional, caring, and efficient NGO. Moreover, its status was subject to
review and if the political winds brought a nationwide scrutiny of NGOs,
then it was important that it had established its reputation and legiti-
macy, over and above its registered legal status.
In the spring of 2002, Angel House launched a trial operation with
3 teachers and 5 children, in a room lent to them by Boluoling Primary
School. On 1 June 2002, it started its operations officially, providing
for 10 children. After two months and with the help of parents, Angel
House moved to Shi Zhugang community in another part of the city,
where it stayed for a year. In September 2003, Angel House moved
again to Ronghe Xincheng residential community, remaining there for
several years. These moves occurred because of discrimination against
people with disabilities and the reluctance of local residents to accept

such activities in the community. Over the subsequent five years, and
with persistent efforts on the part of the director and founder, Wang
Fang, the residents of Ronghe Xincheng community gradually changed
their attitude and opposition towards the work of Angel House and
came to accept the organisation and the children with cerebral palsy
under its care into the community.
As the first non-governmental welfare organisation in Guangxi, Angel
House provided multiple services for children with cerebral palsy includ-
ing rehabilitation, education, and conductive daily living activities. It was
the only service provider offering professional rehabilitative and educa-
tional activities for children with cerebral palsy such as conductive educa-
tion and balance therapy. By 2010, Angel House employees had grown
to number 25 including 23 in-house staff members, who provided
in-house services for 31 children under 18 years of age and outreach
services (community-based or house rehabilitation) for a further 15.4
A training package was provided at the Children’s Centre for children of
14 years of age and upwards, incorporating sports, rehabilitation, con-
ductive education, movement balance therapy, and cultural education.
The services at the Youth Centre focussed on cultural education, voca-
tional rehabilitation, daily living independence, and physical exercises.
As will be seen in the next sections, building accountability along
various dimensions and establishing a reputation and legitimacy was an
important part in the development of Angel House. This process enabled
the organisation to expand its clientele, attract funding from different
sources, and establish a reputation as a professional, efficient organisation
that valued user participation.
It could be expected that a child-welfare organisation based on the
participation of parents would be more likely to ensure that the services
provided address the specific needs of children with disabilities. However,
understanding and awareness of needs is also not sufficient to run a pro-
fessional and efficient organisation. Given the absence of any profes-
sional organisations guiding child welfare services and the lack of local
capacity-building and/or organisational development NGOs or similar
programmes in China, the possibility of working with an international
NGO in the field is an important alternative route for building a more
formal and professional organisation. This was the case with Angel House,
which benefited from working with the international NGO, World Vision,
receiving advice and guidance on organisation-building and professional
issues. To this end, it set in train processes of formalisation and profes-
sionalisation in the early planning stages of the organisation. For exam-
ple, it set development goals and established a management mechanism
with the involvement of donors, managerial staff, users and staff, which
put in place the organisational building-blocks for better efficiency and
accountability.
At the time of the founding of Angel House the parents articulated a
vision of ‘integrating people with cerebral palsy into society’. To achieve
this, it introduced the idea of ‘whole person nursing’ and planned to
provide integrated services including rehabilitation, education, daily liv-
ing abilities and vocational training for children and young people with
cerebral palsy up to the age of 25 years, so as to enable them to par-
ticipate in social life, to realise the value of their life, and to enjoy their
meaningful life together with others. They also decided on the name of
the organisation as Angel House, expressing the hope that children with
cerebral palsy would have a free and happy life like angels, and that car-
ing people from all around would help them like angels. Having outlined
its vision and goals in the first five-year plan (2002–2007), it established
a professional service team and a formalised management system to reg-
ularise the lines of authority and functions in the organisation so as to
promote operational predictability and efficiency. In its second five-year
plan (2008–2012) it aimed to focus on organisational development and
become the leading institution in cerebral palsy nationwide.
As part of its organisational development plan, Angel House estab-
lished an advisory council in 2002 in accordance with the Provisional
Regulations for the Registration of a People’s Run Non-Profit Enterprise
so as to guide and advise the organisation’s work.5 Three years later
in 2005, it set up a new council, comprising seven people including a
project officer from the international NGO, a doctor, a journalist, an
expert for special education, an entrepreneur, and parents. These council
members were strategically selected to add additional value for different
dimensions of the organisation, such as medical issues, media coverage,
fund-raising, and user perspectives. Still, much of the strategic develop-
ment and actual operations of the organisation continued to fall on the
shoulders of the founder, Wang Fang, and her husband, who worked
in media, as several of the council members were too busy or changed
jobs in the period. So, in 2008, the council entered its third round of
members, whereby active members who were enthusiastic and who co-
operated closely with Angel House were retained. As of 2010 there were
five council members, namely, two project officers from the international
organisation, one journalist and two parent’s representatives, namely
the founder, Wang Fang, and her husband. Nevertheless this structure
conflated the multiple roles of Wang Fang as director, parent, and coun-
cil member, potentially undermining the independence of the advisory
council and forgoing the opportunity to enhance user participation by
involving other parents. The external advice was from the international
NGO members. Despite this, the new council comprised more dedicated
members, placing the organisation on a stronger footing to develop
organisational strategies, raise funds, and plan human resource training.
Angel House set up an annual reporting system so as to monitor its
progress towards its goals and address any weaknesses. When Angel
House was first established, organisational structures were underdevel-
oped, regulations inadequate, and resource flows for daily operations
unpredictable. The 2003 Annual Report drew attention to the problems
of an unclear division of labour, incomplete staff management, the lack
of experience in rehabilitation education, and the turnover of support
staff. To address these issues, Angel House established a clear organisa-
tional structure with relevant lines of authority and rules and procedures
governing staff development, management of human resources, training
and supervision, pricing and services for parents, and office support.
With regard to human resource management, Angel House developed
a set of rules, including recruitment and interviews, internships, employ-
ment contracts and dismissals, and training and career development.
Employees were divided into levels according to their positions or posts
including management, rehabilitation, special education, and supported
living. Job duties were specified for each position or post and professional
training was provided to employees. In addition to training, Angel House
emphasised the importance of good management of employees, with each
employee’ position and salary reviewed annually. The review was made
on the basis of their professional ability through a three-level assessment
mechanism, including the employee’s self-evaluation, rating by his/her
immediate superior, and decision of the council. In this way it was able
to overcome the limitations of the previous employment system, where
performance was not assessed, job continuity was guaranteed, wages were
low, and employees lacked incentives to improve their performance.
Angel House also created regular channels of communication

between staff at adjacent levels so that problems were identified early
and addressed as soon as possible. For example, there was face-to-face
communication between the president and centre directors every week,
between each centre director and managers of the two or three depart-
ments within that centre every month, and between each department
manager and front-line teachers within that department every month.
This management structure enabled leaders at different levels to get
prompt information about their immediate staff and also enhanced the
organisation’s internal cohesion by creating a sense of individual respon-
sibility amongst all staff including front-line teachers.
Compared to other NGOs, Angel House received strong rhetori-
cal support from the government. Its clear organisational development
plan, advisory council, and reporting system constituted important for-
mal accountability capital, demonstrating that it had the structures to
function as an efficient organisation. Given the difficulties of registra-
tion in China and the lack of public confidence in NGOs, government
recognition expressed through public praise takes on even greater sig-
nificance as a proxy form of validation, enabling an organisation to sur-
vive, develop, and obtain financial support from society. For example,
Zhang Haidi, then incumbent chair of the China Disabled Persons’
Federation, delivered a congratulatory speech on the second anniversary
of Angel House on 1 June 2004. From 2009 onwards on the occasion
of Children’s Day, June 1st, the secretary of Nanning Municipal Party
Committee began to visit Angel House regularly as a symbolic way of
expressing government approval and appreciation of their work, thereby
adding to its stock of informal accountability. Furthermore, the founder
of Angel House, Wang Fang, was granted various awards and honours
by government and semi-government agencies, even though Angel
House was not registered as a social organisation with the Department
of Civil Affairs. For example, in 2012, she was included in the first list of
“100 Best Mothers in China”; in 2007 in the list of “10 Best Women of
Guangxi”; and in 2008 in the list of “10 Best Citizens of Nanning”. She
became a Torchbearer in the 2008 Olympic Games held in Beijing and in
the same year, she was granted the UN award “Hall of Fame for Serving
the Disabled” in recognition of her “long-term commitment, service and
devotion” for the rehabilitation of children with cerebral palsy. These
honours and awards were important ritualistic inputs into developing a
stock of informal accountability capital over and above legal status.
In contrast to many NGOs, Angel House had from an early stage

put in place clear structures, rules, and procedures to aid organisational
development. Angel House gradually built up structures and systems of
organisational accountability. This degree of formalisation and profes-
sionalisation was important in gaining recognition from the government,
developing its stock of accountability capital, and achieving a legitimate
identity. Without such a legitimate identity, Angel House would not have
been able to garner support from the public.
As well as putting in place systems of organisational accountability, Angel
House also established a financial management system. The revenue of
Angel House came from four sources, namely, external sources such as
international NGOs and foreign corporations, government, the public,
and user charges. In 2010, for example, it received around two thirds
of its income from public donations and a third from service charges
(see Table 5.1). By 2014 the amount of donations tripled to RMB
2,045,600, whilst user charges increased fivefold to RMB 1,787,000,
accounting respectively for 45 and 40% of total revenue. When Angel
House was founded, it relied on the efforts of parents, who invested
Table 5.1 Annual income and expenditure of Angel House (2006–2014) (′000 RMB)
Year Income from Service income Government Annual Annual

donationsa subsidy incomeb expenditure
2006 187.5 124.7 – 316.6 314.8

2007 305.4 134.5 – 508.2 441.7
2008 942.9 155.3 – 1099.9 601.4
2009 464.1 338.7 – 803.2 663.5
2010 618.8 357.0 – 975.9 912.2
2011 299.3 765.5 – 1080.3 1058.3
2012 3893.7 688.5 – 4584.9 4138.0
2013 5292.5 1316.6 500.0 7109.6 6061.2
2014 2045.6 1786.9 680.0 4515.3 4279.2
Source Angel House Annual Audit Reports

aIncluding restricted and non-restricted income
bIncluding small amounts from other sources
considerable human and material resources. As it developed further, it

sought funding from other sources. Philanthropic contributions from the
public were particularly important in these early stages as the House did
not receive any government subsidies. In order to obtain more funds, it
had to diversify its sources of funding and establish formal financial and
organisational accountability processes  for donors.
As noted above the government gave symbolic recognition to Angel
House through publicly displaying support and awarding the founder
and organisation various local and national awards. Nevertheless, in
terms of finance, the organisation received very limited financial sup-
port from the government. For example, according to the 2009 finan-
cial audit report of Angel House, the organisation’s annual income from
donations came to RMB 464,000, of which RMB 55,300 came from the
Disabled Persons’ Federation and/or other quasi-governmental agencies,
thus accounting for only 6.9%6 of the organisation’s total revenue. As a
non-governmental disability services organisation, Angel House did not
receive any financial support from the government budget, nor did it
benefit from any other preferential treatment normally granted to public
institutions like schools, such as preferential rents for premises or prefer-
ential prices for power and water supplies.7
Instead, Angel House relied on social philanthropy, both domestic
and external. As of 2010, the main financial support came from inter-
national NGOs. In its early stages, World Vision and the Mother’s Love
Orphanage, which was founded by Mr. Yang, former Chief Executive of
World Vision, provided financial, technical, and spiritual support to Angel
House. This orphanage helped Angel House with its first development
strategy and assisted them to set objectives at each stage. Following its
establishment, Angel House also gained support from other interna-
tional organisations, enterprises, and individuals such as the International
Federation of the Disabled, Zhongda Toyota Auto Corporation, Rainbow
Missions Hong Kong, Hong Kong Jianhua Foundation, and various
individuals. Drawing on different sources of funding, Angel House was
able to survive and grow, providing services for more parents who are
unable to pay for the rehabilitation of their children.
During the first eight years of its development, Angel House attracted
the support of many individuals and businesses that were enthusias-
tic about public welfare activities, including friends of Wang Fang and
her husband as well as many others who had been moved by her phil-
anthropic action. As a business donor stated, “Our support to Wang’s
organisation means that we are on the way to becoming a qualified citi-

zen”, that is, becoming an upright citizen in ways recognised by the state
and valued by the business community. Moreover, some entrepreneurs
used their support for Angel House as a way to enhance their internal
and external business reputation as a socially responsible company. As of
2010, Angel House had about 200 small donors, making either regu-
lar or irregular donations in amounts ranging from RMB 50 up to over
RMB 1000. Though these were not a reliable source of funding, they
still were important as a key source of public donations.
Angel House also earned some revenue through user charges.
However, in less economically developed regions like Guangxi, most par-
ents cannot afford to pay fees or make donations, and government sup-
port is very limited. The option of providing services solely on the basis
of user fees or donations was not feasible. Given the poor financial cir-
cumstances of the families, Angel House tried to keep service charges as
low as possible, offering three rates, namely, for day care providing indi-
vidual classes with accompanying parents, for day care without accom-
panying parents, and for boarding school on a weekly or termly basis.
Moreover, these rates were competitive, the rate for day school being,
for example, half that of the rates for individual training of children with
cerebral palsy at large hospitals in Guangxi.8 Information about the ser-
vice charges were openly available to all parents. For those parents who
could not afford the charges, Angel House assisted them with financial
support. Thus, nine out of eighteen children at the Children’s Centre
received support through donations towards their school costs with the
help of Angel House’s public relations team. Being parents themselves,
Angel House’s owner and teachers realised that parents cared most about
the quality of the organisation’s rehabilitation education and the level of
user charges. Therefore, they tried to keep the charge rates as low as pos-
sible and at the same time ensure and improve the service quality.
Though Angel House received funding from multiple sources and
had increased its funding 14-fold between 2006 and 2014, it still faced
continued financial constraints such as precarious and unpredictable
resource flows, which put at risk stable organisational development,
long-term planning, and sustainability. Being seen to be accountable for
its expenditure was an important part of its strategy in developing the
organisation. As an organisation initiated by and participated in by par-
ents, Angel House was well aware of the difficulties in raising money, the
urgency of fund-raising to support the children’s rehabilitation, and thus
the importance of accountability. Realising the link between accountability

and fund-raising, Angel House promised publicly at the time of its found-
ing that all donations, whether from organisations or individuals would be
used for children, and that every donor would have the right to look at
the accounts. To meet government requirements, Angel House had their
financial statements and reports audited each year. Following a six month
trial period in 2002, Angel House invited an accounting firm to audit its
financial report, and then published the Annual Audit Report on its web-
site. This practice has continued to date and an audit report is sent directly
to all donors donating large amounts. Before 2005 the accounting regula-
tions that Angel House applied were for state institutions. After the imple-
mentation of Accounting Regulations for Non-profit Organisation 2005,
Angel House changed its accounting policies to be in line with these new
regulations. Angel House ensured it complied with government regula-
tions as a way to strengthen its reputation as an accountable organisation
that could be trusted by the government, donors, and the public.
Accountability Through Building Capacity

and Professionalism
The quality of care provided at a rehabilitation centre is understandably

important to children with cerebral palsy and their parents. Services for
children with disabilities are labour-intensive and so support and training
for employees is particularly important in guaranteeing high-quality ser-
vices. To this end Angel House sought to instil a user-centred approach
to care, build staff capacity, and develop professional skills. It developed
a set of rules to ensure the professional accountability of the organisa-
tion. These rules focused on two areas, namely, the professionalism of
the leading expert staff in the organisation and professional training for
employees. It also created an open environment for parents to engage
in the rehabilitation of their children and involved them in understand-
ing the approach to rehabilitation used. This subsection examines in turn
professionalism, staff training, and understanding of parents.
Leading Role of Professionals

To ensure that users received a professional service, Angel House set up
a core management team of three, made up of the Angel House director,
the head of the community-based rehabilitation centre, and an executive
director, who had considerable experience in rehabilitation nursing. With

experts at its helm, the routine work and operation of Angel House was
guided by professionals with relevant experience and training. This core
management team, along with two or three other key staff members and
a leader from Rainbow Missions Hong Kong met once a month to dis-
cuss Angel House’s operations in order to improve everyday operations
and strengthen the leading role of experts.
Capacity-building was a significant part of Angel House’s develop-
ment strategy. Angel House emphasised the importance of creating
and maintaining a good public image in all respects, both in its inter-
nal organisation and approach and in the way it engaged externally
with donors and the public. In a context where the concept of an NGO
organisation was new, establishing public trust and confidence in the
organisation was a crucial way of ensuring accountability and legitimacy.
Furthermore, though it was registered as a disability services organisa-
tion, its legal status could always be withdrawn, especially if there were
any nationwide rectification of NGOs. Thus it had constantly to work
at maintaining and strengthening its second-order accountability and
strengthening its legitimacy. To this end Angel House used strict inter-
nal management to ensure high quality. Angel House formulated a set
of rules covering areas including employees, services, parents, public-
ity, propaganda, fund-raising, and the use of volunteers. Especially in
the area of staff development and management, the organisation had
employees participating in the running of the organisation, thus intro-
ducing a stronger sense of ownership and a higher degree of loyalty.
Another way of improving the capacity of Angel House was to exchange
knowledge and information with partners in the same field of operation.
In 2006 Angel House established channels of communication with other
three civil organisations of the same nature in Hebei, and Shanxi prov-
inces, and Beijing to exchange experiences and learn from each other. In
2007, with the help of Beijing Capacity Building and Assessment Centre,
these four organisations, including Liming Family, had their first meeting
in Beijing to prepare a cerebral palsy learning website. In November of the
same year, they held the first official meeting and training session and set
up the goals and working principles of the website. Thereafter the learn-
ing website set regular meetings twice a year to promote communication
and learning from those working in this sector. The website was a collec-
tive body of non-governmental rehabilitation organisations for children
with cerebral palsy. Its guiding principles were self-learning, self-growing,
self-management, and self-regulation. The website was open to new mem-

bers, who underwent a probationary period. By 2010, the website had
sixteen members. Building a reputable website was a key strategy to build
accountability capital and reinforce the credibility of non-state welfare
organisations working with children with cerebral palsy. Making the organ-
isation visible and open was a way of inviting professional and public scru-
tiny and building second-order accountability.
Staff Training and Support

Angel House advocated a user-centred approach captured in the idea of
‘All for Children’. This ‘All for Children’ cultural approach encouraged
staff to respect children with special needs, fostered their commitment to
the children, and emphasised professionalism. The spirit of this approach
was captured in the Employee Handbook, which promoted staff develop-
ment to improve professional standards for the ultimate benefit of children.
Building capacity and developing professional skills was also a cru-
cial feature of the work environment at Angel House. Almost all of the
employees were from Guangxi province and there was very little turno-
ver of staff, thus ensuring a stable team of employees for Angel House.
In Guangxi, however, the universities and vocational colleges did not
run any courses or do any research on special education and rehabilita-
tion. Thus, as the Director put it, Angel House had to ‘rely on itself to
develop’, using its own resources. The organisation required each front-
line worker to take part in at least one round of training a year, and each
centre director to take part in two rounds of training a year. Following
years of cooperation with Chongqing Jiangjin Children’s Center,9 Fu
Hong Society and the Spastics Association of Hong Kong, Angel House
was able to introduce an advanced philosophy and methodology for
rehabilitation from Taiwan and Hong Kong, and developed a strong
group of core employees. By focusing on its expertise and professional-
ism, Angel House was able to accumulate a stock of accountability that
bolstered its second-order accountability and legitimacy.
Open Rehabilitation and Parents’ Education

In China, many rehabilitation centres are operated in a closed fashion
so as to avoid disclosure of rehabilitation techniques to parents. They
also maximise the amount of paid-time spent on child rehabilitation.
In contrast, the rehabilitation training at Angel House was completely

open to parents. Parents could read the class schedules of rehabilitation
education posted at Angel House. They could also use the training sites
and equipment for free after individual training and consult training
teachers at any time. By involving parents in the design of individualised
training plans for their own child, parents could improve their own abil-
ity to provide rehabilitation. Furthermore, Angel House ran two training
sessions for parents each semester using professional instructors.
An important element in building professional accountability was to
enable parents to understand Angel House’s rehabilitation methods. In
2008 Angel House changed its rehabilitation method as the professional
advice was that the methods they were using were considered appro-
priate for group training but not for individual training. In the process
some parents, unpersuaded by the change, withdrew their children. With
professional training, Angel House’s employees continued to use this
method, and some of those parents gradually returned persuaded that
the new approach was beneficial.
Accountability of the House for its care of the children was institu-
tionalised through regular reporting to the parents. All parents who
came to the organisation for consultation received an assessment report
and rehabilitation advice for their children without charge. The House
also helped parents understand the latest knowledge and approach
towards treating cerebral palsy and invited them to join in the rehabilita-
tion activities of their children. As the Director commented,
Parents of children with cerebral palsy used to think it was a curable dis-
ease, and so they invested lots of money and effort for whatever treatments
they could find, including hyperbaric oxygen, brain tonics or even correc-
tive surgery. But after all of this, when they came back to rehabilitation,
they no longer had any money to pay for this. Almost all of the parents
had made such mistakes, which is to do with the lack of education and
knowledge about the condition.
Developing staff expertise through training and support was a way of devel-
oping employee capacity but also of building the reputation of the organ-
isation. Moreover, its efforts in involving parents more in rehabilitation
and understanding the philosophical and scientific rationale behind the
approach used also contributed to the accountability capital of the House.
This engagement with parents along multiple fronts created opportunities
for parents to query practice in the organisation and obtain information on
an everyday basis about how the organisation operated. It enabled them to

provide feedback to Angel House about parents’ perceptions about the ser-
vices, their needs and concerns, and to hold staff to account.
Accountability to Funders
As public donations made up most of its annual revenue, Angel House’s
accountability towards the public clearly mattered. In order to strengthen
its accountability to donors, Angel House always sent donors, whether
an organisation or individual, a standard thank-you letter acknowledg-
ing receipt of the donation. For targeted donations, such as for one-to-
one support, the organisation followed procedures to regularly provide
donors with information about how the children they supported were
developing. For non-targeted donations, with no specific use requested,
an audit report was sent to the donors at the end of each year.
In general, large donors had a more formal and rigorous approach
to accountability than small donors. Small donors relied on trust rather
than formal accountability. As a small donor put it: “We don’t need to
ask about how they use the money because we trust Wang Fang and her
husband, and we trust her organisation.” The project leaders of the two
international organisations for children with disabilities that were work-
ing most closely with Angel House were also members of Angel House’s
council. They were involved in the management of Angel House and
played an important part in its personnel management, fund-raising, and
strategic development. By participating in its governance structures, such
donors could ensure indirectly that funds were used appropriately. Some
large donors, especially international donors, directly controlled the
funds for specific programmes, whilst Angel House was only responsible
for programme operations, and not the management of funds, as was the
case with the EU Community-Based Rehabilitation Programme operated
through Handicap International.
Using Mass Media as Surrogate Accountability

As the husband of the Director of Angel House was a journalist and had
connections in the media, it was relatively easy to get media coverage for
Angel House in Guangxi in the early stages. The Director emphasised
the importance of getting media coverage to enhance its legitimacy as
a professional non-governmental child welfare organisation. The earliest
reports in April 2003 focused on the personal charm and leadership style
of the director and founder of the organisation, Wang Fang, but later
shifted onto the development and difficulties of the organisation and the
status of children with disabilities. By 2010 Angel House was regularly
featured at the time of important festivals or special events each year,
and two or three times during school semesters. It received considera-
bly more coverage than other similar organisations and all the coverage
was positive. This positive media coverage helped Angel House to accu-
mulate accountability capital that would enhance the reputation of the
organisation and public and government trust in it.
Accountability to Users
Compared with other child-welfare service organisations, Angel House
put more emphasis on communication with services users. The users
were parents who came to Angel House after hearing about the work of
the organisation from other users, from the Internet, medical services,
or other rehabilitation organisations. The admission procedures for chil-
dren ensured the participation of parents. For example, if new parents
came to Angel House, the child’s physical functions and abilities would
be assessed without charge and the parents were asked to decide on
the basis of the assessment whether they wanted their child to receive
rehabilitation services at Angel House. If the parents decided not to go
ahead, then the teacher carrying out the assessment would provide advice
for House-based rehabilitation and close the case. If they went ahead,
then the teacher would refer the child to the Children’s Centre or Youth
Centre depending on the child’s conditions. Then, the directors of that
centre and relevant departments would work together to make a rehabil-
itation plan based on the assessment and the needs of the child and par-
ent. Throughout this process, staff were trained to listen to the expressed
needs of the parents and involve them in the decision-making process.
Whilst this degree of user participation may be a common experience
in other countries with long established systems, in China such a degree
of involvement is unusual. As some parents stated, “the teachers here are
happy to listen to us”, and “we can stay here to see how the teachers
are working with our children, unlike some other organisations, where
we have to wait outside closed doors and know nothing about what is
happening”. To enhance user participation and greater accountability,
Angel House also provided training for parents. Each semester there
were two parent meetings, where the parents were informed about the
organisation’s development, its personnel and financial changes. Parents
could express their views about the organisation’s rehabilitation training
through face-to-face communication with rehabilitation teachers and
their directors. Parents regarded this as a way to “treat us equally and let
us speak out”. It enabled informal accountability to take place and pro-
vided immediate feedback to staff about parents’ concerns.
When implementing the Community-based Rehabilitation programme
of Handicap International, a self-help group of parents was established at
the initiative of the new community-based rehabilitation centre in order
to better serve families who were scattered across the county. Parents
managed and organised the group, and decided the activities, whilst
Angel House provided a place for them to meet. Such parent-oriented
services and activities provided opportunities for parents to participate in
the programme, to express their opinions, and to monitor the quality of
the organisation’s services.
Conclusion
Angel House is an example of a non-state disability services organisation
that has emphasised building its accountability and legitimacy through
a variety of strategies such as capacity-building, professionalism, creating
opportunities for knowledge exchange and professional alliances with
other civil society organisations, and creating a public image through
use of the media. Though it was registered in 2002 as a disability ser-
vices organisation, it still had to work hard at building and maintaining
accountability and legitimacy. Legal status alone could not guaran-
tee multi-dimensional accountability and there was always the risk that
this could be revoked. Maintaining and strengthening its second-order
accountability to enhance its legitimacy was important in securing its
continued survival and organisational development.
Angel House is distinct in that it was initiated by users, that is, the
parents, who have been able to shape the organisation to be more
accountable to users. This is reflected in the organisation’s goals and
objectives, fund-raising, rehabilitation service, pricing, communication
channels with users and opportunities for user participation such as self-
help groups and education about the latest knowledge about cerebral
palsy. This case thus supports the thesis that user participation can better
reflect the values, interests, and demands of users. The close involvement
of parents in the running and activities of Angel House enhances the

opportunities for accountability to users. Nevertheless, user participa-
tion has still not extended to the children with cerebral palsy, for whom
there were no formal channels through which they could express their
needs, experiences, or views on the services they receive. Furthermore,
the director and husband also sat on the advisory council, which could
potentially lead to a conflict of interests between the role of director and
the role of the council, compromising the independence of the council.
They also sat on the council as parents’ representatives, again conflating
different roles and missing this opportunity to draw in other parents.
A key factor underpinning Angel House’s relative achievements in
providing services for children with cerebral palsy lay in its close involve-
ment with international professional organisations. Merely having finan-
cial support from an international foundation would not have enabled
Angel House to develop its professional capabilities and services. It was
by luck that Angel House happened to come into contact with an inter-
national NGO with expertise in this area. But international professional
organisations only have limited influence in China. It is more likely that
most parents of children with cerebral palsy would not receive such
strong support, even if they were to initiate their own organisations.
Whilst support from an international NGO was pivotal to Angel House’s
development, the local government and the Disabled Persons’ Federation
also had a part to play, especially in the early stages through providing a
small amount of funding, premises, and giving backing to the organisations.
Such official backing was important as it signalled to the public a degree of
government confidence in the organisation, credibility, and reputation, an
important basis for accountability and legitimacy. With the shift since 2015
to governmental purchasing of services, it is possible that the role of gov-
ernment in supporting Angel House financially will increase, introducing
also new forms of accountability around financial management. Indeed in
2013 and 2014 Angel House had already received government contracts
for service provision to people living with cerebral palsy.
Notes
1. This Chapter uses field-work data, Angel House documentation, annual
reviews and audits, and field case reports to analyse Angel House from the
perspective of accountability. For an earlier account of multi-dimensional
accountability issues, see Fisher et al. (2015).
2. Real names and titles are used in this chapter with permission of the
organisation.
3. The incidence of cerebral palsy globally is between 0.2 and 0.5%. There are
around 60,000 children between age 0 and 14 years in Guangxi province
with cerebral palsy. Only a few of these get timely rehabilitation education
(see Angel House Website and brochure).
4. Three people were responsible for community rehabilitation.
5. 2002–2003 annual report submitted to district Disabled Persons’
Federation.
6. According to our nationwide survey of non-governmental disability organ-
isations (Table 1.1 in Chapter 1), the government accounted for only 5%
of their income. Therefore, Angel House received more support than
other non-governmental disability organisations, attributable not least to
its good reputation and the founder’s personal credibility.
7. Though this situation changed after 2012 when new government regula-
tions relaxed the process of registration somewhat so as to facilitate NGOs
to register and so contract for delivering government welfare services.
8. The monthly rate for day school, day care, and boarding school was RMB
600 (RMB 30 per day and 22 days per month), RMB 1,582, and RMB
1,782, respectively. For children who could not return House at the week-
end, a payment was required for a teacher to be on duty. The monthly rate
for the Youth Centre came to RMB 1,900, and the charge for long-term
boarding was RMB 2,300 per month.
9. Chongqing Jiangjin Children’s Centre was set up by a couple from
Taiwan.
References
Cavet, J., & Sloper, P. (2004). The participation of children and young peo-
ple in decisions about UK service development. Child: Care, Health and
Development, 30(6), 613–621.
Fisher, K. R., Shang, X., & Li, J. (2015). Accountability of children’s services
organizations in China. Asian Social Work and Policy Review, 9(1), 94–107.
Gleiss, M. S. (2014). How Chinese labour NGOs legitimate their identity and
voice. China Information, 28(3), 362–381.
Kilby, P. (2006). Accountability for empowerment: Dilemmas facing non-
governmental organisations. World Development, 34(6), 951–963.
Mayhew, S., Douthwaite, M., & Hammer, M. (2006). Balancing protection and
pragmatism: A framework for NGO accountability in rights-based approaches.
Health and Human Rights, 9(2), 180–206.
Narayan, D. (1999). Can Anyone Hear Us? Voices from 47 Countries (Voices of the
Poor Reports Vol. 1). Washington, DC: World Bank Poverty Group, PREM.
CHAPTER 6
Changing Accountabilities—Children’s
Hope Foundation
As China turned to the market from 1978 onwards, new, more inde-
pendent forms of organising emerged, such as learned societies, pro-
fessional associations and trade associations. The market reformers
encouraged these new intermediary organisations as a means to mediate
market relations, transfer government functions, and provide a vehicle
for placing surplus state officials. This led to a growing interest amongst
China scholars in the development of civil society in China. However,
empirical research suggested that most of these newly emerging civil
society organisations were in fact semi- or quasi-governmental agencies,
if not GONGOs. These observations undermined the idea that elements
of an independent civil society were emerging in China. However, such
a picture of civil society organisations, including NGOs, was overly static
and failed to countenance the possibility of organisational change. The
case-study in this chapter, Children’s Hope Foundation, exemplifies well
how an organisation can transit from being semi-governmental to a fully
independent NGO and indeed from being semi-international to fully
domestic. In the process, the need to make accountability so as to gain
legitimacy was crucial in realising the change. As will be seen the reasons
for this organisational transition are complex and rooted in a dynamic
socio-economic context of rapid change.
Children’s Hope Foundation1 was founded in 2001 nestled within a
quasi-governmental sponsoring organisation, Association B.2 In March
2010 Children’s Hope Foundation established itself as an independent
foundation for child welfare in Henan province, eligible to raise funds

https://doi.org/10.1007/978-3-319-90221-0_6
from the public. In this process it lost its legal status that it had derived
from its links to Association B. During the process of severing its ties,
Children’s Hope Foundation astutely began to accumulate its stock of
accountability capital as a way of offering up and demonstrating account-
ability and legitimacy to potential funders. After it had attracted new
funding, it had then to develop new upward-looking forms of accounta-
bility for the new funder.
This case-study provides a granular study of the process of account-
ability-making as a child welfare organisation becomes independent
and seeks new funders. It illustrates three key processes in the making
of accountability: first, the development of new forms of accountabil-
ity in response to a change in status and funder; second, the process of
building stocks of accountability capital, as a form of proxy accounta-
bility in the absence of state-derived legal status; third, the processes by
which certain types of accountability become prioritised over others. As
revealed in this chapter, this accumulation and application of accounta-
bility capital for legitimacy reflects a dynamic context of diversification
of funding sources, the development of social media, and changes in the
regulatory environment governing foundations, all of which have ena-
bled child welfare organisations to develop further and attract additional
revenue streams. From this case-study we can see that proxy, second-
order accountability does not escape the general pattern of prioritising
upward accountability to new funders over downward accountability to
users.
Background to Children’s Hope Foundation

Children’s Hope Foundation started out in 2001 as an internal divi-
sion of a national level, social organisation, Association B. Association
B was a quasi-governmental association, or what is often referred to
as a GONGO, that is set up by government to absorb retired officials
and/or to take on devolved government functions. Children’s Hope
Foundation’s prime objectives were to assist with the medical and edu-
cational needs of orphaned children. Within Association B, Children’s
Hope Foundation took on prime responsibility for international child
welfare and enjoyed close links with an American-based international
Christian child welfare NGO, Children’s Hope International.3 The
director of Children’s Hope Foundation, Ms. Zhang, had previously
worked in Children’s Hope International, whilst the deputy director of
6 CHANGING ACCOUNTABILITIES—CHILDREN’S HOPE FOUNDATION 143
Children’s Hope Foundation, Ms. Wu, was a member of Association B.

In addition they had six staff.
Over time the activities of Children’s Hope Foundation extended
both to promote Children’s Hope International’s activities for the adop-
tion of orphaned children and more generally to arrange foster care,
vocational training for older children, medical and educational support,
and training for the staff of state child welfare institutions. Over a dec-
ade it gradually changed its identity from an international organisation
to a local organisation and from a quasi-governmental organisation to an
independent organisation in response to changes in the funding sources.
By 2010 it was no longer an arm of the Association B and had become a
fully independent NGO.
Between 2001 and 2010 Children’s Hope Foundation had a hybrid
character, neither neatly governmental nor non-governmental, neither
distinctly international nor domestic. First, within China it described itself
as the working department for children of Association B. Its official name
was Children’s Hope Foundation Funds Department (ertong xiwang jijin
bu). However, on the website of Children’s Hope International, it was
positioned as the China-based office of the international organisation.
Second, as a working department of the quasi-governmental Association
B, it was recognised as a governmental organisation, deriving its legal sta-
tus as a social organisation from the Association. Yet, it was also distinct
from other internal organs of the Association in that it had an independ-
ent bank account opened with the assistance of the Association, could
appoint its own staff below director level, and had autonomy over project
management. Furthermore, it had an explicit commitment to raise funds
independently for its administrative costs and projects, and to pay an
annual management fee to Association B. Children’s Hope Foundation
appeared on the one hand to be an independent, Chinese, local NGO,
which received funding support from within China and overseas, but
on the other hand it appeared to be a functional arm of a government
body. In co-operating with both a governmental and an international
organisation, it combined different sources of accountability capital that
would later be beneficial to in transiting from one organisational form to
another. In particular the Janus-like, hybrid arrangement enabled it to
strengthen its organisational reputation and robustness through exter-
nal funding, access to the latest scientific knowledge and professional
expertise around child welfare, and reputational and legal status through
association with a governmental body.
Children’s Hope Foundation’s dual relationships with Association B

and Children’s Hope International were one of resource complementarity
(Ma and Cao 2014; Wang 2008; Pfeffer and Salancik 1978) that proved
useful in its organisational development and in the process of building
its legitimacy and accountability. All three agencies benefited from these
relations. First, the setting up of Children’s Hope Foundation within
Association B was indispensable to Children’s Hope International in
establishing its presence in China. The American organisation, Children’s
Hope International, was founded and registered in 1994 as a non-profit,
international adoption agency. It started its adoption activities in China
in 1992, at a time when the child adoption law of China had just been
promulgated, and when there was limited awareness amongst potential
foreign adoption families of the situation in China. Zhang, who was then
a journalist, together with an American education expert, began work
in the field of child welfare by assisting several American adoption agen-
cies to develop business in China. She then went on to found Children’s
Hope International. Children’s Hope International was not only one
of the first American adoption agencies developing adoption services in
China, but had also set up adoption services in other countries such as
Russia, Vietnam, Ethiopia, and Columbia. Zhang became vice-president
of Children’s Hope International and also director of Children’s Hope
Foundation. Children’s Hope International covered all the administrative
costs and project funds of Children’s Hope Foundation, which though
officially a sub-agency of Association B, did not require any funding
from the Association. Children’s Hope International’s interest in China
extended beyond the material world of international child adoption to
facilitating the dissemination of Christianity.
Children’s Hope Foundation developed two lines of funding through
respectively its international adoption department, which operated
on behalf of and received international funds from Children’s Hope
International, and its fund-raising department, which engaged in
Chinese philanthropic activities. Children’s Hope International, in turn
drew on the fees and donations of American adopting families to fund
Children’s Hope Foundation. The most important Children’s Hope
International resource to Children’s Hope Foundation was its intangi-
ble assets: the skills necessary to develop the adoption services, its sound
relationship with the child placement authorities of the Chinese gov-
ernment, access to children to be placed, and a reliable client base, the
American adopting parents.
Children’s Hope Foundation’s other key relationship was with

Association B. The Association was established in July 1991 as a national
level, Chinese social organisation which was approved and registered
under the Ministry of Civil Affairs (MOCA). Its primary leaders were
influential, ex-senior officials from the civil affairs sector as typical of a
GONGO. The resources of Association B included its legal status,
monopoly position, and extensive linkages with civil affairs departments
nationally. Although Association B had a governmental background and
extensive linkages, it had limited working experience as an NGO, lim-
ited funds, and limited practical experience of professional social work.
The relationship between the Association and the MOCA helped the
Children’s Hope Foundation develop Children’s Hope International’s
child adoption services.
The relationship between these three organisations was mutually ben-
eficial, as their resources were complementary. The international child
adoption agency was able to secure a legal identity through Children’s
Hope Foundation to operate in China. Children’s Hope Foundation
could carry out activities in the name of the governmental Association B,
including supporting the health and education of orphaned children with
the support of civil affairs departments. The donations made by adoptive
parents for successful child adoption services and other donated funds
were also eligible for tax exemption as Children’s Hope Foundation was
a non-profit, internal department working on the front line of child wel-
fare. Meanwhile, Children’s Hope Foundation had its own sources of
funds and was free to appoint its own staff, both essential elements for
developing its autonomy. From Association B’s perspective, it gained
experience in assisting orphaned children and other children at risk
and benefited from working with an international NGO that had social
work expertise. In particular this link to the international exposed the
Association and Children’s Hope Foundation to international best prac-
tice both in terms of child welfare and accountability.
In short, Children’s Hope International had a significant impact
upon the development of Children’s Hope Foundation, covering all its
core costs and thus guaranteeing its financial autonomy from the qua-
si-governmental Association B. Through this funding arrangement,
Children’s Hope Foundation became exposed to international financial
and project management models. On the other hand, Children’s Hope
Foundation facilitated the expansion of Children’s Hope International
in China, growing steadily from being an international adoption service
to supporting other children in need. From 1999 to 2017, it funded

surgery for more than 8,000 children, who returned to their families. It
was one of the first NGOs in China in the early 2000s to prioritise this
approach of supporting families to remain intact. It also developed pro-
grammes such as sponsorship for rural students at risk of dropping out
of school and services to children experiencing abuse. Children’s Hope
Foundation developed child welfare services that enabled Children’s
Hope International to expand into other children’s services in China.
The relationships were thus mutually beneficial, drawing upon resource
complementarities. However, these trilateral relations also required
Children’s Hope Foundation to meet the accountability demands of two
different sponsors, Association B and Children’s Hope International.
Dual Accountability
In the early stages, the dual leadership allowed Children’s Hope
Foundation to secure substantial autonomy. Association B was hands-
off in its management, letting it carry out its work with minimal inter-
ference. Up until 2009, both parties benefited from the relationship.
Children’s Hope Foundation obtained important administrative, legal,
and social resources such as governmental recognition by being part
of Association B, which were conducive to developing its activities,
endowed it with credibility, and established first-order accountability.
Through its leverage of Children’s Hope Foundation, Association B
was able to develop support and assistance for children without incur-
ring any additional expenditure and could expand its influence in China
and overseas. Association B had a positive relationship with the leaders of
Children’s Hope Foundation, not least because Zhang from Children’s
Hope International and Wu from Association B both held leadership
positions in Children’s Hope Foundation.
The relationship between Children’s Hope International and
Children’s Hope Foundation led to the development of a particular
accountability arrangement, whereby Children’s Hope International
demanded accountability and Children’s Hope Foundation held itself
to account, despite the overlapping roles of the key leaders. The overlap
ran the risk of a conflict of interests and potential covering up of prob-
lems, which neither Children’s Hope International nor Children’s Hope
Foundation seemed to consider serious. The risk reflected the more
general weak pattern of accountability in China, whether concerning
governmental or non-governmental agencies. As Children’s Hope

International and Children’s Hope Foundation were subject to the laws
and regulations of two countries, it was essential to establish a robust
mechanism for demanding accountability and holding oneself account-
able. The development of accountability was important for the future
growth and independence of Children’s Hope Foundation and indeed
for Children’s Hope International. For example, Children’s Hope
International was able later to set up an adoption department and foun-
dation, which then supported Children’s Hope Foundation. The adop-
tion department had a Beijing office, which was in fact a programme
managed by Children’s Hope Foundation.
As discussed in Chapters 2 and 3, NGOs in China need a governmen-
tal department or a government-established social organisation to serve as
their supervising agency in order to obtain legal registration. NGOs reg-
istered in such circumstances need to hold themselves accountable to the
sponsoring agency. The laws and regulations pertaining to the registra-
tion and management of social organisations thus define the relationship
between NGOs and their sponsoring agencies as one of rights, obligations,
and responsibilities between the organisations and their supervising bodies.
Sponsoring agencies in China play the roles of supervising and mon-
itoring NGOs on behalf of the government. From the perspective
of demanding accountability from Children’s Hope Foundation and
Children’s Hope Foundation holding itself to account, the sponsor-
ing agency must guide, standardise, and regulate the behaviour of the
organisation and individuals in accordance with relevant laws, regulations
or governmental policies. Furthermore, the sponsoring agency usually
also has specific internal regulations for the operation of the sponsored
organisation. The accountability relationship is thus vertically struc-
tured, with the social organisation answering in a one-way direction
upward. As an internal organ affiliated to Association B, Children’s Hope
Foundation submitted work progress reports according to the proce-
dures, and received a financial audit conducted by an accountant firm
employed by Association B.
New Actors and New Accountability Arrangements

Around 2008 several changes in the external context of Children’s Hope
Foundation were afoot, which had implications for its future develop-
ment. First, in 2009, Children’s Hope International drastically reduced
the funds provided to Children’s Hope Foundation due to a fall in

the number of children for adoption. In 2009 the sources of Chinese
children available for international adoption declined, partly because
parents abandoned their children less, partly because of curbs on inter-
national adoption in 2007 following exposure of a state welfare institu-
tion purchasing children for international adoption, and partly because
the number of domestic adoptions was increasing (Shang and Fisher
2014). This in turn led to a reduction in the income of Children’s Hope
International, and hence the funding provided to Children’s Hope
Foundation.
With the changing context, from early 2009 onwards Children’s
Hope International no longer provided Children’s Hope Foundation
with funds for its project operations. This created a strong incentive for
Children’s Hope Foundation to separate itself from Association B and
establish itself as an independent, non-governmental child welfare organ-
isation. As Children’s Hope Foundation focussed on raising funds from
alternative sources to Children’s Hope International, the accountability
arrangements governing the Foundation changed.
In adapting to this new situation, Children’s Hope Foundation took a
number of measures, including rearranging its internal finances, and tak-
ing advantage of changes in the regulatory environment that enabled it
to move more swiftly towards independence. First, internally, Children’s
Hope Foundation issued a notice that it would use 5% of the medical
programme funds and 10% of the other project funds for project opera-
tional costs, as allowed for by the new relevant government regulations.
In this way, it could plug some of the resource gap left by Children’s
Hope International.
Second, it began to actively raise funds from the public, building upon
the reputation it had already gained as a working department within
Association B. Up until 2001 Children’s Hope International had pro-
vided all the funds for office expenditures and project operational costs
of Children’s Hope Foundation. From 2002 onwards Children’s Hope
Foundation also began to receive donations from within China.4 The
director of Children’s Hope Foundation had already begun to leverage
public relations and approach companies for funding. The Foundation
used the website as a means for raising public awareness of the organi-
sation, providing information to the public and setting up a system for
receiving public donations. Children’s Hope Foundation also raised
funds through the contacts it made by participating in public events such
as the annual conference of the national NGO child care organisations.

Other means were through the media and indirectly through the con-
tribution of volunteers. As it had already established a reputation for
its work, Children’s Hope Foundation did not need to initiate a large
fund-raising campaign to raise funds or approach many businesses for
fund-raising.
In 2009, donations made mainly by individuals and some by busi-
nesses accounted for around 30% of all contributions to Children’s Hope
Foundation within China. Amongst them, Man Wenjun, a celebrity in
China, raised RMB 1,107,947 for children with cerebral palsy. There
were also much smaller donations, and some donations by “anonymous”
individuals who left no contact information. The ability of Children’s
Hope Foundation to raise public donations reflected its efforts in devel-
oping and accumulating accountability capital. By 2007 the amount of
domestic contributions was comparable to that of foreign contributions,
suggesting growing public recognition of the role of NGOs in providing
social welfare, and specifically of Children’s Hope Foundation. By 2015
Children’s Hope Foundation received over RMB 12,094,114 in domes-
tic donations.
Third, there were also changes underway in the regulatory environ-
ment of social organisations that made it easier to raise funding from
non-governmental sources, as discussed in Chapter 3. Relevant here were
the 2004 revision of the Regulations on the administration of Foundations,
the 2006 measures to improve the transparency of foundations, and the
tax exemption in the Law of Enterprise Income Tax 2007 (see Chapter 3).
Together these regulations laid the basis for the expansion of foundations
by making it easier to raise funds. Greater transparency around the use of
foundation funds boosted public confidence in donating to foundations,
whilst enterprises were given incentives to make philanthropic contribu-
tions. The new non-governmental China Foundation Centre promoting
transparency was another milestone in the development of foundations,
bolstering public confidence in their work. These policy changes brought
about the unexpected, rapid development of non-public fund-raising foun-
dations. Whereas in 2005, there were only 253 non-public fund- raising
foundations, by 2015 this had spiralled to 3,198, a more than 12-fold
increase. In contrast, public fund-raising foundations had grown 1.5-fold
from 991 in 2009 to 1,548 in 2015 and formed the minority of founda-
tions. In the six years since 2009, the number of non-public fund-raising
foundations was double that of governmental foundations.5
This new suite of regulations created new opportunities for Children’s

Hope Foundation, making it possible for it to eventually break loose
from both Association B and Children’s Hope International. In the
decade from 2000 to 2010, the importance of the advantages that the
quasi-governmental Association B enjoyed, such as its monopoly of legal
resources and the tax exemption status granted by the government for
donations diminished. The policy changes on foundations enabled other
actors to move into funding welfare services, matched in turn by grow-
ing public awareness about foundations and NGOs. During this period
Children’s Hope Foundation had been increasing its stock of accounta-
bility capital and strengthening public trust in its operations. As the bal-
ance of resource advantages between Association B and Children’s Hope
Foundation began to shift, undermining the dominant and monopolistic
position of the Association, the rationale for the collaboration between
the two parties gradually vanished.
At the same time the relationship between Children’s Hope
Foundation and Association B also changed in two other respects. First,
Director Zhang established a new organisation external to Association B,
officially called the Henan Province Children’s Hope Foundation Relief
Assistance Foundation (henan xheng ertong xiwang jiuzhu jijinhui) and
gradually transferred the associated resources of the former Children’s
Hope Foundation to it. Second, Association B established another affil-
iated organisation, which shared similar objectives and activities with
those of Children’s Hope Foundation. Director Zhang in her capacity
as representative of Children’s Hope International was then ordered to
leave her position in the Children’s Hope Foundation because it was a
working department of Association B and it enjoyed less independence
from Association B. Other employees remained and the organisational
name, finances and project management remained unchanged. For a
while, Association B’s newly established organisation co-existed with
Children’s Hope Foundation, using different names and bank accounts,
and complicating lines of organisational accountability. The overlap-
ping relationship was such that some staff members believed that the
two organisations actually shared the same staff and were one organ-
isation with two names. Following a transitional period of six months,
Association B stopped using the organisational name of Children’s Hope
Foundation, and child welfare activities were developed exclusively in the
name of the newly affiliated organisation. The bank account established
in the name of Children’s Hope Foundation was then terminated, and

only the bank account of the new organisation survived.
Children’s Hope Foundation within Association B gradually lost its
financial independence. In July 2010, Association B appointed a new
finance manager for the new organisation, who was simultaneously
responsible for managing the office of Children’s Hope Foundation.
Thereafter, the income and expenditure of Children’s Hope Foundation
had to be reported to the new finance manager for approval. Meanwhile,
Association B appointed a new director assistant who was simultane-
ously the deputy director-general for the new organisation. As these new
financial and organisational arrangements weakened further the financial
independence of Children’s Hope Foundation within Association B, it
had even more of an incentive to break free and take advantage of the
new non-public fund-raising foundation regulations to become inde-
pendent. Thus, in creating new organisations, the parent organisations—
Association B and Children’s Hope Foundation—paved the way for
the eventual closure of Children’s Hope Foundation. In March 2010,
Children’s Hope Foundation was officially registered in Henan province
as a foundation with an independent legal body identity, whilst its head-
quarters remained in Beijing. Its vision was to carry out assistance and
support for children, including their medical and educational care. Thus,
it became an organisation independent from Association B.
As a foundation, Children’s Hope Foundation was able to raise funds
from the general public in China and rely primarily on domestic fund-
ing for its revenue. Its website made clear how the general public could
donate to the organisation. In 2011 it received three years’ funding from
the well-known Shenzhen One Foundation to support children with dis-
abilities. In 2016 it set up a co-operation agreement to establish a joint
fund to support vulnerable children with the Amity Foundation.6 Most
of the staff were Christian and salaries were not high. As a value-based
organisation not focussed on profit-making, it was able to maintain
reasonable costs. This moral standing strengthened public trust in the
organi sation. Moreover, its claims to be a value-based organisation
served as a basis against which the organisation could be held to
account. Since becoming a foundation it has grown, expanding to sev-
eral provinces and cities in China, including Beijing, Henan, Shanghai,
Guangzhou, Yunnan and Sichuan, with offices or working stations in
these locations. Its headquarters remain in Beijing, though its registration
is in Henan province. By 2017 its staff numbered 30 staff, including ten

based in the Beijing office.
Hence, the changes in the organisational and financial accountability
requirements led to a redefining and re-arrangement of the relationship
between Association B and Children’s Hope Foundation as their interests
in continuing their collaboration shifted. In this process, Children’s Hope
Foundation gradually separated from Association B and became an inde-
pendent new organisation. The affiliated organisation set up by Association
B continued to operate but was effectively in competition for funds and
reputation with the now independent Children’s Hope Foundation.
The relationship between Children’s Hope International and the
Children’s Hope Foundation also changed. Originally, Children’s Hope
Foundation was the China office for Children’s Hope International, within
Association B, until the Foundation became independent from both. Since
becoming independent, the Foundation director continues to be listed as
on the Children’s Hope International webpage, including for Alenah’s
home,7 which is run by Children’s Hope International, fostering children
from orphanages and arranging adoption for many of the children.8
Accumulating a Stock of Accountability Capital on the

Path to Separation and Independence
In transiting from being an organisation affiliated to a governmental
association to becoming an independent foundation, Children’s Hope
Foundation’s steady accumulation of accountability capital proved to
be an essential ingredient for diversifying its funding sources and in par-
ticular gaining public trust. Establishing processes of accountability and
the very fact of being seen to be accountable were pivotal in its growth
and eventual separation from Association B. This section examines the
different dimensions of accountability that Children’s Hope Foundation
built, which enabled the crafting of a relatively accountable NGO given
its time in China. It explores this from the perspectives of organisation,
finance, expertise, and child welfare.
An organisation is organisationally accountable when its structures, sys-
tems, development and practices match the stated organisational mis-
sion, goals, and internal governance principles, including openness,
transparency, and democratic practices. Whilst Children’s Hope

Foundation emphasised clarity of organisational mission and objec-
tives, it gave less importance in practice to governance issues of open-
ness, transparency and democratic practice. Given that visions and
mission statements are inevitably broad, there is considerable room
for developing a range of approaches and activities to achieve these.
Children’s Hope Foundation’s vision was ‘Giving homes, health and
hope for children’. It was closely associated with that of Children’s Hope
International’s mission ‘to mobilise and utilise public benefit resources
and provide professional support and services to safeguard the right of
survival of each child, promote their physical and mental health, enjoy
family life and live a productive life’.
As Director Zhang indicated, her views on how to achieve their
mission were constantly revised and updated. Initially, she sought to
improve the situation of orphaned children and children with disabilities
at the welfare institutions through humane, professional care. After the
government formulated detailed measures for the standardised manage-
ment of children within state child welfare institutions, she re-oriented
the organisation towards assisting disadvantaged children with disability
or living in poverty. In doing so she focussed on both relief and preven-
tion, such as medical care for children living with their families to pre-
vent the families having to abandon them. Her approach shifted from
one confined to service provision to one that also included advocacy.
This advocacy work included promoting legislation on support and
assistance to children. In 2009 Children’s Hope Foundation submit-
ted the ‘Proposal on establishing child health insurance system’ to the
National People’s Congress in an attempt to influence policy. In 2010,
drawing on personal connections, it submitted another two proposals—
‘Establishing the child protection compulsory report system and related
systems’ and ‘Proposal on the Amendment to the Minors Protection
Law’—to the Chinese People’s Political Consultative Conference
(CPPCC) via a member of the CPPCC. Though there is no evidence
that these two proposals singly influenced thinking or led to pol-
icy change in either of these lead political organisations, they can be
expected to have contributed at least to a more general awareness-rais-
ing around these issues. Furthermore, such advocacy work increased the
visibility of the organisation and demonstrated its concern for improving
the situation of disabled children in China. This was important in dis-
playing its moral standing as an organisation that cared about the future
of disabled children and justifying the legitimacy claims articulated in its

mission statements.
In terms of other aspects of organisational accountability such as gov-
ernance, Children’s Hope Foundation’s record has been weak before and
since the 2010 organisational change. The organisation had no board
of directors, leaving authority and oversight in the hands of the direc-
tor and the deputy director, with no internal lines of accountability from
above. Major decisions such as staff salaries were made by two or three
core management team members. For project-related issues, the pro-
ject department usually reported directly to and consulted the director
or deputy director. Daily communication about the work was primarily
done through the half hour morning meeting, mainly via the Internet. In
general, the core decision-making model of Children’s Hope Foundation
was basically informal and centred at the top.
Following its independence in 2010, Children’s Hope Foundation
became a new organisation with a Director and Vice-Director and set
about strengthening its internal governance structures. To improve the
management system, it established a system of position descriptions and
job specifications. It developed an organisational structure, staff manuals,
financial procedures, and regulations on computer use. It also established
a set of procedures for project management, including project prepara-
tions, rationale review, project implementation, project conclusion, pro-
ject process recording, and documentation. These detailed provisions on
job positions and work procedures provided guidance and a reference
point to new staff members on how to carry out their work according
to their position. In this way, it provided a basis for holding staff to
account. It marked a determined shift towards professionalisation, in this
way building up its credibility as a well-run, efficient and professional
organisation.
In addition to formal managerial procedures, it also specifically empha-
sised Christian values such as having ‘a loving heart’ and ‘spirit of devo-
tion’ as essential requirements for any job applicant. Most staff members
were practising Christians and it was clear that a Christian ethos and spirit
underpinned the culture and values of the organisation and contributed
to keeping organisational costs low. This rhetorical commitment to the
values of love and caring also formed part of its efforts to gain legitimacy
in the eyes of the public and clients. Professionalism and values were both
aspects of building accountability and legitimacy that were promoted in
the transition to and after independence. Moral standing and professional
expertise were legitimacy claims that could be scrutinised through the

various accountability processes it established.
Auditing
As Children’s Hope Foundation had multiple funders, it also had to
be accountable in different ways to these funders in accordance with
their specific demands, procedures, and time-lines. Co-operating with
Association B required compliance with Chinese regulations on finan-
cial management. The official financial management system was strin-
gent. Specifically, to verify the receipt of a payment, it was required that
two financial staff members must send the remittance via the post office
to avoid any error. One of them was responsible for collecting the cash
remittance order from the reception office and logging the information
as per the provisions, with a personal seal attached. The registered cash
remittance order was handed over to another staff member who was
responsible for collecting the cash from the postal office and issuing the
receipt. At the end of each month, financial verification was conducted
and the findings were publicised via the Internet or in other ways. For
the management of donated funds that were not earmarked, the finan-
cial department discussed options with the relevant project directors of
the organisation to determine the projects to be funded, formulate pro-
ject plans, and budgets, explain the processes for using the funds and
completing projects, and publicising the results via the Internet. There
were thus formal procedures in place for auditing funds which could be
referred to in providing account to donors.
The funds granted by Children’s Hope International were subject
to a special financial management system. The provisions on donated
funds were handled in the same way as in Association B, as described
above. Following the approval of Children’s Hope International, the
funds could then be used, and the project budgets and the written com-
ments of Children’s Hope International were forwarded to the finance
department which would then disburse the funds in accordance with the
budget. Following the completion of the projects, feedback would be
given to Children’s Hope International within the stipulated time-frame.
Director Zhang was a leader for both Children’s Hope International
and Children’s Hope Foundation, which on the one hand made it
convenient for her to control the use of the funds but on the other hand
raised potential conflicts of interest. At the time of the research there was
no system in place to deal with avoiding these conflicts.
Financial Accountability to the General Public

There has been a growing global consensus since the millennium
around the need for greater financial transparency and accountability
on the part of NGOs, as discussed in Chapter 3. Some practices have
now been widely applied, such as financial transparency, use of funds
for the earmarked purpose, timely feedback, and strengthened monitor-
ing by donors. This was also the case for Children’s Hope Foundation.
Following the establishment of Children’s Hope Foundation, the scope
and volume of its project activities for assistance and support to children
were scaled up substantially. Children’s Hope Foundation undertook
upon its own initiative an increasing number of social responsibilities
beyond its original plan. As a result donations from the Chinese pub-
lic increased constantly. This in turn raised the issue of how best to
develop and provide accountability to the general public. In this regard,
Children’s Hope Foundation made substantial efforts to gain the trust
of the public through, for example, the use of media, a website and
demonstration of professional expertise. The flow of donations and other
kinds of support from the public demonstrated the relative success of this
strategy.
One aspect of Children’s Hope Foundation’s efforts to develop finan-
cial accountability and gain the trust of the Chinese public was through
providing feedback to public donors, primarily by being financially
transparent and reporting feedback from the beneficiaries to donors in
a timely way. The specific measures taken included the following. First,
Children’s Hope Foundation made a commitment on its website and
in its documentation to use public donations for earmarked purposes
only; second, it made public its financial statements, project reports, and
records of donated funds on the Internet. The Beijing Office invited
the public to query its reports on support and assistance to children at
any time, whether by donor, project or beneficiary. Third, starting from
2009 its annual audit reports were also made publicly available on the
Internet. Depending on the specific project, the type of documents pro-
vided also varied. For example, the health reports of the beneficiaries of
medical projects were presented to the donors. Staff at the social worker
station established by Children’s Hope Foundation in Sichuan visited

the families of beneficiaries or their schools on a quarterly basis, and for-
warded the latest information on the progress of the beneficiaries to the
donors. However, beneficiaries were not directly consulted about impart-
ing this private information to donors, underlining the more general lack
of user participation in accountability and weak privacy protection in
China.
Despite all these moves to enhance financial accountability, ensuring
accountability has not been smooth. For example, due to constraints in
human and material resources, it proved difficult to comprehensively
monitor and track the whereabouts and effectiveness of donations.
Some welfare institutions offered only uniform, unspecific information
about the situation of children, and donors were reportedly not sat-
isfied. Children’s Hope Foundation sought to address these issues by
developing a more accurate and updated database, reinforcing the level
of funding at selected support sites, and expanding their replicability
and demonstration effect. It also sought to improve accountability by
encouraging named rather than anonymous donations. Donations made
by anonymous persons made it hard to provide feedback due to the
absence of contact information and effectively meant that donors relin-
quished their right to monitor the use of their donated funds.
Professional Accountability
In China, at the time of research, there was a lack of professionalisation
in the field of child welfare services and an absence of independent pro-
fessional bodies that set standards and ensured the professionalism of
the field. Rather, the pattern has consistently been ‘strong governmental
leadership and weak social participation’, that is, administrative manage-
ment was the dominant mode of ensuring accountability. Nevertheless,
the survival and development of NGOs rely on their important com-
plementary roles in relation to governmental functions. NGOs engaged
in assistance and support to children use a wide variety of flexible
approaches in providing support and assistance that local governments
are unable to provide and can reach individuals beyond the reach of local
governments.
In terms of developing professional accountability, Children’s Hope
Foundation primarily co-operated with professional agencies, which had
facilities, knowledge and skills that Children’s Hope Foundation could
not provide. For example, in the first year Children’s Hope Foundation
linked up with health facilities to assist over 100 children receive surgery
for the treatment of cleft lip and palate. In 2002 it extended these links
to include heart diseases and cerebral palsy in its projects, and established
partnerships with the volunteer worker team ‘Loving Mothers’ and some
other organisations. In the same year, it began to pilot the foster care
support project, and established its own foster home in Beijing in 2004.
In 2006 Children’s Hope Foundation responded to the launch of the
‘Blue Sky Initiative’ developed by the MOCA,9 and began to priori-
tise the assistance and support to children in poor families with health
problems so as to reduce the number of children becoming orphans.
Afterwards, Children’s Hope Foundation launched various projects
providing support at school, care support, psycho-social counselling for
orphaned children affected by HIV, and training for the rehabilitation
of children with cerebral palsy. Thus through its links with a range of
professional institutions, it developed a reputation for working with pro-
fessional organisations and adapting their practices and priorities to new
evidence of good practice.
User Accountability
The main ways in which Children’s Hope Foundation provided some
accountability to users was through its publicity and promotional activ-
ities. Children’s Hope Foundation established a website in 2005–2006,
and had its own journal—Children’s Hope Foundation—with a print run
of around 3,000 copies per issue, which provided information about its
goals, activities, and beneficiaries so as to garner support for children
in difficulties. It also carried out regular promotional activities, pub-
licised its vision as well as successful cases of child aid and support so
as to attract more people to join the organisation and support its work.
Children’s Hope Foundation published the health reports of children
receiving medical support, though as stated earlier this raises issues
around the need to protect children’s rights to privacy. Information was
also provided about the assistance Children’s Hope Foundation prof-
fered in the 2008 earthquake in Wenchuan, Sichuan Province. Children’s
Hope Foundation took the first batch of medicines donated by United
Family Hospital to Dujiangyan and Mianyang City near Beichuan.
Afterwards, it set up a centre in Sichuan to provide support and help to
orphans and children with disabilities and children in difficulties brought

about by the earthquake.
Children’s Hope Foundation used the media to highlight particular
cases where it provided services. A prominent example of this was the
case of Di. A one-year-old girl from a village in Junan County, Linyi
City in Shandong province, Di was severely burned after falling into a
pot of boiling water. The child’s parents were refused medical treatment
at the city hospital and sought help at other health facilities. However,
covering the medical costs of their daughter had pushed them into pov-
erty, despite having above average living conditions. Children’s Hope
Foundation provided considerable assistance in publicising her case and
raising funds for her medical treatment in China and the USA. The
media coverage was important for the profile of the Foundation, but
again did not consider the privacy of the child and family.
Despite users gaining some information about the organisation
and its operations through these media and promotional activities,
there were no formal processes in place to ensure that users could hold
the organisation to account. Parents signed an agreement on the kind
of medical support their children would receive but no procedures of
accountability were built into this; nor did parents apparently feel the
need to monitor the use of funds or safeguard the privacy of the chil-
dren. Whilst the absence of a demand for accountability by users might
suggest a high degree of trust in the organisation or user satisfaction, it
also reflects a certain normalisation of non-accountability in an authori-
tarian state. Where an authoritarian state has had a monopoly over wel-
fare provision, users may feel they have no choice but to accept what
they are given or otherwise exit and fend for themselves. The diversifica-
tion of service-delivery agencies might in theory increase the possibilities
for exiting to another provider, but deference and habit also can make
users reluctant to demand accountability. In practice, the pluralisation of
service-delivery organisations in this welfare field is still very limited so
that the monopoly factor continues to restrict the options open to dissat-
isfied users.
In China people’s access to health services and the quality of their
delivery often depends on gift-giving and/or leveraging personal con-
nections. Children’s Hope Foundation marked a departure from
this practice. Indeed, those parents who received gratis support from
Children’s Hope Foundation found it hard to persuade their neighbours,
friends, and communities that they had not needed to give gifts or cul-
tivate personal connections to access services. This gratis support, which
stood in contrast to gift-giving practices in other medical institutions,
whether public or private, added to the moral standing of the founda-
tion. Demonstrating morality in this way fostered public trust. As dis-
cussed by Lily Tsai, such moral standing was a claim against which the
organisation could be held to account.
Conclusion
This case study generated several findings in relation to the importance
of building second-order accountability in the process of establishing an
independent, non-governmental foundation, the power relations shap-
ing the dimensions of accountability, the role of contextual factors in cre-
ating opportunities for development and survival, and the possibilities for
GONGOs to metamorphise into genuinely independent organisations.
First, the case-study highlighted the need for new players in welfare provi-
sion without legal status to accumulate stocks of accountability capital such
as financial resources, professional reputation, and public trust to ensure
their survival and development. Developing informal accountability capital
such as public trust played an important role in the transfer of the organi-
sation from being a working division in the quasi-governmental Association
B to becoming an independent, non-governmental child welfare organisa-
tion. Expounding the value-base of the organisation c reated moral standing
that in turn strengthened public trust. In this case, on accumulating suf-
ficient accountability capital, the organisation was then able to break free
from the government and become independent.
Second, the case-study revealed how in this process of crafting
accountability, funders played a key role in shaping the hierarchy of
accountabilities. The power of organisational funders such as Children’s
Hope International led to the prioritisation of financial and organisa-
tional accountability over user accountability. Individual funders, how-
ever, did not demand accountability, relying on trust alone. Though they
had the power to withdraw funds, the failure to exercise voice meant that
the foundation did not receive feedback on its performance that could
have led to adjustments of practice and policy.
Third, the changes in the regulatory environment created oppor
tunities for Children’s Hope Foundation to establish a non-public
fund-raising foundation and sever its ties with both Association B and
Children’s Hope International. Though these changes were part of

a broader state strategy of welfarist incorporation to diversify the field
of service-delivery providers and financial sources, they also opened the
door to organisations such as Children’s Hope Foundation to sever their
ties with GONGOs such as Association B.
Finally, the case-study undermined the assumptions of much research
on civil society development and NGOs in China. Many scholars observe
that most NGOs are closely connected to government, often founded
by the state and run by former government officials. This depiction of
NGOs in China does not factor in the possibility of change, whereby
government ties can be weakened, such organisations can develop some
autonomy and even move towards becoming a genuinely independent
civil society organisation. This in-depth study of an organisation mak-
ing such a transition to independence demonstrated that organisations
closely linked to government can become independent entities. This does
not mean that the independent organisation does not continue to lever-
age the governmental connections it had; rather that it can leverage these
ties from the position of organisational independence. As illustrated in
the study, the crafting of accountability to gain legitimacy is a crucial part
of this process.
Notes
1. Names of people and organisations used with permission in this chapter
are publicly available on the organisation’s official website, http://www.
childrenshope.org.cn/pages.php. Other names are anonymised.
2. The name of the Association is anonymised to protect confidentialities.
3. http://childhope.org/.
4. The precise amounts for 2004 and 2006 were not, however, specified in
detail in the audit reports.
5. There were also 202 foundations registered with the Ministry of Civil
Affairs; 9 overseas foundations; and 29 representative offices of foreign
foundations (www.mca.gov.cn/article/sj/tjgb/201607/20160700001136.
shtml).
6. See, http://www.childrenshope.org.cn/pages.php.
7. http://childrenshope.net/our-work-in-china/.
8. http://childrenshope.net/alenahs-home/.
9. The Blue Sky Initiative was a project initiated by the Ministry of
Civil Affairs to support the building of state child welfare institutions
nationwide.
References
Ma, L., & Cao, J. (2014). Policy support for growth of grassroots social
organisations: A resource dependence perspective. Journal of Shanghai
Administration Institute, 15(6), 71–76.
Pfeffer, J., & Salancik, G. R. (1978). External Control of Organisations: A
Resource Dependence Perspective. New York: Harper and Row.
Wang, J. (2008). The mechanism of interactions between Zhejiang govern-
ment and civil society organisations: Analysis of resource dependence theory.
Zhejiang Social Sciences, 9, 31–37.
CHAPTER 7
Accountability of a Mixed Child Welfare

Organisation
The three preceding case-studies focused on how NGOs without legal

registration as child welfare organisations craft accountability as part
of establishing legitimacy so as to raise funds, expand their clientele,
develop and survive as organisations in an authoritarian state. In con-
trast, state child welfare institutions already have legal status that sets in
train certain accountability requirements. These accountability processes
are mainly concerned with financial, procedural, and political account-
ability, with little attention paid to downward user accountability or
horizontal professional accountability. Since the late 1990s, state child
welfare institutions have come under pressure to diversify their sources of
funding because government funding was insufficient to provide the ser-
vices currently expected for children in their care. To this end, they have
to persuade potential donors such as companies, wealthy individuals, the
general public, parents paying service fees, other government depart-
ments and international foundations to fund their operations, open-
ing them up to new actors and accountability demands. As this chapter
shows, state child welfare institutions as well as NGOs had to learn to
make accountability and expand their sources of legitimacy as legal sta-
tus alone was not sufficient to attract funding, particularly in the wake of
scandals around GONGOs and more general state corruption. In doing
so, they had to compete against new actors in the field such as NGOs,
some of which may have a longer trajectory of fund-raising. They also
faced particular constraints related to being a state institution that makes
it hard to alter the behaviour of front-line state employees.

https://doi.org/10.1007/978-3-319-90221-0_7
This case-study, referred to here as the mixed welfare institution,1

exemplifies such an institution that has changed from being an entirely
state-funded welfare institution to one with diversified funding and
mixed links to the local and international community. As mixed welfare
institutions no longer rely solely on state funding, they are obliged

to be accountable to multiple parties. This has expanded the scope of
accountability to a wider range of people and organisations. In addition,
attempting to manage these financial needs and tensions has meant that
the organisation has also gained wider opportunities for legitimacy. The
accountability obligations under this mixed welfare model related to
various government agencies, local and international civil society organ-
isations, the local community, staff, families, and children using the ser-
vices. Its support from international civil society organisations exposed
it not only to international best practice in child welfare but also to new
processes of accountability. The case-study thus raises issues around
how the organisation sought to accumulate second-order accountability
capital to bolster its legitimacy and donor confidence in it, how it man-
aged potentially competing accountabilities, and how it nurtured and
utilised the additional legitimacy.
The chapter begins by introducing the background to the mixed
welfare institution case-study, including the two initiatives of interna-

tional cooperative partnerships and community-based services for local
families. It then analyses the accountability tensions arising from man-
aging multiple accountability obligations to government and other
funders, accountability to and from staff and to children, families, and
the community.
Background to the Mixed Welfare Institution

The Mixed Municipal Welfare Institution is a city-level public institution
established in 1951 and affiliated to the Civil Affairs Bureau in south-
ern China. It is a large integrated welfare institution with 789 beds,
catering for older people and adults with disabilities without family or
other means of support and for orphaned and abandoned children, most
of whom had disabilities. Unusually, it also provides services in return
for a fee to the general public, including care for older people, therapy
for children with disabilities living with their families, and childcare for
young children. It defines itself as a mixed welfare service provider.
7 ACCOUNTABILITY OF A MIXED CHILD WELFARE ORGANISATION 165
The welfare institution has an adoption management division, health-

care and rehabilitation division, and divisions of education, social work,
and operations. The welfare services are divided into departments for
adults and children. The adult department includes sections for nursing,
care, and apartments which are managed as a level of care. The depart-
ment for children has sections for babies and older children, a rehabili-
tation training centre and a kindergarten. Both departments provide free
services to adults and children without families and fee-based services for
other community members with family financial support.
In the child welfare section, the welfare institution manages adoption
and care for orphaned and abandoned children, children with disabilities,
and street children aged under 14 years. The integrated care services in
the institution include care, nursing, health care, therapy, and education.
These are all services provided by most state child welfare institutions in
China. In addition, it also manages family foster care in the community,
family support for child development, domestic and international adop-
tion, and early childhood education services for children living in the
community. This chapter focuses on the implications for accountability
of this particular mix of new children’s services, namely, the co-operative
projects with international organisations and the new focus on the local
community.
Children in the Institution

The first priority of the institution is to arrange adoption for children
who enter state care. These children are in the guardianship of the insti-
tution until they are adopted. All adoption is overseen by the central
government, with strict oversight for international adoption by the for-
eign adoption working group. Domestic adoption procedures require
that the institution collaborates with the local civil affairs bureau (Shang
and Fisher 2014).
In the past three decades, the number of children admitted to or resid-
ing in the institution has steadily increased (Table 7.1 and Fig. 7.1) from
39 in 1985 to 497 in 2009, although the rate of increase has declined.
Child adoption and permanent placement are the preferred placement
approaches. The welfare institution follows the national adoption policy
for domestic and international adoption, so that children can be cared
for in a family if at all possible. The number of children adopted each
year has declined over that period, reflecting the lower number of new
Table 7.1 Children in the Mixed Welfare Institution 1985–2009
Year Number of children Year Number of children
1985 39 1999 599

1987 54 2000 440
1989 70 2001 425
1991 63 2002 381
1992 90 2003 372
1993 102 2004 367
1994 164 2005 472
1995 136 2006 530
1996 585 2007 387
1997 649 2008 403
1998 Missing 2009 497
Source Summary performance reports of the Municipal mixed welfare institution
700
600
500
Child
400
300
200
100
0
1980 1985 1990 1995 2000 2005 2010 2015
Year
Fig. 7.1 Children in the Mixed Welfare Institution 1985–2009
children entering state care (Table 7.2 and Fig. 7.2). In addition, over

the past decade, the institution placed 1,714 children in permanent foster
care families, enabling these children to also live in a family in the com-
munity even though they remain state wards. The state wards in foster
care are more likely to be children with disabilities, who are less likely to
find an adoptive family.
Table 7.2 Children adopted from the Mixed Welfare Institution 2000–2009
Year Total Adoption in China International adoption
2000 208 79 129

2001 244 88 156
2002 264 63 201
2003 129 30 99
2004 181 39 164
2005 192 76 116
2006 155 56 99
2007 197 109 88
2008 95 65 30
2009 49 17 32
Source Summary performance reports of the Municipal Welfare Institution
300
250
200
Child
150
100
50
0
1998 2000 2002 2004 2006 2008 2010
Year
Fig. 7.2 Children adopted from the Mixed Welfare Institution 2000–2009
International Co-operation
Since the 1990s, international child welfare organisations have played a
major, positive role promoting changes in the professionalisation, fund-
ing, and financial transparency of child welfare institutions in China
(Shang 2008), including in the mixed welfare institution. These inter-
national organisations were critically important to the development of
accountability processes in the institutions, as their financial contribu-
tions leveraged changes in expected service quality. The five international
partners were World Vision, Holt International Children’s Services, US
Forever Families, Half the Sky Foundation, and US Grace and Hope
for Children.2 They each posed different accountability requirements,
dependent on the size of the financial contribution. As a large, state wel-
fare institution with legal status, the mixed welfare institution was of
interest to international donors, providing the possibility for influencing
government thinking and policy on child welfare practice. Furthermore,
with its state background, donors had some guarantee that their funds
would be properly used, as a scandal in a state institute would undermine
the reputation of the local state. If the international partnerships led to
positive achievements, local cadres could take credit for the successes and
strengthen their chances of promotion.
World Vision established a long-term, two-stage partnership with the
institution in 1999 and 2005, with a budget in each stage of approxi-
mately RMB 3,450,000 (£400,000). The projects included rehabilitation
for children with disabilities (development of facilities and staff training),
family foster care, and early childhood therapy and education for children
with disabilities. The goals were to enhance and professionalise the qual-
ity of the services and consequently improve the children’s quality of life.
Holt International Children’s Services is a children’s charity organisa-
tion, which aims to arrange a home for every child. In 1994 and 2001,
Holt and Hong Kong Mother’s Choice jointly funded family foster care
for some children at the institution. Both parties contributed funds and
jointly managed foster care for children with severe disabilities or dis-
ease. Over 30 children aged 1–7 years were placed in family foster care,
including children with HIV, cleft lip and palate, albinism, and severe
disabilities. The goal was that the supported foster care would enable the
children to obtain the same care, support, and encouragement as other
children in the community. The partnership with Holt also meant that it
could arrange adoption for hundreds of children with American adoptive
families via the official central government China Centre for Children’s
Welfare and Adoption. Holt also funded additional support for children
with disabilities who continued to live in the institution, including edu-
cation and health care; and monthly activities in the local community.
These children tend to be past an age when foster care is normally able
to be organised. Holt organised for the overseas adoptive families to raise
donations to improve the living conditions of children remaining at the
institution.
The third international partnership since 2003 was with an American
adoption agency, Forever Families. It funded 10 foster families through a
monthly grant of RMB 200 (£25) to each child in foster care. Although
the amount was small, the institution viewed it as an opportunity for
more children to live in a family and receive foster care in the commu-
nity. The next partnership was with Half the Sky Foundation to develop
child support projects in 2006. The Grandmother Initiative was designed
to provide responsive early education to babies and young children aged
0–18 months. The Little Sisters Pre-school Education Project was set up
to provide pre-school education to children aged 18 months through
seven years. Finally, the Older Sisters Project was established to provide
teenagers aged 12–18 years with individualised schooling support and
skills training. These school-age children were provided with additional
training from the teachers. Arts education facilities in the kindergarten
and pre-school projects were provided for the care of orphaned children
aged 2–16 years. The project used a family education programme, which
provides education to the child and family to accelerate their learning.
The final partnership from 2005 was with the American organisation,
Grace and Hope for Children. It developed projects to support chil-
dren with disabilities and other additional needs by expanding the foster
care project. The additional foster families funded by Grace and Hope
for Children increased from 8 to 74 by 2009. A total of 148 children
received grants from the organisation, half of whom were children with
disabilities. It also funded annual activities at the institution for the foster
families to celebrate the New Year, Children’s Day, and the Mid-Autumn
Festival. It promoted cooperation between the institution, foster families,
and other NGOs with the goal of improving the quality of physical and
emotional care and support for the children.
Development of Resource Centres Targeted

at Communities
The second initiative of the welfare institution was to establish services

targeted at community members that provided education and services to
children living with their families, in addition to children in state care at the
welfare institution. The first community service was pre-school education
for children with and without disabilities. In 2005 the institution estab-
lished the kindergarten, which was attended by over 160 young children by
2009. The goal for the kindergarten was to promote integration between
children in the institution and the community. This way it could provide
quality pre-school education to all the children, whilst also integrating the
children in state care with children in families in the community. This step
towards educational integration was innovative for the institution. As such,
it could be used to demonstrate to higher authorities that the institution
was innovative and adopting international best practice.
The institution also established a special education service for children
with disabilities in state care and the community in 2005. The school
came under the direction of the local education authority, with the effect
that it could enhance the school facilities by pooling education resources
from various sources. Securing recognition for these services from the
Education Bureau had a multiplier effect on its standing in local govern-
ment. Other departments such as the Health Bureau and the Disabled
Persons’ Federation increased their annual financial support for the
special education to children with disabilities at the school. The school
enjoyed the same status as other education authority schools. In this way,
the mixed welfare institution extended its accountability horizontally
and gained wider legitimacy. In 2006, the institution also established a
child rehabilitation training centre for over 40 children with autism or
other disabilities to provide individualised special education and rehabili-
tation services, and training and support to their parents. These commu-
nity integration initiatives of the institution were unusual because they
leveraged funding from bureaux beyond the usual Civil Affairs Bureau’s
responsibility for children who were state wards in the institution. In this
way, the mixed welfare institution broadened the scope of its accounta-
bility and legitimacy to the wider community.
The two initiatives of partnering with multiple international organi-
sations and operating services that are available to children in state care
and others who lived with their families in the community broadened the
accountability requirements of the institution because of the variety of
people and organisations contributing funds and involved in its activities.
The next sections explore these accountability changes to examine the
impact on the legitimacy of the institution.
Accountability to Government
The primary accountability of the institution remained with the gov-
ernment because it was state operated and predominantly government
funded. It was affiliated to the Municipal Civil Affairs Bureau and fol-
lowed the policy requirements of the Department of Social Welfare and
Social Affairs under the Bureau. The broader funding base from other
government bureaux, international cooperation, and fee-based services

to the public also positively affected its relationships with other gov-
ernment bureaux such as Civil Affairs, Health, and Education and the
Disabled Persons’ Federation.
The institution was expected to meet government accountability
standards by fulfilling the requirements in the relevant government laws,
regulations, and policies; completing the tasks assigned by higher lev-
els of government; and implementing the instructions from higher level
Communist Party committees. The processes for fulfilling accountability
were to submit work reports; be evaluated by the Civil Affairs Bureau;
and have higher level officials’ performance evaluated by the organisa-
tional department of the municipal government. The performance of
cadres in China is assessed through the cadre appraisal system, which sets
targets for particular tasks such as ensuring social stability or economic
development. Social welfare is not a veto or mandatory target but still
it bears some weight in that it could be seen as a counterforce to social
instability (Zhao 2010; Zhou 2007).
Professional accountability was expected against the national standards
for child welfare services, including organisational standards and tech-
nical standards. The Basic Standards for Child Welfare Institutions 2001
define the mission of child welfare institutions; establish the minimum
standards for categorised services covering nutrition, nursing, rehabili-
tation, mental health, and education; stipulate the detailed management
protocols for institutional certificates, human resources, and regulatory
system development; and define the minimum requirements for the facil-
ities of welfare institutions.
The institution was required to meet government accountability
standards about child welfare outcomes, staff performance, and finan-
cial management. Welfare institution standards reflect the basic functions
of welfare institutions in the interests of children’s development. The
primary responsibility of the institution was to comply with its policy
obligations to provide welfare support to children in state care. If such
obligations were not met, the supervising government agencies could
impose constraints, including replacing the leadership of the institution.
These basic standards require a welfare institution to have departments
of education, rehabilitation, and social work; departments for different
age groups; staffing and professional mix for each department for the
four functions of child welfare institutions, namely health, nursing, reha-
bilitation, and education. The statements of the officials responsible for
the mixed welfare institution and the service portfolio reported that the
management and operation of the institution reflected this child develop-
ment orientation of a welfare institution.
The institution was obliged to be accountable not only to the govern-
ment, but also to the CCP. The Party’s ideology was conveyed through
education and training to its officials and staff members, including politi-
cal ideology, enhancing loyalty to the Party, country, and institution, and
their commitment to the civil affairs and welfare sector. Accountability
to the Party was also enacted by aligning the priorities of the institu-
tion with the current priorities of the Communist Party Committee at
higher levels, such as conducting operations with integrity and with-
out corruption. To illustrate, the mixed welfare institution had poli-
cies and associated training about how to conduct its activities, such as
the Provisions on the Development of Ethical Integrity of the Welfare
Institution, Provisions on Accountability for Democratic Evaluation
of Moral Conduct, and the Measures for Information Publicity of the
Welfare Institution. The policies were intended to enhance the social
reputation of the institution by demonstrating an obligation to the pub-
lic and government for moral integrity, a claim for which it could then
be held to account.
Given the requirement for state welfare institutions to comply with
political accountability, it is not surprising that any tightening of the
political climate affects the behaviour of state officials. Since Xi Jinping
came to office in 2012, there has been a comprehensive and enduring
anti-corruption campaign as well as a crackdown on groups perceived as
potentially destabilising for the regime. Such a climate is likely to have a
strong effect on a state-run institution where high-level leaders are sub-
ject to greater scrutiny and to the cadre appraisal system. The effects of
this political environment also affected our research as we were not able
to update materials for this particular case-study.
Performance evaluation indicators defined by government strongly influ-
enced the priorities of the institution at the risk of neglecting areas of work
not covered by the indicators. For example, the government work perfor-
mance evaluation was mostly centred on quantitative reviews. These crite-
ria gave the institution incentives to prioritise the volume of adoptions and
treatments, rather than quality or individual need. Yet the outcomes for
many services, such as education and therapy for children with disabilities,
can only be observed over a long period and assessed qualitatively. Since the
indicators were not defined qualitatively to evaluate performance in these
areas over time, the institution had no incentive to prioritise these more dif-
ficult, expensive areas of work.
The management directions from the Department of Social Welfare
and Social Affairs under the Municipal Civil Affairs Bureau only focused
on general policy for the institution. In practice, the management could
not stringently apply all the policies due to staffing constraints, so it
stated it was forced to “choose to implement selected policies”. In this
case, the Department of Social Welfare and Social Affairs could not
force the institution to fulfil its obligations. All officials in the institution
were theoretically subject to monitoring and evaluation by the munic-
ipal Organisation Department that supervised all government leaders,
but their performance was not evaluated in detail because there were too
many officials. In practice, only the director and the secretary general of
the welfare institution received regular performance evaluation. In these
circumstances, poor performance by other officials usually went unno-
ticed and had no consequences for their own positions, which dimin-
ished their motivation to ensure accountability. From our wider research
on state child welfare organisations across China, it was clear that the sit-
uation described here reflected a more general pattern. State institutions
were thus weakly accountable with potential consequences for the quality
of services delivered and the legitimacy of state institutions as efficient,
ethical, and professional bodies.
In general, accountability of public welfare institutions affiliated to
civil affairs departments could afford to be lax, remaining unmotivated
to achieve the highest standards of service quality. The combination of
limited opportunities for the government to demand greater account-
ability; weak or no demand from other stakeholders for accountability;
and a weak voice from children in state care poses the risk that welfare
institutions can ignore demands to improve the quality of their services.
In China, welfare institutions have limited opportunities to communi-
cate and negotiate with their sponsoring agencies, because they have no
direct representation in the National People’s Congress (NPC) or the
CPPCC. It is difficult for them to communicate their needs to higher
levels of government or articulate how some policies are inappropri-
ate for local situations. As a result, some welfare institutions choose to
implement only selected policies to manage within their restricted finan-
cial circumstances.
Whilst the monitoring and evaluation of staff applied only to top
leaders in the mixed welfare institution, with regards to accountability
relating to basic standards the institution had less trouble complying. In

practice, the institution fulfilled these requirements and more by extend-
ing the activities and funding base to meet the additional expectations
of support to children in state care and other children in the local com-
munity. The mixed welfare institution also proactively sought reform
to the organisational structure beyond the basic standards to improve
children’s welfare, appealing to higher level authorities for additional
funding. Some of these initiatives were enabled by funds from cen-
tral government, such as remedial surgery for 42 children with disabil-
ities (MOCA and Ministry of Health, Tomorrow Initiative for Surgery
and Rehabilitation of Disabled Orphans, 2004). Again in 2006, the
MOCA funded the construction of a special education building (RMB
12,100,000—UK£1.4 million). Similarly, in 2008, the MOCA funded
the institution to be the post-operative rehabilitation training centre for
children with cerebral palsy in the province.
The third government accountability for a state welfare institution was
for its finances. This assumed even greater importance than previously
as higher levels of government had encouraged welfare institutions to
broaden their sources of finance. To the extent that child welfare insti-
tutions were able to diversify their sources of funding and become mixed
welfare institutions, they also became accountable to new actors with
new demands for accountability.
Under pressure from higher levels of the civil affairs department to
diversify its sources of funding and prioritise economic benefits, the
mixed welfare institution strove to seek independent sources of fund-
ing and put in place financial regulatory systems to meet this require-
ment. Leveraging its legal status to attract international donor support
and increasing its visibility in the community were key accountability
processes for building its stock of accountability capital and extending
its legitimacy. The institution managed to increase its income annually,
although the increase seemed to have reached a plateau by the early
2000s (Fig. 7.3).
From 1994, the institution was required to implement a manage-
ment system based on achieving defined targets and economic indica-
tors, under the Terms of Reference for Objective-based Management
from the Civil Affairs Bureau. Within the institution, each of the

$PRXQW50%

<HDU
Fig. 7.3 Annual income generated by the welfare institution (Source Annual

work reports of Mixed Municipal Welfare Institution 2001–2009)
departments, offices, and care sections were also directed to achieve

defined work objectives. For example, the 2001 agreement for economic
objective-based management system stated that, “The annual target for
economic indicators for the institution throughout the year is RMB
960,000 [UK£111,000], and the monthly target is RMB 80,000”, and
these targets were broken down for assignment to each care section.
In order to achieve the targets laid down in 1994, the mixed welfare
institution issued a document in 1995 entitled “Strengthening Capacity
in Opening-up, Promoting the Development of the Welfare Sector”.
This proposed income-generating options, including income from paid
adoption, welfare businesses, tertiary industry, lease of unused space to
other businesses, and reinforcement of self-developing capacity. In fact
few of the fund-raising initiatives were successful, as reflected in the 2008
work summary report that stated that, “The income targets defined by
the department at higher level [municipal Civil Affairs Bureau] for the
institution have not been achieved, and the gap is huge”. Additional
income was only generated from the release of state-owned real estate
and fees for services for the care of older people. Though the department
of welfare institution services in the mixed welfare institution had very
limited capacity to generate income and did not achieve the targets, it
was able, nevertheless, to raise small donations from the public, develop
international partnerships and earn fees through newly established
community-based children’s services. The director was able to persuade

the local education authority to approve the operation of a community
school, which was otherwise very difficult to obtain.
Under pressure from above to generate alternative sources of funding,
the mixed welfare institution had to ensure that financial accountability
was observed. The first means for achieving this was to train staff and
strengthen accountability via moral self-discipline. The moral education
of staff aimed to address behaviours that might lead to corruption, par-
ticularly highlighting the responsibilities of officials. Some departments
and offices of the institution were likely to be more susceptible to brib-
ery, such as adoption management, office staff relocation, funds manage-
ment, and infrastructure maintenance. These departments were all at risk
of corruption as they involved staffing, use of funds, adoption of young
children, and project outsourcing. The institution formulated detailed
provisions to regulate these areas of work to manage the risks. The offi-
cials themselves attempted to model integrity as an example to other
staff, such as refusing invitations and bribes from families wanting to
adopt and from construction business owners. In these ways, the mixed
welfare institution bolstered its moral standing, providing a stronger
basis from which it could seek funding through other means and demon-
strate accountability for this.
The second means to manage financial accountability was to estab-
lish a tiered financial approval system. For example, procurement proce-
dures for equipment worth more than RMB 1,000 were in place; audit
reports for maintenance and infrastructure projects worth more than
RMB 2,000 were needed; and top management approval for major pro-
jects and large expenditures was required. The mixed welfare institution
stated that it complied with financial regulations, but it could not fulfil
all financial registration practices. For example, a work report noted that
it did not separately list the incomes generated from donations as per
the provisions in the Law on Donations to Public Benefit Undertakings
1999 and the government department had not formulated measures to
regulate such practices. To address these shortcomings, it committed in
its reporting to standardise in future its financial procedures.
Financial Accountability to International Partners

The one financial success for the child welfare services was international
partnerships, which generated contributions towards facilities, resources,
and staff training, as discussed earlier. These new partnerships brought
with them an array of accountability demands, varying in their reporting

requirements and deadlines. Nevertheless, they all prioritised financial
and managerial accountability. The institution reported its service provi-
sion and financial expenditures to the partners to demonstrate that it had
achieved the goals of the projects and attained the quality expected to
improve the children’s welfare.
Of the five international partners, World Vision granted the most
funds and had the most stringent accountability requirements. For exam-
ple, the facilitative education centre project developed by the institution
with World Vision funds, included weekly visits and quarterly financial
reviews by World Vision, quarterly meetings with the institution man-
agers, year-end meetings, and annual evaluations. If the institution
failed any review, it repeated the review after the problem was rectified.
Accountability led to responsiveness and improved the delivery of ser-
vices, results which added to the mixed welfare institution’s stock of
accountability and helped to widen its claims to legitimacy. Sometimes
multiple regional offices of World Vision conducted cross-reviews of the
projects to ensure the quality of the evaluation. Similarly, Half the Sky
Foundation seconded consultants to the institution to advise, monitor,
assist, and communicate with the institution staff on site. Accountability
for the cooperation with Holt and Grace and Hope for Children was less
involved, where the institution merely demonstrated that the earmarked
funds were used for the specified purposes only.
Despite having to deal with the additional bureaucracy and new
accountability demands required from multiple international donors,
officials at the mixed welfare institution stated that these accountabil-
ity processes were constructive because they brought them into a closer
relationship with the donors to achieve the contractual goals in return
for contributions. The participation of the international partners added
to the quality of the welfare services because they became close advis-
ers, contributing international knowledge about good practice both in
relation to accountability processes and to child welfare. Meeting the
accountability demands of the partners also served the direct purpose of
building their stock of accountability capital to secure continued funding
support.
However, shortfalls in meeting the accountability requirements were
also evident due to structural constraints in the partnership. The mixed
welfare institution needed the partners for financial viability. However,
the partners also needed the Institution in that the successful imple-
mentation of projects justified their own continued presence and
partnerships. This ran the risk that the quality of the evaluations could
be compromised in the short term. The fact that the partnerships were
based on mutual benefit and co-existence, indeed a mutual depend-
ency, meant the partners would be unwilling to withdraw their fund-
ing support or terminate the co-operation to constrain the institution’s
practices. This gap in accountability applied equally to the institution’s
relations with various government departments, sometimes undermining
the effectiveness of the accountability.
Managerial Accountability to Staff

Accountability of the institution from and towards staff took place
through the internal governance of the welfare institution. The mutuality
of this accountability arose because staff could only attain quality service
levels if the institution provided them with the organisational support
to do so. The institution stated it was constantly enhancing its organisa-
tional structures to be accountable to its staff for the conditions in which
they could provide good quality services. The practices revealed that
mutual accountability between the institution and staff was a constant
struggle between preferred policies and compromised practices. Evidence
of a positive impact of mixed funding on strengthening this dimension
was weak, although over time the more accountable performance of con-
tracted staff could potentially raise standards.
The institution’s accountability to staff was articulated through its
internal processes, including the procedures, regulations, training, wel-
fare, and performance evaluation for its staff. Its goal was to become a
national level 2 welfare institution, which means that it would receive
more funding and staff to provide a higher standard of services.
Internally it had regulations defined for each area of work and accessible
to the staff, such as the Work Regulations and the Terms of Reference
for Objective-based Management of Posts at Departments/Offices, with
detailed provisions for health care, inspection of wards, sanitation, nurs-
ing practices, financial management, foreign affairs management, and
safety management. Implementation of the regulations was allocated
through defined responsibilities for each position. Attendance and work
performance of each staff member was evaluated through a monthly
100-point evaluation system. Staff achieving full marks were rewarded
and those who violated the regulations were punished financially, as an
incentive to observe the regulations.
The complementary aspect of staff performance evaluation was an

institutional commitment to the training of and welfare benefits for the
staff to enhance their capacity for good service quality. For example,
the institution paid for staff to participate in professional training at city
or higher levels, covering professional nursing skills, knowledge about
health and HIV/AIDS prevention. It also paid for training and qualifica-
tions for disability social workers and other examinations for professional
workers, medical practitioners, or nurse certification. By bolstering the
professional capabilities of the staff, the mixed welfare institution could
demonstrate to potential donors that it was a professional institution,
could enhance its legitimacy and secure further funding.
The institution also attempted to secure welfare benefits for the staff.
As exemplified in its 2004 annual report, it invested in the construction
of an apartment building for 18 households, assisted a further 12 house-
holds with securing accommodation, organised activities for the children
of staff and retired staff, granted awards to staff’s children who were
admitted to university, and improved the allowances staff received for
medical expenses, including retired and casual staff.
The institution relied on staff performance evaluation and training
to achieve quality standards, but bureaucratic procedures and the legacy
of past behaviours and practices limited the effectiveness of such meas-
ures. The first issue was that senior institution officials were appointed
by the provincial Civil Affairs Bureau. This process of appointment ran
the risk that the top officials may not have chosen to work in the insti-
tution, so could lack a vision, passion, and commitment to improving
the quality of child welfare. The second issue was that permanent staff
were often unmotivated despite the evaluation and training. They knew
that it was highly unlikely that they would ever be dismissed or their
benefits downgraded, irrespective of the quality of their performance.
Moreover, although the performance system applied to permanent staff,
most staff were rotated between positions, so the system was not rigor-
ously implemented. Bureaucratic processes were insufficient for changing
staff behaviour. This inertia related to wider issues of public institutional
reform in China such as the practice of “waiting, reliance and request-
ing”. This common phrase captures how institutions did not actively
deal with the problems they faced, rather they waited for and relied on
decisions made by higher authorities and requested more resources to
deal with it, rather than taking the initiative to improve performance.
Shifting behaviour clearly needed more than bureaucratic directives;
strengthening systems of accountability to parents and children and

using advocates for children could have put additional pressure on staff
to improve performance.
In response to the ongoing quality problems, in 2010, the mixed wel-
fare institution attempted to improve its image in the community with an
ethics improvement campaign in which,
Departments and offices of the institution corrected some of the improper

practices in work, e.g. absence from post, being late for work or leaving
the post prematurely, and doing things not relevant to the job, in order to
avoid bad experiences for the clients.
Such a campaign was a way of demonstrating commitment to improving

practice so as to instil community confidence in services and expand the
clientele of fee-paying service users. Mixed funding put added pressure
on the institution as contracted staff were seen to be more accountable
to the institution and users than the permanent staff. The ethics cam-
paign was a way of demonstrating reflexive accountability to the local
community, adding to the institution’s stock of second-order accounta-
bility to enhance its wider legitimacy in the community.
Accountability to Children and the Community

The primary purpose of the child welfare part of the institution was to
care for children who were state wards, enhancing their quality of life.
The legitimacy claims were articulated in its mission statement: “Helping
the country and the people to address the difficulties”. Accountability
to these service users was the dimension with the greatest potential for
change as a mixed welfare institution because the new community ben-
eficiaries of the services were more likely to have different expectations
and capacity to demand change. Historically, the only users of the child
welfare services had been orphaned children and other children with dis-
abilities without known family members. Their dependence on the insti-
tution for the entirety of their livelihood meant it was highly unlikely
that they would have the capacity or willingness to demand greater
accountability. They relied on the responsibility and advocacy of the staff
and perhaps visitors to focus on their needs or voice their interests.
However, accountability to the children was sometimes in ten-
sion with accountability to the government. For example, when the
institution was required to concentrate on broadening its financial

sources in the 1990s, it prioritised the provision of fee-paying services for
the care of older people and other income-generating activities, instead
of child welfare services. In the short term, this was to address the finan-
cial constraints on the institution. However, children in care were the
most disadvantaged and their voices are the least heard. The mixed wel-
fare institution was the guardian of the children and the children’s only
advocate. The fee-raising issue pushed it to prioritise older people, where
there were greater opportunities because of the demographic shift to an
ageing population for raising more money than for children. Responding
to government requests to fund-raise took precedence over meeting chil-
dren’s needs more widely.
In order to enhance its reputation and accountability in the commu-
nity, the mixed welfare institution established a public information sys-
tem in the 1990s, making its operations more transparent. In its 1995
self-evaluation report, it stated that it,
… revised the Work Regulations and Staff Responsibilities of Mixed

Municipal Welfare Institution; posted Mixed Municipal Welfare Institution
Regulations on Open Service Provision on the walls of relevant depart-
ments/offices and all care sections, with the photos and names of service
personnel exhibited, the ‘service comment box’ placed nearby, and work
cards worn by service providers; in this way the regulations, protocols and
scope of service provision, clients, requirements, rules, supervisors, tele-
phone numbers, service staff, and ‘service comment box’ are made pub-
lic, in order to voluntarily receive monitoring by service clients, families
and various social actors. The services and responsibilities are broken down
to the individual posts and staff members through the stringent system of
post responsibility, and therefore the objective-based, effectively monitored
work mechanism has been established.
In this way, the mixed welfare institution opened itself up to wider

accountability by establishing a service comment box, making trans-
parent the duties and obligations of staff and making public the names
and photos of staff. These yielded accountability inputs that added to its
stock of accountability and could be used to justify its claims to legit-
imacy. By enhancing its transparency and making itself more visible to
the community, the mixed welfare institution could build public confi-
dence in its activities. This placed new accountability demands upon it
as parents and children in the community who paid fees became new
principals, who could hold the agent of the mixed welfare institution to
account. With the introduction of community-based services, the chil-
dren and their parents in the community potentially had greater advo-
cacy capacity to voice the children’s interests. The community parents
paying fees for their children to attend the school, kindergarten, and
disability services at the institution had the right to give feedback or to
raise complaints about the service quality. Nevertheless, in practice, the
director informed us that parents did not take up this opportunity and as
a result they had not received any feedback. The reasons for the lack of
uptake are unclear but may have reflected a more general apathy towards
feedback, particularly given that the issues of bureaucratic procedural
constraints and the difficulties in changing staff behaviour already men-
tioned. It probably also reflected a culture of deference to authority and
expertise and a sufficient degree of satisfaction with the services.
In contrast to the parents, the international partner organisations were
more likely to have had the capacity to advocate from the perspective of
child welfare, and to demand accountability on behalf of the children.
In seeking accountability for their funding contributions, they could also
scrutinise aspects of the children’s care and thus mitigate the problems of
asymmetric information that parents faced, despite some efforts by the
mixed welfare institution to become more transparent. Seeking improve-
ments in the children’s quality of life was part of their mission and they
had fewer conflicts of interest than government funders.
The shift towards community services meant that the mixed welfare
institution faced new demands for accountability from the local commu-
nity and new service users. Providing community services, including the
kindergarten, special needs education, disability therapy and rehabilita-
tion, enabled children to remain in their families, reducing the risk that
they became abandoned to state care in order to access the support they
need. Community services created opportunities for social integration of
the children in state care, and also for additional income from fees. With
a wider social policy lens, it demonstrated a stronger sense of accounta-
bility of the institution to the welfare of children in their local commu-
nity by also addressing prevention and early intervention for children so
that they remained in the care of their own families. In this way, it ena-
bled the mixed welfare institution to accumulate further accountability
capital and strengthen its legitimacy.
However, the steps of the mixed welfare institution towards greater
transparency applied to fee-paying service users in the community.
The general public still knew very little about the institution’s responsi-
bility to care for state wards. As the institution and other levels of gov-
ernment were keen to avoid encouraging parents to abandon children,
they had a policy of not publicising their services for state wards. This
was particularly the case after the national scandal in 2013 concerning
the case of seven children in informal care who died in the fire, referred
to in Chapter 1. The fire had aroused global concern about whether
state institutions were condoning the activities of informal carers and
NGOs that were caring for children without parents. The public discus-
sion about institutions compromising their formal guardianship role of
these children meant the local government and the mixed welfare insti-
tution became more cautious about publicising their state ward activities.
Greater transparency may have created the possibility for accountability
by fee-paying service users but had not altered the status quo for build-
ing wider accountability for state wards.
Conclusion
This chapter demonstrated how accountability and legitimacy changed
with a shift towards mixed funding of a public institution. The broader
income sources introduced new situations where a wider range of
funders and service users had the potential to scrutinise the activities
of the institution. Government institutions, too, had to develop sec-
ond-order accountability capital to bolster their reputation and legit-
imacy amongst new funders, community providers, and the general
public in order to generate new non-governmental sources of income.
This included informal accountability processes, such as making their
activities more visible to the public, enhancing transparency, emphasising
the moral purpose of the institution as well as revising formal systems of
accountability to provide incentives to staff and establishing channels of
feedback for users to hold staff to account.
Accountability for the mixed welfare institution had become multi-
dimensional. Accountability was no longer just vertical and downwards
from higher levels of government or within the operational bureaucracy
of the institution. The need to diversify funding increased the range of
people and organisations to which the mixed welfare institution was
obliged to provide accountability. Opening up to the local community
widened the scope of accountability to families and children. Providing
inclusive services to children in the community exposed the institution
to greater scrutiny. Working with other government authorities called

for horizontal accountability and engagement with international part-
ner organisations brought with it downward accountability outside the
government system. International partnerships also built accountability
capacity, where donors expected participatory accountability and gave
advice on quality services and management standards.
Compared to child welfare NGOs, the mixed welfare institution
started off in a more privileged position, where it enjoyed legal legiti-
macy. This legitimacy set in motion certain financial and professional
accountability requirements. It gained further legitimacy as it extended
its work to involve other government departments such as the educa-
tion and health authorities, the disabled person’s federation and families
in the community. However, compared to child welfare NGOs, it lacked
the drive of a charismatic leader and the objective necessity of raising
funds to effectively accumulate second-order accountability capital.
Differences in power relations between multiple account-holders
meant that accountability to government and international partners
took precedence. Financial and organisational accountability was privi-
leged over other forms of accountability, even though other dimensions
of accountability had been introduced. Moreover, higher level pres-
sure to raise funds prioritised easier targets such as care for older people
over children with disabilities. Attention to financial and organisational
accountability was at the expense of downward accountability to parents
and children. Issues around deference and social attitudes towards the
ability of children, and particularly those with disabilities, to articulate
their demands and needs also fed into this hierarchy. Gains for users’
rights were that the international donors expected participatory processes
to be established. However, there was a mutual dependency between
international partners and the receiving organisation that worked to
weaken the enforcement of accountability. Accountability was also com-
promised because of the continuing difficulty in motivating changes in
staff performance.
Since the passing of the Foreign NGOs Law in 2016, the effects of
the new regulations governing the operations of international NGOs
have yet to be clearly seen. As stated in Chapter 3, early signs are that
it is becoming harder for foreign NGOs to operate in China, though
for the reasons given above, it was not possible to gauge the impact
on this mixed welfare institution. Given that this case-study illustrates
the benefits to institutions in having close professional advice through
international organisations and exposure to international best practice, it

is of some concern that the mixed welfare institution may not so easily be
able to avail itself of such professional support. Furthermore, as cooper-
ation with international organisations brought with it new accountabil-
ity demands and exposure to accountability practice in other countries,
it remains to be seen whether these new accountability practices will
become more firmly embedded in the institution. Though the power
relations between donors and the recipient institution shaped the direc-
tion of accountability, the relations were not a zero-sum game. In any
case given that the mutual dependency between the mixed welfare insti-
tution and international donors weakened enforcement of accountabil-
ity, it cannot be assumed that these newer accountability processes will
remain in place if the donors can no longer co-operate with the mixed
welfare institution.
Notes
1. The name of the institution and province have been removed to protect
confidentiality. Instead, we refer to it as the mixed welfare institution.
2. The descriptions of the cooperative projects are adapted from the mixed
welfare institution website.
References
Shang, X. (2008). The System of Social Protection for Vulnerable Children in
China. Beijing: China Social Sciences Academic Press (Chinese).
Zhao, H. (2010). Criteria for appraising local governments performance in
China. Journal of Nanjing Normal University (Social Science), 6, 17–23.
Zhou, L. (2007). Governing China’s local officials: An analysis of promotion
tournament model. Economic Research, 7, 36–50.
CHAPTER 8
Conclusion
The story of the Wang family with which we opened this book
highlighted the efforts of parents in China to address the yawning wel-
fare service gap for disadvantaged children. In doing so they faced a
mountain of obstacles and constraints, ranging from the difficulties of
registering as a non-governmental organisation (NGO), to raising funds,
building an organisation, developing professional expertise, and gaining
public confidence. Living in a post-socialist authoritarian state, where
government suspicion of independent citizen organising prevailed and
where public understanding of non-governmental welfare groups was
limited, made their efforts even more difficult. As for other non-gov-
ernmental groups, acquiring legal status proved almost impossible. The
changes in registration requirements in 2013 reduced somewhat the bar-
riers to registration but still posed a formidable obstacle. In this context
crafting accountability and legitimacy through other means was crucial to
their growth, expansion, and sustainability. Despite these obstacles and
constraints some NGOs have survived for over 30 years in the interstices
of legality, Liming Family being a case-in-point.
Though China, like many other authoritarian states, is mov-
ing towards a mixed welfare system, allowing NGOs to expand is not
without risks from the perspective of the Party/state. The civil society
dilemma, as for most authoritarian states, is how to foster a service-ori-
ented non-governmental stratum of providers without increasing the risk
that this creates an opening for rights-based groups, advocates of policy
change, and political opposition to flourish, a development that such a

https://doi.org/10.1007/978-3-319-90221-0_8
state would likely perceive as regime-threatening. Managing this tension

between the risks of social instability and the development of a mixed
welfare system where non-governmental actors play an increasing role in
service delivery has shaped the interactions between the state and NGOs
and in particular the crafting of accountability and legitimacy. Welfarist
incorporation is a strategy deployed by the Party/state to take instru-
mental advantage of the potentially beneficial dimensions of civil society
whilst reducing the perceived risks of social instability and regime threat
that a more diverse, engaged civil society might entail.
Whilst numerous studies have documented the strategies and tactics
used by civil society organisations, including NGOs, to resist repression
and surveillance, very few have explored the role that accountability
and legitimacy play in enabling the survival, development, and growth
of NGOs. This book thus set out to examine the politics of how ser-
vice-provision NGOs in authoritarian states craft accountability and legit-
imacy to ensure their organisational development and survival. In doing
so, it argued that NGOs had developed a ‘second-order accountability’,
accumulating stocks of accountability capital, as a means to build their
accountability and legitimacy. Our goal here was not to evaluate the
implementation and effectiveness of accountability processes in NGOs
but rather to understand the tensions that emerged in shaping the types
of accountability that came to prevail.
Several key questions guided this research. First, what combination
of accountability capital did NGOs draw upon to build second-order
accountability? Second, what hierarchy of accountabilities did this cre-
ate and how did this in turn affect user participation? Third, what kind
of politics informed processes of accountability-making in post-social-
ist authoritarian states? How did NGOs navigate their relations with
the state and public, how did social biases against disadvantaged chil-
dren affect the hierarchies of accountability, and how did state pro-
cesses of institutional change affect the prospects for child welfare
NGOs?
We explored these questions through the lens of four child welfare
organisations, three of which were NGOs and one of which was a state
organisation under pressure to diversify funding sources. In all cases,
the organisations were facing multiple accountability demands, which
required them to strengthen and demonstrate their accountability and
legitimacy and pushed them towards prioritising some dimensions of
8 CONCLUSION 189
accountability over others. These four case-studies provide the first tex-
tured and granular analysis of processes of accountability-making and
legitimacy in child welfare organisations in an authoritarian state, and
China specifically. Each case-study exemplified in different ways the strat-
egies that were adopted by NGOs to build accountability and legitimacy
to ensure survival and the importance of building second-order account-
ability in a context where legal status was difficult to achieve, and where
public trust in NGOs was weak. Though these processes were more
developed in the four case-studies presented here, they were also evident
in our broader sample of NGOs that we investigated.
The case-studies represented different types of child welfare organisa-
tions: Liming Family exemplified the constraints and challenges facing a
religious organisation providing services to children and its determined
efforts to gain legal status that would enable it to offer citizen rights
to its orphaned children. It was also a good example of a child welfare
organisation that promoted professionalism and established a nation-
wide network for sharing experiences, knowledge, and promotion of
child welfare as a professional enterprise. Angel House was distinct from
Liming Family and Children’s Hope Foundation in that it was founded
and run by the parents of children with cerebral palsy. Its proximity to
its beneficiaries was thus closer than other child welfare organisations
that worked ‘on behalf of’ children with cerebral palsy. The incentives
to hold the organisation to account were thus stronger. Moreover, as the
degree of user participation was greater than in the other organisations,
subtle, informal methods of accountability propped up the more formal,
institutionalised processes. The third case, Children’s Hope Foundation,
illustrated the complex changes in accountability in transiting from a

hybrid quasi-governmental/quasi-non-governmental and quasi-inter-
national/quasi-domestic organisation to an independent, domestic,
non-governmental child welfare foundation. The last case of a mixed
child welfare organisation represented the increasingly common position
of state organisations that must now raise funds from public and pri-
vate sources to sustain and develop their activities. As a result, the mixed
welfare institution faced new multiple accountabilities that required it
also to build second-order accountability to its new funders and service
users. The choice of these four cases and the priority focus in the anal-
ysis were informed by the fieldwork data in the other organisations we
researched.
Key Findings
What then were there key findings from our in-depth, granular study?
These relate to the combination of accountability capital that NGOs
accumulate to gain and maintain legitimacy, the hierarchies of account-
ability that these lead to and the politics around the process of account-
ability-making and the importance of context and institutional change.
Accumulating Stocks of Accountability Capital

All three NGOs and the mixed child welfare institution facing multiple
accountabilities gradually accumulated a stock of formal and informal
accountability capital that could be leveraged to justify their claims to
legitimacy. These stocks were constantly being built upon and re-made
to ensure the maintenance of legitimacy. These inputs included vari-
ous combinations of media support, developing professional expertise,
moral standing, government awards, visits by higher-level governments
as examples of best available practice, development of websites detailing
goals, programmes, activities, and results and transparency of informa-
tion. These inputs addressed asymmetries of information that weakened
voice for users and individual donors and tackled government and pub-
lic distrust. Children’s Hope Foundation, for example, drew media
attention to enhance its public visibility and boost public confidence. It
utilised connections with international organisations to develop profes-
sional expertise and capitalised on personal relations to bolster funding.
Similarly, Liming Family developed a website with information about
its aims, finances, operations, sought positive media coverage, received
government delegations, made efforts to improve its professional exper-
tise, and drew the community around it into the broader sustenance of
their activities. It exposed the community, local government officials,
and potential funders to its work through transparency and openness
and performative acts of good practice. Angel House emphasised the
importance of building a reputation for caring and professionalism. Like
Liming Family, it had adopted a range of strategies to build the organ-
isation, attract funders and support, expand the number of users, and
create a reputation for itself as a professional child welfare organisation.
Values, such as love and care, gave the NGOs moral standing for which
they could be held to account. The mixed state child welfare institution
was also exposed to a similar need to accumulate accountability capital
8 CONCLUSION 191
as it accepted funding from international organisations for new types of

care and extended its reach by providing fee-based services to children
living with their families in the community. Each of these new directions
meant that it had to account for its finances and service quality to a range
of other government departments, NGOs, and members of the public,
learn new ways of making accountability and adapt existing formal proce-
dures for ensuring staff accountability in the NGOs.
These second-order sources of informal accountability were com-
plemented by the gradual establishment of internal formal systems of
accountability such as boards of trustees, reporting processes to inter-
national donors, rules for the recruitment, development and promo-
tion of staff along with clear job descriptions that strengthened the links
between performance and reward and created a basis for accountability.
Angel House, for example, accumulated a stock of accountability capi-
tal including both formal and informal accountability. It created formal
structures of organisational and financial accountability, including audit
reports and regular reports to donors. It also built up informal stocks
of accountability by developing the professional expertise of its staff
through training and access to international knowledge, getting publicity
for the organisation through use of the media, and emphasising its scien-
tific and caring approach.
Furthermore, in parallel to developing second-order accountability,
some NGOs continued to try to register with the Civil Affairs Bureau.
During its 30 years of existence in a legal limbo, Liming Family persisted
in trying to register as a social organisation to obtain legal status that
would enable children to gain citizenship and access certain state ben-
efits. Angel House, too, courted government in various ways to offer up
accountability, hoping to ensure continuing tolerance, if not support,
for its work, maintain and build its reputation, and guard against a situ-
ation where its registration as a non-profit enterprise might be revoked.
Children’s Hope Foundation and the Mixed Child Welfare Institution
did not struggle with registration because they were both integrated with
state functions. The welfare institution was a state organisation under the
responsibility of Civil Affairs. It managed to use its legal status to extend its
activities that were the responsibilities of other government departments,
such as education, disability, and health. Children’s Hope Foundation’s
legal status was initially clear because it was an internal department in
Association B, and its leadership included state officials. However, once
the government no longer benefited financially from that relationship,
Children’s Hope Foundation found it pragmatic to re-establish itself as a

separate organisation.
In all four cases, whilst gaining legal status through registration might
have bolstered the credibility of any of the NGOs, legal accountabil-
ity was still insufficient to ensure multi-dimensional accountability that
could guarantee child welfare and best international practice, and give
greater weight to user perspectives.
Hierarchies of Accountability
The cases revealed how accountability-making processes led to the prev-
alence of certain hierarchies of accountability. In all cases, financial and
organisational accountability to international donors and government
funders was privileged over accountability to public donors, account-
ability to staff and carers, and accountability to the ultimate users of
services, namely, disadvantaged children and their families. This find-
ing confirms a broader tendency found in NGOs across the world for
financial and organisational accountability to international donors and
governments to prevail. By tracing the trajectory of accountability in
Children’s Hope Foundation as it changed institutional form, we were
able to demonstrate how funding agencies, be they the semi-government
organisation, Association B, or the international agency, Children’s Hope
International, put their stamp on the type of accountability processes
that developed in an organisation, echoing resource dependency analy-
ses of organisational development. Significantly, upward accountability
to the sponsoring agency or donor trumped any downward accounta-
bility to users or staff. Liming Family, a religious organisation, provided
upward accountability to the church but this type of accountability was
limited, too, in that it related primarily to the effective and efficient use
of funds. The mixed welfare institution prioritised financial accountabil-
ity to government, international organisations, and donors. It had some
processes in place for community families to provide feedback, although
the families had not taken up this opportunity, whether for reasons of
deference to authority, sufficient satisfaction, or low expectations of there
being any responsiveness to their demands.
Of course, introducing formal financial and organisational systems
of accountability was important for bolstering the credibility of organ-
isations. Such formal institutionalised arrangements were an important
step in building the longer term accountability of the organisations.
8 CONCLUSION 193
However, the bias towards upward accountability reflected the differ-

ential power relations, incentives, and leverage that different principals
had. The church and international donors were large scale, hierarchi-
cal organisations with operations straddled across the globe, operating
with tight budgetary frameworks. In demanding financial and manage-
rial accountability from their funding recipients, they were also driven by
pressures higher up the line to account for their programmes and pro-
jects within timelines that did not coincide with the slower processes of
participation and involvement of users. An interesting reversal in upward
accountability was the pressure that Liming Family put on government
officials when they did not take responsibility for orphaned children in
their jurisdiction. The government responded with a small offering of
resources, but would not concede to care for the children or to register
the organisation.
This process of upward accountability was valuable to the cases we
studied, as it demonstrated probity and accountability, which were vital
for gaining public and governmental confidence, attracting clients, and
building a reputation as a professional organisation. Sometimes this
upward transparency was at the expense of the privacy of the children,
such as revealing the details of the recipient children to the donors.
Hierarchy, professional expertise, and organisational autonomy are
important for running an effective organisation. However, the domi-
nance of upward accountability limited the voice and participation of
users in holding organisations to account and ultimately could have an
impact on efficiency and effectiveness.
Politics of Building Accountability and Legitimacy

The hierarchy of accountabilities that emerged was not inevitable; rather,
it reflected the differential relationships of power between those who
demanded account and those who were held to account. Institutional
and individual donors, for example, had the power to sanction an organ-
isation for any misuse of funds or inadequate performance by withdraw-
ing funding. However, institutional donors were better positioned to
demand accountability and sanction a recipient organisation than indi-
vidual donors. The threat of a withdrawal of funds was a strong incentive
for organisations to attend first to the accountability demands of donors,
especially institutional donors. As international NGOs had themselves
to provide account to taxpayers in their host countries, the pressure to
secure the effective and appropriate use of their funds was a key prior-
ity for their own development and sustainability and was an incentive
to press for accountability. The pressures of this were then passed on
to the organisations that received their funding. However, in all cases
there was the risk that mutual dependency between donors and part-
ner organisation could compromise the monitoring and enforcement of
accountability.
For individual donors, who were not answerable to higher-level
organisational authorities, the pressure on them to demand accountabil-
ity was much less than for international NGOs. Moreover, their ability
to do so was hindered through asymmetries of information as well as the
effects of an authoritarian culture where using voice can have political
costs. Nevertheless, it is important also to recognise there are different
types of donors and that for individual donors their trust in the organ-
isation and/or leaders may be sufficient for them to continue support
(Keating and Thrandardottir 2017). Similarly, service users faced greater
asymmetries of information than institutional donors and issues of def-
erence to authority were an added constraint on exercising demands for
accountability. Given the limited supply of child welfare organisations,
parents and children could not readily exit to alternative providers, thus
weakening their relative bargaining power.
The privileging of accountability to international donors was at the
expense of other dimensions of accountability such as internal demo-
cratic accountability between staff and management and accountability
to carers and users. This matters because a lack of downward account-
ability to staff could affect motivation and commitment and also create
distrust in the capabilities of higher levels. Similarly, a lack of account-
ability to carers and users could make the organisation less effective by
not utilising resources in the best away so as to ensure the concerns and
needs of carers and users are met. Liming Family, for example, had in
place both formal processes of accountability to the church and later
local government, as well as informal means of demonstrating account.
Yet, the process of accountability-building led to a biased hierarchy of
accountability dimensions. Vertical accountability to authorities, both
religious and governmental, was privileged over downward accountabil-
ity to staff and users, whether carers or children. Those with the least
power, the children who received the services, had no formal chan-
nels for expressing voice and instituting change in care arrangements.
Moreover, there were no accountability processes linking foster carers
8 CONCLUSION 195
with the state or church. Given that Liming Family had a monopoly
over services to orphaned children and children with disabilities and
families, users did not have the option of exiting to another provider,
making it thus even more important that the voice option should exist.
Fortunately, some of the international donors also demanded that the
child welfare organisations institute practices to encourage user partic-
ipation, such as in the case of the mixed welfare institution. However,
bureaucratic constraints and weak monitoring capacity affected staff
motivation to move in this direction.
The reasons for this lack of downward accountability is complex,
lying partly in cultural attitudes, social divisions, and pressures to enforce
accountability. The lack of accountability to children as users in all cases
reflects cultural attitudes around age, gender, expertise, and deference.
Weak professional accountability to carers and children is in part related
to cultural deference towards expertise, authority, and knowledge. The
lack of internal democratic accountability whereby staff could hold man-
agement and leaders to account reflects employment practices in China
where staff engagement in the running of organisations, be they state or
private firms or welfare institutions, are weak.
Though user participation and empowerment are part of policy and
academic discourse, external donors continued to prioritise the organi-
sational and financial aspects of accountability at the expense of user par-
ticipation. Such behaviour is not a mere matter of expediency and the
immediate practical needs of organisational development, nor of the
greater amenability of these accountabilities to measurement and quanti-
fication. There is not an underlying rationality to hierarchies of account-
ability dimensions. It reflects enduring social biases against citizens, in
general, and marginalised groups, in particular, having opportunities to
voice their concerns, participate in governance, and challenge established
social hierarchies around age, class, and professional expertise. The mak-
ing of accountability and legitimacy cannot thus be divorced from the
socio-political context in which they are constructed. In an authoritar-
ian state there is in general a broader lack of accountability, particularly
to less powerful groups, that is likely to be reproduced in new types of
organisations such as NGOs, unless there are powerful counter-forces
working to change entrenched cultural values such as a strong child
rights movement and youth movement.
Our research did suggest that an organisation founded by users was
more likely to have favourable conditions for providing account to its
users than an organisation working on behalf of a particular constitu-

ency. For example, there were likely to be fewer information asymmetries
and greater convergence between users and organisational goals. Angel
House provided an interesting case-study of a child welfare organi-
sation that was founded by, run by and supported by the users of the
services for children and youth with cerebral palsy, that is, in this case,
the parents. It also had the benefit of learning from participatory prac-
tices advocated by its international partners in Hong Kong. Compared
to other child welfare groups, parents were involved in the running and
activities of Angel House and could see through their regular participa-
tion the approach of the organisation to the beneficiaries, their children.
Through their everyday engagement users had greater opportunities to
informally exercise voice, provide feedback to the organisation, and seek
accountability.
Angel House provides an unusual example of an organisation that was
not only founded and run by the parents of children with cerebral palsy,
but also had a philosophical commitment to user participation. Unlike
other child welfare organisations, information about activities and price
structures were open for all to see. Furthermore, the organisation sought
to enhance parents’ understanding of the approaches to cerebral palsy
that they followed because they were recognised as international good
practice. They also taught parents how to apply these methods them-
selves, with parents able to use equipment and space outside of classes.
In this way they attempted to break down the sharp divisions between
professional expert and user, and between provider and user. Moreover,
by involving parents in the care of their children the organisation was
developing the capacity of parents not only to acquire relevant skills but
also to participate and exercise voice.
The politics of building accountability not only shaped the hierarchies
of accountability that emerged but also state-NGO interactions. Most
child welfare NGOs were unregistered and thus were at constant threat
of closure and subject to surveillance. Nevertheless, many have contin-
ued to exist and thrive over two or more decades, despite having no
legal registration status. This is in part because local government officials
observed that they were often addressing welfare needs that the state
could not or did not seek to deal with. Moreover, they provided a useful
source of information about citizens’ preferences, addressing the infor-
mation deficit that authoritarian regimes face. It was also in part because
of the tactics and strategies used by NGOs to court government officials
8 CONCLUSION 197
to recognise their work. NGOs had to tread a careful line between draw-
ing too much government attention that might ultimately work against
them as they were always vulnerable to closure, and attracting sufficient
attention from local officials to reassure them of their intentions and
even to solicit their support. As was seen in our case-studies the success-
ful child welfare NGOs were able to persuade local officials of the organ-
isation’s contribution to child welfare, sometimes garnering support
in kind, and earning legitimacy through government awards and high-
level delegation visits. This was equally the case with the mixed welfare
institution as it sought support from other government departments to
extend its activities to children living in the community.
Some NGOs such as Liming Family were skilful in deploying a range
of tactics that both courted state officials but also exposed the shortcom-
ings of state provision to justify their own interventions. As well as its
performative acts of demonstrating good practice and openness, Liming
Family also used tactics such as embarrassing the government around its
failure to meet the needs of all orphaned children and underlining thereby
its vital role in filling gaps. It also manoeuvred its way around rules gov-
erning entitlements to benefits so as to ensure that the children in its care
were not disadvantaged. These were clever politics of courting, exposure
and the navigation of rules to the benefit of disadvantaged children.
Though Angel House was registered as a people’s run non-profit
enterprise, it still had to work hard at maintaining and enhancing its
accountability and legitimacy as legal status could always be revoked.
Part of this involved ensuring that the local government continued to
tolerate its activities. To this end, it invited local government officials to
visit the organisation and maintained active links with the local Disabled
Persons’ Federation. Though the government could not provide Angel
House with any financial subsidies due to its non-governmental status,
it did provide some support through a small amount of funding at the
start, use of premises and governmental backing. This was not sufficient
to address broader societal issues of discrimination against people with
disabilities, which meant the House had to move location several times
before it could settle down. The government also expressed its sup-
port through symbolic gestures such as giving awards and honours to
the founder and visiting the House on Children’s Day. In this way, the
success of the Home in garnering informal governmental support had
a multiplier effect in building the confidence and trust of the donating
public and philanthropic entrepreneurs.
Institutional Change
As Pollitt and Hupe (2011) noted (see Chapter 2), the “magical” con-
cept of accountability can only be grasped and analysed within its con-
text. Our research showed how contextual factors such as regulatory
changes, the development of social media and the pluralisation of fund-
ing streams shaped the development of child welfare organisations, their
accountability, and legitimacy. Small processes of gradual state institu-
tional change such as the rules expanding eligibility to start a foundation,
the process of drift, and the adjustment to the registration regulations
in 2013 shaped the context within which child welfare NGOs pursued
accountability and legitimacy. Children’s Hope Foundation, for example,
would have found it more difficult to survive and develop, had not the
regulations governing foundations changed, had alternative sources of
funding not become available and had not media coverage rendered it
more visible to the public and government.
The process of institutional drift, for example, enabled local govern-
ment officials to tolerate, benefit from and even reward unregistered
NGOs, whilst for NGOs the process created spaces and opportunities
for them to develop organisationally and build their accountability and
legitimacy. As central government became increasingly aware that NGO
registration rules were a barrier to efforts to build a mixed welfare sys-
tem that would deploy both market actors and non-governmental players
in service delivery, it adjusted the rule through a process of layering so
as to make it easier for NGOs to bid for government service contracts.
Layering contributed to the strategy of welfarist incorporation whereby
service-delivery NGOs were brought into welfare reform.
Gradual institutional change created both contextual opportuni-
ties and constraints for NGOs. When authoritarian regimes adjusted
the rules to open up legal spaces for service-provision NGOs, NGOs
that had built up stocks of accountability capital were better positioned
to gain legal status and legitimacy, providing they were not seen to be
regime-threatening. Institutional drift and layering in state institutions
had positive knock-on effects on the development of NGOs in China.
However, not all gradual institutional change benefits NGOs, the new
Foreign NGO Law being a case in point. This new law has re-shaped
the context within which child welfare NGOs pursue accountability and
legitimacy. The requirement for NGOs to register with the relevant level
of Public Security highlighted the politics around welfarist incorporation
8 CONCLUSION 199
and the concerns of security agencies in ensuring political stability and

regime survival. How NGOs navigate this changing political and regula-
tory context will affect not only their access to international funding but
also to professional expertise, knowledge and international best practice.
The loss of international funding reduces also exposure to institutional-
ised arrangements for accountability that can provide important exam-
ples of worldwide principles and practice.
NGOs, too, changed gradually rather than through abrupt exogenous
events. NGOs did not come in a ready-made package. External factors
shaped the way organisations developed, be that through the transfer
of established formal systems used by international NGOs or through
efforts by domestic NGOs to seek informal government approval. The
making of accountability was iterative and cumulative, with child wel-
fare NGOs gradually accumulating a stock of adaptive inputs, namely
accountability capital, as a way to build their organisations and survive.
In an authoritarian context such stocks of accountability capital take on
greater salience than in liberal democratic contexts where there is already
some degree of government and public confidence and belief in the role
of non-governmental actors in welfare provision and where legal status
is much more easily acquired. Furthermore, as the government adjusted
regulations to facilitate the uptake of government services contracts by
NGOs from 2008 onwards, it also underlined the need to ‘professional-
ise’ NGOs. Ensuring the efficiency, good governance, financial probity,
and sustainability of NGOs were seen as crucial to expanding the role of
NGOs in welfare provision.
In the case of Children’s Hope Foundation, its success in accessing
funds, building its programmes, and gaining client and public trust ena-
bled the organisation to expand and grow further after it had separated
from Association B. Its efforts to accumulate accountability capital were
thus crucial to its continued development. Similarly, Liming Family, a
long established non-governmental orphanage with religious affiliations,
had endured in the interstices of legality for over 30 years. Given that it
was a religious organisation and thus suspect in the eyes of government
officials, it is perhaps even more noteworthy that it succeeded in finally
registering in 2013 as an NGO for disability services with the local Civil
Affairs Bureau. This was a result not only of the gradual changes in the
regulatory framework governing NGOs that were hastened by the need
to reform the welfare system and fill service gaps, but also due to its per-
sistence in seeking registration and its strategies deployed to strengthen
its accountability and legitimacy. These second-order forms of accounta-

bility bolstered the formal, upward accountability initially to the church
and later to local government officials and eased the path to registration.
It never achieved registration as a child welfare institution, and eventu-
ally the government established its own institution, preventing Liming
Family from receiving any newly orphaned children.
The mixed welfare institution also changed gradually in response to
financial pressures by making new opportunities for funding relation-
ships with international donors and community families. These new
relationships built from the legitimacy attached to its previous activities,
and resulted in changes to the type of services it offered and the wider
accountabilities for them. In order to attract fee-paying service users and
raise funds, it went beyond basic procedures to strengthen its ethical rep-
utation and open itself up to account to the local community.
Making Accountability but Far from Perfect

Though the four case-studies illustrated the processes of accountabili-
ty-making and legitimation and how they had enabled the survival and
development of the organisations, our findings by no means assert that
the accountability processes in place were perfect. Indeed, most child
welfare NGOs still have rudimentary systems of accountability compared
to more mature organisations found in liberal democracies. Without insti-
tutionalised arrangements that require organisations to give account,
enable different principals such as users, donors, and staff to use voice,
and put in place sanctions for incompetence, malfeasance or corruption,
making accountability work in practice can only fall short. The informal
stocks of accountability were important ingredients in crafting a degree
of accountability and legitimacy, but they were a less than robust means
for ensuring accountability across child welfare organisations. Selective
media coverage, visits by government delegations, and demonstrating
professional expertise deliver some information to users and donors about
how the organisation operates. The range of information needed to hold
the organisations fully to account was usually not sufficient. Even where
the information was available to people affected by organisations’ activ-
ities, formalised channels for their feedback and processes for sanctions
would have been necessary for ensuring that accountability was effec-
tive and for issues to be rectified. Such accountability capital is impor-
tant for its role in potentially reassuring users, donors, and government
8 CONCLUSION 201
and providing a basis for limited accountability. In an authoritarian state

where gaining legal status is cumbersome, such accountability capi
tal assumes greater salience than might be the case in advanced liberal
democracies.
Recognising in general the limitations of informal accountability
capital and the need for institutionalised channels of accountability and
participation, we highlight specific problems that emerged in the cases
studied. Ironing out sources of potential conflict of interest, and improv-
ing the level of professionalisation were but some of the weaknesses iden-
tified in the research that warranted further commitment and effort. For
example, the director of Children’s Hope Foundation had dual roles
in both the domestic and the international child welfare organisation.
Though to our knowledge this had not created any problems, it did rep-
resent a potential conflict of interest that had escaped scrutiny, despite
supervision from two higher agencies. Had there been processes for
staff to voice accountability, there could potentially have been a change
in this arrangement. Angel House, too, revealed a similar potential
conflict of interests. The director played multiple roles on the advisory
council as parent, director, and council member, which could potentially
undermine the independence of the council. It also reduced opportuni-
ties for other parents to have a part in the council. As in all the child
welfare organisations, Angel House had still to institute processes to

enable the children and youth with cerebral palsy to hold staff and the
organisation to account.
Similarly, the lack of professional codes of conduct for child welfare
organisations weakened the sources of accountability to peer profession-
als. Although registered and state child welfare organisations must meet
minimum service standards, the standards do not extend to include pro-
fessional child development approaches. Unlike many NGOs, Liming
Family had taken considerable steps to develop its professional expertise,
providing training opportunities to its staff, and establishing contact with
international organisations that imparted international best practice. Of
all the child welfare organisations examined in the wider study, Liming
Family stood out for its pioneering role in building cross-provincial pro-
fessional alliances. As stated in Chapter 4 by 2016 over 47 child wel-
fare organisations had joined this network, providing opportunities for
exchange, learning, and exposure to good practice. The mixed welfare
institution struggled to hold staff and managers to account on service
quality because of bureaucratic inertia, lack of monitoring capacity and
constraints on the redeployment of staff. An interesting contrast was that

staff employed by the institute for externally funded projects were more
accountable and motivated. Nevertheless, the professionalisation of child
welfare was still in its early stages as there were no codes of conduct,
criteria or principles guiding practice in non-governmental child welfare
organisations.
Another area of accountability that might have warranted further
attention related to individual donors. Our research found that despite
efforts by some NGOs to inform individual donors about their work
and provide open accounts, thus addressing issues around asymmetries
of information, individual donors rarely challenged the NGOs or held
them to account. Though this reflected their trust in the organisation
and the success of the NGOs in building their reputation, it also meant
that individual donors were not exercising their power to hold account
through voice and relied on limited, general information and selective
media coverage.
This issue is not confined to the case of China or authoritarian states;
individual donors are often content to rely on trust that their donations
will be used effectively and do not want to commit the time to examin-
ing audit reports and evaluations. If they are concerned, it is often about
how the donation is spent, whether it directly benefits the children and
whether the activities of the NGO are recognised as best practice. Even if
they were to provide feedback, without institutionalised arrangements to
channel their concerns, their account-seeking would be less effective than
say for an international donor that had formal systems of accountability
in place. Though individual donors could withdraw money as a sanction,
they have no legal power to sanction the organisation. However, in an
authoritarian context where criticism has to be tactfully made and where
voice has historically had costs, there may be a reluctance to challenge
authority, be that even the authority of an NGO. As a result individual
donors exercised less actual power and leverage than other donors such
as international NGOs or government, which had regularised systems for
seeking account.
Theoretical Contribution
This book not only filled an empirical gap through its in-depth, ten-
year-study of accountability and legitimacy in NGOs in China but
also an important theoretical gap in understanding of accountability
8 CONCLUSION 203
in authoritarian states, and specifically regarding NGOs. It found liberal

democratic theories of accountability inadequate for comprehending
the specific systemic and contextual constraints on accountability in an
authoritarian state. As Pollitt and Hupe (2011) noted, understanding
context is crucial to making sense of accountability. Developing a new
approach to analysing accountability in authoritarian states then becomes
imperative. To address this, we introduced a new conceptual framework
to describe and analyse accountability in NGOs in authoritarian states.
As discussed in the book, NGOs in authoritarian states, be they one-
Party, post-socialist, military, or patrimonial states, face a different set
of circumstances within which they have to build accountability and
legitimacy. These circumstances include a suspicious and hostile state, a
weak civil society, the lack of an independent media, curbs on political
rights to organise and freedom of expression, and often a lack of public
knowledge about and confidence in NGOs. These make it more diffi-
cult than in a liberal democratic state for an NGO to survive, develop
organisationally, and expand. Whilst new NGOs in liberal democracies
also have to make efforts to establish their accountability and legitimacy,
the situation in authoritarian states is more challenging. Registering as
an NGO in a liberal democracy is a less politically charged process than
in an authoritarian state where government suspicion of the agendas and
purposes of NGOs prevails. Liberal democratic civil societies also have
an array of infrastructural, umbrella NGOs that provide support to the
development of NGOs, including advice on accountability, research, and
a channel for influencing government policy towards NGOs. Such sup-
port institutions tend to be absent in authoritarian states where restric-
tions on alliance-building and state surveillance limit the development of
civil society. In such a context building informal routes to accountability
and legitimacy, that is second-order accountability, become more salient
in authoritarian states. It is thus not just a matter of an NGO being rel-
atively new and needing to build its reputation and legitimacy as might
occur in an established liberal democracy, but a case of gaining govern-
ment support and public confidence in a context of suspicion and limits
on expression and association.
Our conceptual framework of first-order and second-order account-
ability recognises the importance for NGOs in an authoritarian state
of both legal status and other paths to accountability and legitimacy.
NGOs strategically accumulate stocks of formal and informal account-
ability capital that can be leveraged to strengthen their position as a
legitimate organisation, especially if they cannot gain legal status which

would trigger first-order accountability requirements. These stocks of
accountability capital include not only establishing formal processes
of accountability such as auditing, report-writing, internal systems of
recruitment, and promotion and acquiring legal accountability, but also
building up informal accountability capital such as gaining positive media
coverage, professional expertise, positive relations with local govern-
ment officials, a caring reputation amongst the public, transparency of
information about the organisation, and encouraging user involvement
in the organisation. Demonstrating accountability is thus not limited to
discursive communication but also involves concrete, material elements
and institutional processes. These stocks are akin to the adaptive “inputs”
that Nathan refers to in relation to the Party/state’s moves to enhance
its legitimacy and survival. So, too, do these stocks of accountability cap-
ital function as inputs in creating legitimacy for NGOs, enhancing public
confidence and government trust in NGOs, and ensuring the durability
of NGOs. They are relevant not only to NGOs but also to state institu-
tions such as the mixed welfare institution which are under pressure to
diversify their funding and activities under new government and public
expectations in a mixed welfare state.
By tracing the gradual processes whereby NGOs build their account-
ability and legitimacy, we demonstrate how crafting accountability and
legitimacy are as much strategies of survival as other kinds of tactics to
resist repression. In this way the book contributes to understanding of
the survival of NGOs, extending this beyond a focus on the strategies
and tactics used by NGOs to limit repression and surveillance to strat-
egies and tactics to diversify the sources of legitimacy and authority. We
suggest that the authoritarian state does not completely call all the shots
and totally direct the development of NGOs; instead, NGOs have some
room to subtly navigate their way around the labyrinth of constraints and
barriers to develop their accountability and legitimacy and ensure their
survival.
In analysing the multifold strategies used by NGOs in China to build
accountability and legitimacy this book also contributed to understand-
ing of institutional change in authoritarian states. By tracing the pro-
cesses by which NGOs make accountability, we demonstrated that
accountability was not a product or outcome that was grafted onto an
institution by a state or by a donor but rather an informal, discrete, and
continuous process of accumulating stocks of accountability capital. The
8 CONCLUSION 205
rules governing organisational development in NGOs thus proceeded

gradually, iteratively, and cumulatively but also could interlock with grad-
ual state institutional change and were shaped by a wider politics around
state-NGO relations. Furthermore, the book challenged notions that
authoritarian states remain static until sudden exogenous or endogenous
change occurs. Rather, these gradual, hidden processes of institutional
change created opportunities and constraints for NGOs that could be
navigated and leveraged to promote their survival and development.
Our book also contributed to understanding the power relations
behind accountability which served to privilege certain dimensions of
accountability over others and to entrench social biases against vulnera-
ble groups. It confirmed theories of accountability such as Mattei’s that
recognise the multi-dimensionality of accountability and theories of par-
ticipation that highlight the power relations steering whose accounta-
bility demands become heard and attended to. What is distinct in our
book is our focus on post-socialist authoritarian states coupled with our
in-depth analysis of the privileging of certain accountabilities over others.
First, it highlighted the importance of the authoritarian context in shap-
ing the possibilities for strengthening the voices of disadvantaged groups.
Politics mattered in determining who could hold whom to account, for
what purposes and with what consequences. The lack of a vibrant child
rights movement in an authoritarian state such as China was due in part
to the constraints over organising and freedom of expression. Second,
it analysed empirically how NGOs develop second-order accountability
by accumulating stocks of accountability capital. It considered the impli-
cations of this for user participation and the hierarchy of accountabili-
ties that emerges. It did not, however, seek to assess accountability in
practice in child welfare organisations, not least because the processes
of accountability are dynamic and in some cases rudimentary, and such
assessment would require resources beyond the scope and capacity of this
research project.
Whilst the research focused on child welfare organisations, most of
which are non-governmental, the situation and processes described
in this book are not unique to child welfare NGOs. To be sure, child
welfare organisations face some particular challenges such as the more
restrictive registration requirements, risks for children’s citizenship if the
NGO is not registered and the socio-cultural forces that render the voices
of children unheard. Though there are few studies of accountability in
NGOs in China, existing research on NGOs focussing on the strategies
and tactics of resistance to state repression suggests that other types of

NGOs also deploy similar strategies to raise their profile, gain govern-
mental approval, and secure their survival. Environmental and labour
NGOs, for example, seek positive media coverage of their activities to
mitigate government suspicion. Non-governmental groups working on
labour issues, HIV/AIDs, environment, pollution, disability, gender
issues have often been supported by international donors with funding,
advice on organisation-building, and professional guidance. They also
have had to respond to international donors’ demands for accountabil-
ity. These demands have similarly privileged financial and organisational
accountability over accountability to users. By focussing on a particular
type of NGO the book has been able to highlight the processes, pat-
terns, and dynamics of power relations that feed into the development of
organisations, and specifically the making of accountability and legitimacy
in an authoritarian context.
Policy Implications
The findings of the book have implications for policy in relation to the
development of NGOs in authoritarian China, to civil society, and to
child welfare. As the government is moving towards a mixed welfare
model, it is vital that it not only expands the number of service-provid-
ers, be they market-based or non-profit, non-governmental agencies,
but also ensures that the services provided meet the needs of their users,
are delivered with care and professional expertise, and are run efficiently
and effectively. Though the regulatory framework has been adjusted to
promote certain types of NGOs, it remains restrictive and constrain-
ing in many respects. NGOs that lack capacity to meet the regulatory
standards, also lack government or other support to acquire that capac-
ity. Those NGOs that meet government criteria to apply for service
sub-contracting face uncertain procedures for bidding, problems of cor-
ruption and reluctance of some government officials to grant contracts
to unfamiliar NGOs. Furthermore, government moves to sub-contract
some welfare services to non-state actors such as NGOs are also likely
to change the balance of accountability towards governments, though
probably leaving in place the patterns of privileging upward accounta-
bility over downward accountability. This is only likely to be disrupted
if the government sub-contracts require NGOs to implement downward
accountability, such as the Hong Kong NGO participatory governance
8 CONCLUSION 207
requirements. The curbs on international funding of NGOs could place

limits on the opportunities for NGOs and state welfare institutions to
access best practice international expertise.
This then raises questions around the future shape of civil society in
China. The Party/state’s approach of welfarist incorporation, whereby
it has rhetorically encouraged the growth of service-oriented NGOs and
adjusted registration requirements to promote government sub-con-
tracting to NGOs, particularly from 2008 onwards, has been the main
strategy over the last ten years for managing civil society. This has been
accompanied by the continued harassment, surveillance and repression
of other NGOs perceived to be a threat to the Party, leading to a sus-
tained and harsh clampdown since 2015 on activist lawyers, feminists,
and rights-focussed NGOs, particularly in sensitive areas such as labour.
Welfarist incorporation takes instrumental advantage of the potentially
beneficial dimensions of civil society from the Party/state’s perspective
whilst reducing the perceived risks of social instability and regime threat
that a more diverse, engaged civil society might entail.
From the perspective of child welfare NGOs the Foreign NGOs Law
raised issues around not only the loss of a source of funding with rela-
tively stringent accountability demands attached to it, but also the loss
of non-financial support that many foreign NGOs provided. Each of the
NGO cases in this book had benefited from the engagement with foreign
NGOs and the expertise in the field of child disability that they intro-
duced. Funding was of course important for running projects and pro-
grammes, but it was the permeation of ideas about professionalism and
exposure to international practices around child welfare and accountabil-
ity that were perhaps the most important contribution of international
NGOs to the organisational development of these non-governmental
child welfare groups. But not all NGOs are able to partner or engage
with international NGOs.
In the light of the new Foreign NGOs Law, it has yet to be seen how
this Law will affect in practice the work of foreign NGOs in China. In a
pessimistic scenario where it becomes very difficult for foreign NGOs to
operate in China, it is likely that access to the latest scientific knowledge
and professional training through on-site assistance and international
exposure could be a significant loss. Child welfare NGOs will then clearly
need to develop alternative strategies to accessing this knowledge and
professional guidance. From the perspective of foreign NGOs the more
constrained regulatory environment is likely to limit opportunities to
engage with Chinese NGOs and learn from Chinese experiences. In a more
positive scenario where foreign NGOs are able to continue to operate in
China, then ideas, best practice and professional support can be sustained,
albeit facing considerable constraints and challenges.
However, there is not a clear dividing line between service-deliv-
ery NGOs and rights-based or advocacy NGOs, thus the implementa-
tion of a welfarist incorporation strategy will not be without contention.
Cultivating a legion of purely service-delivery NGOs cannot address the
causes underlying poverty, disadvantage and social injustice nor lead to
the most effective and efficient welfare system. Empowerment and par-
ticipation are essential ingredients for ensuring that the welfare needs and
perspectives of disadvantaged groups are listened to. For this to occur,
society needs more than service-delivery NGOs. Shaping civil society to
consist of service-delivery NGOs that effectively become appendages of
the state fails to capture the energies, ideas, and innovation of citizens.
The current strategy of welfarist incorporation is thus likely to hamper
organisational efficiency and effectiveness and constrict the development
of civil society in a way that ultimately hinders welfare reform.
With regard to child welfare, the empowerment of and participation by
users remains a major hurdle, not just in China but globally. Social divisions
along the axes of age, class, and expertise, coupled with deeply embedded
socio-cultural attitudes hinder the prioritisation of children’s voices in deter-
mining their welfare needs. The issue is not just one of empowerment and
participation but also of the effective delivery of services. If services do not
address the needs of their users, then resources are not being used in the
best way. There are also issues of child protection, which make the determi-
nation of professional standards, along with methods of enforcement, par-
ticularly important. The consequences of a lack of supervision and standards
were evident in the case of the fire in 2013 that took the lives of children
who were supposed to be protected. The development of non-govern-
mental professional organisations bringing together child welfare groups to
exchange experiences, ideas and promote professional standards and prac-
tice would clearly benefit child welfare and the development of this sector.
As seen in the book, some steps towards professional networks have been
taken by the case-study NGOs but much more remains to be done.
Supporting the participation of children in state care and advocat-
ing for their interests cannot continue to rely only on the institution
staff, who have a conflict of interest, between representing the interests
of the children and representing their own interests as workers—it also
requires the participation of community members. The involvement of
8 CONCLUSION 209
families in the community and international organisations with a similar

interest may go some way to enhancing this approach. Internationally,
processes for this purpose include independent official visitors, third
party child advocates, and representatives to speak to the interests of
children who are too young or disabled to speak for themselves with-
out support (McDowall 2016). Such processes are embedded in a rights-
based framework supported by an international child rights movement.
Demonstrating this approach through the continued involvement of
international partners could also motivate the staff in the institution to
adopt a similar professional focus in their work. However, in China there
is no cohesive child rights’ movement that could influence policy or
reflect the demands and needs of children. Indeed, the welfarist incorpo-
ration strategy of the CCP does not encourage the formation of rights-
based social movements that could play an advocacy role and influence
policymaking.
Future Research
This book provides the first, in-depth study of the processes of mak-
ing accountability and NGOs in an authoritarian context and in China.
The research extended over ten years and as such is also unique in its
relatively long-term gaze at the developmental history of NGOs.
Nevertheless, there is considerable room for further in-depth, longer
term, empirical research on NGOs in China, and specifically on the
aspects of accountability and legitimacy. As discussed in Chapters 1–2,
there is a paucity of work on accountability and legitimacy of NGOs
in authoritarian states. Further comparative research could reveal the
effects of different state-NGO and welfare systems in authoritarian states
on accountability and legitimacy in NGOs. China is distinct in that it is
an economically successful example of a post-socialist state in terms of
growth and poverty reduction. It also has an adaptive Party-state that
has been able to change its skin in response to shifting economic, polit-
ical and social circumstances and thus endured for over 60 years. With
a strong secular state at its helm and a focus on development it is dis-
tinct from patrimonial, military, or theocratic authoritarian regimes and
from weak authoritarian states that are unable to extend their reach
nationwide. It would thus be instructive to explore whether accounta-
bility-making by NGOs in other authoritarian contexts faces similar chal-
lenges, opportunities, and processes as in China.
The increasing media coverage of child abuse in institutions and other

children’s services, even in some of the most expensive commercial ser-
vices, means that public awareness of the importance of accountability is
rising. The Chinese government and civil society are realising that protect-
ing child safety in services relies on proper accountability processes built
into the regulation of child welfare service organisations. Continuing to
follow the changes to accountability of child welfare organisations as the
child welfare system in China develops will remain a useful focus for under-
standing the crafting of accountability and legitimacy of NGOs in China.
This book sought to move beyond liberal democratic theories of
accountability to conceptualise and theorise accountability in an author-
itarian context. To this end, it put forward the idea of first-order and
second-order accountability and stocks of accountability capital as a way
of describing and analysing the process of crafting accountability and
legitimacy in NGOs in authoritarian states. Further research using this
analytic framework could demonstrate whether this framework can be
applied more generally across authoritarian states. Similarly, the focus of
the book on bringing politics back into the discussion of accountability
and legitimacy suggests that more research through this approach could
deepen understanding more generally of accountability and legitimation
processes in other contexts.
As NGOs build their organisations, and specifically accountability and
legitimacy, they also engage in institutional change, creating new rules,
borrowing rules from legitimate sources, and capitalising on institutional
change within the state. The concepts of drift and layering proved par-
ticularly relevant in the case of China. Understanding gradual processes
of change through drift and layering adds texture to our conceptualis-
ation of authoritarian state-NGO relations. In particular, it shows that
where there may be mutual benefits to the state and NGOs, rules get
subtly and informally changed, creating opportunities for NGO survival,
development, and growth. Exploring more closely processes of institu-
tional change in authoritarian state institutions and their connections
with non-governmental agencies undermines the neat and tidy idea
that authoritarian states are static and repressive. The dynamics of state-
NGO relations in authoritarian states are likely far more subtle and shift-
ing than crude, normative depictions of authoritarianism across country
and time suggest. By exploring institutional change in this way, further
research can contribute to unmasking the crude binary divisions of
authoritarianism and democracy, which are conceptually inadequate for
describing empirical reality and understanding change over time.
8 CONCLUSION 211
References
Keating, V. C., & Thrandardottir, E. (2017). NGOs, trust and the accounta-
bility agenda. British Journal of Politics and International Relations, 19(1),
134–151.
McDowall, J. J. (2016). Connection to culture by indigenous children and
young people in out-of-home care in Australia. Communities, Children and
Families Australia, 10(1), 5–26.
Pollitt, C., & Hupe, P. (2011). Talking about government: The role of magic
concepts. Public Management Review, 13(5), 641–658.
Appendix
Relevant Government Documents

Central Committee of the CCP (2013). Making Innovations in the Social
Governance System. Decision of the 3rd Plenum of the 18th Central
Committee of the CCP, Section XIII. Retrieved from http://www.gov.
cn/jrzg/2013-11/15/content_2528179.htm.
General Office of the Yunnan Provincial People’s Government
(2009). Yunnan Province Provisional Regulations Standardizing the
Activities of Foreign NGOs. Retrieved from http://www.yunnan.cn/
html/2010-02/23/content_1082060.htm.
Government Administration Council of the Central People’s
Government (1950). Provisional Regulations on the Registration of Social
Organisations. Shanxi Government Gazette, 10, 107–108. Retrieved
from http://mall.cnki.net/magazine/article/SXBA195011043.htm.
Ministry of Civil Affairs (1999). Interim Measures for Registration of
Private Non-enterprise Entities. Retrieved from http://swshzz.chinanpo.
gov.cn/6036/62171.html.
Ministry of Civil Affairs (1999). Interim Measures for the
Administration of Social Welfare Institutions. Retrieved from http://
www.mca.gov.cn/article/swgk/fvfg/sdshbs/200711/20071110003485.
shtml.
© The Editor(s) (if applicable) and The Author(s), under exclusive license 213
to Springer International Publishing AG, part of Springer Nature 2019
https://doi.org/10.1007/978-3-319-90221-0
214 Appendix
Ministry of Civil Affairs (2001). Basic Standards for Child Welfare

Institutions. Retrieved from http://shfl.mca.gov.cn/article/bzgf/
etfl/200807/20080700018266.shtml.
Ministry of Civil Affairs (2006). Measures for Release of Information
of Foundations. Retrieved from http://www.mca.gov.cn/article/gk/fg/
shzzgl/201507/20150700849534.shtml.
Ministry of Civil Affairs (2006). Measures for the Annual Examination
of Foundations. Retrieved from http://www.mca.gov.cn/article/gk/fg/
shzzgl/201507/20150700849647.shtml.
Ministry of Civil Affairs (2010). Measures for the Evaluation and
Management of Social Organisations. Retrieved from http://www.mca.
gov.cn/article/gk/fg/shzzgl/201507/20150700849650.shtml.
Ministry of Civil Affairs (2015). Interim Measures for Administration
of Social Welfare Institutions. Retrieved from http://www.liuxiaoer.com/
tc/6000.html.
Ministry of Civil Affairs and Ministry of Health (2004). A Notice
on the Work: Tomorrow Initiative for Surgery and Rehabilitation of
Disabled Orphans. Retrieved from http://shfl.mca.gov.cn/article/zcfg/
zcfgc/200807/20080700018548.shtml.
Ministry of Civil Affairs and State Administration for Religious Affairs
(2014). Notice on Regulating the Adoption of Orphaned and Abandoned
Children by Religious Organisations. Retrieved from http://www.mca.
gov.cn/article/swgk/fvfg/shflhshsw/201405/20140500631165.shtml.
Ministry of Civil Affairs, National Development and Reform
Commission, Ministry of Public Security, Ministry of Justice, Ministry
of Finance, National Health and Family Planning Commission,
State Administration of Religious Affairs (2013). Notice on Further
Improvement of Relevant Work for Abandoned Infants. Retrieved from
http://www.mof.gov.cn/zhengwuxinxi/zhengcefabu/201306/
t20130618_925460.htm.
Ministry of Civil Affairs, State Development and Reform
Commission, Ministry of Public Security, Ministry of Justice, Ministry
of Finance, National Health and Family Planning Commission, and
State Administration for Religious Affairs (2013). Notice on Further
Strengthening the Work with Abandoned Children. Retrieved from
http://www.mca.gov.cn/article/swgk/fvfg/shflhshsw/201305/
20130500460312.shtml.
Ministry of Finance and Ministry of Civil Affairs (2014). Notice
on Supporting and Regulating Social Organizations to Undertake
Appendix 215
Government-Purchased Services, MOF GAD [2014] 87. Retrieved from

http://swshzz.chinanpo.gov.cn/6036/82687.html.
Ministry of Finance and State Administration of Taxation (2014).
Notice on Issues About Determining the Qualification of Non-profit
Organizations for Tax Exemption. Retrieved from http://swshzz.chi-
nanpo.gov.cn/6036/74956.html.
National People’s Congress (2000). The Bidding Law of the People’s
Republic of China. Retrieved from http://www.npc.gov.cn/wxzl/gong-
bao/2000-12/05/content_5004749.htm.
National People’s Congress (1986). General Principles of the Civil
Law of the P.R. China. Retrieved from http://www.npc.gov.cn/wxzl/
wxzl/2000-12/06/content_4470.htm.
National People’s Congress (1999). Contract Law of the People’s
Republic of China. Retrieved from http://www.npc.gov.cn/wxzl/
National People’s Congress (2007). Law of Enterprise Income
Tax. Retrieved from http://www.gov.cn/flfg/2007-03/19/con-
tent_554243.htm.
National People’s Congress (2016). Law of the People’s Republic of
China on the Management of Activities of Overseas Non-governmental
Organisations in mainland China. Retrieved from http://www.npc.gov.
cn/npc/xinwen/lfgz/flca/2015-05/05/content_1935666.htm.
President of the People’s Republic of China (1999). Law of the
People’s Republic of China on Donation to Public Benefit Undertakings.
Retrieved from http://www.gqb.gov.cn/node2/node3/node5/node9/
userobject7ai1270.html.
Standing Committee of Law 105 (2006). Law of the People’s Republic
of China on the Protection of Minors. Retrieved from http://www.ben-
zhai.gov.cn/html/show-7-418-1.html.
Standing Committee of the National People’s Congress (1992).
Adoption Law. Retrieved from http://www.npc.gov.cn/wxzl/gong-
bao/2000-12/05/content_5004561.htm.
Standing Committee of the National People’s Congress (2002).
Procurement Law. Retrieved from http://www.npc.gov.cn/wxzl/
State Administration of Foreign Exchange (2010). Notice on
Issues Concerning the Administration of Foreign Exchange Donated to
or by Domestic Institutions. Retrieved from http://www.safe.gov.cn/
wps/portal/!ut/p/c4/04_SB8K8xLLM9MSSzPy8xBz9CP0os3gP
ZxdnX293QwMLE09nA09Pr0BXLy8PQyNPI_2CbEdFAKLWUno!/
216 Appendix
?WCM_GLOBAL_CONTEXT=/wps/wcm/connect/safe_web_store/
safe_web/zcfg/jcxmwhgl/fwmywhgl/node_zcfg_jcxm_fwmy_store/
d7bcf580485026d5b637b6362e8d3913.
State Council (1989). Regulations on the Registration and Administration
of Social Organisations. Retrieved from http://law.npc.gov.cn/FLFG/flfg-
ByID.action?txtid=2&flfgID=11984&showDetailType=QW.
State Council (1989, 2013 revised). Provisional Regulations on the
Administration of Foreign Chambers of Commerce. Retrieved from http://
www.mca.gov.cn/article/gk/fg/shzzgl/201507/20150700847911.
shtml.
State Council (1998). Provisional Regulations on the Registration
and Administration of Private Non-enterprise Entities. Retrieved from
http://swshzz.chinanpo.gov.cn/6036/62170.html.
State Council (1998). Regulations on the Registration and
Administration of Social Organisations. Retrieved from http://swshzz.
chinanpo.gov.cn/6036/62166.html.
State Council (1998). Regulations on the Registration and
Administration of Social Organisations. Retrieved from http://www.
mca.gov.cn/article/yw/shjzgl/fgwj/201507/20150700850197.shtml.
State Council (2004). Regulations on the Administration of
Foundations. Replacing Administrative Regulations on Foundations
1998. Retrieved from http://www.mca.gov.cn/article/zwgk/
tzl/200711/20071100003953.shtml.
State Council (2007). Regulations on Open Government Information.
Retrieved from http://www.gov.cn/zwgk/2007-04/24/con-
tent_592937.htm.
The National People’s Congress and its Standing Committee (1999).
Law of Donations on Public Welfare. Retrieved from http://www.npc.
gov.cn/wxzl/gongbao/2000-12/05/content_5004744.htm.
The National People’s Congress and its Standing Committee
(2016). Charity Law. Retrieved from http://www.npc.gov.cn/npc/
dbdhhy/12_4/2016-03/21/content_1985714.htm.
Glossary
CCP Chinese Communist Party

CPPCC
Chinese People’s Political Consultative Conference
GONGO
Government-Organised NGO
MOCA Ministry of Civil Affairs
NGO Non-governmental Organisation
NPC National People’s Congress
RMB Renminbi (Chinese unit of currency)
https://doi.org/10.1007/978-3-319-90221-0
Index
A legal, 21, 22, 89, 96, 192, 204

Abandoned infants/children, 19, 20, managerial, 6, 10, 12, 27, 37, 53,
24, 87, 88, 97, 100, 102, 103, 84, 85, 177, 178, 193
105–107, 109, 115, 164, 165, mechanisms, 4, 12, 25, 46, 48, 49,
214 51, 57, 86, 101, 108, 130,
Accountability 155, 163, 167, 174, 183, 185,
bureaucratic, 36, 46, 61 188, 192, 194, 200, 210
capital, 6, 7, 9, 10, 13–15, 27, 28, multi-dimensional, 99, 124, 138,
53–55, 57, 59–61, 81, 95, 96, 139, 192
99–101, 104, 106, 110, 111, political, 35, 37–39, 89, 163, 172
115, 116, 128, 129, 134, 135, professional, 12, 27, 96, 115, 118,
137, 142, 143, 149, 150, 152, 132, 135, 157, 163, 171, 184,
160, 174, 177, 182, 188, 190, 195
191, 198–201, 203–205, 210 second-order, 6, 9, 10, 14, 28, 34,
democratic, 6, 13, 37, 39, 40, 53, 59–61, 96, 108, 118, 133,
83–85, 194, 195 134, 138, 142, 160, 164, 180,
downward, 13, 36, 37, 39, 41, 42, 183, 184, 188, 189, 191, 203,
52, 114, 117, 118, 121–123, 205, 210
142, 184, 192, 194, 195, 206 societal, 38, 47, 49, 54
economic, 89 state, 46
financial, 6, 10, 12, 19, 36–38, 40, upward, 61, 118, 122, 142, 192,
46, 53, 84, 112, 114, 118, 193, 200, 206
123, 129, 152, 155–157, 174, user, 28, 37, 38, 40, 52, 54, 96,
176, 191, 192 118, 121, 122, 158, 160, 163
horizontal, 46, 52, 53, 84, 184 vertical, 46, 52, 53, 194
https://doi.org/10.1007/978-3-319-90221-0
220 Index
Adoption, 87, 88, 96, 100, 103, 106, 160, 161, 163, 164, 172, 184,
109, 115–117, 143–145, 147, 189, 196, 197, 200, 208
148, 152, 165, 167, 168, 175, Catholic, 97
176, 214, 215 Cerebral palsy, 24, 98, 102, 114, 116,
Albinism, 168 117, 123–126, 128, 131–135,
All-China Federation of Trades 138–140, 149, 158, 174, 189,
Unions, 44, 74 196, 201
All-China Women’s Federation, 44, 74 Child-care, 70, 73, 111
Amity Foundation, 117, 151 Children, 1, 11, 14, 15, 19–24,
Angel House, 27, 90, 119, 122–140, 28, 41, 43, 61, 77, 83, 86–90,
189–191, 196, 197, 201 95–119, 121–126, 128, 130–137,
Anti-government, 8 139, 140, 142–146, 148, 149,
Asian Development Bank, 79 151–154, 156–159, 163–171,
Authoritarian, 1–4, 6, 8, 9, 11, 13–15, 173, 174, 176, 177, 179–184,
17, 18, 26–29, 33, 34, 39, 187–189, 191–197, 200–202,
42–45, 51–53, 55, 59–62, 69, 74, 205, 208–210
83, 84, 89, 90, 101, 159, 163, with disabilities, 19, 23, 86, 87,
187–189, 194–196, 198, 199, 96, 98, 100, 102, 110, 111,
201–206, 209, 210 113, 118, 122, 125, 132, 136,
Autism, 24, 77, 170 137, 151, 153, 159, 164–166,
Awareness, 47, 118, 125, 144, 148, 168–170, 172, 174, 180, 184,
150, 153, 210 195
of prisoners, 15, 86
Children’s Hope Foundation, 28, 90,
B 141–161, 189–192, 198, 199,
Baoding, 102 201
Beichuan, 158 Children’s Hope International,
Beijing, 16, 23, 25, 47, 73, 76, 79, 142–148, 150, 152, 153, 155,
119, 128, 133, 147, 151, 152, 160, 161, 192
156, 158 Child rights, 195, 205, 209
Biancun, 98 Child welfare, 8–15, 19–28, 43,
Bias, 27, 39, 42, 49, 193 50, 69, 73, 80–82, 85–90, 95,
Bribery, 176 100–104, 106, 108, 109, 111,
Buddhist organisations, 113 112, 115–119, 122, 125, 136,
141–146, 148, 150, 152, 153,
157, 160, 161, 163–165, 167,
C 168, 171, 173–177, 179–182,
Cadre(s), 16, 46, 47, 50, 99, 168, 184, 188–192, 194–202,
171, 172 205–208, 210, 214
Capitalist/capitalism, 1 China Centre for Children’s Welfare
Case-study(ies), 8, 23, 25–28, 39, 49, and Adoption, 168
69, 90, 95, 119, 122, 141, 142,
Index 221
Chinese Communist Party (CCP), 12, D

14, 16–18, 34, 45, 83, 85, 91, Decentralisation, 36, 46
172, 209, 213, 217 Decollectivisation, 71
Chinese People’s Political Democracy/Democratic regimes, 35,
Consultative Conference 36, 41, 42, 44–46, 51, 75, 210
(CPPCC), 104, 108, 109, 153, Democracy Movement, 75
173, 217 Democratisation, 6, 13, 34, 35, 42, 43, 51
Chinese Red Cross, 18, 60 Development, 2, 3, 7, 9, 11–17, 19,
Chongqing, 48, 134, 140 25–29, 34–37, 40, 46, 49, 51,
Christian, 142, 151, 154 53, 54, 57, 59–61, 69, 71–77,
Church(es), 24, 87, 95–97, 100, 79, 80, 82, 85, 90, 91, 109,
103, 106, 111–114, 116, 118, 115, 116, 118, 123, 125–131,
192–195, 200 133, 134, 136–139, 141, 142,
Citizens, 1, 2, 4, 7, 13, 16, 17, 35–40, 144–147, 149, 152, 157, 160,
42, 44, 45, 47, 49–52, 56, 60, 161, 165, 167–169, 171, 172,
77, 79, 82, 83, 85, 128, 195, 175, 187, 188, 190–192, 194,
196, 208 195, 198–201, 203–210, 214
Civil Affairs Bureau, 23, 24, 27, 50, Direct action, 106, 107
80, 81, 91, 95, 98, 99, 101, 103, Disability(ies), 1, 23, 24, 27, 39, 73,
104, 106, 107, 112, 123, 124, 76, 86, 87, 95, 96, 98, 100,
164, 165, 170, 171, 173–175, 102–104, 108, 110, 111, 113,
179, 191, 199 116, 118, 122, 124, 125, 132,
Civil servants, 35–37 136–138, 140, 151, 153, 159,
Civil society, 2, 3, 6, 8, 9, 16–18, 164–166, 168–170, 179, 180,
21, 27, 34–39, 44, 45, 74–76, 182, 184, 191, 195, 197, 206, 207
79, 81, 82, 84, 85, 89, 90, 138, services, 27, 95, 96, 98, 102, 103,
141, 161, 164, 187, 188, 203, 109, 112, 117, 118, 124, 130,
206–208, 210 133, 138, 182, 199
Cleft lip and palate, 98, 158, 168 Disabled Persons’ Federation, 1, 28,
Commodification, 16 74, 102, 140, 197
Community groups, 5 Disadvantage/Disadvantaged groups,
Compliance, 89, 155 4, 41, 43, 54, 205, 208
Confucianist social traditions, 121 Discrimination, 122, 124, 197
Constitution, 7, 35, 58, 76 Dissent, 8
Contractualisation, 36
Corporations, 34, 77, 129
Corruption, 16, 17, 46, 49, 81, 163, E
172, 176, 200, 206 Education, 21, 23, 24, 49, 70, 75,
Courts, 3, 20, 36, 42, 47 84, 87, 101, 116, 119, 123–127,
Credibility, 25, 95, 101, 110, 134, 131, 134, 135, 138, 140, 144,
139, 140, 146, 154, 192 145, 165, 168–172, 174, 176,
Criminal liability, 29, 89 177, 182, 184, 191
222 Index
Education Bureau, 170 Governance, 2, 7, 9, 12, 14, 17, 18,

Effectiveness, 4, 37, 40, 43, 44, 46, 25, 27, 35, 44, 45, 47–49, 57,
49, 53, 58, 61, 157, 178, 179, 58, 74, 75, 77, 78, 80, 84, 91,
188, 193, 208 99, 100, 122, 136, 152–154,
Efficiency, 37, 40, 43, 58, 126, 193, 178, 195, 199, 206, 213
199, 208 Government/governmental, 2–11,
Electoral system, 46 15, 17–19, 21, 22, 24–28, 33,
Entrepreneurs, 23, 24, 48, 74, 77, 35–40, 42–52, 54–60, 73–86,
102, 114, 131, 197 88–90, 95–97, 99–113, 115–
EU Community-Based Rehabilitation 119, 124, 128–132, 136, 137,
Programme, 136 139–150, 152, 153, 157, 160,
161, 163–165, 168, 170–174,
176, 178, 180–184, 187,
F 189–194, 197–200, 202–204,
Falun Gong, 76 206–208, 210, 213, 214, 216,
Feminists/feminism, 81, 207 217
Financial Bureau, 107, 113 Government funding/money, 7, 23,
Financial sustainability, 82 101, 163
Firms, 40, 56, 195 Government officials, 3–5, 7, 15–17,
Foreign-financed NGOs, 78 22, 37, 45, 50–52, 57, 60, 72–
Foreign governments, 78 74, 77, 79, 81, 83, 95, 99–105,
Foreign investment, 71 107, 108, 110, 111, 114, 117,
Forever Families, 168 119, 142, 161, 190, 193, 196,
Foundations, 18, 19, 40, 61, 73, 198–200, 204, 206
75–78, 82, 85, 86, 91, 114, 142, Government-organised NGOs
149, 150, 161, 163, 198, 214, 216 (GONGOs), 7, 18, 60, 74, 99,
Fourth World Summit of Women, 76 141, 160, 161, 163
Fu Hong Society, 134 Grace and Hope for Children, 168,
Funders/Funding, 5, 7, 9–11, 14, 19, 169, 177
22–25, 28, 38, 40, 42, 52, 54– Grassroots, 4, 7, 8
59, 61, 73, 78, 79, 84, 86, 90, Great Leap Forward, 70
102, 108, 113–115, 122, 125, Guangdong, 79, 80
130, 131, 136, 139, 142–145, Guangxi, 23, 124, 125, 128, 131,
148–152, 155, 157, 160, 163, 134, 136, 140
164, 167, 170, 174, 176–180, Guangzhou, 73, 151
182, 183, 188–194, 197–200, Gui Gang Mother’s House, 123
204, 206, 207
H
G Half the Sky Foundation, 168, 169,
Gaoyi, 98, 102, 113, 119 177
Globalisation, 36, 45 Handan, 102
Index 223
Handicap International, 136, 138 International donors, 61, 82, 136,

Harassment, 4, 5, 7, 25, 79, 83, 207 168, 177, 184, 185, 191–195,
Harbin, 48 200, 206
Health Bureau, 98, 170 International NGOs, 20, 129, 130,
Hebei, 23, 24, 95, 98, 102, 109, 111, 184, 193, 194, 199, 202, 207
133 International organisations, 5, 22, 23,
Heilongjiang, 48 28, 130, 136, 165, 167, 170,
Henan, 27, 103, 141, 150–152 185, 190–192, 201, 209
Hierarchies, 15, 26, 33, 40, 43, 121, International partner organisations,
188, 190, 192, 195, 196 182, 184
HIV/AIDs, 23, 73, 75, 158, 168, Internet, 13, 24, 49, 81, 113, 137,
179, 206 154–156
Holt International Children’s Services,
167, 168
Hong Kong, 51, 114, 123, 130, 134, J
168, 196, 206 Jiabao, Wen, 3, 71, 72, 77
Hukou, 70 Jiang era, 73
Humanitarian relief, 77 Jiangnan, 124
Hu-Wen administration (era/years), 3, Jiangxi, 79
19, 69, 73 Jiaozuo, 49
Jinping, Xi, 4, 17, 28, 80, 105, 172
Jintao, Hu, 3, 71, 72, 77
I Junan, 159
Independent watchdog, 84
Industrialisation, 17, 45
Inequality, 9, 18, 54 L
Informal government approval, 106, Labour NGOs, 62, 81, 206
110, 118, 199 Lawyers′ Association, 74
Information, 4, 11, 13, 17, 23, 24, 35, Legal status, 4, 5, 8, 14, 21, 34, 53,
37–39, 41–44, 47–50, 53, 58, 70, 57–59, 81–83, 85, 87, 95, 96,
77, 78, 82, 83, 110–112, 115, 99–101, 104, 106, 108, 111,
117, 123, 128, 131, 133, 135, 113, 115–118, 124, 128, 133,
136, 148, 149, 155, 157–159, 138, 142, 143, 145, 160, 163,
172, 181, 182, 190, 194, 196, 168, 174, 187, 189, 191, 192,
200, 202, 204, 214, 216 197–199, 201, 203, 204
Institutional change, 9, 11–14, 26, Legal system/laws, 3, 47, 82
28, 33, 34, 49, 50, 85, 119, 188, Legitimacy, 1–7, 9–14, 17–19, 25–28,
190, 198, 204, 205, 210 33, 34, 38, 44, 47, 48, 50,
Institutionalisation, 42, 48 52–62, 69, 74, 75, 81–83, 85,
International agencies, 5 90, 95, 96, 100, 101, 104, 105,
International best practice, 82, 145, 108–111, 116, 118, 123–125,
164, 170, 185, 199, 201 133, 134, 136, 138, 139, 141,
224 Index
142, 144, 154, 155, 161, Mixed Welfare Institution, 90,

163, 164, 170, 173, 174, 177, 164, 166–168, 170, 172–177,
179–184, 187–190, 193, 195, 179–185, 189, 192, 195, 197,
197, 198, 200, 202–204, 206, 200, 201, 204
209, 210 Mixed Welfare System, 1, 2, 18, 20,
Liberal democracy(ies), 9, 43, 50, 56, 74, 187, 188, 198
200, 201, 203 Mother’s Love Orphanage, 130
regimes, 18, 33, 34, 40, 43 Mother Teresa’s Missionaries of
states, 11, 12, 33 Charity, 112
Liming Family, 27, 90, 95–119, 133,
187, 189–195, 197, 199–201
Linyi, 159 N
Little Sisters Pre-school Education Nanjing Amity Foundation, 117
Project, 169 Nanning Municipal Party Committee, 128
Local government, 4, 5, 10, 16, 27, National People’s Congress (NPC),
28, 50, 51, 72, 75, 79, 81, 83, 46, 173, 215, 217
88, 99–106, 108, 109, 112, 113, Network Alliance, 116, 117, 119
118, 119, 139, 170, 183, 190, New Rural Cooperative Medical
194, 196–198, 200, 204 System, 107
Ningjin, 98, 102, 103, 110, 114, 119
Non-governmental organisations
M (NGOs), 1–28, 33, 34, 36, 37,
Managerialisation, 36 39–43, 49–53, 55–62, 69, 73–85,
Maoist, 69, 70, 91 87–90, 99–101, 105, 108, 110,
Marginalised groups, 42, 77, 121, 117, 121, 122, 124, 125, 128,
122, 195 129, 133, 141, 146, 147, 149,
Marketisation, 16, 45 150, 156, 157, 161, 163, 169,
Market-oriented, 70 183, 184, 187–192, 195–210, 213
Media, 3, 6, 10, 17, 27, 36, 37, 39, Non-Governmental Orphan Relief
44, 49, 54, 57–59, 85, 99, 100, Union, 117
111, 114, 118, 123, 126, 136– Norms, 12, 41, 45, 53, 56
138, 149, 156, 159, 190, 191,
198, 200, 202–204, 206, 210
Medical insurance, 106 O
Mianyang, 158 Ocean Heaven Program, 114
Migrant workers/migrants, 18, 71–73 Older Sisters Project, 169
Ministry of Agriculture, 48 Ombudsmen, 85
Ministry of Civil Affairs (MOCA), One Foundation, 78, 114, 116, 151
3–5, 8, 18, 20–23, 29, 73–75, Openness, 40, 110, 111, 152, 153,
77–80, 82, 86–89, 91, 145, 158, 190, 197
174, 213, 214, 217 Orphanage/Orphans, 20, 88, 95–101,
Ministry of Public Security, 29, 78, 82, 103, 104, 108, 109, 111, 116,
91, 214 130, 158, 159, 174, 199, 214
Index 225
P R
Participation, 6, 9–11, 13, 14, 19, 26, Rainbow Missions Hong Kong, 130, 133
33, 34, 39, 40, 42–45, 49, 51, Reforms, 15, 17, 26, 46, 69–73,
53, 58, 59, 84, 121–123, 125, 78–80, 82, 90
127, 137–139, 157, 177, 188, Register/Registration, 3–5, 8, 9,
189, 193, 195, 196, 201, 205, 13, 15, 18, 20–25, 27, 29, 34,
208 50, 53, 55, 60, 75, 77, 79–82,
People’s Congress, 49 86–89, 91, 95, 96, 98–109, 111,
Petitioning/petitioning system, 13, 112, 118, 126, 128, 140, 147,
16, 46, 47, 52 151, 163, 176, 187, 191, 196,
Philanthropic causes/philanthropists, 198, 199, 205, 207
77 registered organisations, 20–24
Post-socialist, 2, 3, 5, 6, 18, 29, 187, registered status, 61, 85
188, 203, 205, 209 Regulation, 2, 4, 9, 17, 21, 23, 26, 27,
Poverty, 9, 18, 19, 39, 42, 74, 76, 79, 35, 41, 43, 48, 50, 53, 73, 75–80,
86, 124, 153, 159, 208, 209 82, 84, 86–89, 91, 99, 100,
Power, 6, 11, 13–15, 19, 26, 27, 111, 126, 127, 132, 134, 147,
33–35, 38–45, 52–54, 59, 76, 78, 149–151, 154, 155, 171, 176,
84, 90, 118, 123, 130, 160, 184, 178, 181, 184, 198, 199, 210
185, 193, 194, 202, 205, 206 regulatory bodies, 42
Private sector, 2, 3, 18, 19, 71, 73 regulatory environment, 2, 6, 61,
Privatisation, 36, 71 69, 73, 74, 76, 78, 83, 85, 90,
Propaganda, 13, 133 95, 142, 148, 149, 160
Public donations, 23, 24, 27, 76, 129, Rehabilitation, 28, 98, 100, 102,
131, 136, 148, 149, 156 112–114, 116, 117, 119, 123–128,
Public perceptions, 3, 46, 73 130–135, 137, 138, 140, 158,
Public trust/confidence, 2–4, 15, 27, 165, 168, 170, 171, 174, 182, 214
53, 59, 74, 76–78, 81, 95, 96, Religious Affairs Bureau, 101, 107
99, 128, 133, 149–152, 160, Religious affiliations/organisations,
181, 187, 189, 190, 199, 203, 87, 88, 96, 101, 103, 199
204 faith-based organisations, 96
Reputation, 6, 9, 27, 49, 55, 59,
60, 95, 96, 99, 104, 108, 110,
Q 111, 118, 123–125, 131, 132,
Qizhi Child Rehabilitation and Care 135, 137, 139, 140, 143, 148,
Home, 1 149, 152, 158, 160, 168, 172,
Quality, 2, 13, 19, 21, 22, 43, 44, 70, 181, 183, 190, 191, 193, 200,
72, 87–89, 112, 118, 131–133, 202–204
138, 159, 167–169, 172, 173, Rights, 2, 4, 7, 17, 21, 22, 34–36,
177–180, 182, 184, 191, 201 43, 44, 46, 47, 49, 52, 60, 77,
Quasi-governmental associations/ 81, 83, 90, 96, 106, 121, 122,
agencies, 37, 74, 130, 141 147, 158, 184, 187, 189, 203,
207–209
226 Index
RMB/Renminbi, 102–104, 106, 107, State Administration of Foreign

112, 113, 129–131, 140, 149, Exchange, 78, 215
168, 169, 174–176, 217 State Council, 80, 91, 216
Rongji, Zhu, 71 State funding, 86, 164
Rural, 16–18, 27, 60, 70–73, 95, 106, State provision, 1, 197
113, 146 State-run institutions, 28
Street children, 19, 86, 97, 165
Sub-contracting, 36, 73, 79, 81, 83,
S 105, 206, 207
Sanctions, 5, 11, 16, 35, 39, 40, 42, Surveillance, 79, 83, 188, 196, 203,
54, 200 204, 207
Scandals, 21, 60, 78, 99, 163
Service gap, 101, 106, 109, 187
Service providers, 2, 3, 5, 9, 16, 27, T
36, 80, 81, 181 Taiwan, 114, 116, 134, 140
Shandong, 28, 159 Tangshan, 102
Shanghai, 151 Tax exemption, 145, 149, 150, 215
Shanxi, 119, 133, 213 Third sector, 8
Share-holders, 40 Tianjin, 1, 102
Shenzhen, 73, 78, 79, 151 Transparency, 6, 10, 13, 40, 45, 46,
Shijiazhuang, 98, 119 48, 49, 53, 57–59, 77, 123, 149,
Shijiazhuang Jinde Foundation, 117 153, 156, 167, 181–183, 190,
Sichuan, 151, 157, 158 193, 204
Silk Trade Association, 74 Trust, 7, 22, 54–57, 59, 60, 96, 101,
Sisters of Teresa, 97 110, 118, 136, 137, 156, 159,
Social capital, 53 160, 194, 197, 202, 204
Social groups, 7, 8, 22, 27, 41, 47, 76
Socialist/socialism, 2, 8, 45, 49, 69
Social media, 17, 49, 61, 85, 142, 198 U
Social organisations, 3, 15, 19, 23, United Nations (UN), 128
27, 61, 74–82, 85–90, 100, 116, Unregistered organisations, 22, 79, 96
147, 149, 213, 214, 216 Urban areas, 16, 70–73
Social protection/security, 24, 69, 71, Urbanisation, 17, 45
73, 106
Socio-economic change, 45
Spastics Association of Hong Kong, 134 V
Standards, 41, 45, 51, 57, 59, 61, 84, Values, 7, 41, 45, 53, 56–58, 84, 118,
88, 89, 115, 117, 134, 157, 171, 138, 154, 190, 195
173, 174, 178, 179, 184, 201, Voluntary sector, 7, 36, 62
206, 208, 214 Vulnerable children, 115, 118, 151
Index 227
W X
Welfare, 1–6, 9, 14–18, 20, 21, 25, Xi administration (era/years), 4, 5,
26, 36, 37, 51, 56, 60, 69–74, 50, 80
76–83, 85, 87, 88, 90, 91, 95, Xiamen, 49
98, 99, 102, 103, 105, 110, 115, Xiaonanhai dam, 48
117, 118, 122, 125, 130, 134, Xiaoping, Deng, 70
137, 140, 148–150, 153, 157, Xingtai, 98, 110, 119
159, 160, 164–175, 177–179, Xingtai Parish, 97, 112
181, 182, 187, 191, 195, 196,
198, 199, 204, 206–209, 213,
214, 216 Y
Welfarist incorporation, 16, 81, 161, Yunnan, 23, 49, 79, 151, 213
188, 198, 207–209
Wenchuan earthquake, 77, 79
Wenling County, 48 Z
World Trade Organisation (WTO), Zemin, Jiang, 69, 71
15, 71 Zhejiang, 48
World Vision, 126, 130, 167, 168, Zhongnanhai, 76
177
Wubao, 113
Wuxi, 48, 49

+++ NGOs and Accountability in China PDF

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

+++ NGOs and Accountability in China PDF

Uploaded by

Copyright:

Available Formats

NGOs and

Jude Howell, Xiaoyuan Shang, and

ISBN 978-3-319-90220-3 ISBN 978-3-319-90221-0 (eBook)

Library of Congress Control Number: 2018939754

Cover image: © Photography by Bobi

Printed on acid-free paper

This Palgrave Macmillan imprint is published by the registered company Springer

This book is the latest result of over three decades of research on

Any research project relies always on a team of dedicated researchers.

London, UK Jude Howell

2 Setting the Theoretical Scene 33

3 Welfare Reforms, Child Welfare NGOs,

Challenges of Accountability for NGOs in China 83

4 Making Accountability—Liming Family 95

5 Accountability and User Participation—The Case

7 Accountability of a Mixed Child Welfare Organisation 163

Policy Implications 206

Fig. 7.1 Children in the Mixed Welfare Institution 1985–2009 166

Table 1.1 Characteristics of child welfare organisations 24

© The Author(s) 2019 1

providers have these crucial components hinges on putting in place

service-delivery NGOs eligible to bid for governmental welfare services

government delegations to visit their services. This tolerance is not just

Clearing the Conceptual Path

(1) Who can demand accountability?

Conceptually, the notion of accountability is complex, contested, and

organisation, or third sector organisation (Bebbington et al. 2008; Lewis

unregistered due to the considerable difficulties obtaining registration.

Aims and Research Questions

The key research questions investigated are:

• What processes of accountability has the organisation established

• How do users participate in the organisation and how is informa-

• What are the power relations between those demanding account-

welfare in China. In particular, it examines accountability to these three

accepting of state propaganda and able to organise through the Iinternet.

system of welfare provision that centred on the work unit (danwei).

that local NGOs complied with financial accountability to funders but

Why Child Welfare Groups?

child protection so as to improve the welfare of disadvantaged children

maintaining their legal accountability, they also have to be politically and

Thus, a situation of both over-regulation and under-regulation pre-

semi-structured interviews with key informants, and process tracing

Table 1.1 Characteristics of child welfare organisations

All organisations 188 100

Hebei province has been home to many orphanages run by churches

all willing to participate in more detailed interviews, interactions, and

We sketch the development of policies, laws, and regulations governing

times. Though the local government and Disabled Persons’ Federation

Kilby, P. (2006). Accountability for empowerment: Dilemmas facing non-­

Setting the Theoretical Scene

In exploring the issue of accountability and legitimacy of non-­governmental

© The Author(s) 2019 33

demanding accountability from their governments through the courts or

of new public management coupled with the delegation of authority to

accountability as noted above (Mattei 2007), there are also tensions

informally summon sanctions to alter behaviour. Legal or regulatory

Accountability and NGOs

formula of A and B. Whilst governments in liberal democratic regimes

legal frameworks shaping the accountability relationship between citizen

Accountability and User Participation

substantive democratisation of society. Without addressing unequal

Accountability in Authoritarian Regimes

misuse of power (Bovens 2007, p. 462). It is also important as a means

Fig. 7.1 Children in the Mixed Welfare Institution 1985–2009 166

Table 1.1 Characteristics of child welfare organisations 24

(1) Who can demand accountability?

organisation, or third sector organisation (Bebbington et al. 2008; Lewis

Aims and Research Questions

Table 1.1 Characteristics of child welfare organisations

Kilby, P. (2006). Accountability for empowerment: Dilemmas facing non-

In exploring the issue of accountability and legitimacy of non-governmental

Accountability and User Participation

Accountability in Authoritarian Regimes

Accountability and Institutional Change

Framework of Analysis of Accountability

morally obliged to respond to account-holders’ demands for account

Table 2.1 Legitimacy and accountability of NGOs

Background on Development of NGOs in China

In 2010 the launch of the China Foundation Centre, a non-

Challenges of Accountability for NGOs in China

Accountability of Registered Child Welfare

Liming Family: Origins, Purpose, and Activities

Operating in the Interstices of Legality

Struggle for Legitimate Registration

Seeking Government Funds for Shared Responsibilities

Extracting Benefits to Secure Children’s Rights

Reputation and Trust as Accountability Capital