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Audit Database Project Compliance Recommendations
The Audit Project Recommendations - Contents
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# Article Title
1 USAID’s Marking Requirement Is Not Being Followed - ADS 320.3

According to USAID Automated Directives System 320.3.2.4b, “Marking Requirements for Specific Contract Deliverables,” programs, projects, or activity sites financed by USAID contracts that are physical in nature must prominently display the USAID identity, including the USAID logo.

The regulations further state that USAID contractors may request waivers from the Marking Plan, in whole or in part, through the contracting officer. Exceptions to contract marking requirements include situations in which the USAID identity would compromise the intrinsic independence or neutrality of a program, such as independent media.

General Recommendations

  • Require the implementing partner to mark [the center] with the USAID logo or submit a written request to the mission for a waiver.

Source: AUDIT REPORT NO. 5-388-11-005-P FEBRUARY 11, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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2 USAID Branding Requirements not Followed - ADS 320 - 22 U.S.C. § 2401

Section 641 of USAID's framework legislation, the Foreign Assistance Act of 1961, as amended, codified at 22 U.S.C. § 2401 requires that all programs under the Foreign Assistance Act be identified appropriately overseas as "American Aid."

To help ensure compliance with this requirement, ADS 320, Branding and Marking, contains USAID’s policy directives and required procedures for branding and marking USAID-funded programs, projects, activities, public communications, and commodities.

Contracts and subcontracts exclusively funded by USAID, must use the USAID identity for branding and marking purposes. Where applicable, a host-country symbol or ministry logo or another U.S. Government logo may be added.

General Recommendations

  • Develop and implement a plan for monitoring the implementation of the branding and marking plan in compliance with USAID branding requirements.

Source: AUDIT REPORT NO. 4-650-11-010-P JULY 28, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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3 Implementer Has Not Complied With the Project Branding and Marking Plan - ADS 320

The [project’s] branding and marking plan stipulates that co-branding with a local project name to emphasize local government oversight and leadership would be considered on a case-by-case basis by the contracting officer’s technical representative (COTR), contracting officer, and chief of party.

Additionally, if a decision was made to adopt an alternative project name in order to enhance host-government ownership, a waiver request would be made to allow such a deviation from the guidelines.

“Branding” refers to how a program or project is named and positioned, who it is from; it identifies the sponsor of the work. “Marking” refers to applying graphic identities or logos to program materials or project signage to visibly acknowledge contributors; it identifies organizations supporting the work. [USAID regulation ADS 320.1] 

General Recommendations

  • Comply with the branding and marking policy and submit a written request to the mission for a waiver to use the [Network] name and logo on appropriate project documents and signage.

Source: AUDIT REPORT NO. 5-388-11-008-P JULY 21, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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4 USAID Branding and Marking Requirements Are Not Being Followed - Foreign Assistance Act of 1961, Public Law 87–195, section 641 - ADS 320

According to USAID’s framework legislation, the Foreign Assistance Act of 1961, Public Law 87–195, section 641, all programs under the act must be identified appropriately overseas as “American Aid.” In addition, the USAID Automated Directive System (ADS) contains USAID’s policies and required procedures on branding and marking USAID-funded programs, projects, activities, public communications, and commodities (ADS 320).

General Recommendations

  • Document compliance with requirements of USAID Automated Directive System 320, “Branding and Marking”, or submit a written request to the mission for a waiver from the requirements.

Source: AUDIT REPORT NO. 5-306-10-006-P January 29, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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5 Branding Requirements Were Not Followed - ADS 320, Branding and Marking - Section 641 of USAID’s framework legislation, the Foreign Assistance Act of 1961

Ensuring that the American people are appropriately recognized for their generosity in funding U.S. foreign assistance has been a long-standing U.S. Government objective. For example, section 641 of USAID’s framework legislation, the Foreign Assistance Act of 1961, as amended, specifies that all programs under the act be identified as “American Aid.”

More recently, the importance of development in the United States’ post–September 11 national security strategy increased the need for U.S. foreign assistance activities to be identified more fully in host countries as being provided by the United States.

To help ensure that U.S. foreign assistance is recognized as such, USAID has issued Automated Directives System 320, Branding and Marking, which requires an approved marking plan for USAID projects. USAID programs, projects, activities, public communications, and commodities with USAID funding are required to be branded as from USAID.

The failure to have effective branding of USAID-funded vehicles and other commodities contributes to a lack of awareness of USAID programs.

General Recommendations

  • Issue written guidance to implementing partner staff reinforcing the Agency's branding requirements and their importance.

  • Analyze current branding practices and develop a written plan that makes the branding of USAID-funded activities, commodities, and other elements effective.

  • Develop and implement a written plan to (a) identify USAID-funded commodities that have not been properly branded and (b) brand those commodities.

Source: AUDIT REPORT NO. 4-663-10-003-P  MARCH 30, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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6 Implementing Partner Need to Adhere to Branding and Marking Policy - ADS 320.3.1 - ADS 320.3.2.4

According to ADS 320.3.1, USAID employees must ensure that the applicable branding and marking policy directives and procedures are included in the instruments USAID uses to implement development assistance programs and projects.

ADS 320.3.2.4 generally requires Marking Plans to be incorporated in USAID direct contracts to ensure that programs, projects, activities, public communications, or commodities prominently display the USAID identity. ADS 320.3.1 also states that to comply with the general requirement that USAID-funded foreign assistance be branded and marked, employees involved in program implementation must ensure that USAID implementing partners communicate that the assistance is from the American people.

ADS 320.3.2.5 provides for exceptions to contract marking requirements, and ADS 320.3.2.6 addresses waivers to contract marking requirements.

General Recommendations

  • Require Implementing Partner to Adhere to Branding and Marking Policy.

Source: AUDIT REPORT NO. 7-685-10-005-P March 15, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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7 Adhering to Branding Requirements - ADS 320

ADS 320, Branding and Marking, Section 320.3.2, requires an approved marking plan for USAID contracts. USAID programs, projects, activities, public communications, and commodities with USAID funding are required to be “branded with a standard graphic identity.”

It is also USAID policy to prohibit the use of the USAID identity on contractor and recipient business cards, although they may include such wording as “USAID Contractor” or “USAID Grantee” as appropriate on their employees’ business cards to identify that these individuals are working on a USAID-funded activity.

General Recommendations

  • Require partners to implement branding plans and take the necessary steps to ensure adherence to USAID branding guidelines.

Source: AUDIT REPORT NO. 7-688-10-004-P February 26, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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8 USAID Branding and Marking Guidelines Were Not Followed

According to a Government Accountability Office (GAO) report dated March 2007, the United States is one of the largest donors of foreign assistance to countries around the world; however, many of the recipients of this aid are unaware that it is provided by the United States.

Congress has expressed concerns that the United States has frequently understated or not publicized information about its foreign assistance programs and, as a result, the generosity of the people of the United States has not been fully understood abroad. Congress, concerned about poorly marked U.S. foreign aid donation, required that all programs under the Foreign Assistance Act be identified appropriately overseas as from American aid.

Responding to Congress’ concerns, USAID states in its policies that adequate public recognition shall be given in the press, by radio and other media that the commodities or assistance have been provided through the friendship of the American people [as food for peace]. At distribution and feeding centers or other project sites, cooperating sponsors shall, to the extent feasible, display banners, posters, or similar media, and recipients’ individual identification cards shall, insofar as practicable, be imprinted to contain such information, such as the USAID emblem or indication that the commodities were provided through the friendship of the American people [as food for peace].

General Recommendations

  • Develop a plan and timetable for assistance programs to (a) sensitize communities benefiting from the [food] aid, and (b) mark projects and sites supported with [food] aid.

Source: AUDIT REPORT NO. 7-685-10-003-P February 11, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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9 Partner Did Not Adhere to Branding Requirements - ADS 320

ADS 320, “Branding and Marking,” generally requires “that all USAID-funded foreign assistance must be branded through the use of a ‘Branding Strategy’ and marked through the use of a ‘Marking Plan.’” USAID programs, projects, activities, public communications, and commodities with USAID funding are generally required to be branded with a standard graphic identity.

Examples of noncompliance with USAID’s branding requirements include:

  • At the offices visited, none of the USAID-funded fixed assets—air-conditioners, chairs, TVs, computers, etc.—were branded with the appropriate USAID logo.
  • Personnel did not know that USAID was the sponsor of the training they received.
  • Computers and printers donated by USAID were inappropriately branded with [implementing partner's] logos and markings.
  • Students were unable to identify USAID or the American people as the sponsor.
  • USAID trainee was unable to identify USAID as the donor.
  • Vehicles used were not appropriately branded. Although the Regional Security Office opposed branding vehicles, no waivers were obtained.
  • Branding implementation plan was not approved. 

General Recommendations

  • Direct all partners in writing to develop branding plans to ensure adherence to USAID branding guidelines (which may include obtaining waivers).

Source: AUDIT REPORT NO. 7-641-10-006-P JUNE 28, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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10 Branding Policy Not Enforced - Section 641 of the Foreign Assistance Act of 1961 - 22 U.S.C. 2401.

Section 641 of the Foreign Assistance Act of 1961, as amended, requires that all foreign assistance programs be identified appropriately overseas as American aid. USAID’s policy is that programs, projects, activities, public communications, or commodities implemented or delivered under grants, cooperative agreements, or other assistance awards are generally “co-branded and co-marked.” 22 U.S.C. 2401.  

General Recommendations

  • Enforce partner compliance with USAID’s branding requirements, including obtaining documentation from partners that they have effectively communicated to service providers and beneficiaries that the American people are funding program activities

SOURCE: AUDIT REPORT NO. 4-656-10-006-P  JULY 16, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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11 Obtain Commitment From Beneficiaries - USAID’s joint Strategic Plan, Fiscal Years 2007–2012 - ADS 596.3.1 - GAO Standards for Internal Control in the Federal Government2 GAO/AIMD-00-21.3.1 (11/99), page 15

The Department of State and USAID’s joint Strategic Plan, Fiscal Years 2007–2012 discusses the concept of transformational diplomacy as a relationship wherein U.S. assistance plays a catalytic role in supporting a host country’s national vision for advancement. However, the primary responsibility for achieving transformation ultimately rests with the developing nation’s leadership and citizens.

Lasting economic, social, and democratic progress—through a transformation of institutions, economic structures, and human capacity—can begin with USAID development, but host countries, as benefactors, will need to sustain further advances on their own. USAID programs are expected to help move countries through the development process that leads to their graduation from U.S. foreign assistance.

Also, Automated Directives System 596.3.1, “Establishing Internal Controls,” states that USAID managers and staff must develop and implement appropriate, cost-effective internal controls toward management that produce results. These controls include appropriate documentation. The U.S. Government Accountability Office’s (GAO) Standards for Internal Control in the Federal Government - GAO/AIMD-00-21.3.1 (11/99), page 15- states that all transactions and other significant events need to be clearly documented, and the documentation should be readily available for examination.

General Recommendations

  • Develop a memorandum of understanding with the Government of [...] regarding a commitment to use the [...] for a specific time for its intended purpose and document the results of any disagreements.

SOURCE: AUDIT REPORT NO. 6-268-10-006-P August 24, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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12 USAID-Funded Publications Not Properly Marked - 22 CFR 226.91

Branding and marking requirements for USAID assistance are established by 22 CFR 226.91, which requires that specific activities partially or fully funded by a USAID grant or cooperative agreement or subaward be marked appropriately with the USAID identity.

Activities financed by USAID should bear the USAID identity, including the USAID logo. The regulations further state that USAID implementing partners may request waivers from these requirements, in whole or in part, through the contracting officer.

Presumptive exceptions to the requirements include situations in which the USAID identity would compromise the intrinsic independence or neutrality of a program, such as elections monitoring or ballots, and voter information literature and political party support.

General Recommendations

  • Develop a marking and branding plan and verify that the plan has been implemented.

Source: AUDIT REPORT NO. F-306-11-003-P JUNE 19, 2011 

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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13 Implementers’ Branding and Public Announcement Efforts Not Monitored - ADS 320.3.1 - ADS 320.2a(3)

Mission employees involved in program implementation must ensure that implementing partners communicate that the USAID-funded foreign assistance is from the American people, according to ADS 320.3.1. Therefore, foreign assistance must be branded through use of a branding strategy and marked with a marking plan.

In addition, the mission should inform host-country government officials and their implementing partners about USAID’s marking requirements and the host-country government’s responsibilities, and negotiate changes as needed (ADS 320.2a(3)). Failure to meet the marking requirements may be considered noncompliance with the contract, assistance award, or other USAID funding mechanism. Exceptions and waivers to the branding and marking requirements are available, if requested by the awardees and approved by the mission.

General Recommendations

  • Develop and implement a plan to monitor and document the status of branding and marking plans of contractors and provide training as necessary for compliance with Automated Directives System 320.

Source: AUDIT REPORT NO. G-391-11-005-P JUNE 20, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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14 Locations Lacked USAID Branding - Section 641 of USAID's framework legislation, the Foreign Assistance Act of 1961 - ADS 320, ?Branding and Marking

Section 641 of USAID's framework legislation, the Foreign Assistance Act of 1961, as amended, requires that all programs under the Foreign Assistance Act be identified appropriately overseas as "American Aid."?

To help ensure compliance with this requirement, ADS 320, ?Branding and Marking, contains USAID’s policy directives and required procedures on branding and marking USAID-funded programs, projects, activities, public communications, and commodities.

General Recommendations

  • Include a section in the standard site visit report template to verify compliance with USAID branding policies and regulations.

Source: AUDIT REPORT NO. 4-696-11-008-P JULY 1, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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15 Items Funded by USAID Were Not Properly Marked - ADS 320.3.3

USAID’s Automated Directives System 320.3.3 sets forth USAID’s policy that programs, projects, activities, public communications, or commodities implemented or delivered under co-funded instruments, such as cooperative agreements, generally be co-marked with the USAID identity.

General Recommendations

  • Evaluate the branding and marking plan and make a determination as to the acceptability of the plan.

Source: AUDIT REPORT NO. 5-306-11-002-P NOVEMBER 5, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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16 Effectiveness of USAID Branding Needs to Be Improved - section 641 of USAID’s framework legislation, the Foreign Assistance Act of 1961, codified as amended in 22 U.S.C. 2401 - ADS 320.3.4.5 - , 22 CFR 211.5(h)

Ensuring that the American people are appropriately recognized for their generosity in funding U.S. foreign assistance has been a long-standing U.S. Government objective. For example, section 641 of USAID’s framework legislation, the Foreign Assistance Act of 1961, codified as amended in 22 U.S.C. 2401, specifies that all programs under the act be identified appropriately overseas as “American Aid.” More recently, the United States’ post–September 11 national security strategy increased the need for U.S. foreign assistance activities to be more fully identified in host countries as being provided by the United States.

To help ensure that U.S. foreign assistance is recognized as such, ADS 320.3.4.5 requires that commodities funded under the Food for Peace program be marked in accordance with 22 CFR 211. In addition, 22 CFR 211.5(h) states that to the maximum extent practicable, and with the cooperation of the host government, adequate public recognition shall be given in the press, by radio, and other media that the commodities or assistance financed by monetized proceeds or program income have been provided through the friendship of the American people as Food for Peace.

At distribution and feeding centers or other project sites the cooperating sponsor shall, to the extent feasible and unless otherwise specified, display banners, posters, or similar media which shall contain the USAID emblem, commodity names, and language to reflect that commodities are provided through the friendship of the American people as Food for Peace and are not to be sold or exchanged (where applicable).

General Recommendations

  • Ensure branding strategy focuses  on direct communication with project beneficiaries.

Source: AUDIT REPORT NO. 4-617-11-001-P NOVEMBER 10, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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17 Subcontractor Did Not Manage Beneficiary Expectations Effectively - USAID’s Nine Principles of Development and Reconstruction Assistance

According to USAID’s Nine Principles of Development and Reconstruction Assistance, partnership is another principle crucial to the success of U.S. foreign assistance. Partnership entails close collaboration between USAID and the governments and communities it assists.

Part of this close collaboration involves informing stakeholders of estimated dates for completion.

General Recommendations

  • Regularly inform recipients of technical assistance about program status.

Source: AUDIT REPORT NO. 4-650-11-003-P DECEMBER 29, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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18 Public Awareness of U.S. Efforts Needs To Be Improved - ADS 320 - Section 641 of USAID’s framework legislation - the Foreign Assistance Act of 1961, codified as amended in 22 U.S.C. 2401

The importance of ensuring that the American people are appropriately recognized for their generosity in funding U.S. foreign assistance has been a longstanding U.S. Government objective. For example, section 641 of USAID’s framework legislation, the Foreign Assistance Act of 1961, codified as amended in 22 U.S.C. 2401, specifies that programs under the act be identified appropriately overseas as “American aid.”

More recently, the rising importance of development as part of the United States’ post–September 11 national security strategy increased the need for U.S. foreign assistance activities to be more fully identified in host countries as being provided by the United States. This need is addressed in ADS 320, which contains USAID’s branding and marking requirements.

General Recommendations

  • Ensure compliance with contractual branding and (2) devise a branding and marking plan that is in accordance with contractual branding requirements.

Source: AUDIT REPORT NO. 4-674-11-004-P JANUARY 4, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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19 Branding and Marking Plan Not Approved - ADS 320 - Section 641 of the Foreign Assistance Act of 1961 - 22 CFR 226.91

ADS 320 implements the requirement in Section 641 of the Foreign Assistance Act of 1961, as amended, that “[p]rograms under this Act shall be identified appropriately overseas as ‘American Aid.’” Branding and marking requirements for assistance are also established by 22 CFR 226.91 and ADS 320.

A branding and marking plan permits implementing partners to propose a strategy emphasizing the [host] Government’s participation in or leadership of program activities.

General Recommendations

  • Determine the acceptability of the branding and marking plan and verify its implementation.

SOURCE: AUDIT REPORT NO. F-306-11-001-P FEBRUARY 13, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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20 Locations Do Not Have Adequate Branding - ADS 320.3.2.4.a-b

Ensuring that the American people are appropriately recognized for their generosity in funding U.S. foreign assistance has been a long-standing U.S. Government objective.

USAID’s branding guidance is established in ADS 320.3.2.4.a, which states that “commodities or equipment provided under humanitarian assistance, disaster relief or development programs, and all other program commodities and equipment funded by USAID contracts, and their export packaging, must prominently display the USAID Identity.”

Additionally, ADS 320.3.2.4.b states that “program, project, or activity sites financed by USAID contracts, including visible infrastructure projects (roads, bridges, buildings, etc.) or others that are physical in nature (agriculture, forestry, water management, etc.), must prominently display the USAID Identity.

Temporary signs must be erected early in the construction or implementation phase. When construction or implementation is complete, the contractor must install a permanent, durable and visible sign, plaque, or other marking.”

General Recommendations

  • Establish and implement procedures to ensure that staff are aware of their responsibilities regarding USAID’s branding requirements.

Source: 7-669-11-007-P Year: 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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Anti-Trafficking top
# Article Title
1 Establish Baseline Data on Trafficking Victims - Foreign Assistance Act of 1961, Section 621A, 22 U.S.C. 2381a - ADS 203.3.4.5

The Foreign Assistance Act of 1961, Section 621A, 22 U.S.C. 2381a, is entitled Strengthened Management Practices and states that Congress believes that U.S. foreign aid funds could be utilized more effectively by applying advanced management decision making, and information and analysis techniques. To meet this need, the President shall establish a management system that includes methods for comparing actual results of programs and projects with the results anticipated when they were undertaken.

In addition, Automated Directives System (ADS) 203.3.4.5 states that, for each indicator in a performance management plan, the assistance objective team should include performance baselines and set performance targets that are ambitious but that can be achieved realistically within the stated timeframe and with the available resources.

Baseline values should be measured using the same data collection source and method that will be used to collect actual performance data. If baseline data cannot be collected until later in the course of an assistance objective, the assistance objective team should document when and how the baseline data will be collected.

According to a U.S. Government Accountability Office (GAO) audit report on Human Trafficking dated July 2007, estimates of the numbers of trafficking victims are needed for baselines to evaluate how effectively specific interventions are reducing trafficking. Another GAO audit report on human trafficking issued in 2006 found that, for data collection as a whole, the accuracy of the estimates of trafficking is in doubt because of methodological weaknesses, gaps in data, and numerical discrepancies. The report further states that country data are not available, reliable, or comparable and a considerable discrepancy exists between the numbers of observed and estimated victims of human trafficking.

GAO-07-1034, HUMAN TRAFFICKING: Monitoring and Evaluation of International Projects Are Limited, but Experts Suggest Improvements, July 2007.

5 GAO-06-825, HUMAN TRAFFICKING: Better Data, Strategy, and Reporting Needed to Enhance U.S. Anti-trafficking Efforts Abroad, July 2006.

General Recommendations

  • Develop and implement a plan to establish and implement a national data collection system.

Source: AUDIT REPORT NO. 9-000-10-002-P December 10, 2009

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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2 The William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008 (the Wilberforce Act), Public Law 110-457 - Section 106(g) of the Trafficking Victims Protection Act of 2000 (22 U.S.C. 7104) - FAR Clause 52.222-50

The William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008 (the Wilberforce Act), Public Law 110-457, requires the Office of Inspector General of USAID to investigate contracts and subcontracts under which there is a high risk that the contractor may engage in acts related to trafficking in persons. The Wilberforce Act requires a review each fiscal year from 2010 until 2012.

The Wilberforce Act describes actions that indicate trafficking in persons, including confiscation of an employee’s passport, restriction of an employee’s mobility, abrupt or evasive repatriation of an employee, deception of an employee regarding the work destination, and acts otherwise described in Section 106(g) of the Trafficking Victims Protection Act of 2000 (22 U.S.C. 7104).

  • Contract Clauses. May include FAR Clause 52.222-50 on combating trafficking in persons.
  • Contractor Policies. Communicate policy on human trafficking to employees in staff meetings, in staff members’ native languages. Post information about human trafficking policies at the housing compound and in the dining facility.
  • Hiring Practices. The employees said they specifically chose to work in [country] and were told in advance the type of work they would be doing.
  • Passport Restrictions. Employees maintained possession of their passports at all times. Their employment agreement explicitly forbids [contractor] from withholding their passports except when required for necessary administrative procedures.
  • Movement Restrictions. According to the employees and their employers, their movement was not restricted beyond normal security procedures. The employees are free to leave their housing compound during their 1 day off each week.
  • Repatriation. The employment agreement includes a provision for repatriation, stating that the company will pay for transportation for employees back to their home countries after the end of the agreement. If employees resign or are terminated before the completion of the full year of the agreement, they become responsible for the cost of transportation to their home countries.
  • Work Destination and Other Terms of Employment Agreements. Each employee had a 1-year employment agreement written in English. Many of the employees spoke and read English, and all employees interviewed said that they understood the content of the agreement. In addition, some employees reported that the agency had explained the agreement to them in their native languages. The agreement also includes clauses expressly forbidding debt bondage and the confiscation and withholding of employee passports and other immigration documents.

Source: Based on Report No. E-267-11-002-S

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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Anti-Terrorism top
# Article Title
1 Review and Obtain Antiterrorism Certifications - ADS 596.3 - Executive Order 13224

Management controls and contractual requirements provide the basis for minimal requirements to ensure that program goals are achieved efficiently and effectively. ADS 596.3.1.c, Establishing Internal Controls, states that in order for control activities to be effective and efficient to accomplish Agency objectives, management must conduct reviews at the functional and activity level.

Executive Order 13224 prohibits transactions with, and the provision of resources and support to, individuals and organizations associated with terrorism. The antiterrorism certification is used to provide USAID with assurance that the Agency is not entering into an assistance agreement with an individual or organization that provides or has provided assistance to terrorists or terrorist activity.

The antiterrorism certification requires an applicant to state that “to the best of its current knowledge, it did not provide, within the previous ten years, and it will take all reasonable steps to ensure that it does not and will not knowingly provide, material support or resources to any individual or entity that has engaged or engages in terrorist activity.”

General Recommendations

  • Obtain and review antiterrorist certifications for grants and implement specific procedures to obtain antiterrorism certifications before awarding any new grant.

  • Remind contractors of the antiterrorism certification requirements and periodically verify that procedures are followed.

Source: AUDIT REPORT NO. 6-278-10-004-P March 31, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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2 Required Antiterrorism Provisions Were Not Included in Some Subawards – Executive Order 13224 on Terrorism Financing

U.S. law prohibits transactions with individuals and organizations associated with terrorism. Consequently, grants, and cooperative agreements with implementing partners contain the following section, titled “Executive Order 13224 on Terrorism Financing”:

U.S. Executive Orders and U.S. law prohibits transactions with, and the provision of resources and support to, individuals and organizations associated with terrorism. It is the responsibility of the contractor/recipient to ensure compliance with this Executive Order and applicable laws. This provision must be included in all subcontracts/subawards issued under contract.

Contract provisions such as Executive Order 13224 heighten public awareness of individuals and entities linked to terrorism, and promote due diligence by private sector entities to avoid associations with terrorists. Without ongoing communication about specific antiterrorism requirements and periodic verification of procedures and compliance, [one] has little assurance that programs do not inadvertently support entities or individuals associated with terrorism.

General Recommendations

  • Require that implementing partners verify and certify that all subawards include the required provision related to Executive Order 13224.

Source: AUDIT REPORT NO. 4-663-10-003-P  MARCH 30, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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3 Ensure That Antiterrorism Measures Are Conducted - ADS 303 - Assistance Policy Directive 04-14, Certification Regarding Terrorist Financing Implementing E.O. 13224, issued on September 24, 2004 - Executive Order 13224

Mandatory Standard Provisions for Non-U.S., Nongovernmental Recipients, a mandatory reference for ADS 303, Grants and Cooperative Agreements to Nongovernmental Organizations, and Acquisition and Assistance Policy Directive 04-14, Certification Regarding Terrorist Financing Implementing E.O. 13224, issued on September 24, 2004, implemented Executive Order 13224 on Terrorist Financing.

The directives establish the legal responsibility for recipients of USAID funds to comply with the order and other laws.. Some USAID missions implement Executive Order 13224 using three specific requirements:

  • Mandatory Clauses – require mandatory provisions to be included in all solicitations and awards for contracts, grants, cooperative agreements, subcontracts, and subawards indicating that a recipient will comply with antiterrorism guidance.
  • Certification – requires all U.S. and non-U.S. entities to certify that they do not provide material support or resources for terrorism.
  • Vetting – requires inquiries from individuals and searches of special databases for background information on contractors and subcontractors who receive in excess of $25,000, as well as recipients of assistance instruments regardless of the dollar amount.

Additionally, ADS 303.2, Primary Responsibilities, requires agreement officers’ technical representatives to be responsible for prudently managing assistance awards by monitoring to ensure recipients’ compliance with legally binding award terms and conditions.

General Recommendations

  • Review programs to determine whether antiterrorism measures would help to mitigate the risk of inadvertently providing financing to terrorist organizations or individuals associated with terrorism.

  • Provide training on USAID’s antiterrorism measures.

Source: AUDIT REPORT NO. 6-263-10-001-P October 27, 2009.

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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4 Project Documentation to Ensure Adequate Monitoring Not Reviewed - ADS 303.2.f - ADS 596.3.1

USAID provides guidance to staff regarding management controls for monitoring and evaluating an implementer’s performance under USAID awards.

ADS 303.2.f, Primary Responsibilities, requires the AOTR to ensure that USAID exercises prudent management over its awarded assistance by monitoring and evaluating the recipient and its performance during the award. Moreover, the AOTR designation letter for the project states that the AOTR is responsible for monitoring the recipient’s progress in achieving the objectives and for verifying that the recipient’s activities being funded by USAID conform to the terms and conditions of the award.

In addition, ADS 596.3.1, Establishing Internal Controls, requires USAID managers to develop internal control activities to help ensure that management directives are carried out. The control activities must be effective and efficient in accomplishing the Agency’s control objectives and include the establishment and review of performance measures and indicators and appropriate documentation for internal control.

General Recommendations

  • Provide documented procedures on USAID’s antiterrorism measures to its implementers and establish and implement a schedule to periodically verify that procedures are followed.
  • Develop an annual training plan for agreement officers' technical representatives and document annual course completion.

SOURCE: AUDIT REPORT NO. 6-279- 11-005-P February 28, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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5 Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism - Executive Order 13224 of September 23, 2001

Much federal guidance exists regarding the implementation of Executive Order 13224 of September 23, 2001—Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism, which prohibits support to individuals and organizations associated with terrorism.

To implement Executive Order 13224, USAID uses (1) certifications, (2) vetting, and (3) special contract provisions, such as a mandatory clause.

USAID’s Acquisition and Assistance Policy Directive 04-14, “Certification Regarding Terrorist Financing Implementing E.O. 13224” (Revision 2), requires agreement officers to obtain certifications from recipients that they did not and will not knowingly provide material support or resources, such as currency, lodging, or training, to any individual or entity that has engaged or engages in terrorist activity before an award is made.

As stated in the USAID policy directive, the implementer should verify that an individual or entity to which it provides material support or resources does not appear on lists maintained by the U.S. Government or the United Nations. Moreover, .... the implementer [is] required to include mandatory clauses regarding terrorist financing in all contracts and subawards issued under the agreement.

In addition, at the mission level, the agreement officer’s technical representative (AOTR) is responsible for verifying that the recipient’s activities conform to the terms and conditions of the award as outlined in the designation letter for agreement officer’s technical representatives, a management control.

General Recommendations

  • Obtain the antiterrorism certifications required and include the information in official award files.
  • Verify that secondary implementers and individuals provided with material support are not associated with terrorism.
  • Include requirements for certifications and mandatory clauses for the prohibition of terrorist financing.
  • Develop a schedule to verify periodically that implementers have taken actions to ensure that antiterrorism measures are followed in a timely manner.

Source: 6-263-11-007-p Year: 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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Grants Management top
# Article Title
1 Cost-Sharing Regulations - 22 CFR 226

The Code of Federal Regulations (CFR), Title 22, Part 226, establishes uniform administrative requirements for grants and cooperative agreements awarded by USAID to U.S. institutions of higher education, hospitals, and other nonprofit organizations.

Among the administrative requirements, 22 CFR 226.23 establishes the requirements for cost sharing or matching when the USAID awards include cost-sharing or matching provisions. According to 22 CFR 226.23(a), all contributions, including cash and third party in-kind, shall be accepted as part of the recipient's cost sharing or matching when such contributions are:

  • Verifiable from the recipient’s records;
  • Necessary and reasonable for proper and efficient accomplishment of project or program objectives;
  • Allowable under the applicable cost principles.

The Code of Federal Regulations (22 CFR 226.23(d)) states that volunteer services furnished by professional and technical personnel, consultants, and other skilled and unskilled labor may be counted as cost sharing or matching if the service is an integral and necessary part of an approved project or program.

Rates for volunteer services shall be consistent with those paid for similar work in the recipient’s organizations. In instances in which the required skills are not found in the recipient organization, rates shall be consistent with those paid for similar work in the labor market in which the recipient competes for the kind of services involved. In either case, paid fringe benefits that are reasonable, allowable, and allocable may be included in the valuation.

Source: AUDIT REPORT NO. 1-519-11-007-P AUGUST 9, 2011

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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2 Various Bank Accounts Were Used to Manage Program Expenses - ADS 303

According to USAID’s Mandatory Standard Provisions for Non-U.S. Nongovernmental Recipients (a mandatory reference for Chapter 303 of USAID’s Automated Directives System), the [grantee] should deposit all USAID advance cash payments in a separate bank account and make all disbursements for program goods and services (such as salaries, rent, and supplies) from this account.

General Recommendations

  • Establish and use a dedicated bank account for all program activity.

Source: Review Report No. 1-521-11-001-S  October 29, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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3 Monitoring Cost-Sharing Contributions - ADS 302.2

According to ADS 302.2, an AOTR is required to ensure that USAID exercises prudent management of its awarded assistance and facilitates the achievement of program objectives by monitoring recipient performance. Specifically, ADS requires the AOTR to monitor financial records to ensure that the recipient is making the required cost-sharing contributions.

Cost-sharing refers to amounts expended by an implementing partner—which are typically in-kind contributions of goods or services—in furtherance of an agreement’s objectives.

Source:AUDIT REPORT NO. 4-674-11-009-P JULY 20, 2011

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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4 Strengthen Monitoring of Partners’ Performance - ADS 303.3

USAID’s Automated Directives System (ADS), chapter 303.3.17, addresses the administration of grants and cooperative agreements and advises that administration responsibilities may include reviewing and analyzing performance reports, performing site visits, and substantial involvement by USAID in a cooperative agreement.

ADS 303.3.17(b) states that site visits are an important part of effective award management because they usually allow a more effective review of the project.

General Recommendations

  • Establish and implement a plan to provide performance monitoring and oversight for awards with the regular review of partner reports, compliance with award requirements, and random checks to ensure that implementing partners have support for claimed results.

Source: AUDIT REPORT NO. E-267-10-001-P MARCH 31, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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5 Grants With Special Conditions Were Not Monitored and Were Susceptible to Fraud - (22 CFR 226.14, “Special Award Conditions”) - ADS 303.3.9.2, “High Risk Recipients"

The Code of Federal Regulations (22 CFR 226.14, “Special Award Conditions”) states that if an applicant or recipient has:

a history of poor performance, is not financially stable, has a management system that does not meet the standards prescribed in this part, has not conformed to the terms and conditions of a previous award, or is not otherwise responsible, the USAID Agreement Officer may impose additional requirements as needed, provided that such applicant or recipient is notified in writing as to: The nature of the additional requirements, the reason why the additional requirements are being imposed, the nature of the corrective action needed, the time allowed for completing the corrective actions, and the method for requesting reconsideration of the additional requirements imposed.

Any special conditions will be promptly removed once the conditions that prompted them have been corrected.

ADS 303.3.9.2, “High Risk Recipients,” notes that although 22 CFR 226 is not directly applicable to awards to non-U.S. organizations, the standards in 22 CFR 226 may be used for non-U.S. recipients.

ADS also notes that an agreement officer may consider making a high-risk award with “special award conditions” only if it appears likely that the potential recipient can correct its deficiencies in a reasonable period of time. To minimize the risk of such awards, the following temporary conditions may be added: (1) special award conditions and (2) technical assistance to the recipient.

The contract {being reviewed] laid out specific requirements for the contractor in awarding and managing grants, regardless of recipient. The requirements are as follows.

  • The contractor shall comply in all material respects with ADS Chapter 303, “Grants and Cooperative Agreements to Non-Governmental Organizations,” in awarding and administering grants, as well as with 22 CFR 226 (Agency for International Development Part 226—“Administration of Assistance Awards to U.S. Non-Governmental Organizations”) to the extent that it may be relevant to such grants.
  • Prior USAID approval must be obtained for grants in accordance with ADS 302.5.6.
  • The COTR must approve the criteria for and selection of all grantees.
  • These grants will be awarded competitively. Limited competition may be considered. However, a program description and a list of prospective applicants must be approved by the cognizant technical officer.
  • Contracting officer approval is required for all grants over $100,000.
  • Minimum evaluation criteria will be proposed by the contractor and approved by USAID.
  • The contractor will carry out any necessary preaward actions with respect to the proposed grantees, such as financial reviews and an assessment of management capability, in accordance with criteria to be provided by USAID.
  • The contractor will ensure postaward management—reporting, audits, etc.—in accordance with USAID directives and policies.

General Recommendations

  • Require the contractor to comply with its internal procedures and grant requirements within the contract by developing an adequate records system to support claimed grant costs and (2) verify the contractor’s completed actions.
  • Make a complete inventory of grants awarded by the contractor from program inception, review grant files to ensure that documentation is adequate to support required procurement and monitoring requirements, and question and collect amounts for those grants not adequately supported.

SOURCE: AUDIT REPORT NO. E-267-11-002-P MAY 16, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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6 Monitor Cost Share Contributions - ADS 303.3.10.4, Meeting Cost Sharing Requirements

ADS 303.3.10.4, Meeting Cost Sharing Requirements, states that a technical representative should monitor the recipient's financial reports to ensure that contributions are being met and should elevate any issues to the agreement officer for resolution.

Cost share contributions are the resources a recipient contributes to the total cost of an agreement, which may include in-kind contributions, such as volunteer time, valuation of donated supplies, equipment, and other property. Furthermore, guidance authorizes an agreement officer to reduce the amount of the agreement or request recipients to refund the difference.

General Recommendations

  • Determine if appropriate cost share contributions have been made and document a plan to recover any outstanding contributions.

Source: AUDIT REPORT NO. 6-263-10-001-P October 27, 2009.

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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Environmental Assessments top
# Article Title
1 Environmental Requirements in Solicitations and Awards - 22 CFR 216 - ADS 204

The first step in USAID’s environmental assessment process is the Initial Environmental Examination, a document that details the effects of a proposed action on the environment, if that activity is not exempt from or excluded by Title 22 of the Code of Federal Regulations, Part 216—Environmental Procedures (22 CFR 216).

The Initial Environmental Examination evaluates the potential of program or project activities for environmental impact and establishes mitigation actions, including the monitoring and evaluation required from project design through implementation. The Initial Environmental Examination also determines the threshold decision, which is a formal agency assessment of whether a proposed agency action is a major action significantly affecting the environment and whether an Environmental Assessment or Environmental Impact Statement, more detailed environmental studies, will be required.

Threshold decisions are divided into the following categories:

  • Negative Determination Without Conditions (no impacts)
  • Negative Determination With Conditions (some risk of environmental impact)
  • Positive Determination (significant risk of environmental impact)
  • Deferral (activity is not developed enough to make a determination)

ADS Chapter 204, “Environmental Procedures” (204.3.4.a(6)), requires strategic objective teams and operating units to incorporate factors and mitigative measures identified in environmental evaluation documents (e.g., Initial Environmental Examination), as appropriate, in the design and implementation instruments for programs, projects, activities, or amendments.

The responsibilities of project implementers regarding these environmental requirements should be determined up front and explicitly enumerated in the solicitations and subsequent awards prior to project implementation. Therefore, contracting officer or agreement officer must incorporate these requirements into any contracts, grants, cooperative agreements, or other mechanisms used to implement the activity.

Monitoring Environmental Compliance Components During Project Implementation

The Code of Federal Regulations (22 CFR 216.3(a)(8)) requires that monitoring take into account environmental impacts during the implementation of certain projects, programs, and activities. ADS 204.2.c and ADS 204.3.4.b state that mission officials are responsible for ongoing monitoring and evaluation of activities to ensure they comply with USAID’s environmental procedures and to identify and address any new or unforeseen consequences arising during implementation. Monitoring and evaluation responsibilities include conducting site visits to ensure that all mitigative environmental measures in the award are implemented throughout the life of the award.

Designated Officers for Overseeing Implementation of 22 CFR 216

ADS 204.2 describes the responsibilities of USAID’s environmental advisors at the bureau, regional, and mission levels. The Agency Environmental Coordinator is responsible for overseeing the effective implementation of 22 CFR 216 throughout the Agency. At the bureau level, the bureau environmental officer is responsible for overseeing the effective implementation of 22 CFR 216 throughout all operating units in their bureau. Regional environmental advisors and mission environmental officers are responsible for advising teams, activity managers, contracting and agreement officer’s technical representatives, and operating unit heads on how best to comply with 22 CFR 216 requirements.

Source: AUDIT REPORT NO. 9-000-11-002-P JULY 21, 2011

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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2 Implementing Partner is Not In Compliance With Environmental Procedures - Code of Federal Regulations Title 22 Section 216, “Environmental Procedures - ADS 204

Code of Federal Regulations Title 22 Section 216, “Environmental Procedures,” requires USAID to ensure that the environmental consequences of USAID-financed activities are identified and considered prior to a final decision to proceed with an agreement, and that appropriate environmental safeguards are adopted.

It cites several agriculture-related activities (e.g., agricultural land leveling, use of pesticides, and irrigation and water management projects) as activities that automatically require an environmental assessment. This regulation requires that the mission prepare an initial environmental examination and subsequently monitor ongoing activities for compliance with approved initial environmental examination as well as related documents and assessments. The following are two key elements of an environmental examination:

  • A threshold decision, which is a formal Agency decision that determines, based on an Initial Environmental Examination, whether a proposed USAID action is a major action significantly affecting the environment.
  • Mitigation measures, which are steps to mitigate any adverse environmental impact that might arise as a result of USAID activities.

Conducting environmental reviews is an important step because agricultural activities such as using pesticides, grading land, installing permanent structures, and constructing facilities to care for animals can carry significant risk to the environment. Without proper environmental reviews, [one] cannot ensure that the program includes proper environmental safeguards. This heightens the risk of environmental damage as well as injuries to program workers and/or beneficiaries.

General Recommendations

  • Provide annual training to technical officers and document and monitor compliance with the environmental regulations outlined in USAID’s Automated Directives System 204.

  • Perform and document an environmental examination of the program and activities and (b) document the completion of any actions identified in the environmental examination as necessary to safeguard the environment.

Source: AUDIT REPORT NO. 4-663-10-003-P  MARCH 30, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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3 Environmental Expertise - ADS 204

ADS Chapter 204 describes roles, responsibilities, and decision-making authorities regarding USAID’s environmental procedures. ADS 204.3.5 states that it is the mission environmental officer’s role to assist and advise activity managers and their implementing partners in preparing environmental documents and monitoring environmental compliance on ongoing activities.

ADS 204.3.5 tasks the regional environmental advisor with providing supplementary professional support, training, and regional coordination on environmental matters to Mission Directors, mission staff, and mission environmental officers. Per ADS 204.2.e, bureau environmental officers are responsible for overseeing the effective implementation of environmental procedures throughout all missions and operating units in their bureau. The Agency environmental coordinator oversees Agencywide implementation of environmental procedures to ensure that intended results are achieved.

ADS 204 also requires mission environmental officers and regional environmental advisors to liaise with the bureau environmental officer on issues affecting their operating units and missions. Mission environmental officers and regional environmental advisors are responsible for advising mission staff on how to obtain additional environmental expertise to assist in their environmental responsibilities. In addition, ADS 204.2.a states that allocating adequate staffing and financial resources to fulfill Agency environmental policy is the responsibility of the bureau. The mission is responsible for providing the staff and financial resources to its management units to implement the approved strategies consistent with the Agency’s environmental procedures.

Implementation of USAID’s environmental procedures should be coordinated and enforced by the network of individuals outlined in ADS 204 and, when necessary, supplemented by additional resources available to missions.

Additionally, ADS 204 states that mission environmental officers and regional environmental advisors are responsible for advising mission staff on how to obtain additional environmental expertise to assist in their environmental responsibilities, and that allocating adequate staffing and financial resources to fulfill USAID environmental policy is the responsibility of the bureau.

Indefinite quantity contracts for specialists in sectors with complex environmental concerns such as agriculture, infrastructure, and industry are available to missions.

Source: AUDIT REPORT NO. 9-000-10-004-P MARCH 9, 2010

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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4 Improve Environmental Monitoring Procedures and Practices - 22 CFR 216.3.a.8 - ADS 204.3.4.b

According to 22 CFR 216.3.a.8, to the extent feasible and relevant, projects and programs with potential for environmental impact should be designed to include measurement of any changes in environmental quality, positive or negative, during their implementation.

This requires the collection of baseline data before project implementation. ADS 204.3.4.b states that mission staff is responsible for ongoing monitoring and evaluation of whether the environmental components designed for the activity resulting from the 22 CFR 216 process are being implemented effectively. This includes identifying and addressing new or unforeseen environmental consequences arising during implementation.

General Recommendations

  • For activities with Threshold Decisions of Negative Determination with Conditions and Positive Determination, we recommend that [the mission] include a clause in its contracts and assistance agreements to require distinct language in the implementing partners’ annual work plans stating how the partner will address environmental baseline data requirements as outlined in the Initial Environmental Examination and/or as required for the Environmental Review documents.

  • For activities with Threshold Decisions of Negative Determination with Conditions and Positive Determination, we recommend that [the mission] establish procedures to require implementing partners to provide activity managers with Environmental Mitigation and Monitoring Plans as part of their annual work plans.

Source: AUDIT REPORT NO. 9-000-10-004-P MARCH 9, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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5 Incorporate Environmental Assessment Requirements in Solicitations and Awards - ADS 204.3.4.a.6 - ADS 303.3.6.3.e - ADS 204.3.8

Automated Directives System (ADS) 204.3.4.a.6 and 303.3.6.3.e require incorporating the environmental assessment requirements outlined in the environmental evaluation documents into implementation instruments for programs, projects, activities, or amendments.

 ADS 204.3.8 states that strategic objective teams and activity managers must consider the environmental findings and recommendations made in the approved environmental evaluation documents when designing and approving funding for a program or activity. The contracting officer or agreement officer must incorporate these requirements into any contracts, grants, cooperative agreements, or other mechanisms used to implement the activity.

General Recommendations

  • For activities with Threshold Decisions of Negative Determination with Conditions and Positive Determination, we recommend that [the mission] establish and implement procedures to require implementing partners to respond to environmental assessment requirements in their proposal, detailing staff and budget necessary to address environmental assessment and monitoring concerns associated with the project.

  • For activities with Threshold Decisions of Negative Determination with Conditions and Positive Determination, we recommend that [the mission] establish and implement procedures to require activity managers to include environmental assessment and monitoring requirements in agreements and contracts signed by implementing partners.

Source: AUDIT REPORT NO. 9-000-10-004-P MARCH 9, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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6 Environmental Procedures - 22 CFR 216

Mission environmental officers are appointed by the Mission Director. Mission environmental officers assist and advise mission staff and their implementing partners and contractors in preparing documents on new activities and monitoring compliance on ongoing activities, in accordance with the Code of Federal Regulations (22 CFR 216, “Environmental Procedures”).

While the mission environmental officer assists and advises on environmental requirements, the strategic objective team leader and activity managers share the responsibility and accountability for meeting environmental requirements. The ultimate responsibility is with the Mission Director. Typically, mission environmental officer duties are only part of the full range of tasks of a USAID staff position.

Regional environmental advisors are typically based in select missions and support all the field offices in their geographic regions. Regional environmental advisors provide supplementary professional support, training, compliance auditing, compliance evaluations, and regional coordination on 22 CFR 216 matters to Mission Directors, strategic objective teams, activity managers, and mission environmental officers.

Bureau environmental officers are based in Washington, DC, and oversee and monitor compliance with 22 CFR 216 across all operating units in the bureau. The bureau environmental officer decides and approves all 22 CFR 216 documents and ensures that all staff in his or her bureau are aware of and trained in 22 CFR 216 procedures and standards.

The Initial Environmental Examination is the first step in USAID’s environmental assessment process. The Initial Environmental Examination is a document that details the effects of a proposed action on the environment. It evaluates the program activities with respect to environmental impact potential and establishes mitigation actions, including the monitoring and evaluation required from project design through implementation. The Initial Environmental Examination also determines the threshold decision, which is a formal agency assessment that determines whether a proposed agency action is a major action significantly affecting the environment. Threshold decisions are divided into the following categories:

  • Categorical Exclusion (no risk of environmental impact).
  • Negative Determination without Conditions (no impacts).
  • Negative Determination with Conditions (some risk of environmental impact).
  • Positive Determination (significant risk of environmental impact).
  • Deferral (activity is not developed enough to make a determination).

If sufficient detail is available at the time of development of the Initial Environmental Examination, this document also establishes environmental baseline data to be collected before activities commence.

Environmental Review documents are completed by implementing partners when specific project locations and activities are further defined after the contract is awarded and more detailed analysis is needed. These documents can include a variety of assessments, but they are meant to determine the scope and extent of additional environmental evaluation, mitigation, and monitoring necessary to fulfill Federal environmental requirements.

Environmental Mitigation and Monitoring Plans detail the measures required by the Initial Environmental Examination or the Environmental Review documents that will be implemented to lessen (or mitigate) any potential environmental impacts of an activity. These plans determine indicators or criteria for monitoring their implementation and effectiveness, and lay out who is responsible for mitigation and monitoring, as well as the frequency with which mitigation and monitoring data will be reported to mission staff.

Although compliance with USAID’s environmental requirements is mandatory, the internal processes by which missions and strategic objective teams must meet these requirements are largely unspecified. Each strategic objective team or operating unit is expected to develop its own processes or system.

Source:  AUDIT REPORT NO. 9-000-10-004-P MARCH 9, 2010

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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7 Revisions to Environmental Assessments Delay Agreements - Section 117 of the Foreign Assistance Act of 1961, as amended and as reflected in ADS Chapter 204, Environmental Procedures - ADS 202

Section 117 of the Foreign Assistance Act of 1961, as amended and as reflected in ADS Chapter 204, ?Environmental Procedures,? requires that the impact of USAID’s activities on the environment be considered and that USAID include environmental sustainability as a central consideration in designing and carrying out its development programs in foreign countries. According to ADS 202, program managers are responsible for managing and monitoring the compliance of their activities.

General Recommendations

  • Designate one person in each technical office who has received training to oversee environmental compliance for projects and activities.
  • Identify projects planned to determine whether sufficient support and technical expertise for environmental compliance exists.

Source: AUDIT REPORT NO. G-391-11-005-P JUNE 20, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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8 Environmental Procedures Not Followed - Title 22 of the Code of Federal Regulations, Part 216, “Environmental Procedures” Section 216.2(d)

Title 22 of the Code of Federal Regulations, Part 216, “Environmental Procedures,” requires USAID to ensure that the environmental consequences of USAID-financed activities be identified and considered prior to a final decision to proceed, and that appropriate environmental safeguards be adopted.

Title 22 of the Code of Federal Regulations, Section 216.2(d), identifies several classes of actions that normally have a significant effect on the environment and therefore require an environmental assessment or environmental impact statement. Among the classes of actions are irrigation and water management projects and leveling of agricultural land.

General Recommendations

  • Perform an environmental assessment for the program when required and implement any corrective actions that may be required.

SOURCE: AUDIT REPORT NO. F-306-11-001-P  FEBRUARY 13, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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9 Required Environmental Assessments Were Not Carried Out - Title 22 of the Code of Federal Regulations, Part 216, “Environmental Procedures.” Section 216.2(d)(1) - Section 216.2(d)(2)

USAID’s environmental procedures are included in Title 22 of the Code of Federal Regulations, Part 216, “Environmental Procedures.” Section 216.2(d)(1) states that new land development is part of a class of actions that have been determined generally to have a significant effect on the environment. Therefore, an environmental assessment or environmental impact statement, as appropriate, will be required.

Under Section 216.2(d)(2), however, if the originator of the project believes that the project will not have a significant effect on the environment, than an initial environmental examination will be prepared. If the initial environmental examination determines that the project would have a significant effect, an environmental assessment or environmental impact statement will be prepared.

General Recommendations

  • Complete the environmental assessments required by Title 22 of the Code of Federal Regulations, Part 216, “Environmental Procedures.”
  • Provide adequate supervision to reasonably ensure compliance with USAID’s environmental procedures.

SOURCE: AUDIT REPORT NO. F-306-11-002-P MARCH 27, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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10 Environmental Monitoring Was Not Conducted - 22 CFR 216, Environmental Procedures - ADS 204, Environmental Procedures - ADS 204.2.c

22 CFR 216, Environmental Procedures, describes the environmental procedures that USAID must follow on all its programs, projects, and activities. ADS 204, Environmental Procedures, requires USAID to ensure that the requirements of 22 CFR 216 are included in project design and implementation. Specifically, ADS 204.2.c, Primary Responsibilities, states that assistance objective teams, activity managers, and technical representatives are responsible for ensuring full compliance with 22 CFR 216.

An environmental review begins with an Initial Environmental Examination (IEE) of the reasonably foreseeable effects of a proposed action on the environment. Environmental conditions listed may include protection of air, surface soils/waters, and groundwater from wastewater contamination. They may also include the development of an environmental screening and review process to identify and mitigate adverse environmental impacts, and a requirement for strategic objective teams to actively monitor ongoing activities for compliance with approved IEE recommendations and to ensure adequate monitoring and reporting by a USAID contractor.

As required by the IEE, a USAID implementer’s annual and progress reports must contain a brief update on mitigation and monitoring measures being implemented, results of environmental monitoring, and mitigation and monitoring procedures.

General Recommendations

  • Develop and implement a plan with steps to ensure that implementers meet reporting requirements listed in Initial Environmental Examinations and any other environmental documentation.
  • Develop procedures on environmental compliance that outlines roles, responsibilities, and expectations.
  • Require that technical officers receive environmental compliance training.

SOURCE: AUDIT REPORT NO. 6-279-11-005-P February 28, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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11 Awards Without Conducting Required Environmental Assessments - Foreign Assistance Act of 1961, as amended, Section 117 - 22 CFR 216 - ADS 201.3.11.2 - ADS 204.3.4

USAID activities may have an adverse impact on the environment. The Foreign Assistance Act of 1961, as amended, Section 117, requires that the impact of USAID’s activities on the environment be considered and that USAID take into account environmental sustainability in designing and carrying out its development programs.

This requirement is codified in 22 CFR 216 and in ADS.

Title 22 of the Code of Federal Regulations, Part 216, establishes several requirements, including (1) assigning responsibilities within USAID for assessing the environmental impacts of its actions, (2) requiring that environmental safeguards be incorporated into program planning and design, and (3) directing that programs, to the extent feasible and relevant, be continually monitored and modified when necessary to mitigate environmental impact.

ADS requires that the activity manager ensure that the requirements in 22 CFR 216 for an environmental impact assessment have been met, approved in writing by the relevant bureau environmental officer, and incorporated into the implementation instruments.

Specifically, ADS 201.3.11.2 states that federal law mandates that an Initial Environmental Examination (IEE), Request for Categorical Exclusion, environmental assessment, or other appropriate action under the USAID environmental procedures promulgated in 22 CFR 216 must be completed and approved in writing by the relevant bureau environmental officer before funds are obligated.

In addition, ADS 204.3.4 requires that missions develop effective environmental review procedures consistent with their strategic and operational plans to ensure that environmental reviews are completed, including completing an IEE for each program or activity at the earliest point in the planning and design process.

General Recommendations

  • Establish policies to ensure compliance with environmental requirements for the entire portfolio and that these requirements be communicated to staff and implementing partners.
  • Determine that all activity documents under the Program incorporate appropriate language regarding environmental compliance and be approved by the appropriate officials prior to project implementation.
  • Develop an action plan that contains a timetable to ensure that no environmentally sensitive activities are begun under the Program until the Initial Environmental Examination is approved.

Source: 7-669-11-007-P Year: 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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Religious Organizations top
# Article Title
1 Building of Religious Structures - Title 22 of the Code of Federal Regulations, Section 205(d), “Participation by Religious Organizations in USAID Programs”

Title 22 of the Code of Federal Regulations, Section 205(d), “Participation by Religious Organizations in USAID Programs,” states that USAID funds may not be used for the acquisition, construction, or rehabilitation of structures to the extent that those structures are used for inherent religious activities.

However, at the request of the Ministry of Education, male prayer buildings and female prayer rooms were funded at provincial teacher training colleges.

Funding for the religious structures violated the prohibition in 22 CFR 205(d) and diverted resources that could have been used for other, allowable purposes under the program.

General Recommendations

  • Educate staff on the policy on funding religious activities.

SOURCE: AUDIT REPORT NO. F-306-11-002-P MARCH 27, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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Financial Management and Budgets top
# Article Title
1 Obligated Program Funds - ADS 202.3 - ADS 602.3

USAID ADS 202.3.7.4 states that current pipelines [1] and new obligations should be adequate to finance 12 to 24 months of planned expenditures. This policy encourages USAID missions/offices and AO teams to manage resource flows prudently so that scarce resources are optimally used throughout the Agency.

Further, ADS 602.3.1 states that appropriate budget and program staff in the field and USAID/Washington must follow forward funding policy directives and required procedures to ensure that the percentage of pipeline does not exceed Agency standards. A balance must be achieved between providing adequate funds for activities and the need to limit obligations to only required needs.

ADS 602.3.7 states that program managers must review annually all unliquidated obligations and make adjustments to bring pipelines, at least at the strategic objective level, into compliance with the forward funding policies. Any amounts identified as excessive for programmatic needs may be considered candidates for deobligation.

[1] The amount of funds obligated but not expended; the difference between cumulative obligations and cumulative expenditures, including accruals.

Source: AUDIT REPORT NO. 1-511-11-006-P JULY 28, 2011

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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2 Program Funding Plans - ADS 202.3.7 - FAR 16.306 (d)(1)

USAID’s Automated Directives System (ADS), chapter 202.3.7, states that the USAID mission or office and its assistance objective (AO) teams [1] are responsible for managing the resources made available to them so that planned outputs and results are achieved in a cost-effective and timely manner, in accordance with applicable regulatory requirements.

Federal Acquisition Regulation (FAR) 16.306 (d)(1) states that a cost-plus-fixed-fee completion form contract describes the scope of work by stating a definite goal or target and specifying an end product. This form of contract normally requires the contractor to complete and deliver the specified end product (e.g., a final report of research accomplishing the goal or target) within the estimated cost, if possible, as a condition for payment of the entire fixed fee.

However, if the work cannot be completed within the estimated cost, the government may require more effort without increase in fee, provided the government increases the estimated cost.

[1]An AO team is a group of people with complementary skills who are empowered to achieve a specific foreign assistance result for which they are willing to be held accountable (ADS 200.6(b)).

Source: AUDIT REPORT NO. 1-511-11-006-P JULY 28, 2011

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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3 Ensure That Costs Are Appropriate - ADS 596.3.1 - 634.3.2

Automated Directives System 596.3.1, “Establishing Internal Controls,” states that managers must implement appropriate, cost-effective internal controls that reasonably ensure that obligations and costs comply with applicable laws and regulations. Moreover, these controls should reasonably ensure that assets are safeguarded against waste, loss, unauthorized use, or misappropriation.

Automated Directives System 634.3.2, “General Standards for Funds Control,” states that obligations and expenditures may not be authorized or incurred in excess of available funds.

General Recommendations

  • Establish written procedures regarding actions required for approvals of activity expenditures and provide them to the implementer.

SOURCE: AUDIT REPORT NO. 6-268-10-006-P August 24, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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4 Financial Audits of Subrecipients Were Not Completed - ADS 591.3.2.1

According to USAID’s Automated Directives System (ADS) 591.3.2.1, foreign nonprofit organizations that expend $300,000 or more during their fiscal year in USAID awards must have an annual audit conducted of those funds in accordance with the Guidelines for Financial Audits Contracted by Foreign Recipients, published by the Office of Inspector General.

Prime recipients are responsible for monitoring their subrecipients and ensuring that non-U.S. subrecipients are audited in accordance with the guidelines. (U.S. nonprofits all fall under the Single Audit Act and receive audit coverage under a different mechanism).

General Recommendations

  • Prepare and implement a plan of action for completing all required financial audits for non-U.S. nonprofit organizations that received funding under the Program.

SOURCE: AUDIT REPORT NO. 5-391-10-012-P AUGUST 31, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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5 Mission Could Not Determine Whether Food Storage and Distribution Costs Were Reasonable - ADS 596.3.1 - Food for Peace Act - Office of Management and Budget Circular A-122, “Cost Principles for Non-Profit Organizations,” Attachment A

ADS section 596.3.1 states that USAID “must develop and implement appropriate, cost-effective internal controls” to help ensure that costs comply with applicable laws and regulations and that assets are not wasted.

One applicable regulation is that eligible uses for funding under the Food for Peace Act must be reasonable, allowable, and allocable and must support costs associated with the provision of Title II commodities to the final distribution point, including household or local warehouse.

Office of Management and Budget Circular A-122, “Cost Principles for Non-Profit Organizations,” Attachment A, states: “A cost is reasonable if, in its nature or amount, it does not exceed that which would have been incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur costs.”

General Recommendations

  • Coordinate an independent cost analysis to determine whether internal transport, storage, and handling costs have been correctly classified and to ascertain the most cost-effective method of transporting and distributing commodities.

SOURCE: AUDIT REPORT NO. 4-611-10-007-P SEPTEMBER 1, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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6 Unreasonable Costs Charged to USAID - Office of Management and Budget Circular A-122

Office of Management and Budget Circular A-122 states that, to be allowable under an award, costs must be reasonable for the performance of the award. A cost is reasonable if, in its nature or amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the costs.

General Recommendations

  • Establish procedures and criteria for determining the reasonableness of costs charged by implementing partners.

Source: AUDIT REPORT NO. F-306-11-003-P JUNE 19, 2011 

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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7 Contract Budgeting Did Not Align With Program Areas - ADS 200.3.2

ADS 200.3.2, “Guiding Principles,” identifies “Managing for Results” as one of the five guiding principles for performing work and achieving development results all over the world. Managing for results means that USAID seeks to define and organize its work around the end result it seeks to accomplish.

General Recommendations

  • Determine budget and financial reporting formats that will support oversight roles and instruct the contractor to provide budget and financial reports that meet this need.

SOURCE: AUDIT REPORT NO. E-267-11-002-P MAY 16, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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8 Project Funding Was Not Authorized - Title 22 Code of Federal Regulations (CFR) Part 226, Administration of Assistance Awards to U.S. Non-Governmental Organizations, section 226.25, Revision of Budget and Program Plans - (ADS) 303.3.18(a) - ADS 601.3.1

Title 22 Code of Federal Regulations (CFR) Part 226, Administration of Assistance Awards to U.S. Non-Governmental Organizations, section 226.25, Revision of Budget and Program Plans, requires award recipients to report deviations from budget and program plans, and request prior approvals for budget and program plan revisions.

Furthermore, Automated Directives System (ADS) 303.3.18(a), Unauthorized Commitments, states that an unauthorized commitment occurs when a USAID official, who does not have the authority to do so, acts in a way that leads a recipient acting in good faith to believe that USAID has committed to revise an existing award program description, or any of the terms and conditions of the award.

Moreover, ADS 303.3.18(a) requires an agreement officer (AO) to obtain the cognizant General Counsel or Regional Legal Advisor concurrence on a recommendation to ratify and recommend payment for an unauthorized commitment. The guidance also requires the Director of the Office of Acquisition and Assistance at USAID headquarters to ratify the unauthorized commitment.

ADS 601.3.1, Appropriations Law, states that a fundamental principle of appropriations law is that, except as otherwise provided by law, appropriations must be applied solely for the purposes for which they are made.

ADS 601, Funding Source Policy, further states that it is the responsibility of the individual approving the commitment of funds to ensure that the funding source used is correct and in accordance with the policy directives in this ADS chapter.

General Recommendations

  • Seek the approval and ratification of any changes to projects from the agreement office and legal advisor, and obtain the proper approvals before revising project plans.

SOURCE: AUDIT REPORT NO. 6-279-11-005-P February 28, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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Monitoring and Evaluation top
# Article Title
1 Indicators to Measure Higher Level Results - ADS 203.3

USAID Automated Directives System (ADS) 203.3.4.2 states that performance indicators selected by the mission should be unambiguous about what is being measured, useful for the relevant level of decision-making, and attributable to USAID/U.S. Government efforts.

ADS 203.3.2.1 further addresses how USAID should use performance information to influence assistance objective (AO) decision-making and resource allocation. ADS 203.3.2.1 states that the basis for decision-making by AO teams will vary according to the implementation stage of a program.

Early in the implementation of an AO, AO teams are likely to base their program management decisions largely on input and output data. As implementation proceeds and outputs become more substantial, AO teams will still need to consider the input and output data sources, but will also focus on whether intended results are being achieved. Therefore, AO teams will need information that measures progress at the AO level.

Source:AUDIT REPORT NO. 1-519-11-007-P AUGUST 9, 2011

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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2 Program’s Indicators, Targets and Goals Should Be Revisited - ADS 203

According to USAID’s Automated Directives System (ADS) Chapter 203, “Assessing and Learning,” technical offices should set performance targets that are ambitious but can realistically be achieved within the stated timeframe and with the available resources.

In addition, USAID’s Performance Monitoring and Evaluation TIPS No. 6, “Selecting Performance Indicators,” stipulates that performance indicators are at the heart of a performance monitoring system—they define the data to be collected to measure progress and enable actual results achieved over time to be compared with planned results.

Setting ambitious, yet achievable, targets is essential for the successful management and achievement of planned results of foreign assistance programs. Targets help establish clear expectations for USAID staff, implementing partners, and key stakeholders. In contrast, targets that are easily achievable are not useful for management and reporting.

General Recommendations

  • Establish ambitious yet achievable targets, outcomes, and goals, and modify the program’s agreement as required to reflect these changes.

  • Develop and implement a plan to collect baseline data so that progress in achieving the program’s outcomes and goals can be measured.

Source: AUDIT REPORT NO. G-391-11-001-P DECEMBER 10, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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3 Reported Results Did Not Meet Data Quality Standards - ADS 203.3

To measure performance effectively and make informed management decisions, missions must ensure the collection and availability of quality data.

USAID provides its assistance objective teams with extensive guidance to help them manage for improved results. Among this guidance is Automated Directives System (ADS) 203.3.5.2, which states that the USAID mission or office and assistance objectives teams should be aware of the strengths and weaknesses of their data and the extent to which the data’s integrity can be trusted to influence management decisions. According to ADS 203.3.5.1, “Data Quality Standards,” USAID missions should ensure that performance data meets data quality standards for validity, integrity, precision, reliability, and timeliness.

Source: AUDIT REPORT NO. 7-641-11-005-P MARCH 17, 2011

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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4 Baseline Data, Indicators, and Targets Needed to Measure Progress and Achievement - ADS Chapter 203

USAID policy gives guidance on developing and implementing performance management plans (PMPs). According to Automated Directives System (ADS) Chapter 203, “Assessing and Learning,” performance monitoring reveals whether desired results are occurring and whether outcomes are on track.

That is, performance monitoring uses indicators chosen in advance of activities to measure progress toward planned results. Performance monitoring is an assessment tool involving:

  • Identifying indicators, baselines, and targets;
  • Collecting results data, and;
  • Comparing actual performance with targets.

Specifically, ADS 203.3.3 requires assistance objective teams to prepare a complete PMP for each assistance objective for which they are responsible, and notes that:

The purpose of this requirement is to establish indicators that will provide accurate baseline data on the initial program or project/activity conditions. As the project unfolds, management can measure the degree of change. While a solicitation instrument may include a preliminary PMP, once the award is executed the project staff must complete the PMP, with relevant indicators and baseline data, within the first few months and before major project implementation actions get underway.

General Recommendations

  • Establish baselines and develop indicators and targets to measure the progress and achievement of activities, and include the measures in the performance management plan.

Source: AUDIT REPORT NO. 9-000-11-001-P February 24, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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5 Indicators Do Not Effectively Measure Program Impact - ADS 203.3.2.2 - ADS 200.2.b

Both implementing partners and USAID missions have a responsibility to set appropriate indicators and targets and to review and assess their relevancy periodically. According to Performance Monitoring and Evaluation TIPS No. 8, “Establishing Performance Targets,” a supplemental reference to the Automated Directives System (ADS) 200 series on USAID programming policy, targets should be based on analysis of what is realistic to achieve, given factors such as the stage of program implementation, resources available, and country conditions.

Additionally, ADS 203.3.2.2 states that USAID missions and offices should use performance information to assess progress in achieving results and to make management decisions. ADS 200.2.b, “Primary Responsibilities,” states that USAID missions must develop the capacity to manage foreign assistance programs and ensure that teams have the necessary expertise, authorities, resources, and support to achieve their objective. In addition, TIPS No. 12, “Characteristics of Good Indicators,” includes “[t]he degree to which performance indicators and their related data accurately reflect the process or phenomenon they are being used to measure” and “the level of comparability of performance indicators and data over various measurement contexts.”

General Recommendations

  • Strengthen program results reporting to ensure that indicators are effective in measuring goal achievements and that baseline data are collected to measure impact.

Source: AUDIT REPORT NO. 6-294-11-006-P March 22, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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6 Performance Data Lacked Support - ADS 203.3

USAID’s results-oriented approach to management calls for its managers to consider performance information when making decisions. Sound decisions require accurate, current, and reliable information, and the benefits of USAID’s results-oriented approach depend on the quality of performance information available.

To this end, the USAID Automated Directives System (ADS) discusses the importance of reliable data. To be reliable, data should reflect stable and consistent data collection processes and analysis methods over time so that USAID managers can be confident that progress toward performance targets reflects real changes rather than variations in data collection methods (ADS 203.3.5.1d).

Additionally, the U.S. Government Accountability Office’s Standards for Internal Control in the Federal Government requires accurate and timely recording of all transactions and significant events. These standards also require that transactions and significant events be clearly documented, with the documentation readily available.

General Recommendations

  • Develop and implement procedures to document results.

Source: AUDIT REPORT NO. 4-650-11-010-P JULY 28, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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7 Performance Indicators and Targets Did Not Facilitate Program Management - ADS 203.3

Indicators and targets are important tools for assessing performance in USAID’s results-oriented management philosophy. Indicators, which can be either quantitative or qualitative, are used to measure actual results of USAID activities, whereas targets indicate expected results.

Targets orient stakeholders to the tasks to be accomplished and motivate individuals involved in a program to do their best to ensure the targets are met. Once a program is under way, targets serve as guideposts for judging whether progress is occurring as scheduled and at the levels originally envisioned.

USAID’s Automated Directives System (ADS) 203.3.4.2 states that a good performance indicator should be objective, useful for management, and attributable to USAID or U.S. Government efforts, while ADS 203.3.4.5 states that missions should set performance targets that are ambitious, but can realistically be achieved within the stated timeframe and with the available resources.

General Recommendations

  • Implement a standard annual work plan to effectively report and evaluate program performance.

Source: AUDIT REPORT NO. 4-674-11-009-P JULY 20, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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8 Setting Performance Targets for Partners - ADS 203

USAID policy, under Automated Directives System (ADS) 203.3.2 on performance management, states that USAID missions and their assistance objective teams are responsible for measuring progress toward the results identified in the planning stage to achieve foreign assistance objectives.

Further, ADS states that collecting and analyzing performance information is a principal step in performance management, and missions should be reporting on results in addition to outputs in the later years of an assistance objective. Finally, ADS 203.3.4.2 calls for indicators that are practical and timely.

Performance targets are a critical part of managing for results. ADS 203.3.4.5 states that missions should be willing to be held accountable for targets, and that targets should be ambitious but achievable given USAID and other donor inputs. As stated in USAID’s Performance Monitoring and Evaluation TIPS No. 8, “Establishing Performance Targets,” once a program is underway, targets serve as guideposts for judging whether progress is being made on schedule and at the levels originally envisioned.

For performance data to be useful in managing for results and credible reporting, ADS 203.3.5.1 states that USAID missions should ensure that performance data for each assistance objective meet the data quality standards of validity, integrity, precision, reliability, and timeliness. Additionally, ADS 203.3.5.2 states that data reported to Washington, DC, or externally on agency performance must have had a data quality assessment within the 3 years before submission.

Source: AUDIT REPORT NO. 9-000-10-008-P June 15, 2010

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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9 Thorough Site Visits Not Conducted - ADS 202.3 - Performance Management Toolkit

ADS 202.3.4.6 states that assistance objective teams must ensure that they have adequate official documentation on agreements used to implement USAID-funded projects, as well as on the resources expended, issues identified, and corrective actions taken.

Furthermore, ADS 202.3.6 states that monitoring the quality and timeliness of implementing partners’ outputs is a major task of cognizant technical officers (now referred to as “contracting officer’s technical representatives”) and assistance objective teams.

ADS specifies that problems in output quality provide an early warning that results may not be achieved as planned and that early action in response to problems is essential in managing for results. To assess the quality of partner data, USAID’s Performance Management Toolkit recommends periodically sampling and reviewing partner data to ensure completeness, accuracy, and consistency, as well as determining whether the partner appropriately addressed known data quality problems.

The Toolkit also recommends developing a simple site-visit guide, covering all topics of interest, to be used systematically by teams visiting all sites.

General Recommendations

  • Develop and implement a risk-based monitoring plan for activities that includes regular site visits involving programmatic review, verification of reported results, and the documentation of site visits performed.

Source: AUDIT REPORT NO. 4-674-10-005-P MAY 12, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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10 Data Quality Assessments Not Completed - ADS 203.3.5 - Government Performance and Results Act of 1993 (Public Law 103–62) - Performance Management Toolkit

USAID’s ADS 203.3.5.2 states that the purpose of data quality assessments is to ensure that the USAID mission/office and assistance objective teams are aware of (1) the strengths and weaknesses of the data, as determined by applying appropriate quality standards, and (2) the extent to which data integrity can be trusted to influence management decisions.

The ADS also states that data reported to USAID/Washington in compliance with the Government Performance and Results Act of 1993 (Public Law 103–62) or for reporting externally on USAID performance must have had a data quality assessment within 3 years before submission.

USAID’s Performance Management Toolkit elaborates on this statement, adding that missions should determine whether there are procedures to (1) ensure that data are free of significant error or bias; (2) periodically review data collection, maintenance, and processing; and (3) provide for periodic sampling and quality assessment of data.

To assess the quality of partner data, the Toolkit recommends periodically sampling and reviewing partner data to ensure completeness, accuracy, and consistency and determining whether the partner appropriately addressed known data quality problems.

To monitor whether implementation is on track toward expected results, missions can use field visits, data from other sources, and independent surveys or evaluations to ensure acceptable data quality. According to ADS, missions should assess whether reports accurately reflect performance in the field. All assessments should be documented and available.

General Recommendations

  • Complete data quality assessments for program indicators in accordance with Automated Directives System requirements.

Source: AUDIT REPORT NO. 4-674-10-005-P MAY 12, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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11 Performance Management Plan Not Completed - ADS 203.3 - Performance Management Toolkit

ADS 203.3.3 states that assistance objective teams must complete performance management plans for each assistance objective. ADS 203.3.3.1 indicates that such plans must (1) identify the performance indicators that will be tracked; (2) specify the source, method of collection, and schedule of collection for all required data; and (3) assign responsibility for collection to a specific office, team, or individual.

Furthermore, USAID’s Performance Management Toolkit states that a complete performance management plan contains a statement of all performance indicators that will be used to assess progress over the life of the strategic objective.

Baseline values and performance targets for each indicator should also be included, with specifications for the various data sources and collection methods to be employed. In addition to these requirements, the plan should include specifications for the schedule for data collection and a description of known data limitations.

The goal of assessing data from implementing partners is for missions to be aware of data strengths and weaknesses and of the extent to which data can be trusted when reporting and making management decisions. For data from implementing partners, the Toolkit recommends that performance plans include periodically sampling and reviewing data for completeness, accuracy, and consistency. It also recommends conducting field visits to compare central office records with field site records, and visiting a broad range of sites.

General Recommendations

  • Prepare an updated performance management plan that is complete and that contains all current performance indicators and reference sheets.

Source: AUDIT REPORT NO. 4-674-10-005-P MAY 12, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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12 Performance Indicator Definitions Not Consistently Applied - ADS 203.3 - GAO Standards for Internal Control in the Federal Government

USAID’s results-oriented approach to management calls for its managers to consider performance information when making decisions. Sound decisions require accurate, current, and reliable information, and the benefits of USAID’s results-oriented approach depend on the quality of performance information available (USAID’s “Guidelines for Indicator and Data Quality” - TIPS No. 12).

To be valid, an indicator must accurately reflect the performance element that it purports to measure. This requirement is recognized by both USAID’s Automated Directives System (ADS) and the Guidelines for Indicator and Data Quality. ADS 203.3.4.2. states that indicators selected for inclusion in the performance management plan should measure changes that are clearly and reasonably attributable, at least in part, to USAID.

The Guidelines for Indicator and Data Quality states that one of the critical requirements for an indicator is the degree to which it and the related data accurately reflect the process the indicator is being used to measure. The guidelines further explain that “validity” refers to data that clearly and directly measure the result they are intended to measure; “reliability” refers to data that have a stable or consistent measuring process; and “timeliness” refers to data that are sufficiently up-to-date to be useful in decision making.

In addition to the above, it is important that performance information be recorded and documented. The GAO Standards for Internal Control in the Federal Government requires accurate and timely recording of all transactions and significant events. These standards also require that transactions and significant events be clearly documented, with the documentation readily available.

General Recommendations

  • Apply performance indicator definitions when collecting, summarizing, and reporting program results.

Source: AUDIT REPORT NO. 4-674-10-005-P MAY 12, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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13 Reported Results Were Not Verified – ADS 203.3.5.1. - ADS 202.3.6.

USAID’s results-oriented approach to management calls for its managers to consider performance information when making decisions. Sound decisions require accurate, current, and reliable information, and the benefits of USAID’s results-oriented approach depend substantially on the quality of performance information available (13 ADS 203.3.5.1).

ADS 202.3.6.states that monitoring the quality and timeliness of implementing partners’ outputs is a major task of cognizant technical officers (now referred to as contracting officer’s technical representatives) and assistance objective teams. It specifies that problems in output quality provide an early warning that results may not be achieved as planned and that early action in response to problems is essential in managing for results.

To assess the quality of partner data, USAID’s Performance Management Toolkit (Toolkit) recommends periodically sampling and reviewing partner data to ensure completeness, accuracy, and consistency and determining whether the partner appropriately addressed known data quality problems. The Toolkit also recommends developing a simple site-visit guide, covering all topics of interest, to be used systematically by teams visiting all sites.

Having accurate and reliable data is a key element in making well-reasoned management decisions. Without knowing the strengths and weaknesses of reported data, USAID officials cannot adequately determine the extent to which such data can be trusted in making sound management decisions.

General Recommendations

  • Establish written procedures to ensure that site visits provide for data quality testing and adequate documentation of the test results.

Source: AUDIT REPORT NO. 4-663-10-003-P  MARCH 30, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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14 Partner Implementation Plans Lacked Vital Information – ADS 200.6

ADS 200.6 defines an output as “[a] tangible, immediate, and intended product or consequence of an activity within USAID’s control.” - Examples of outputs include items such as people fed, personnel trained, better technologies developed, and new construction.

Outputs are important because they are critical to achieving results. Such outputs are specifically described in contract statements of work, and describing grant agreement program and monitoring the quality and timeliness of outputs produced by implementing partners is a major task of USAID technical officers and assistance objective teams, because delays in completing outputs or problems in output quality provide an early warning that results may not be achieved as planned.

Ensuring that the annual implementation plans (some partners refer to these plans as performance monitoring and evaluation plans)  of the mission’s implementing partners include targets for outputs is important because such targets enable USAID technical officers to monitor the partner’s progress on outputs effectively during the year.

Annual implementation plans are the blueprints for the specific tasks to be done and outputs to be achieved during the year. Without established, documented, and approved annual implementation plans and performance management plans, USAID officials do not have a reliable and sound basis for monitoring the performance of their partners during the year.

General Recommendations

  • Require that partners’ annual implementation plans include targets for the outputs to be achieved during the year and (b) approve these implementation plans in writing.

Source: AUDIT REPORT NO. 4-663-10-003-P  MARCH 30, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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15 Lack of a Current Performance Management Plan (PMP) - ADS 203.3.3

A performance management plan is a tool to plan and manage the process of monitoring, evaluating, and reporting progress toward achieving an assistance objective. USAID’s Automated Directives System (ADS) 203.3.3 requires that assistance objective teams prepare a complete performance management plan for each of their assistance objectives. Among other things, a performance monitoring plan states the full set of performance indicators that the assistance objective team will use to assess progress over the life of the program. The performance management plan should also:

  • Justify briefly why each performance indicator was selected.
  • Provide baseline values and targeted values for each performance indicator included in the performance management plan.
  • Specify the source of the data and the method for data collection in enough detail that an objective observer can understand how the raw data are collected, compiled, analyzed, and reported.
  • Describe known data limitations of each performance indicator by discussing any data quality limitations and steps to be taken to address them. Assistance Objectives teams must also ensure that all data used to report performance to Washington meet USAID data quality standards.
  • Describe the data quality assessment procedures that will be used to verify and validate the measured values of actual performance of all the performance information.

USAID’s Performance Management Toolkit also addresses performance management plans, stating that a complete performance management plan contains a statement of all performance indicators that will be used to assess progress over the life of the assistance objective and that performance management plans shall be reviewed and revised at least annually.

General Recommendations

  • Provide staff with training regarding the requirements of performance management and evaluation and document the training.

  • Develop a written comprehensive performance management plan for programs.

Source: AUDIT REPORT NO. 4-663-10-003-P  MARCH 30, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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16 Thorough Site Visits Were Not Conducted - ADS 202.3.4.6 - ADS 202.3.6

USAID’s ADS 202.3.4.6 states that assistance objective teams must ensure that they have adequate official documentation on agreements used to implement USAID-funded projects, as well as on the resources expended, issues identified, and corrective actions taken. Furthermore, ADS 202.3.6 states that monitoring the quality and timeliness of implementing partners’ outputs is a major task of cognizant technical officers (now referred to as contracting officer’s technical representatives) and assistance objective teams. It specifies that problems in output quality provide an early warning that results may not be achieved as planned and that early action in response to problems is essential in managing for results.

To assess the quality of partner data, USAID’s “Performance Management Toolkit” recommends periodically sampling and reviewing partner data to ensure completeness, accuracy, and consistency and determining whether the partner appropriately addressed known data-quality problems. The Toolkit also recommends developing a simple site-visit guide, covering all topics of interest, to be used systematically by teams visiting all sites.

General Recommendations

  • Establish written procedures requiring that site visits provide for data-quality testing and adequate documentation of the test results.

Source: AUDIT REPORT NO. 4-696-10-002-P March 24, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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17 Data Quality Assessments Were Not Completed - ADS 203.3.5.2 - Performance and Results Act of 1993

USAID’s ADS 203.3.5.2 states that the purpose of data quality assessments is to ensure that the USAID mission/office and assistance objective teams are aware of (1) the strengths and weaknesses of the data, as determined by applying appropriate quality standards, and (2) the extent to which data integrity can be trusted to influence management decisions. The ADS also states that data reported to USAID/Washington for reporting purposes in compliance with the Government Performance and Results Act of 1993 or for reporting externally on USAID performance must have had a data-quality assessment within 3 years before submission.

USAID’s “Performance Management Toolkit” states that missions should determine whether there are procedures to (1) ensure that data are free of significant error or bias; (2) periodically review data collection, maintenance, and processing; and (3) provide for periodic sampling and quality assessment of data.

To assess the quality of partner data, the Toolkit, in conjunction with the ADS, recommends periodically sampling and reviewing partner data to ensure completeness, accuracy, and consistency and determining whether the partner appropriately addressed known data-quality problems. To monitor whether implementation is on track toward expected results, missions can use field visits, data from other sources, and independent surveys or evaluations to ensure acceptable data quality.

According to the ADS, missions should assess whether reports accurately reflect actual performance in the field. All assessments should be documented and available.

General Recommendations

  • Establish written procedures requiring that data-quality assessments be completed in a timely manner in accordance with applicable guidance.

Source: AUDIT REPORT NO. 4-696-10-002-P March 24, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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18 Performance Management Plan Was Not Completed - ADS 203.3.3

ADS 203.3.3 states that assistance objective teams must complete performance management plans for each assistance objective. In addition, ADS 203.3.3.1 indicates that such plans must (1) identify the performance indicators that will be tracked; (2) specify the source, method of collection, and schedule of collection for all required data; and (3) assign responsibility for collection to a specific office, team, or individual.

Furthermore, USAID’s “Performance Management Toolkit” states that a complete performance management plan contains a statement of all performance indicators that will be used to assess progress over the life of the strategic objective. Baseline values and performance targets for each indicator should also be included, with specifications for the various data sources and collection methods to be employed.

In addition to these requirements, the plan should include specifications for the schedule for data collection and a description of known data limitations. The goal of assessing data from implementing partners is for missions to be aware of data strengths and weaknesses and of the extent to which data can be trusted when reporting and making management decisions.

General Recommendations

  • Establish written procedures that require performance management plans to be complete, containing all performance indicators and reference sheets, and provide for data-quality testing.

Source: AUDIT REPORT NO. 4-696-10-002-P March 24, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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19 Improve Data Quality and Program Monitoring - ADS 203.3.5.1 - ADS 203.3.5.3.b

USAID’s ADS 203.3.5.1 outlines five data quality standards that it deems useful to manage for results and to add credibility to its reporting: validity, integrity, precision, reliability, and timeliness.

Furthermore, ADS 203.3.5.3.b details how data quality assessments can be conducted when data comes from secondary sources. When data are not under USAID control, data quality assessments should place an increased focus on the accuracy and apparent consistency of the data. Missions should either compare central office records with those at field sites or meet regularly with implementing partners to determine the accuracy and credibility of data reported in periodic reports.

General Recommendations

  • Establish defined procedures to sample on a routine basis the accuracy of the contractor’s estimating methodologies and quality and accuracy of the underlying data that serves as the basis for reported results.

  • Strengthen internal controls, such as providing training to its subimplementing partners, to decrease the risks of errors in the results data collected and reported at the operating level.

Source:  AUDIT REPORT NO. 1-514-10-004-P March 12, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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20 Performance Management Plans Were Not Approved - ADS 203.3.3

According to ADS 203.3.3, an assistance objective team is responsible for preparing a PMP to establish baseline data from which to measure progress toward intended objectives. It should systematically monitor results, collect and analyze performance information, and communicate results achieved or not achieved to advance organizational learning and tell the Agency’s story.

ADS 203.3.3 emphasizes that assistance objective teams must prepare a PMP for each assistance objective for which they are responsible. According to ADS 203.3.3.1, a PMP should define at least one performance indicator to be tracked and specify the source, method of collection, schedule of collection, and known data limitations.

General Recommendations

  • Work closely with implementing partners to finalize the performance management plan.

Source: AUDIT REPORT NO. 7-688-10-004-P February 26, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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21 Monitoring and Evaluation of Activities Was Weak - ADS 303.2(f) - ADS 203.3.5.2

USAID has developed extensive guidelines on the management of awards. Most notably, USAID’s ADS 303, Grants and Cooperative Agreements to Nongovernmental Organizations, Section 303.2(f) states that technical representatives should review and analyze reports, monitor reporting requirements, and ensure the recipient’s compliance with numerous terms and conditions of an award.

ADS 203.3.5.2 states that the purpose of data quality assessments is to ensure that the USAID mission/office and assistance object team are aware of (1) the strengths and weaknesses of the data as determined by applying applicable quality standards and (2) the extent to which data integrity can be trusted to influence management decisions.

General Recommendations

  • Introduce expanded data quality assessments, including a thorough review of data validity and reliability for all standard and customized performance indicators.

  • Require a written site visit report to document the purpose and the results of each visit and specify that each site visit include the confirmation of data validity and reliability, when possible.

Source: AUDIT REPORT NO. 7-688-10-004-P February 26, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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22 Some Results Reported by Implementing Partners Were Unsupported or Inaccurate - ADS 203.3.5.1. - ADS 203.3.5.2 - ADS 203.3.2.2

To enable USAID staff to manage for results and produce credible reporting, performance data should meet data quality standards, including standards for reliability and precision (i.e., data should be sufficiently precise) to present a fair picture of performance, according to ADS 203.3.5.1.

Moreover, ADS 203.3.5.2 requires that missions perform data quality assessments and take steps to ensure that submitted data are of reasonable quality and adequately supported. The ADS further states that when missions conduct quality assessments of data from secondary sources (including implementing partners, government counterparts, and international agencies), the mission should focus the assessment on the apparent accuracy and consistency of the data.

According to the ADS, missions should consider visiting a broad range of sites to assess whether reports accurately reflect conditions and events in the field. When a mission provides technical assistance to a government ministry to improve data collection and analysis, the mission may be in a good position to assess the quality of the data. Finally, according to ADS 203.3.2.2, USAID missions should report information candidly and communicate any limitations in data quality so that achievements can be honestly assessed.

General Recommendations

  • Require contractors to develop and implement a written plan that includes procedures for monitoring subgrantees and for confirming that results are accurate and supported by source documentation.

  • Provide and document training and administrative guidance to staff n preparing support documentation that requires the submission of accurate, well-documented results and (2) report any limitations on data quality when reporting results from counterparts.

Source: AUDIT REPORT NO. 1-504-10-003-P DECEMBER 29, 2009

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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23 Performance Targets Were Inconsistent - ADS 203.3.4.5 - ADS 203.3.2.2

ADS 203.3.4.5 states that each indicator “should include performance baselines and set performance targets that are ambitious, but can realistically be achieved within the stated timeframe and with the available resources.” Furthermore, according to ADS 203.3.2.2, USAID missions and offices should use performance information to assess progress in achieving results and to make management decisions on improving performance.

General Recommendations

  • Develop and implement written procedures for work plans that include approved targets tied to the program’s overall targets.

Source: AUDIT REPORT NO. 1-504-10-003-P DECEMBER 29, 2009

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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24 Impact Indicators Not Tracked - ADS 203.3.4

USAID’s results-oriented management approach relies on its managers’ consideration of performance information when making decisions. Sound decisions require accurate, current, reliable information, and the benefits of USAID’s results-oriented approach depend on the quality of the performance information available.

Such information includes performance indicators, which are an important element in measuring progress. USAID’s Automated Directives System Section 203.3.4 notes that performance indicators are used to observe progress and to measure actual results compared with expected results. Performance indicators help to show whether an operating unit or strategic objective team is progressing toward its objectives.

General Recommendations

  • Develop and implement a plan with milestones to track progress toward meeting impact indicators.

Source: AUDIT REPORT NO. 4-654-10-001-P DECEMBER 21, 2009

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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25 Develop Indicators and Targets to Measure Progress and Achievement of Project Goals - Assistance Act of 1961, Section 621A, 22 U.S.C. 2381a - ADS 203.3.

As noted in the Foreign Assistance Act of 1961, Section 621A, 22 U.S.C. 2381a, foreign aid funds could be utilized more effectively by the adoption of methods for comparing actual results of programs and projects with those anticipated when they were undertaken.

ADS 203.3.4 notes that missions/offices must include performance indicators in their performance management plans, and states that performance indicators are used to observe progress and to measure actual results compared with expected results and to help answer how or if a USAID mission/office or assistance objective team is progressing toward its objective. Performance indicators may measure performance at any level from outputs to the goals of the project.

Furthermore, according to ADS 203.3.4.7, it is expected that, over the life cycle of a project, different types of indicators will be more informative at different times: In the early stages, output indicators will be the primary source of performance information; at later stages, outcome and impact indicators will be more important.

General Recommendations

  • Develop performance indicators and targets to measure progress and achievement of the project goals.

Source: AUDIT REPORT NO. 9-000-10-002-P December 10, 2009

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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26 Verify and document reported results periodically for PMP - (ADS) 203.3.4 - ADS 596, Management’s Responsibility for Internal Control

USAID’s Automated Directives System (ADS) 203.3.4, Selecting Performance Indicators for Performance Management Plans, states that performance indicators are used to observe progress and to measure actual results compared to expected results. Specifically, ADS 203.3.4.2 states that performance indicators should be directly related to the activity and closely track the results they are intended to measure.

Moreover, the guidance states that the selected performance indicators should measure changes that are clearly and reasonably attributable to USAID efforts. Moreover, ADS 596, Management’s Responsibility for Internal Control, requires managers to review performance measures and indicators. Additionally, USAID’s Guidebook for Managers and Cognizant Technical Officers on Acquisition and Assistance states that contracting officer’s technical representatives are responsible for ensuring the accuracy of all reports submitted by their implementing partners.

General Recommendations

  • Develop a plan to verify and document reported results periodically.

Source: AUDIT REPORT NO. 6-263-10-002-P November 30, 2009

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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27 Performance Management Plan Needs to Be Improved - ADS 203.3.3 - ADS 203.3.4.6

ADS 203.3.3 states that assistance objective (AO) teams must prepare a complete PMP for each assistance objective for which they are responsible. ADS section 203.3.4.6 states that AO teams should update PMPs regularly with new performance information, as assistance objectives develop and evolve.

General Recommendations

  • Develop a performance management plan for the program that meets USAID policy requirements.

Source: AUDIT REPORT NO. 1-520-10-001-P OCTOBER 30, 2009

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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28 Verify Reported Data - ADS 303.2

ADS 303.2, Primary Responsibilities, states that technical representatives should review and analyze reports, verify timely performance, monitor reporting requirements, and maintain contact, including site visits, which allow for a more effective review of the project.

USAID’s Guidebook for Managers and Cognizant Technical Officers (CTOs) on USAID Acquisition and Assistance further states that these site visits may include checking actual contractor performance against scheduled and reported performance or determining whether the recipient is using its best efforts to achieve the purpose of the grant or agreement.

In addition, as required by the technical representative’s designation letter, staff is authorized to request that the agreement officer take necessary action when a recipient does not submit performance reports or when information about implementation activities is inadequate or indicates a problem.

General Recommendations

  • Develop a standardized checklist to document management reviews as a part of program assessments.

Source: AUDIT REPORT NO. 6-263-10-001-P October 27, 2009.

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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29 Management of Performance Data Needs to Be Improved - ADS 203.3.5.1

According to USAID’s ADS 203.3.5.1, to be useful in managing for results and credible for reporting, operating units should ensure that the performance data in the mission’s performance management plan meet data quality standards, such as validity, integrity, precision and reliability.

To meet the standard of validity, performance data should clearly and adequately represent the intended result. To meet the integrity standard, data that are collected, analyzed, and reported should have established mechanisms in place to reduce the possibility that data might be intentionally manipulated.

The precision standard requires that data be sufficiently precise to present a fair picture of performance and enable decision-making. The reliability standard requires that data reflect stable and consistent data collection methods over time and that operating units be confident that progress toward performance targets reflects real changes rather than variations in data collection methods.

Additionally, according to USAID’s Guidebook for Managers and Cognizant Technical Officers on Acquisition and Assistance, the agreement officer’s technical representatives[1] are responsible for ensuring the accuracy of all reports submitted by their implementers.

[1] In January 2009, USAID’s guidance replaced the term “cognizant technical officer” with “agreement officer’s technical representative,” for use in grants and cooperative agreements.

General Recommendations

  • Review the performance management plan on an annual or semiannual basis to ensure that it contributes to an effective system of measuring progress toward intended objectives.

  • Develop and implement procedures to periodically conduct an independent review of the performance data submitted by implementers.

Source: AUDIT REPORT NO. 5-492-10-001-P October 9, 2009.

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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30 Performance Management Plan Was Not Updated ADS 203.3

Automated Directives System (ADS) 203.3.3 states that operating units must prepare a complete performance management plan for each strategic objective within 1 year of approval of the strategic objective. It also notes that a performance management plan is a “tool used by an Operating Unit and Strategic Objective Team to plan and manage the process of assessing and reporting progress towards achieving a Strategic Objective.”

The performance management plan must provide performance indicators that include baseline levels and targets to be achieved. ADS 203.3.4.6 states that usually, as part of the operating unit’s annual portfolio review process, the operating units should update these plans regularly with new performance information as programs develop and evolve.

General Recommendations

  • Update the performance management plan in accordance with USAID guidance and develop specific procedures to assign responsibility for regularly updating the document.

Source: AUDIT REPORT NO. 7-660-10-001-P October 8, 2009.

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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31 Partners Set Unrealistic Targets for Development Programs - ADS 200.2 - ADS 203

Both the implementing partners and the USAID missions have a responsibility to appropriately set indicators and targets and to review and assess their relevancy on a periodic basis. According to Performance Monitoring and Evaluation TIPS No. 8, “Establishing Performance Targets,” a publication by the USAID Center for Development Information and Evaluation, and a supplemental reference from Automated Directives System (ADS) chapter 203, “Assessing and Learning,” targets should be based on analysis of what is realistic to achieve, given factors such as the stage of program implementation, resources available, and country conditions.

Additionally, ADS 203 states that, “USAID Missions/Offices should use performance information to assess progress in achieving results and to make management decisions.” Moreover, ADS 200.2, “Primary Responsibilities,” states that USAID missions must develop the capacity to manage foreign assistance programs and ensure that teams have the necessary expertise, authorities, resources, and support to achieve their objective. 

General Recommendations

  • Reevaluate and document the validity of existing targets on the overall success of program activities.

Source: AUDIT REPORT NO. 9-000-10-007-P June 4, 2010 

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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32 Performance Targets Set Too Low - ADS 203.3.4.5

 

USAID’s ADS 203.3.4.5 states that, for each indicator in a performance management plan, the operating unit should set performance baselines and set targets that can be optimistically but realistically achieved within the stated timeframe and with the available resources.

Targets should be ambitious but achievable given USAID inputs. Performance targets that are set too low are not useful for management or for reporting results to stakeholders.

General Recommendations

  • Establish written procedures to revise performance targets to reflect realistic expectations.

Source:  AUDIT REPORT NO. 7-641-10-006-P JUNE 28, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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33 Too Much Credit Claimed for the Results Achieved - ADS 203.3.4.2

According to ADS 203.3.4.2, performance indicators should be useful for the relevant level of decision making for which they are intended; they should be unambiguous and closely track the results they are intended to measure.

In addition, performance indicators selected for inclusion in the performance management plan should measure changes that are clearly and reasonably attributable to USAID efforts. In the context of performance indicators and reporting, changes are attributable when the outputs of USAID-financed activities have a logical and causal effect on the result(s) being measured by a given performance indicator.

One way to assess attribution is to ask, “If there had been no USAID project or activity, would the measured change have been different?” If the answer is no, there likely is an attribution problem, and the team should look for a more suitable performance indicator. If more than one agency or government is involved in achieving a result, [one] should describe exactly what role each played in achieving the result.

General Recommendations

  • Develop a system that carefully measures the results of the activities performed.

Source:  AUDIT REPORT NO. 7-641-10-006-P JUNE 28, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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34 Improve Reporting on Activities - USAID’s guidance for the FY 2009 Performance Plan and Report (PPR)

According to USAID’s guidance for the FY 2009 Performance Plan and Report (PPR), missions were required to provide information about the mission’s performance against targets for standard indicators, as well as a narrative description of the program status. The guidance requires the narrative to be frank and objective regarding the results in each program area.

Without more complete reporting in the PPR, stakeholders may receive an incomplete understanding regarding the level of support provided by the program and the difficulties faced by the program as a result of limited distribution and use of education materials. Without a written distinction or qualification of this information, USAID cannot plan effective follow-up activities to address identified barriers to implementation and ensure the maximum effectiveness of the program.

General Recommendations

  • Adjust future performance plan and reports to include written explanations or qualifications that more appropriately define the U.S. Government support that is reported.

SOURCE: AUDIT REPORT NO. 1-522-10-007-P  JULY 13, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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35 Fiscal Year [...] Performance Management Plan Not Developed - ADS 203.3.3 - USAID’s Performance Management Toolkit

USAID’s ADS states that operating units must complete performance management plans for each strategic objective (ADS 203.3.3. - ADS now refers to “assistance objectives” rather than “strategic objectives”).

ADS further notes that performance management plans shall (1) identify the performance indicators that will be tracked; (2) specify the source, method of collection, and schedule of collection for all required data; and (3) assign responsibility for collection to a specific office, team, or individual - ADS 203.3.3.1.  

USAID’s Performance Management Toolkit provides additional criteria for performance management plans:

  • Baseline values and performance targets for each indicator should also be included, with specifications for the various data sources and collection methods to be employed.
  • Performance management plans should include periodically sampling and reviewing data for completeness, accuracy, and consistency, and field visits should be conducted to compare central office records with field site records.

The goal of assessing data from implementing partners is for missions to be aware of data strengths and weaknesses and of the extent to which data can be trusted when reporting and making management decisions.

General Recommendations

  • Complete an FY [...] performance management plan that (a) complies with Automated Directives System 203.3.3 and USAID’s Performance Management Toolkit and (b) includes performance targets and the actual performance data for FY [...].

SOURCE: AUDIT REPORT NO. 4-656-10-006-P  JULY 16, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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36 An Evaluation May Help Determine Program Impact - ADS 203.3.6

As defined in ADS 203.3.6, evaluations provide a systematic way to gain insight and reach conclusions about the effectiveness of specific activities, the validity of a development hypothesis, the utility of performance monitoring efforts, factors in the development context that may affect the achievement of results, and the types of actions that need to be taken to improve performance.

General Recommendations

  • Complete an independent technical evaluation of the program to assess its progress and to evaluate the potential for further activities.

SOURCE: AUDIT REPORT NO. 1-525-10-008-P JULY 29, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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37 Reported Results Are Not Useful for Program Management - ADS 203.3.2.1.c - ADS 203.3.5.1 - ADS 203.3.5.2

ADS 203.3.2.1.c acknowledges that, early in the implementation of a program, decisions are based largely on input and output data; however, as implementation proceeds, program managers need to focus their decisions more on whether intended results are being achieved.

Also, ADS 203.3.5.1 states that for performance data to be useful in managing for results and credible for reporting, data quality standards should be met. To help ensure compliance with the data quality standards, ADS 203.3.5.2 requires that a data quality assessment be performed for all data reported to Washington for reporting purposes or for reporting externally on Agency performance within the 3 years before its submission.

General Recommendations

  • Work with implementing partners to develop a monitoring plan that includes additional qualitative indicators that allow managers to collect and report data relevant to the program’s overall goals and objectives.
  • Complete data quality assessments for all performance indicators within the 3 years before their submission to Washington, as required by Automated Directives System 203.3.5.2.

SOURCE: AUDIT REPORT NO. 1-525-10-008-P JULY 29, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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38 Field Activities Do Not Correlate Well With Program Indicators - ADS 203.3.4.1 - ADS 203.3.4.2.e

USAID’s Automated Directives System (ADS) 203.3.4.1 advises missions to select performance indicators, whether qualitative or quantitative, for a program’s performance management plan (PMP) that are the most appropriate for the result being measured.

Furthermore, according to ADS 203.3.4.2.e, the performance indicators selected for inclusion in the mission’s PMP should measure changes that are clearly and reasonably attributable to USAID efforts. Changes can be attributed to USAID efforts when there is a logical and causal effect on the result(s) measured by a given performance indicator for the outputs of USAID-financed activities.

General Recommendations

  • Develop performance indicators that demonstrate that program results are clearly attributable to USAID efforts.

SOURCE: AUDIT REPORT NO. 1-525-10-008-P JULY 29, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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39 Strengthen Data Reporting - ADS 203.3.5.1 - USAID’s Performance Management Toolkit

Under ADS 203.3.5.1, “Data Quality Standards,” USAID missions should ensure that performance data meet five data quality standards—validity, integrity, precision, reliability, and timeliness. USAID missions should ensure that data quality standards are met so that performance data are useful in managing for results and credible for reporting.

Moreover, USAID’s Performance Management Toolkit provides guidance to operating units to periodically sample and review the implementing partner’s data to ensure completeness, accuracy, and consistency.

General Recommendations

  • Develop and implement a monitoring system to validate reported data regularly.

SOURCE: AUDIT REPORT NO. 6-268-10-006-P August 24, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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40 Data Collection and Reporting Did Not Always Yield Useful Information - ADS 203.

The USAID Automated Directives System includes guidelines on how to report on performance indicators, including defining a target as a “planned level of result” and noting that “data should reflect stable and consistent data collection processes and analysis methods

The USAID Automated Directives System10 (ADS) states that (1) for data to be valid, they should clearly and adequately represent the intended result; (2) for data to be reliable, they should reflect stable and consistent data collection processes and analysis methods; (3) a performance target is a specific, planned level of result to be achieved within an explicit timeframe that is required for each indicator; and (4) collecting data too often is not economical because data require resources and effort to collect, analyze, report, and use.

General Recommendations

  • Develop written procedures to improve oversight of reporting on performance indicators.
  • Provide guidance to officials responsible for implementing activities on the purpose of performance indicators, including how to develop targets and report valid, relevant, and reliable information.
  • Determine whether currently reported indicators that are not required should be modified or eliminated to improve the value and quality of the reporting on performance indicators.

 SOURCE: AUDIT REPORT NO. 4-611-10-007-P SEPTEMBER 1, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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41 Program Targets Were Not Clearly Defined - ADS 203

USAID uses performance indicators to measure actual results compared with expected results and determine whether programs are progressing toward their objectives. Agency guidance, ADS 203, requires setting performance targets for each performance indicator that are ambitious but can be realistically achieved. Performance targets are specific planned levels of results to be achieved within an explicit timeframe and may be set for the end of the agreement period or for each year of the program.

Periodic progress reports are the means by which the implementing partner details progress against results and targets. Progress reports are critical to the mission’s ongoing monitoring efforts of the implementing partner’s progress. A progress report should compare actual achievements with targets outlined in the award document and the work plan.

General Recommendations

  • Clarify the targets that the implementing partner is responsible for achieving by the end of the program. Those targets should be clearly communicated and agreed to by the implementing partner and incorporated in key performance management documents.
  • Establish written procedures for providing adequate oversight of program’s activities.

Source: AUDIT REPORT NO. 5-492-10-013-P SEPTEMBER 23, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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42 Data Reported for a Key Indicator Were Not Consistent With the Indicator Definition - ADS 203

According to Agency guidance, ADS 203, operating units and strategic objective teams should select performance indicators that are most appropriate for the result being measured. To assist operating units in selecting appropriate indicators, the guidance identifies seven criteria that operating units can use. One criterion is that the indicator should be direct, which means that it should closely track the results it is intended to measure.

Data should reflect stable and consistent data collection processes and analysis methods. USAID missions and offices should be confident that progress toward performance targets reflects real change rather than variation in data collection methods.

General Recommendations

  • Clarify the definition of indicators with the implementing partner, in writing, and require the implementing partner to verify and report the accomplishments that meet the indicator definition.

Source: AUDIT REPORT NO. 5-492-10-013-P SEPTEMBER 23, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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43 Some Reported Results Were Not Reliable - ADS 203

USAID’s Automated Directives System (ADS), Chapter 203, states that the missions and assistance objective teams should be aware of the strengths and weaknesses of their data and the extent to which the data’s integrity can be trusted to influence management decisions.

Additionally, ADS 203 emphasizes that performance data should meet data quality standards of validity, integrity, precision, reliability, and timeliness and that missions should take steps to ensure that submitted data are adequately supported.

To measure performance effectively and make informed management decisions, missions must ensure that quality data are collected and made available. USAID provides its assistance objective teams with extensive guidance to help them manage for improved results. Therefore, we make the following recommendations.

General Recommendations

  • Develop and implement procedures that include data validation steps in site visits and document the results.
  • Require implementing partners to develop and implement data validation steps in monitoring visits and document the results.
  • Require implementing partners to validate the performance data reported and certify the accuracy of the data in their management information system.

Source: AUDIT REPORT NO. 5-492-10-013-P SEPTEMBER 23, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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44 Impact Indicators Were Not Measured - ADS 203.3.2 - ADS 203.3.4.5

USAID policy (Automated Directives System  203.3.2, ? Performance Management) defines performance management as a systematic process of monitoring program achievements and collecting and analyzing performance information to track progress toward planned results.

As part of USAID performance management policy (ADS 203.3.4.5, ? Setting Performance Baselines and Targets), missions should collect baseline data to determine the value of performance indicators prior to USAID interventions.

General Recommendations

  • Develop and implement a cost-effective written plan to measure the impact of activities.

Source: AUDIT REPORT NO. 4-696-11-008-P JULY 1, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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45 Data Quality Assessment Recommendations Were Not Fully Implemented - ADS 203.3.5.1

According to USAID’s ADS 203.3.5.1, high-quality data are valid, have integrity, are precise, are reliable, and are timely. USAID uses data quality assessments to determine whether program data meet these standards and to determine the extent to which the data can be trusted as a basis for management decisions.

General Recommendations

  • Conduct training on data quality assessment for the implementing partner and subpartner to define how data should be collected for the program.

AUDIT REPORT NO. 4-617-11-001-P NOVEMBER 10, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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46 The Reliability of Performance Data Is Unknown - ADS 202.3.6 - USAID’s Performance Management Toolkit

USAID’s Automated Directives System (ADS) states that monitoring the quality and timeliness of outputs produced by implementing partners is a major task of an agreement officer’s technical representative (AOTR) and assistance objective teams. It specifies that problems in output quality provide an early warning that results may not be achieved as planned and that early action in response to problems is essential in managing for results (ADS 202.3.6).  

To assess the quality of partner data, USAID’s Performance Management Toolkit (Toolkit) recommends periodically sampling and reviewing partner data to ensure completeness, accuracy, and consistency and determine whether the partner appropriately addressed known data quality problems. The Toolkit also recommends developing a simple site visit guide, covering all topics of interest, to be used systematically by teams visiting all sites.

This document is listed on USAID’s Web site as a reference for its ADS Series 200 – Program Policy. Refer to Part II, Task 4, for additional guidance on collecting baseline data and verifying data quality.  

General Recommendations

  • Establish written procedures to ensure that site visits provide for data quality testing and adequate documentation of the test results and provide training to staff on those procedures.

AUDIT REPORT NO. 4-617-11-001-P NOVEMBER 10, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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47 Reporting on Key Indicators Needs to Be Improved - ADS 203.3.5.1

To be useful in managing for results and credible for reporting, indicators should be measured consistently and accurately. Specifically, USAID’s Automated Directives System 203.3.5.1, “Data Quality Standards,” sets forth five data quality standards, including “validity” and “reliability.”

To meet the “validity” standard, data should clearly and adequately represent the intended result, with consideration given to how well the data measure the intended result.

To meet the “reliability” standard, data should reflect stable and consistent data collection processes and analysis methods over time.

General Recommendations

  • Clarify indicators used to measure the impact of the Program.
  • Ensure that assessment results are accurately attributed from the statistical samples to the rest of the population and that accurate projections are reflected in upcoming progress reports.

 Source: AUDIT REPORT NO. 5-367-11-003-P DECEMBER 14, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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48 Performance Targets Were Not Disaggregated by Gender - ADS 200.5

Summary: Agency policy calls for the collection and analysis of sex-disaggregated data for individual-level indicators and targets.

USAID has long recognized that collecting sex-disaggregated data is a critical component of performance management. To this end, an additional-help reference to ADS 200.5 specifies that targets for individual-level indicators should be disaggregated to establish expectations about a program’s intended impact on men and women.

Performance Monitoring and Evaluation TIPS No. 8, “Establishing Performance Targets.” TIPS No. 8 is listed as an Additional Help reference in ADS 200.5.  

General Recommendations

  • Establish policies and procedures to ensure that gender-specific targets for indicators are set.

Source: AUDIT REPORT NO. 4-674-11-004-P JANUARY 4, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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49 Performance Indicators and Targets Are Inappropriate Measures of Program Progress - (ADS) 203.3.5.1 - ADS 203.3.4.5

According to Automated Directives System (ADS) 203.3.5.1, data should be sufficiently precise to present a fair picture of performance and enable management decision-making at the appropriate levels. Stable and consistent data collection processes and analysis methods support reliability of data over time. Data should be timely enough to influence management decision-making at the appropriate levels.

Furthermore, in establishing targets to measure progress, ADS 203.3.4.5 states that assistance objective teams should set targets that are ambitious but achievable given USAID (and other donor) inputs. Targets that are set too low are not useful for management and reporting purposes. Assistance objective teams are accountable for achieving the targets and should plan for the analysis and interpretation of actual performance data against the performance targets.

General Recommendations

  • Revise performance indicators and associated targets so that they will assess progress toward the program’s overall goals and objectives.

Source:  AUDIT REPORT NO. 1-523-11-001-P JANUARY 12, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.


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50 Inaccurate Performance Data Reported - ADS 203.3.2.1 - ADS 203.3.5.1 - Government Performance and Results Act of 1993

According to guidance issued by the Office of the Director of U.S. Foreign Assistance for preparing the FY 2009 PPR, missions were required to provide performance information against targets for indicators, as well as a narrative description of the program status.

ADS 203.3.2.1 states that one of the principal steps in performance management is communicating results achieved or not achieved, to advance organizational learning and demonstrate the Agency’s contribution to achieving the overall U.S. Government foreign assistance goal.

The performance information reported in the annual PPR is not only one of the ways USAID communicates results, but it also helps meet statutory requirements and management needs in compliance with the Government Performance and Results Act of 1993.

In addition, because of the escalation of interest related to performance and performance management by the administration, Congress and public groups the performance information helps to:

  • Define best practices and lessons learned from field activities;
  • Inform current and out?year budget decisions;
  • Respond to congressional and public inquiries;
  • Construct required special reports;
  • Prepare speeches and testimonies for State and USAID principals;
  • Aggregate foreign assistance performance for State and USAID principals.

For that reason, it is important that missions comply with ADS 203.3.5.1, which states that data should be sufficiently precise to present a fair picture of performance and enable management decision-making at the appropriate levels.

General Recommendations

  • Adjust future performance plans and report to correct inaccuracies in any reported results in the Fiscal Year Performance Plan and Report.

Source: AUDIT REPORT NO. 1-514-11-002-P  JANUARY 26, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.



 

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51 Late Submission of Performance Management Plan - ADS 203.3 - 203.3.3.1 - ADS 203.5.1

A performance management plan (PMP), as described in ADS 203.3, is a mandatory monitoring and evaluation tool used to track and monitor program progress toward achieving results.

Incomplete PMPs. PMPs did not include performance indicator definitions, information sources, methods of collection, or procedures for assessing data quality, as required by ADS 203.3.3.1.

Lack of Performance Targets. ADS 203.3.3.1 explains that PMPs should include baseline values and target values for each performance indicator

Unverifiable Reported Results. ADS 203.5.1 requires that performance data meet the five data quality standards of validity, integrity, precision, reliability, and timeliness. Data should accurately reflect the program’s performance and enable management to make appropriate decisions.

General Recommendations

  • Periodically verify the results reported by the project.
  • Provide written definitions of the performance indicators and discuss them with staff members periodically to ensure that the definitions are understood.
  • Document challenges and implementation shortfalls in reports.

SOURCE: AUDIT REPORT NO. F-306-11-001-P FEBRUARY 13, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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52 Some Main Indicators Were Not Included in Monitoring Plans - ADS 203.3.2 - ADS 203.3.8.3

According to ADS 203.3.2, “Performance Management,” managing performance involves the systematic process of monitoring the achievements of program operations and collecting and analyzing performance information to track progress toward planned results.

ADS 203.3.8.3, “Performance Report Indicators,” states that the use of standard indicators facilitates the aggregation of results across operating units worldwide and improves the U.S. Government’s ability to report on how U.S. foreign assistance resources are being used.

General Recommendations

  • Update agreements, work plans, and other documents with  implementing partners to require reporting on relevant indicators and other performance measures.

SOURCE: AUDIT REPORT NO. 7-680-11-004-P FEBRUARY 14, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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53 Outdated Results - ADS 203.3.5.1

ADS 203.3.5.1 states that performance data need to be timely enough to influence management decision making at the appropriate levels. ADS also indicates that known data limitations should be documented in annual reports.

General Recommendations

  • Require timely data to support reported annual results. If the implementer is unable to provide the data for the fiscal year indicated in the performance reports, this data limitation needs to be clearly documented in the results reporting.

SOURCE: AUDIT REPORT NO. 5-442-  11-006-P MARCH 31, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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54 Missing Baselines, Targets, and Cumulative Results - ADS 203.3.4.5

ADS 203.3.4.5 states that baselines are needed to measure a project’s progress. A baseline should be included for each indicator before the implementation of the project’s activities. Additionally, ambitious but realistic targets should be set for the end of the project with annual targets for the interim years. The auditors note that reporting cumulative project activity results, along with definitions of how those results are to be measured, provides context and a pragmatic view of how the project is progressing.

Without baseline data, targets against which accomplishments can be measured, and cumulative accomplishments reported against life-of-project targets, it is difficult to determine whether progress is being made in accomplishing the project’s objectives and where potential weaknesses in implementation may be occurring.

General Recommendations

  • Assign life-of-project targets to all performance indicators in the project’s monitoring and evaluation plan.
  • Require indicator baselines, cumulative accomplishments, and life-of-project targets to be included in the project’s annual performance reports alongside annual results.

SOURCE: AUDIT REPORT NO. 5-442-  11-006-P MARCH 31, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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55 Performance Measurements Did Not Reflect Project Impact - (ADS) 203.3.4

According to USAID’s Automated Directives System (ADS) 203.3.4, “Performance indicators are used to observe progress and to measure actual results compared to expected results.” Performance indicators help answer how or whether a project is progressing toward its goal.

When selecting performance indicators, one should ensure they are objective—meaning they are unambiguous, measure only one aspect at a time, and are precisely defined. ADS also states that performance indicators should be direct so that they “closely track the results they are intended to measure.”

General Recommendations

  • Adequately define performance indicators and provide the methodology used to measure and report on them.

SOURCE: AUDIT REPORT NO. 5-442-  11-006-P MARCH 31, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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56 Did Not Conduct Data Quality Assessments for Key Data Reported to USAID Headquarters - ADS 203.3.5.2

ADS 203.3.5.2, “Purpose of Data Quality Assessments,” states that the purpose of a data quality assessment is to ensure that the USAID mission staff are aware of the strengths and weaknesses of data, according to five data quality standards—validity, integrity, precision, reliability, and timeliness—and are aware of the extent to which the data integrity can be trusted to influence management decisions.

Data reported to Washington for Government Performance and Results Act reporting purposes or for reporting externally on USAID performance must have had a data quality assessment within the 3 years before submission.

USAID missions may choose to conduct data quality assessments more frequently if needed. Managers are not required to do data quality assessments on all performance indicators that they use. However, managers should be aware of the strengths and weaknesses of all indicators.

General Recommendations

  • Conduct a data quality assessment of contractor performance indicators.

SOURCE: AUDIT REPORT NO. E-267-11-002-P MAY 16, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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57 Performance Management Plan Was Not Current, Not Realistic, Not Aligned With Implemented Projects, and Not Used - ADS 200.6 - ADS 203.3.3

According to ADS 200.6, “Definitions,” performance management is the systematic process of monitoring the achievements of program operations; collecting and analyzing performance information to track progress toward planned results; using performance information and evaluations to influence decision making and resource allocation; and communicating results achieved or not attained. ADS also states that a performance management plan is a tool to plan and manage the process of assessing and reporting progress.

Although ADS 203.3.3 notes that there is no prescribed format for the performance management plan, it should include a set of performance indicators; provide baseline values and targeted values; disaggregate performance indicators by sex whenever possible; specify data sources; data collection methods; a schedule for data collection; and describe known data limitations, data quality assessment procedures, estimates of the cost of collecting, analyzing, and reporting performance data, and possible evaluation tasks.

General Recommendations

  • Require the contractor to update the performance management plan so that it contains realistic targets and aligns with planned projects to clearly measure progress against expected results and (2) approve the updated performance management plan in writing.

SOURCE: AUDIT REPORT NO. E-267-11-002-P MAY 16, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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58 Program Evaluation by Mission Was Not Shared With Contractor - ADS 203.3.6.7

ADS 203.3.6.7, “Responding to Evaluation Findings,” states that USAID mission staff should share and openly discuss evaluation findings, conclusions, and recommendations with relevant stakeholders, including partners, unless there are compelling reasons for not doing so.

General Recommendations

  • Review evaluations to determine whether they have all been appropriately shared with implementing partners, and if not, share the evaluation results.

SOURCE: AUDIT REPORT NO. E-267-11-002-P MAY 16, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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59 Performance Results Were Not Measured, Reported, or Supported - (ADS) 203.3.5.1

The Government Accountability Office’s Standards for Internal Control in the Federal Government states that “all transactions and other significant events need to be clearly documented and the documentation should be readily available for examination.”

According to USAID’s Automated Directives System (ADS) 203.3.5.1, “Data Quality Standards,” for data to be reliable, there should be consistent methods of collection and analysis over time so that if the data collection and analysis were repeated by different analysts, they would come to the same conclusion.

General Recommendations

  • Establish mechanisms to verify the contractor’s significant reported results.
  • Increase program oversight to verify that the contractor focuses on expected results.

SOURCE: AUDIT REPORT NO. E-267-11-002-P MAY 16, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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60 Contractor Data Did Not Accurately Reflected Outreach Efforts - (ADS) Chapter 203 - section 203.3.5.2 - ADS 203.3.5.1

USAID’s Automated Directives System (ADS) Chapter 203, Assessing and Learning, section 203.3.5.2, states that missions should be aware of the strengths and weaknesses of their data and the extent to which the data’s integrity can be trusted to influence management decisions.

Additionally, under ADS 203.3.5.1, performance data should meet data quality standards for validity, integrity, precision, reliability, and timeliness. In particular, performance data should be sufficiently precise to present a fair picture of performance and enable decision making at the appropriate level.

General Recommendations

  • Require contractors to provide additional written guidance to subcontractors on the purpose of the outreach protocols and the need for accurate reporting of outreach data that exceed targets.

SOURCE: AUDIT REPORT NO. 6-278-11-004-P January 10, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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61 Program Did Not Conduct Required Gender Analysis

The World Health Organization, in its 2009 publication Integrating gender into HIV/AIDS programmes in the health sector: tool to improve responsiveness to women’s needs, advises that to create a supporting environment for the integration of gender in HIV/AIDS activities, programs should build the capacity of program staff to respond to gender inequalities. I

General Recommendations

  • Request that implementing partners perform a gender analysis that includes a timeline for the development and implementation of a strategy to incorporate gender into activities performed under programs.

SOURCE: AUDIT REPORT NO. 4-611-11-006-P MARCH 29, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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62 Coverage of Gender in HIV/AIDS Programming Left Gaps - The Lantos-Hyde Act

The Lantos-Hyde Act revised requirements for the President’s comprehensive five-year strategy to combat global HIV/AIDS and added several requirements relating to gender. These requirements focus attention on key gender issues related to HIV/AIDS outcomes.

In response to this, the Office of the U.S. Global AIDS Coordinator developed the PEPFAR Gender Framework, which calls for more rigorous strategic planning and monitoring of gender programming.

The framework also calls for more systematic and intensified gender programming, demonstrated through, among other commitments, a more strategic and explicit focus on preventing and responding to gender-based violence.

As the U.S. Global AIDS Coordinator stated, “Gender-based violence, in particular, directly promotes the spread of HIV/AIDS by limiting women’s ability to negotiate sexual practices, disclose HIV status, and access medical services and counseling due to fear of GBV [gender-based violence].”

General Recommendations

  • Develop and distribute a plan or guidance to help ensure that HIV/AIDS programming systematically addresses gender-related goals.
  • Establish roles and responsibilities for a mission gender focal point with input on all the mission’s HIV/AIDS activities, and appoint an individual to the position.

SOURCE: AUDIT REPORT NO. 4-611-11-006-P MARCH 29, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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63 Partner Results Were Not Verifiable - ADS 203.3.5.1 - ADS 203.3.5.2

To measure performance effectively and make informed management decisions, missions must ensure that quality data are collected and made available. USAID provides its assistance objective teams with extensive guidance to help them manage for improved results.

Among this guidance is ADS 203.3.5.2, which states that the USAID mission/office and assistance objectives teams should be aware of the strengths and weaknesses of their data and the extent to which the data’s integrity can be trusted to influence management decisions.

According to ADS 203.3.5.1, Data Quality Standards, performance data should meet data quality standards for validity, integrity, precision, reliability, and timeliness, and should clearly and adequately represent the intended result.

General Recommendations

  • Require beneficiaries to maintain adequate documentation supporting results and establish an action plan to train beneficiaries on maintaining adequate documentation.
  • Develop and implement a site visit plan, which incorporates data verification into site visits.

SOURCE: AUDIT REPORT NO. 7-685-11-006-P MARCH 31, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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64 Program Targets Were Imprecise - ADS 203.3.4.5 - ADS 203.3.7.1

According to Automated Directives System (ADS) 203.3.4.5, USAID operating units should set performance targets that are ambitious, but can realistically be achieved within the stated timeframe and with the available resources. Targets should also be established for the end of the assistance and may be set for the interim years as well.

Additionally, ADS 203.3.7.1 requires mission personnel, during their portfolio review process, to address the adequacy of the performance indicators selected in the performance management plan and expectations that activities will meet their planned targets and results.

General Recommendations

  • Establish accurate performance targets for the end of the contract period for all indicators reported by the program.

 SOURCE: AUDIT REPORT NO. 7-685-11-006-P MARCH 31, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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65 Targets for Key Interventions Were Not Sufficient to Track Progress - Automated Directives System 203.3.4.5

Performance targets are critical elements of USAID’s results-oriented management philosophy. Targets orient stakeholders to the tasks to be accomplished and motivate individuals involved in a program to do their best to ensure the targets are met. Once a program is under way, targets serve as the guideposts for judging whether progress is being made on schedule and at the levels originally envisioned.

Reflecting the importance of targets, the USAID Automated Directives System 203.3.4.5 states that missions should “set performance targets that are ambitious, but can realistically be achieved within the stated timeframe and with the available resources."

General Recommendations

  • Develop realistic targets to track progress toward achieving the overall goals of the Initiative.

SOURCE: AUDIT REPORT NO. 4-621-11-007-P APRIL 29, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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66 Program Performance Reporting Needs Improvement - Automated Directives System 203.3.2.

To help ensure that projects deliver their planned outputs and meet their overall objectives, missions are expected to follow the performance management steps outlined in Automated Directives System 203.3.2.

The four principal steps in performance management are:

  • Establishing a performance management framework that identifies intended results, with concurrent planning to monitor and evaluate progress toward those results,
  • Collecting and analyzing performance information to track progress toward planned results,
  • Using performance information to influence program decision making and resource allocation, and
  • Communicating results achieved, or not achieved, to advance organizational learning and tell USAID’s story.

The contractor submitted monthly reports as required by the task order contract with the mission, but these progress reports did not convey a complete picture of the progress made toward achieving planned results.

The monthly reports were only several pages long, generally contained brief descriptions of current activities, and did not track progress against targets. In addition, the contractor submitted quarterly reports, although the task order contract does not require them.

However, the quarterly reports did not compare accomplishments with established annual performance indicator targets; the reports merely listed completed and upcoming activities. This lack of monthly or quarterly tracking of results occurred because the contract does not require tracking by month or quarter.

General Recommendations

  • Require the contractor to submit periodic progress reports that clearly convey key activities/initiatives accomplished, achievements versus targets of program indicators, and outstanding issues and implementation problems and options for resolving them.

Source:  5-440-11-007-P MAY 27, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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67 Monitoring and Evaluation Plan Was Not in Compliance With the Task Order

The task order required the contractor to develop and execute an M&E plan in consultation with the contracting officer’s technical representative (COTR). Furthermore, the task order required the M&E plan to include expected results with illustrative indicators, midterm milestones or benchmarks, and end-of-project planned results, along with data sources and collection methodologies for each indicator.

General Recommendations

  • Finalize and approve a monitoring and evaluation plan that includes expected results with illustrative indicators, midterm milestones or benchmarks, and end-of-project results, as well as clear definitions, data sources, and collection methodologies for each indicator.
  • Revise performance management plan to be consistent with the approved monitoring and evaluation plan.

Source:  5-440-11-007-P MAY 27, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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68 Unrealistic Annual Performance Targets - ADS 203.3.4.5

ADS 203.3.4.5, “Setting Performance Baselines and Targets,” states that yearly targets are generally required for the standard indicators selected for the annual joint operational plan and the joint performance report. These targets should be ambitious but achievable given the resources provided to the program.

In addition, Performance Monitoring & Evaluation TIPS No. 8, “Baselines and Targets,” a supplemental reference to ADS 203, states that if a project does not meet targets, it is important for managers to reexamine the focus or priorities of the project and make related adjustments in indicators or targets. Senior managers, staff, and implementers should review performance information and targets as part of ongoing project management responsibilities.

General Recommendations

  • Document a plan to conduct the required reviews and updates of targets for program indicators on a recurring basis.

Source: 6-263-11-007-p Year: 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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69 Inaccuracy of the Reported Performance Data - Automated Directives System (ADS) 203.3.5.1

Automated Directives System (ADS) 203.3.5.1, “Data Quality Standards,” states that USAID missions should ensure that performance data meet five data quality standards—validity, integrity, precision, reliability, and timeliness.

USAID missions should ensure that data quality standards are met so that performance data are useful in managing for results and credible for reporting. Moreover, USAID’s Performance Management Toolkit provides guidance to operating units to sample and review the implementer’s data periodically to ensure completeness and accuracy.

General Recommendations

Develop and implement a written data verification checklist for staff to use to verify the accuracy of information provided by the implementer.

Develop and implement a written plan for training assistance recipients about data verification and performance monitoring plans.

Source: 6-263-11-007-p Year: 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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70 Unrealistic Performance Targets - ADS 203.3.2.2.b

Both the cooperating sponsors and the USAID missions have a responsibility to set appropriate targets and to review and assess their relevancy on a periodic basis.

According to Performance Monitoring and Evaluation TIP No. 8, “All targets, both final and interim, should be based on a careful analysis of what is realistic to achieve, given the stage of program implementation, resource availability, country conditions, technical constraints, etc.”

ADS 203.3.2.2.b also states that USAID missions/offices should use performance information to assess progress in achieving results and to make management decisions.

General Recommendations

  • Reevaluate and establish realistic and achievable targets for program indicators.

Source: 7-683-11-008-P Year: 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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71 Reported Results Are Not Verifiable - Automated Directives System (ADS) 203.3.5.2

To measure performance effectively and make informed management decisions, missions must ensure that quality data are collected and made available. USAID provides its assistance objective teams with extensive guidance to help them manage for improved results.

Among this guidance is Automated Directives System (ADS) 203.3.5.2, which states that the USAID mission/office and assistance objectives teams should be aware of the strengths and weaknesses of their data and the extent to which the data’s integrity can be trusted to influence management decisions.

According to ADS 203.3.5.1, “Data Quality Standards,” performance data should meet data quality standards for validity, integrity, precision, reliability, and timeliness, and missions should take steps to ensure that the data clearly and adequately represent the intended result.

General Recommendations

  • Develop and implement a policy requiring all contracting and agreement officer’s technical representatives to conduct and document site visits and, when feasible, verify reported indicator data during these site visits.
  • Develop and implement an annual site visit plan.

Source: 7-669-11-007-P Year: 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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72 Tracked Too Many Indicators, Some Loosely Defined - ADS 200.6 - ADS 203.3.4.2 - ADS 203.3.3.1

According to ADS 200.6, performance indicators are used to observe progress and to measure actual results compared with expected results. Performance indicators help answer how or if a USAID mission/office is progressing toward its objective. ADS 203.3.4.2 states that good performance indicators should be:

  • Objective—unambiguous about what is being measured and precisely defined in the performance management plan (PMP)
  • Practical—selected based on the availability of data that can be obtained at reasonable cost and in a reasonable time
  • Useful—for management and the relevant level of decision making
  • Adequate—inclusion of only as many indicators as are necessary and cost-effective for results management and reporting purposes

Additionally, ADS 203.3.3.1 states that performance indicators should be chosen with care so that they are kept to a minimum and accurately reflect the performance of the result they are intended to track.

General Recommendations

  • Reevaluate performance management plan indicators, determine the important indicators to track, eliminate the less significant indicators, and document the results.
  • Formulate clear definitions for selected indicators, and train staff to ensure that consistent terminology is used in gathering and reporting data.

Source: 7-683-11-008-P Year: 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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Cash Disbursement top
# Article Title
1 Cash Disbursements Requirements - Title 22 of the Code of Federal Regulations, Section 226.21(b)(6)

Title 22 of the Code of Federal Regulations, Section 226.21(b)(6), requires that USAID’s contractors and grantees have effective internal controls to ensure that disbursements are reasonable, allocable, and allowable under the agreements. Implementing partners are also required to maintain financial records, supporting documents, statistical records, and all other records pertinent to the award to sufficiently substantiate charges to their awards.

During the review, the Office of Inspector General observed a number of best practices and internal control measures. These best practices, which could help other contractors and grantees strengthen their cash management practices and reduce risk exposure, are described below.

Establishing and Maintaining a Cash Fund. All of the selected implementing partners had set up formal cash funds denominated in U.S. dollars or the local currency. We observed two types of cash funds: revolving and nonrevolving.

  • Under a revolving fund, a fixed cash balance was established, and as the funds were spent, the cash was replenished up to the level of the fixed cash balance.
  • Under the nonrevolving type fund, the cash balance was based on periodic expense forecasts, usually done monthly. When the funds were spent, the cash replenishment was based on the next period’s expense forecast.

When they withdrew cash from the bank to replenish the funds, most of the selected implementing partners maintained a low profile for their security. One grantee used hawala to transport money from the bank to its office, thereby eliminating any risk associated with its staff traveling back from the bank with large sums of cash.

Designating a Cashier and an Alternate. All of the selected implementing partners formally designated a qualified cashier and an alternate to manage and disburse cash. These individuals were entrusted with the safekeeping of all cash. The following are basic functions of a cashier:

  • Making payments and obtaining receipts for goods and services, such as small purchases, travel advances, etc.
  • Paying local employees
  • Performing cash advance functions for employees and temporary-duty visitors
  • Processing payroll cash advances for expatriates
  • Making other cash payments as necessary for operations under the contract/agreement

Some implementing partners provided formal training to their cashiers on cash management practices by sending them abroad, but most provided on-the-job training. All partners regularly provided sessions on rules of ethical behavior.

Supporting Documentation for Cash Disbursements. We performed surprise counts of all selected implementing partners’ cash funds and reviewed a judgmental sample of cash payments and supporting documents. We observed that all of the implementing partners required receipts or some form of support for each cash payment regardless of the amount. Such supporting documentation included approved cash requests, original receipts, approved vouchers, sales slips, cash register tickets, and invoices for purchases (or an equivalent receipt itemizing supplies or services purchased).

Several of the selected implementing partners had exceptionally well-organized filing systems, using labeled binders that were stored in secured cabinets to file authorizations and liquidations of cash advances, payment vouchers, and supporting documentation. Most of the selected implementing partners electronically scanned their financial documentation and sent the originals to their home offices in the United States. Electronic copies were kept in the field for audit and reference purposes.

Surprise Cash Counts. All the chiefs of party or finance managers performed surprise cash counts regularly. Surprise cash counts serve as an excellent deterrent against fraud and the possibility of cashiers giving out unauthorized short-term cash loans to employees or friends.

Supervisory Review of Cash Disbursements. All of the selected implementing partners implemented internal control procedures that included supervisory review of cash disbursements. Some supervisors were more involved than others in reviewing cash payment vouchers. For two of the selected implementing partners, both the chief of party and the finance manager reviewed and approved each voucher before a cashier could make a cash payment. Supervisory review over cash disbursements is a standard internal control that is intended to provide the last line of defense to ensure that such disbursements are reasonable, allocable, and allowable under the agreements.

Performing Cost Analysis of Goods and Services. By most accounts, corruption and fraud are widespread in [the country]. As a countermeasure, as part of their procurement and payment process for local goods and services, all of the selected implementing partners implemented procedures to determine fair market prices to detect inflated costs and fraudulent activity.

Some of the implementing partners sent out their staff as “secret shoppers” to verify prices before making a procurement or payment. Partners also trained their financial staff to be vigilant when reviewing receipts and invoices, to look for irregularities and indicators of possible fraud such as inflated prices, forged receipts, and duplicate invoices. Several partners had terminated local vendors or subcontractors for inflating the cost of their goods and services.

Written Policies and Procedures for Cash Operations. All of the selected implementing partners had either written policies or procedures for their cash operations or followed corporate policies and procedures. Written policies and procedures help ensure that management directives are carried out and employees understand their roles and responsibilities.

Proactively Searching for Ways to Reduce Cash Exposure. Five of the ten selected implementing partners reduced their cash exposure by continuously seeking ways to minimize cash transactions. For example, they worked with local vendors and subcontractors who had bank accounts and paid them through EFT or check. Some of the implementing partners refused to issue subcontracts to companies who did not have bank accounts. Partners also required employees to have bank accounts so that their salaries could be paid through direct deposit. Finally, partners paid taxes to the Ministry of Finance using EFT. This has proven to be a fast and efficient mechanism for remitting and tracking tax payments sent to the Government, as well as a way to reduce the risk of fraud with tax remittances.

The importance of proactively reducing the number of cash transactions is illustrated by a 2010 OIG fraud case concerning tax payments. An employee working for a USAID/Afghanistan contractor embezzled about $129,495 in cash and falsified receipts to make it appear that the cash payments were received by the Ministry of Finance. If the tax payments had been made through EFT, this instance of fraud would have been prevented.

General Recommendations

  • Disseminate the best practices described above to implementing partners to minimize cash transactions.

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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Per Diem and Allowances top
# Article Title
1 Beneficiaries Received Incorrect Per Diem Payments - ADS 596.3.1 - ADS 596.3.2 - Government Accountability Office’s Standards for Internal Control in the Federal Government

ADS 596.3.1, “Establishing Internal Controls,” states that management control activities include top-level and functional-level management reviews, as well as the accurate recording and proper execution of transactions and events.

ADS 596.3.2, “Assessing the Adequacy of Internal Controls,” states that “USAID managers and staff must continuously assess and improve the effectiveness of internal controls for the Agency’s programs and operations.”

Further, the Government Accountability Office’s Standards for Internal Control in the Federal Government states that transactions and other significant events need to be clearly documented, and that the documentation should be properly managed, maintained, and readily available for examination.

General Recommendations

  • Develop and implement adequate internal controls over per diem payments.
  • Do not delegate to an employee sole responsibility for overseeing the distribution of per diems, increasing the risk of misappropriation of funds.
  • Ensure checks and balances and verification are in place to decrease the risk of misappropriation.

Source: 7-683-11-008-P Year: 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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Asset Management and Transfer top
# Article Title
1 Conduct Property End-Use Checks - Code of Federal Regulations, Title 22: Foreign Relations, Part 226.34 - ADS 324

According to the Code of Federal Regulations, Title 22: Foreign Relations, Part 226.34 Equipment, the recipient’s property management standards for equipment acquired with federal funds shall include standards to ensure that equipment records are maintained accurately and include a description of the equipment, an identification number, and unit acquisition cost.

Although this regulation refers to tangible nonexpendable property, the applicability of the requirement to maintain records of software development is a best practice for missions that expend millions of dollars on such programs.

Furthermore, ADS 324, Post Procurement, states that the mission is responsible for selecting a representative sampling or percentage of commodities at all value levels under the program and reviewing progress reports to verify that commodities financed by USAID are being used effectively.

General Recommendations

  • Develop a schedule for the implementer to submit to the mission a complete list of USAID-funded equipment with a program description and assigned values.

  • Develop and implement a procedure to perform end-use checks as part of routine site visits and retain documentation of the equipment reviewed.

Source: AUDIT REPORT NO. 6-268-11-003-P December 6, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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2 The Process for Resolving Food Losses - 22 CFR 211.9(f)(e) - Food for Peace Handbook

Requirements for cooperating sponsors’ reporting of loss, damage, or misuse of commodities to USAID or the diplomatic post are set forth in 22 CFR 211.9(f)(e). Specifically, the regulation delineates the information that cooperating sponsors must provide to USAID in loss reports.

The regulation requires that quarterly loss reports to USAID or the diplomatic post provide information on losses valued over $500, including the kind and quantity of commodities; the size and type of containers; the time and place of loss, damage, or misuse; the current location of the commodities; the estimated value of the loss, damage, or misuse; and other pertinent information. If any of this information is not available, the cooperating sponsors must explain why.

In addition, the Food for Peace Handbook, formally known as USAID Handbook 9, Chapter 10 D.2.b, states that the cooperating sponsor must review every loss to determine if a claim was warranted against a third party, and submitted loss reports should include the reason(s) for either instituting or not instituting claim action.

It is extremely important that consultation and discussions with the USAID mission take place on a regular basis to review the criteria that are being used to determine if claim action is justified. Missions are also responsible for determining the validity or propriety of each commodity loss claim, including whether the loss or damage could have been prevented. If the cooperating sponsor is found to be responsible for the loss, 22 CFR 211.9(d) requires the cooperating sponsor to pay the U.S. Government for the value of any commodities lost or damaged, unless USAID determines that the loss could not have been prevented by proper exercise of the cooperating sponsor’s responsibility.

Source:AUDIT REPORT NO. 7-685-10-003-P February 11, 2010

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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3 Adequate Controls Over Food Distribution Were Not Fully Implemented - Principle IV-2 of the Generally Accepted Commodity Accountability Principles - 22 CFR 211.10(a) - Principle II-3 of the Generally Accepted Commodity Accountability

Principle IV-2 of the Generally Accepted Commodity Accountability Principles requires that recipient organizations establish and use appropriate storage and handling procedures to protect the quality of commodities and guard against undue losses. It further states that when organizations turn over commodities to subrecipients, issuing organizations have a responsibility to ensure that the subrecipients have acceptable storage and handling capabilities.

Furthermore, Principle II-3 of the Generally Accepted Commodity Accountability Principles states that recipient organizations should maintain documents and records that accurately reflect all transactions involved in the receipt and disposition of all commodities until the commodities are issued for distribution or issued for consumption.

Food assets should be accounted for through an integrated system of financial record keeping at the field and headquarters levels. The books and records at these levels must (1) be accurately kept, (2) reflect at all times the quantities on hand and the amounts disbursed, and (3) meet the needs of internal and external audits.

In addition, 22 CFR 211.10(a) requires that cooperating sponsors and recipient agencies “maintain records and documents in a manner which accurately reflects the operation of the program and all transactions pertaining to the receipt, storage, distribution, sale, inspection and use of commodities.”

General Recommendations

  • Develop a plan to limit the amount of time between food delivery and distribution and to record the reason(s) for food distributions that take place more than 12 hours after the food delivery.

  • Develop a list of documents to be retained at distribution sites and require that this documentation is verified during postdistribution monitoring visits.

Source: AUDIT REPORT NO. 7-685-10-003-P February 11, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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4 Storage Conditions for Food Commodities Need Improvement - Generally Accepted Commodity Accountability Principles - 22 CFR 211.10(c) - 22 CFR 211.5(a)

According to Generally Accepted Commodity Accountability Principles, commodity management organizations should establish and use appropriate storage and handling procedures to protect the quality of commodities and guard against undue losses.

USAID commodity storage guidelines also require that storage space requirements should be given careful attention and storage should be secure. Warehouses should be free of leaks and holes in the walls.

Also, 22 CFR (Code of Federal Regulations) 211.10(c), Inspection and Audit, requires cooperating sponsors and recipient agencies to cooperate with and assist U.S. Government representatives to enable them to, among other things, inspect commodities in storage or the facilities used in the handling or storage of commodities. Furthermore, 22 CFR 211.5(a) requires that cooperating sponsors submit information for the Operational Plan, from which it may be determined that “…adequate storage facilities will be available in the recipient country at the time of arrival of the commodity to prevent spoilage or waste of the commodity.”

General Recommendations

  • Develop a plan of action with a timetable to (a) upgrade storage facilities, including roof and wall repairs, and (b) implement measures to ensure that warehouse staff are aware of the USAID Office of Food for Peace storage guidelines.

Source: AUDIT REPORT NO. 7-685-10-003-P February 11, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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5 Requiring Containerization Has Not Been Fully Considered - Principle IV-2 of the Generally Accepted Commodity Accountability Principles

Principle IV-2 of the Generally Accepted Commodity Accountability Principles requires that recipient organizations establish and use appropriate storage and handling procedures to protect the quality of commodities and guard against undue losses. The principle also requires that shipments from the port to the inventory locations must be done in a manner that preserves the quality and characteristics of the product. This phase can require proper vehicles, good stacking techniques, and protective coverings.

Furthermore, the Food Aid Logistics Operational Handbook states that containerization of cargo has made it possible to significantly reduce the physical handling of the contents, thereby reducing the need to tally units during each transfer and reducing the potential for damage during the handling process.

Sources:

The Generally Accepted Commodity Accountability Principles are a set of standards developed by a coalition of 13 private voluntary organizations.

The Food Aid Logistics Operational Handbook is a document prepared by CARE used to provide guidance for developing logistics plans for food aid projects.

General Recommendations

  • Conduct a cost-benefit analysis of using containers to ship all food commodities and (b) take appropriate actions on all future Assistance Programs based on the results of the analysis.

Source: AUDIT REPORT NO. 7-685-10-003-P February 11, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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6 Assets May Have Been Diverted - GAO’s “Standards for Internal Control in the Federal Government

GAO’s “Standards for Internal Control in the Federal Government” states that transactions should be recorded promptly to maintain their relevance and value to management in controlling operations and making decisions. In the context of inventory, such controls include the timely and accurate recording of the addition or removal of stock.

General Recommendations

  • Reassess and document the risk of loss in distribution arrangements for [assets] including the implementation of additional controls to ensure that the [assets] reach the intended beneficiaries.

Source: AUDIT REPORT NO. 4-654-10-001-P DECEMBER 21, 2009

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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7 Strengthen Commodity Controls - P.L. 480 Handbook

According to the P.L. 480 Handbook, it is essential for the USAID mission to establish oversight and monitoring procedures for good food aid management, and to establish an atmosphere of day-to-day consultation and collaboration with cooperating sponsors and other food donors. While cooperating sponsors have primary responsibility for implementing, monitoring, reporting on, and auditing their Title II program activities, commodities, and funds, USAID missions are expected to monitor cooperating sponsor's management of the commodities and use of sales proceeds and grant funds.

General Recommendations

  • Provide training to the staff regarding inventory controls and program policies and procedures.

  • Document and verify that cooperating sponsors (a) have developed a complete beneficiary database and are using it to print lists of eligible beneficiaries prior to each distribution, and (b) have developed and implemented written procedures for food distribution.

Source:AUDIT REPORT NO. 1-521-10-002-P December 9, 2009

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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8 Options for Unused Equipment - ADS 324.5.4b

ADS 324.5.4b, Post Procurement, Arrival and Disposition Records, requires missions to verify that commodities financed by USAID are being effectively used in an activity, and if not, that the commodities are transferred to other activities

Source: AUDIT REPORT NO. 6-263-10-001-P October 27, 2009.

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

 

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9 Adequate Controls Over Food Distribution Were Not Fully Implemented - Principle II-3 of the Generally Accepted Commodity Accountability Principles - 22 CFR 211.10(a)

Principle II-3 of the Generally Accepted Commodity Accountability Principles states that commodity management organizations should maintain documents and records that accurately reflect all transactions involved in the receipt and disposition of all commodities until the commodities are issued for distribution or consumption.

In addition, 22 CFR 211.10(a) requires that cooperating sponsors and recipient agencies “maintain records and documents in a manner which accurately reflects the operation of the program and all transactions pertaining to the receipt, storage, distribution, sale, inspection and use of commodities.”

General Recommendations

  • Develop a list of documents to be retained at the distribution site and require that this documentation be verified during postdistribution monitoring visits.
  • Develop a complete beneficiary database and use it to print lists of eligible beneficiaries prior to each distribution, (b) review the eligibility of each beneficiary monthly, and (c) have developed and implemented written procedures for food distribution.

AUDIT REPORT NO. 4-617-11-001-P NOVEMBER 10, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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10 Storage Conditions for Food Commodities Need Improvement - Generally Accepted Commodity Accountability Principles, Principle IV-2,11 - 22 CFR 211.5(b) - USAID Commodity Reference Guide

According to Generally Accepted Commodity Accountability Principles, Principle IV-2,11 commodity management organizations should establish and use appropriate storage and handling procedures to help ensure quality and minimize losses.

The USAID Commodity Reference Guide states that sound storage procedures should also be followed in order to minimize insect and rodent problems. Specifically, the guidelines require warehouse cleanliness, segregation of damaged food, routine inspection for any visual signs of insect infestation, and fumigation to destroy all stages of insects that may be present.

Further, they state that just because there are no visual signs of residual kill, insects or rodents may recontaminate the commodity immediately after fumigation. Therefore, in order to protect stored foods, a great emphasis must be placed on cleaning in order to avoid commodities contamination, especially if sprays and fogs are used to eliminate insects.

Further, 22 CFR 211.5(b) highlights program supervision as one of the responsibilities of cooperating sponsors. Cooperating sponsors must provide adequate supervisory personnel for the efficient operation of the program, including personnel to:

  • Plan, organize, implement, control, and evaluate programs involving distribution of commodities or use of monetized proceeds and program income, and
  • Make warehouse inspections, physical inventories, and end-use checks of food or funds.

The Generally Accepted Commodity Accountability Principles are a set of professional standards relating to management, handling, tracking, and reporting on the use of food commodities in the international development and relief program. They are compiled and published by Food Aid Management, an association of private voluntary organizations engaged in international food aid programming.

General Recommendations

  • Implement a plan of action with a timetable to (a) include commodities and warehouse inspections during site visits to the warehouses and distribution centers, and correct the weaknesses noted; (b) ensure that distribution centers warehouse staffs are aware of the USAID Office of Food for Peace storage guidelines; and (c) ensure that commodities are regularly inspected, and fumigated when signs of infestation are found.
  • Develop policies and procedures to inspect commodities and warehouses during site visits and to ensure that internal transportation, storage, and handling are adequate by local commercial standards.

AUDIT REPORT NO. 4-617-11-001-P NOVEMBER 10, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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11 Assets Were Missing, Diverted, and Sold for Profit - GAO publication Standards for Internal Control in the Federal Government, pages 14 and 15

The GAO publication Standards for Internal Control in the Federal Government, pages 14 and 15, states that an agency must establish physical control to secure and safeguard vulnerable assets. The publication also states that transactions should be recorded promptly to maintain their relevance and value to management in controlling operations and making decisions.

General Recommendations

  • Improve monitoring of asset distributions by (1) increasing site visits to facilities and sales points, and (2) developing a site visit template that specifically identifies areas to review during visits.
  • Develop and implement a uniform system for documenting and communicating cases of missing or diverted assets.

SOURCE: AUDIT REPORT NO. 7-680-11-004-P FEBRUARY 14, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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12 Partner Did Not Track or Manage Inventory Effectively - ADS 596.3.1 - GAO’s publication Standards for Internal Control in the Federal Government

ADS 596.3.1, “Establishing Internal Controls,” requires managers and staff to implement internal controls to safeguard assets against waste, loss, unauthorized use, and misappropriation.

In addition, GAO’s publication Standards for Internal Control in the Federal Government, pages 14 and 15, states that an agency needs to establish physical control to safeguard vulnerable assets.

The publication also states that transactions should be recorded promptly to maintain their relevance and value to management in controlling operations and making decisions.

General Recommendations

  • Develop and implement procedures to improve inventory tracking processes, including training of staff on the best practices in inventory management.

SOURCE: AUDIT REPORT NO. 7-680-11-004-P FEBRUARY 14, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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13 Sustainability of Facilities Is Questionable - Section 611(e) of the Foreign Assistance Act of 1961

Section 611(e) of the Foreign Assistance Act of 1961, as amended, provides that whenever certain types of funds are proposed to be used for a capital assistance project exceeding $1 million, the mission director must provide a certification as to the capability of the country to effectively maintain and utilize the project.

General Recommendations

Prepare an analysis of the Government of [country's] ability to fund maintenance for the structures turned over under the program, (1) determine the need for a separate operation and maintenance program and (2) revise as appropriate the 611 (e) certification previously prepared for the program.

SOURCE: AUDIT REPORT NO. F-306-11-002-P MARCH 27, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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14 Contractor’s Property Accounting System Was Not Approved, and Required Reports Were Not Submitted - USAID Acquisition Regulation (AIDAR) 752.245-71 - AIDAR 752.245-70 - ADS 629.3.3.2

USAID Acquisition Regulation (AIDAR) 752.245-71, “Title to and Care of Property,” sets forth a contract clause under which contractors must prepare and establish a program, to be approved by the mission, for the receipt, use, maintenance, protection, custody, and care of nonexpendable property for which it has custodial responsibility, including the establishment of reasonable controls to enforce such a program.

AIDAR 752.245-70 also requires the contractor to submit an annual report on all nonexpendable property. The contractor needs to attest that physical inventories of government property are taken at least annually, accountability records for government property agree with inventories, and the total of the accountability records agrees with the property values.

ADS 629.3.3.2, “Property Accounting Systems for Contractors,” also states that USAID does not prescribe a specific system of property accounting for contractors. However, any system employed by a contractor requires written approval by the cognizant property administrator. This process ensures adequate contractor control, accuracy, and consistency in reported information. In addition, the USAID COTR is responsible for:

  • Monitoring the contractor’s management of government property.
  • Reporting annually on government property and any property acquired by the contractor for use in the contract.
  • Verifying the return or disposition of government property.

General Recommendations

Require the contractor to submit its property accounting system for approval and (2) determine whether that system is acceptable for managing government property according to USAID Acquisition Regulation requirements.

SOURCE: AUDIT REPORT NO. E-267-11-002-P MAY 16, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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15 Property Transfers Were Not Appropriate - Title 22 Code of Federal Regulations Part 226, Administration of Assistance Awards to U.S. Non-Governmental Organizations, Section 226.34, Equipment - U.S. Government Accountability Office issued Standards for Int

The U.S. Government and its Federal agencies have documented specific guidance regarding property use and disposal. Title 22 Code of Federal Regulations Part 226, Administration of Assistance Awards to U.S. Non-Governmental Organizations, Section 226.34, Equipment, states when the recipient no longer needs equipment, the equipment may be used for other activities in accordance with the following standards for equipment with a current per unit fair market value of $5,000 or more:

  • A recipient may retain the equipment for other uses provided that compensation is made to the original federal awarding agency or its successor.
  • If the recipient has no need for the USAID-financed equipment, the recipient shall request disposition instructions from the USAID AO.
  • USAID shall determine whether equipment can be used to meet the Agency’s requirements.
  • If there is no Agency need, USAID shall report the availability of the equipment to the General Services Administration to determine whether a requirement for the equipment exists in other Federal agencies.

In addition, the U.S. Government Accountability Office issued Standards for Internal Control in the Federal Government (the Standards) in November 1999.

One of the five standards for internal control is information and communication. The Standards state that information should be recorded and communicated to management and others within the entity who need it, in a form and within a time frame that enables them to carry out their internal control and other responsibilities.

General Recommendations

  • Submit planned replacement needs to and request disposition instructions from the agreement officer for USAID-financed equipment in excess of $5,000 for which the recipient has no need.

SOURCE: AUDIT REPORT NO. 6-279-11-005-P February 28, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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16 Plan for End-Use Checks of Donated Commodities is Not Available - Automated Directives System (ADS) 324.5.6,

Automated Directives System (ADS) 324.5.6, “End-Use Checks,” requires missions to confirm that USAID-procured commodities are being used as specified in agreements. ADS states that the mission shall carry out, or arrange to have carried out, end-use checks on commodities to confirm their use in accordance with the requirements of the underlying agreement. It is not necessary that every commodity be checked. The mission may determine a representative sampling or percentage of commodities to be checked.

General Recommendations

  • Develop and implement a procedure to conduct intermittent end-use checks for commodities procured under the program.

Source: 1-521-11-005-P Year: 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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17 Inventory is Not Tracked or Managed Effectively - ADS 596.3.1 - U.S. Government Accountability Office’s publication Standards for Internal Control in the Federal Government

ADS 596.3.1, “Establishing Internal Controls,” requires managers and staff to implement internal controls to safeguard assets against waste, loss, unauthorized use, and misappropriation.

In addition, the U.S. Government Accountability Office’s publication Standards for Internal Control in the Federal Government states that an agency needs to manage risk and establish physical control to safeguard vulnerable assets by periodically comparing inventory counts with control records. The publication also states that transactions should be recorded promptly to maintain their relevance and value to management in controlling operations and making decisions.

General Recommendations

  • Develop an action plan to establish adequate management and financial internal controls and oversight over assets and community stores and establish adequate management and financial internal controls and oversight over assets, community stores, warehouses, etc.
  • Review the inventory and financial records of assets, community stores, warehouses, etc. to determine the correct inventory.

Source: 7-683-11-008-P Year: 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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Host Country Requirements top
# Article Title
1 Program Design Should not Hinder Achievement of Stated Goal - ADS 201 - ADS 200.3

USAID’s Automated Directives System (ADS) 201.3.8.  “Planning,” notes that USAID missions should “devise foreign assistance programs and activities to have the greatest possible development impact.”

ADS Chapter 200, “Managing for Results,” states that “USAID seeks to define and organize its work around the end result it seeks to accomplish. This requires making intended results explicit; ensuring agreement among partners, customers, and stakeholders that proposed results are worthwhile; and organizing daily work and interactions to achieve results effectively” (ADS 200.3.2.1.)

Source: AUDIT REPORT NO. 4-615-11-002-P DECEMBER 14, 2010

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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2 Program Activities and Sustainability - ADS 201.3 - ADS 303

Two automated directives define how USAID programs should be designed and the role of an AOTR in monitoring a program for sustainability. ADS 201.3.4, Planning, USAID Mission/Office Long-Term Planning, requires USAID to work closely with partners, customers, and stakeholders to:

  • Design and implement projects and activities that will ensure that results are achieved;
  • Include resources required to execute the plan over its proposed time period;
  • Include indication of the specific results expected and how performance will be measured and managed; and
  • Produce sustainable benefits after termination of USAID funding.

In addition, ADS 303, Grants and Cooperative Agreements to Non-Governmental Organizations, Designation of the Agreement Officer’s Technical Representative, states that the agreement officer and AOTR share oversight of an assistance award.

The agreement officer designates the AOTR to monitor the implementer’s progress toward achieving program objectives and to verify that an implementer’s activities conform to the terms and conditions of the award. Moreover, site visits conducted by the AOTR are to be documented with findings highlighted and retained in the award files. The AOTR is also responsible for communicating potential problems to the agreement officer.

To achieve desired results, mission officials must ensure that sustainability is an integral component when monitoring program activities for results. Furthermore, monitoring of program activities for sustainability should be documented and potential problems communicated to the agreement officer immediately. For USAID programs with information technology components, communication on system requirements, protocol, and procedures to maintain the information technology infrastructure can be documented in the program’s activity approval document.

Source: AUDIT REPORT NO. 6-268-11-003-P December 6, 2010

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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3 Program Design and Sustainable Development Methods

According to USAID guidance - USAID's Strategy for Sustainable Development: An Overview:

Development is “sustainable” when it permanently enhances the capacity of a society to improve its quality of life. Sustainable development mandates participation. It must be based on the aspirations and experience of ordinary people, their notion of what problems should be addressed, and their consultations with government, development agencies, and among themselves. Sustainable development requires investments in human capital—in the education, health, food security, and well-being of the population.

Additional USAID guidance ("Theory and Practice in Sustainability and Sustainable Development") describes benefit sustainability: Within the development community, sustainability refers to the ability of benefit flows to be maintained after project funding ceases. Components of benefit sustainability include:

  • Analysis of host government policies that support or constrain program objectives
  • National and/or local commitment to project goals
  • Program technology appropriate to the recipient country’s financial, ecological, and institutional capabilities, well integrated into the country’s social and cultural setting
  • Community participation
  • Ecological soundness
  • Technical assistance oriented toward transferring skills and increasing institutional capacity and ability of the project to provide training to transfer the skills needed for capacity building
  • Host country perception that the project is “effective”
  • The degree of the program’s integration into the existing institutional framework
  • Analysis of external political, economic, and environmental factors

Source: AUDIT REPORT NO. 1-511-11-006-P JULY 28, 2011

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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4 Sustainability Requirements - 22 U.S.C. 2361

Sustainability is a core element of USAID program design, as shown in the Agency’s Strategic Plan Checklist, which requires strategic teams within the mission to address two questions:

(1) Is the achievement of sustainability for governmental institutions and processes realistic and within the planned timeframe for the completion of USAID’s assistance to a specific strategic objective and/or a country’s graduation from USAID assistance?

(2) Will sustainability plans be provided for key institutions and processes that will be necessary beyond the timeframe of the USAID strategy?

Furthermore, section 611(e) of the Foreign Assistance Act of 1961, as amended and codified in 22 U.S.C. 2361, provides that whenever certain types of funds are proposed to be used for a capital assistance project exceeding $1 million, the head of agency must take into consideration the mission director’s certification as to the capability of the country to effectively maintain and utilize the project.

Source: AUDIT REPORT NO. 5-306-10-002-P November 10, 2009

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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5 Develop Negotiation Points for Tax Exemptions for USAID-Funded Property - ADS 155.3.2

USAID operates its programs under a technical cooperation agreement that the Governments of the United States and [...]. The agreement offers customs duties exemption privileges to USAID and the Department of State staff but does not provide tax protection to implementers of U.S. Government programs.

Accordingly, implementers have no protections from payment of local taxes, customs duties, or levies. Although Automated Directives System 155.3.2, “Tax Exemptions,” sets forth USAID’s general policy that USAID assistance should be exempt from host government taxes and customs duties, the policy is not self-executing. The policy states that operating units must negotiate exemptions with a host government to include exemption clauses in bilateral agreements, strategic objectives grant agreements, and other agreements.

Historically, the U.S. Congress has expressed concern that U.S. assistance in developing country populations not be diverted to the treasuries of foreign governments - GAO, “Foreign Assistance: USAID and the Department of State Are Beginning to Implement Prohibition on Taxation of Aid”.

Since value-added taxes are revenues based on local purchases sometimes valued at millions of dollars, these tax payments decrease the availability of scarce resources for program activities.

General Recommendations

  • In cooperation with the regional legal advisor, develop written procedures for negotiations to protect USAID-funded property from being subjected to taxes and customs duties imposed by the host country government.
  • In cooperation with its Regional Contracting Office, develop written procedures for incurring costs for taxes and customs duties imposed by the host country government.

SOURCE: AUDIT REPORT NO. 6-268-10-006-P August 24, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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6 Program Lacked Approval as Required by Governmental Regulations

The Government of ....  issued Decree x. Article 7, Section 2 sets forth procedures for developing and approving a list that prioritizes programs and projects, with attachments containing specified information for each listed program and project. The Ministry of .... takes the lead role in selecting programs and projects, in coordination with relevant agencies and donors, and is responsible for submitting the list to the Prime Minister for approval.

General Recommendations

  • Develop and implement a clear plan of action to expedite the approval process of initiatives with the Government of ....

Source:  5-440-11-007-P MAY 27, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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Internal Control and Anti-Corruption top
# Article Title
1 Program Oversight - ADS 303 - ADS 202.3 - ADS 203.3

Automated Directives System (ADS) 303, “Grants and Cooperative Agreements to Non-Governmental Organizations,” requires the agreement officer’s technical representative (AOTR) to monitor and evaluate a recipient’s performance during the award. In addition, it requires USAID to always have some involvement in assistance awards—for example, monitoring performance and reviewing implementer reports.

Moreover, the AOTR’s designation letter [may] outline various oversight responsibilities, including monitoring progress in achieving the objectives of the cooperative agreement and verifying that program-funded activities conform to the terms and conditions of the award.

In addition, ADS 202.3.6, “Monitoring Quality and Timeliness of Key Outputs,” notes that monitoring the quality and timeliness of outputs produced by implementing partners is a major role for AOTRs.

USAID also provides extensive guidance related to data quality. ADS 203.3.5.1, “Data Quality Standards,” identifies five criteria for assessing data quality: validity, integrity, precision, reliability, and timeliness. These criteria can be used as a resource to help missions to ensure the appropriateness of data on which they rely.

Source: AUDIT REPORT NO. 6-263-11-002-P November 10, 2010

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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2 File Documentation - Procurement Executive Bulletin (PEB 2005-06)

The Agreement Officer Technical Representative (AOTR) Designation Cooperative Agreement Administration letter states that AOTRs’ files are the primary tools for conducting and accomplishing AOTRs’ duties and responsibilities and for documenting staff actions.

Moreover, the letter lists the documents that should be included in the AOTR files, including correspondence between the AOTR and the implementer, copies of financial documents, and actions taken by the AOTR.

In addition, Procurement Executive Bulletin (PEB 2005-06) File Standardization Pilot includes a checklist of various documents that USAID/Washington contracting officers should include in assistance files.

The checklist also includes references to specific laws, regulations, and guidance applicable to each document type. Although the bulletin refers to USAID/Washington contracting officers, the checklist is an example of a good business practice for managing and maintaining implementer files for program review.

Source: AUDIT REPORT NO. 6-268-11-003-P December 6, 2010

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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3 Monitoring and Oversight Needs Improvement - ADS 596.3

ADS 596.3.1 stipulates that USAID managers and staff must develop and implement cost-effective management controls for results-oriented management to reasonably ensure that assets are safeguarded against loss and unauthorized use.

Furthermore, the ADS states that management control activities must be both effective and efficient in accomplishing the Agency’s control objectives. A key control activity is adequate documentation of internal control, of which monitoring is a central component.

General Recommendations

  • Develop written procedures to document, track, and take corrective action on all deficiencies identified.

  • Verify that material internal control weaknesses identified are corrected and document the results.

Source: AUDIT REPORT NO. G-391-11-001-P DECEMBER 10, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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4 Staff Overrode Management Controls - (GAO) Standards for Internal Control in the Federal Government - ADS 303.3

According to the U.S. Government Accountability Office (GAO) Standards for Internal Control in the Federal Government, a good management control environment requires that organizational structures clearly define key areas of authority and responsibility and establish appropriate lines of reporting.

Controls are also affected by delegations of authority and responsibility for operating activities, reporting relationships, and authorization protocols. Good human capital policies and practices are also critical factors, including a proper amount of supervision. However, GAO notes that factors outside the control or influence of management can affect the achievement of goals. For example, errors of judgment and acts of collusion to circumvent controls can affect objectives. Although management controls cannot provide absolute assurance that all objectives will be met, established controls provide a reasonable assurance of meeting objectives.

Furthermore, management controls should provide reasonable assurance of compliance with applicable laws and regulations. For example, USAID’s Automated Directives System (ADS) prescribes that USAID and U.S. Government policy prohibits U.S. officials from acting without proper authority in a way that leads a recipient or potential recipient acting in good faith to believe that USAID has changed the amount of an existing award or revised an existing award budget, program description, or any of the terms and conditions of the award (ADS 303.3.18). Such actions could rise to the level of an unauthorized commitment.

General Recommendations

  • Develop and implement a periodic training program for staff that clearly defines the authority, responsibility, and accountability of agreement officers, technical representatives, and program staff, including their communications with implementers, to support an effective management control environment.

Source: AUDIT REPORT NO. G-391-11-002-P DECEMBER 10, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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5 Review and Test Conflict-of-Interest Mitigating Processes - ADS 596 - Standards for Internal Controls in the Federal Government - USAID Contract and Information Bulletin 99-17

ADS 596, Management's Responsibility for Internal Control, requires managers to develop and implement appropriate, cost-effective internal controls which reasonably ensure that assets are safeguarded against waste, loss, unauthorized use, or misappropriation.

Furthermore, the U.S. Government Accountability Office’s Standards for Internal Controls in the Federal Government states that managers should review activities at the functional and activity levels. Management review and knowledge of critical communications and events allows officials to assess risks to operations and review and test mitigating controls to ensure effectiveness and efficiency.

Generally, as defined by USAID Contract and Information Bulletin 99-17, Organizational Conflict of Interest, USAID policy precludes a contractor from furnishing implementation services as the prime contractor or subcontractor when the contractor has a substantial role in the design of an activity under contract with USAID.

Source:  AUDIT REPORT NO. 6-278-10-004-P March 31, 2010

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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6 Suspension and Debarment - FAR 9.4 - 22 CFR 208

The Federal Acquisition Regulation (FAR) and the Code of Federal Regulations (CFR) stipulate that suspension and debarment actions are to be used to protect the public interest (FAR 9.402 and 22 CFR 208.110(e) and (c)). To carry out this purpose, the FAR and CFR provide causes that an official may cite for suspension and debarment actions.

FAR 9.406-2 and 9.407-2 cite the causes used for suspending or debarring a contractor. Causes are listed in 22 CFR 208.800 and 208.700 for suspending or debarring a participant in a nonprocurement program. Both statutes seek to exclude parties that are determined not to be responsible enough at present to carry out Federal awards.

The FAR and CFR provide timeframes within which those notified of a proposed debarment must respond, the agency must make its final debarment decision, and written notice of its final debarment decision must be provided (FAR 9.406-3(c)(4) and 22 CFR 208.820(a) and 208.870).

For procurement, the final notice of a decision to debar must be sent to the contractor at most 30 days from the date of the contractor’s response to the agency’s notice of intent. For nonprocurement, the agency’s final notification of a decision to debar must be sent at most 45 days from the date of the participant’s response, and notice must be made promptly. For both types of debarment actions, when no response is received within the prescribed period, final notice of a debarment must be sent sooner.

AUDIT REPORT NO. 9-000-10-001-P October 1, 2009

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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7 Potential Corruption Went Unreported - USAID’s Handbook on Fighting Corruption

USAID’s Handbook on Fighting Corruption states that improving accountability entails efforts to improve the detection of corrupt acts and strengthen sanctions. The audit disclosed several instances of potential program corruption that were not reported to the mission or to the implementing partner. Specifically, according to the program partner responsible for constructing and repairing classrooms, its subpartner was subjected to illegal checkpoints, theft, and extortion of construction materials.

Neither the program partner nor its subpartner maintained adequate documentation of these incidents; therefore, it is unclear how much was incurred in losses and whether those losses were charged to or reimbursed with program funds.

Reported examples included the following:

  • Workers removed from the worksite, and claimed as their own, tools and other materials provided during construction.
  • Armed individuals set up barriers along various points in the roads and forced passersby to pay a fee. The subpartner usually paid this fee by providing materials such as a bucket of paint, a bag of cement, or cash.
  • Local government officials felt they were entitled to materials brought into their communities, and such materials often disappeared from worksites. For example, a missing generator used to supply electricity to the worksite was found at a local government official’s residence.
  • The program partner gave the auditors one incident report, that showed six separate occurrences of loss, theft, or extortion of materials in 9 days. Even though the total monetary amount of these incidents was marginal, the report highlights the fact that these incidents were occurring regularly. Furthermore, the implementing partner and the mission were unaware of these incidents.

General Recommendations

  • Mandate that all agreements and contracts have a clause requiring partners and subpartners to report all suspicion or allegation of waste, fraud, abuse, or corruption through appropriate channels including USAID’s Office of Inspector General.

Source: AUDIT REPORT NO. 5-492-10-013-P SEPTEMBER 23, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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8 Contractor Lacked a Code of Business Ethics and Conduct - Federal Acquisition Regulation Clause 52.203–13

The Federal Acquisition Regulation requires that contractors have a written code of business ethics and conduct made available to employees; an ongoing business ethics awareness and compliance training program; and an internal control system with a periodic review of practices, procedures, and policies for compliance (Clause 52.203–13).

General Recommendations

  • Verify that the contractor has a code of business ethics and conduct that meets USAID standards and regulations.
  • Provide implementers with copies of USAID’s policies on ethics and conflicts of interest, and with written explanations and examples of potential conflicts.

Source: AUDIT REPORT NO. G-391-11-005-P JUNE 20, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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9 Subcontractor Had a Conflict of Interest - FAR Subpart 9.5 Organizational and Consultant Conflicts of Interest - Contract Information Bulletin 99-17

Federal Acquisition Regulations (FAR) Subpart 9.5 Organizational and Consultant Conflicts of Interest prescribes responsibilities, general rules, and procedures for identifying, evaluating, and resolving organizational conflicts of interest.

FAR 9.504(a) provides that the contracting officer is to identify potential conflicts of interest as early in the acquisition process as possible and is to avoid, neutralize, or mitigate significant conflicts before contract award. Also, Contract Information Bulletin 99-17 precludes a contractor from furnishing implementation services, as the prime or subcontractor, when the contractor has a substantial role in the design of an activity under contract with USAID by providing USAID with “material leading directly, predictably, and without delay” to a work statement for the implementation of the activity, subject to some exceptions.

Owner of a subcontractor employed by the project had an organizational conflict of interest with the project. At the time of employment the individual was an owner and manager of a dairy producer (the subcontractor). Contractor and this individual informally agreed that subcontractor would turn over the dairy business to an “arms-length manager,” but employee did not reveal to the contractor that the new manager was in fact the brother of the employee.

General Recommendations

  • Require contractors and subcontractors’ senior technical and management personnel involved with selecting beneficiaries to sign conflict of interest statements.
  • Require contractor to establish and implement procedures with regard to the selection of beneficiaries to minimize the risk of other conflicts of interest.

SOURCE: AUDIT REPORT NO. 7-685-11-006-P MARCH 31, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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1 Intellectual Property Rights Clauses in Agreements - ADS 318.2

According to ADS 318.2, Intellectual Property Rights, Primary Responsibilities, the Office of General Counsel (General Counsel) is the primary USAID office responsible for reviewing and providing guidance on intellectual property rights reports. Moreover, both contracting officers and agreement officers are responsible for ensuring that:

  • Appropriate intellectual property rights provisions and clauses are included in solicitation documents and funding agreements;
  • Appropriate intellectual property rights provisions and clauses are included in grants and cooperative agreements with U.S. nongovernmental organizations; and
  • Claims by offerors, applicants, or current implementers of exclusive or proprietary rights to intellectual property that has specific and frequent application in USAID activities are closely examined.

As an additional management oversight, contracting officer’s technical representatives (COTRs) and AOTRs ensure that the provisions and other applicable regulations are met. For intellectual property materials used overseas, the COTR and AOTR must coordinate with the Regional Legal Advisor to ensure that the beneficiary rights in intellectual property developed for a project are properly documented under local laws.

Source: AUDIT REPORT NO. 6-268-11-003-P December 6, 2010

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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2 Program Lacks a Detailed Gender Strategy - ADS 201.3.9.3

According to ADS 201.3.9.3, gender analyses are mandatory for strategic plans, assistance objectives, and projects/activities. ADS 201.3.9.3 further states, “gender issues are central to the achievement of strategic plans and Assistance Objectives (AO) and USAID strives to promote gender equality, in which both men and women have equal opportunity to benefit from and contribute to economic, social, cultural, and political development; enjoy socially valued resources and rewards; and realize their human rights.”

General Recommendations

  • Provide guidance to staff to reemphasize the requirements of Automated Directives System 201 to implement a gender strategy in all [program] activities.

Source: AUDIT REPORT NO. 6-294-11-006-P March 22, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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3 Prioritize or Follow Up on Significant Vulnerabilities - ADS 303.3.9.2

According to USAID’s Automated Directives System (ADS) 303.3.9.2, if, after conducting a comprehensive review of a potential recipient, USAID is unable to affirm that the recipient has the capacity to responsibly manage USAID funds, USAID can deny the award or make the award with “special award conditions.” USAID may consider making this choice only if it appears likely that the potential recipient can correct its deficiencies within a reasonable amount of time. These conditions are intended to be for a limited time, not for the life of the award.

Preaward Assessments

To minimize the risk in making awards to [...] governmental and local organizations, local accounting firms [can be contracted]  to conduct preaward assessments.

The assessments [could] identify weaknesses in the recipients’ financial management operations and make corresponding recommendations to resolve the weaknesses. The results of the assessments [can be] discussed and determinations [can be] made as to which of the recommendations should be included in the award agreement as:

  • Predisbursement requirements, or “special award conditions,” or
  • Postdisbursement recommendations.

Source: AUDIT REPORT NO. G-391-11-004-P MAY 6, 2011

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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4 The Authorization to Make Changes to the Contract’s Terms and Conditions

According to [a] COTR designation letter, the COTR [did] not have the authority to direct the contractor, either in writing or verbally, to make changes to the contract’s statement of work or the terms and conditions of the contract that could affect the quantity or quality of the work.

Further, the Contracting Officer’s Authority Clause of the [contractor’s] contract states that the contracting officer is the only person authorized to make or approve any changes in the requirements of the contract. In the event that the contractor makes any change at the direction of any person other than the contracting officer, the change shall be considered to have been made without any authority.

Source:  AUDIT REPORT NO. 5-440-11-009-P JULY 27, 2011

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

 

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5 Contractor Overbilling - FAR 31.2, Contracts with Commercial Organizations

FAR 31.2, Contracts with Commercial Organizations, provides that costs claimed should have been incurred and that costs are allocable and therefore chargeable to a contract on the basis of relative benefits received or other equitable relationship [FAR 31.201-2 and -4].

This subpart and the contract also state that costs refunded to the U.S. Government will include all applicable related costs, such as overhead, fixed fees, and interest [FAR 31.201-6(a)].

Source:AUDIT REPORT NO. 5-306-10-002-P November 10, 2009.

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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6 Contractor Performance Reviews Were Not Completed - FAR 42.15024 - USAID Acquisition Regulation (AIDAR) 742.15

The Federal Acquisition Regulation (FAR 42.15024) requires the mission to evaluate contractor performance and prepare a past-performance report for each construction contract of $550,000 or more and each architectural services contract exceeding $30,000.

According to the regulation, these performance reports should be prepared at the time of final acceptance of a completed construction project or at other times in accordance with Agency procedures. USAID Acquisition Regulation 742.15 requires contracting officers to report on contractor performance at least annually.

Regular, comprehensive, and conscientious performance evaluations can provide the mission with information to make better acquisition decisions and serve as a significant incentive to contractors to provide USAID with superior products and services. Further, the U.S. Government Accountability Office has ruled that failure to properly document contractor performance information and make the information available for use in source selections for the same or similar items is a sufficient basis to sustain a protest of a contract award in a subsequent source selection.

General Recommendations

  • Complete all required contractor performance reviews in accordance with Agency procedures.

Source: AUDIT REPORT NO. 5-306-10-007-P MARCH 31, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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7 Unauthorized Commitments - 22 CFR 226.25(e) - ADS 303.3

ADS 303.3.18 states that an unauthorized commitment has occurred when aN USAID official, who does not have the authority to do so, acts in a way that leads a recipient or potential recipient acting in good faith to believe that USAID has committed to make a specific award; change the amount of an existing award; or revise an existing award budget, program description, or any terms and conditions of the award.

The Code of Federal Regulations 22 CFR 226.25(e)  allows a recipient to initiate a one-time extension of the expiration date of an award for up to 12 months under certain conditions. However, to do so, the recipient must notify the USAID agreements officer in writing, with the supporting reasons and revised expiration date, at least 10 days before the expiration date of the award.

In particular, this one-time extension may not be exercised merely for the purpose of using unobligated balances, and it may not be initiated if the terms and conditions of the award prohibit the extension, if the extension requires additional Federal funds, or if the extension involves any change in the approved objectives or scope of the project.

Source: AUDIT REPORT NO. E-267-10-001-P MARCH 31, 2010

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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8 Conduct Audits of Foreign Organizations - ADS 591.3.2 - Guidelines for Financial Audits Contracted by Foreign Recipients - General Act of 1978

Automated Directives System (ADS) 591.3.2, Audits of Foreign Organizations and Host Government Entities, provides guidance on audits of foreign organizations. Specifically, ADS 591.3.2.1, Foreign Organizations, states that a mission must assess risk at least annually to determine whether financial audits of foreign for-profit organizations are warranted.

Furthermore, ADS 591.3.2.1 requires a Federal cognizant agency or independent auditor to audit the direct and indirect costs[1] incurred under an award to determine allowable direct costs and to recommend indirect cost rates.

The USAID guidance states that the prime recipient must impose the Guidelines for Financial Audits Contracted by Foreign Recipients on foreign subrecipients. These guidelines state that USAID agreements with foreign recipients require recipients to contract independent auditors acceptable to USAID’s Office of Inspector General (OIG) to perform financial audits of the funds provided under the agreements.[2]

In addition, ADS 591.3.6, USAID Audit Rights, clearly states that USAID retains the right to require audits or otherwise ensure adequate accountability of recipient organizations regardless of the audit requirement.

[1] According to the Federal Acquisition Regulation, a direct cost is any cost that can be identified with a particular final cost objective, and an indirect cost is any cost that is not directly identified with a single, final cost objective but can be identified with two or more final cost objectives, such as rent, utilities, and supplies.

[2] Such audits are in accordance with the Inspector General Act of 1978, as amended. The OIG reserves the right to conduct audits using its own staff, notwithstanding acceptable audits performed by other auditors, in cases where special accountability needs are identified.

General Recommendations

  • Develop and implement procedures to require the prime contractor to periodically conduct independent financial reviews of for-profit local subcontractors’ incurred costs to determine if audits are warranted.
  • Conduct incurred costs audits as required by the Guidelines for Financial Audits Contracted by Foreign Recipients.

Source:AUDIT REPORT NO. 6-278-10-004-P March 31, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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9 Implementing Partner Record Retention Regulations - 22 CFR 226.53(b)

Record retention requirements for awards to recipients receiving a grant or cooperative agreement directly from USAID to carry out a project or program are set forth in Title 22 of the Code of Federal Regulations (CFR), Section 226.53.

According to 22 CFR 226.53(b), with limited exceptions, “Financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of three years from the date of submission of the final expenditure report or, for awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, as authorized by USAID.”

Part 226.53(e) further states that “USAID, the Inspector General, Comptroller General of the United States, or any of their duly authorized representatives, have the right of timely and unrestricted access to any books, documents, papers, or other records of recipients that are pertinent to the awards, in order to make audits, examinations, excerpts, transcripts and copies of such documents.”

Source: AUDIT REPORT NO. 7-688-10-004-P February 26, 2010

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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10 Verify Continued Separate Maintenance Allowance Eligibility - Department of State Standardized Regulations, General Provisions, Section 077.3, Granting Allowances and Difficult to Staff Incentive Differential on SF-1190 (Foreign Allowances Application

Department of State Standardized Regulations, General Provisions, Section 077.3, Granting Allowances and Difficult to Staff Incentive Differential on SF-1190 (Foreign Allowances Application, Grant, and Report), Subsection 077.31, General, states that each agency shall grant, revise, and terminate SMA benefits on the SF-1190.

The guidance requires employees to suspend or terminate grant based on specific events. In addition, DSSR Chapter 260, Section 266, Suspension/Termination of Grant, also requires that the grant be suspended or terminated based on specific events that include:

  • A visit from a family member to post that is in excess of 30 consecutive days.
  • An employee’s transfer from post.
  • When an employee is separated from the agency while assigned at post where benefits have been granted.

Continued eligibility can be negatively affected when an employee becomes legally separated from a spouse or when a dependent child reaches a specific age. Moreover, ADS 596.3.2, Assessing the Adequacy of Internal Controls, requires managers to assess the adequacy of internal controls and improve the effectiveness of those associated with operations.

General Recommendations

  • Verify continued separate maintenance allowance eligibility.

Source: AUDIT REPORT NO. 6-263-10-003-P January 14, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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11 Local Subgrantees Need Codes of Conduct for Interactions with Orphans and Vulnerable Children - U.S. Global AIDS Coordinator (OGAC) Guidance July 2006

According to guidance issued by Office of the U.S. Global AIDS Coordinator (OGAC), OGAC in July 2006, the guiding principles of Orphans and Vulnerable Children (OVC) program implementation are rooted in the principles of child protection: developing and implementing programs that place the best interests of the child and his or her family above all else.

Thus, programs should include efforts to confront and minimize the reality of stigma and social neglect faced by OVCs, as well as abuse and exploitation, including trafficking, theft of inherited property, and land tenure.

General Recommendations

  • Establish and document a standard code of conduct for all subgrantees with activities affecting orphans and vulnerable children, outlining appropriate and inappropriate conduct in dealing with children in the program.

Source: AUDIT REPORT NO. 1-504-10-003-P DECEMBER 29, 2009

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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12 Technical Representative Requirements - ADS 458.3.5.5 - ADS 303.3.14

USAID has documented requirements for its technical representatives in guidance in two ADS sections. ADS 458.3.5.5, Federal Acquisition Certification Programs, requires a technical representative to complete mandatory acquisition and assistance courses for certification within 6 months of being appointed as a technical representative.

In addition, ADS 303.3.14, Designation of the Agreement Officer’s Technical Representative, requires the agreement officer to use a designation letter to define the scope of the technical representative’s responsibilities. The designation letters authorize technical and administrative oversight of an award that includes monitoring, verifying, and recommending changes to the agreement, as well as administratively approving financial payments of USAID funds, if required.

If a technical representative cannot fulfill his or her responsibilities, the representative should notify the agreement officer to ensure the timely designation of a successor.

Source: AUDIT REPORT NO. 6-263-10-001-P October 27, 2009.

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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13 Assistance Awards and Requirements - ADS 303 - ADS 621.3.4

USAID has developed extensive guidelines on the management of assistance awards and requirements for implementers that require agreement with the terms of an award and mandatory standard provisions. USAID’s Automated Directives System (ADS) 303, Grants and Cooperative Agreements to Nongovernmental Organizations, states that technical representatives should review and analyze reports, monitor reporting requirements, and ensure the recipient’s compliance with numerous terms and conditions of an award.

Some of these mandatory standard provisions for non-U.S., nongovernmental recipients require that subagreements shall contain provisions about financial audit requirements, termination or suspension of awards, antiterrorism financing responsibilities, and branding and marking responsibilities.

Furthermore, ADS 621.3.4, Types of Obligations and Documentary Evidence, states that only a USAID signature is required for an assistance award unless major issues are unresolved between USAID and the grantee, in which case both parties must sign the award.

However, ADS 303.3.13, The Award Process and Elements of an Award, states that recipients are required to agree to the terms of the agreements, which are legally binding.

AUDIT REPORT NO. 6-263-10-001-P October 27, 2009

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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14 Certification Regarding Responsibility Matters - FAR 9.104-6 - FAR 9.105-2(b) - FAR 9.4

When a contract value is expected to exceed the simplified acquisition threshold, FAR 9.104-6 requires prospective contractors to complete and submit the Certification Regarding Responsibility Matters, stating whether they are sufficiently responsible to hold a Federal contract. FAR 9.105-2(b) requires that documents supporting a responsibility determination, such as the completed certification, be kept in the contract file. If the certification is made electronically, FAR 4.1201(c) requires that either a verification date or a paper copy of the certification be included in the file.

AUDIT REPORT NO. 9-000-10-001-P October 1, 2009

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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15 Excluded Parties List System Reviews During the Bidding and Awarding Process - FAR 9.404 - 22 CFR 208 - ADS 502.5.1b - FAR 9.405(d) - FAR 9.105-2(b)

The FAR and CFR state that agencies are required to enter information about exclusion actions into the Excluded Parties List System database within 5 workdays after the action becomes effective (FAR 9.404(c)(3) and 22 CFR 208.520(c)). The purpose of this entry is to disseminate, in a timely manner, information on parties that are excluded from Federal awards.

Automated Directives System 502.5.1b asserts that official records must be preserved because of the informational value of evidence of an agency’s decisions. Furthermore, FAR 9.404(c)(6) requires each agency to maintain records relating to each debarment, suspension, or proposed debarment taken by the agency. Title 22 of the CFR implies a similar requirement in that agencies must be able to respond to inquiries about exclusions (22 CFR 208.525).

Specifically, FAR 9.405(d) requires that the Excluded Parties List System (EPLS) database be reviewed twice by the contracting officer—once during the bidding process, as bids and proposals are received, and again prior to the award of a contract—to make sure that no award is made to a contractor listed as excluded. Additionally, FAR 9.105-2(b) requires that documents supporting a responsibility determination, such as database reviews, be included in the contract file.

General Recommendations

  • Conduct Excluded Parties List System reviews during the bidding and awarding process and document those reviews, in accordance with Federal Acquisition Regulation 9.405(d) and 9.105-2(b).

Source: AUDIT REPORT NO. 9-000-10-001-P October 1, 2009.

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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16 Implementer Performed Unauthorized Program Activities - ADS 202.3.6.1

Automated Directives System 202.3.6.1, “Assessing Performance of Contractors and Recipients,” states that the COTR for direct procurement instruments must ensure that the implementing partner is performing in accordance with the terms contained in the contract or other agreements. It also states that COTR responsibilities for monitoring contractor performance may include reviewing and approving deliverables and performance reports.

General Recommendations

  • Ask the Regional Contracting Office to make a management decision regarding the allowability of questioned ineligible costs in the amount of [...] and recover all amounts determined to be unallowable.

SOURCE: AUDIT REPORT NO. 6-268-10-006-P August 24, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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17 Ensure That Funding Requests Are Appropriate - ADS 602.3.2

USAID guidance on forward funding generally prohibits program managers from carrying obligations for more than 12 months beyond the end of the fiscal year in which the obligation takes place [ADS 602.3.2].

However, Automated Directives System 602.3.3, “Exceptions to the Maximum Length of Forward Funding,” states that some flexibility is required to facilitate the execution of some activities, if compelling reasons exist. Operating unit directors have the authority to approve exceptions to the policy directives and required procedures, if compelling reasons exist and are documented. For example, an exception for new programs is made that allows full funding to be provided at the outset if a new program is under $2 million. If a new program costs $2 million or more, obligations must be sufficient to cover at least the first 18 months but not more than 24 months.

General Recommendations

  • Develop written procedures regarding the required support documentation that should accompany waiver requests for funding.

SOURCE: AUDIT REPORT NO. 6-268-10-006-P August 24, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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18 Strengthen Oversight of Renovation Activities - FAR Part 36, “Construction and Architect-Engineer Contracts” - GAO/AIMD-00-21.3.1 (11/99), page 20

The FAR prescribes policies and procedures for acquisitions of supplies and services with federally appropriated funds. FAR Part 36, “Construction and Architect-Engineer Contracts,” documents policies and procedures regarding contracting for construction and architect-engineer services.

The guidance requires the use of certain clauses and standard forms that are applicable to contracts for dismantling, demolishing, or removing improvements.

In addition, according to FAR Subpart 36.6, “Architect-Engineer Services,” the Federal Government’s policy is to negotiate architect-engineer services contracts on the basis of the demonstrated competence and qualifications of prospective contractors to perform the services at fair and reasonable prices.

Moreover, GAO’s Standards for Internal Control in the Federal Government - GAO/AIMD-00-21.3.1 (11/99), page 20  - states that internal control should generally be designed to assure that ongoing monitoring occurs continually as an integral part of the agency’s operations, including regular management and supervisory activities, comparisons, and reconciliations.

General Recommendations

  • Review the recommendations documented in the engineering consultant’s technical report.
  • Implement the recommendations and document justifications for any deviations from the recommendations contained in the technical report.

SOURCE: AUDIT REPORT NO. 6-268-10-006-P August 24, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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19 Mission Did Not Complete Contractor Performance Review - USAID Acquisition Regulation 742.15 (also known as 48 CFR 742.1502) - FAR 42.1502

The Federal Acquisition Regulation (FAR 42.1502) requires agencies to evaluate and report on contractor performance for each contract exceeding the simplified acquisition threshold, which is currently $150,000. Furthermore, USAID Acquisition Regulation 742.15 (also known as 48 CFR 742.1502) requires contracting officers to report on contractor performance at least annually.

Regular, comprehensive, and conscientious performance evaluations can provide the mission with information to make better acquisition decisions and can serve as a significant incentive to contractors to provide USAID with superior products and services.

Further, the U.S. Government Accountability Office has ruled that failure to properly document contractor performance information and make the information available for use in source selections for the same or similar items is a sufficient basis to sustain a protest of a contract award in a subsequent source selection.

General Recommendations

  • Complete all required contractor performance reviews in accordance with Federal Acquisitions Regulation and Agency for International Development Acquisitions Regulation requirements.

Source: AUDIT REPORT NO. F-306-11-003-P JUNE 19, 2011 

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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20 Contracting Officials Did Not Document Contract Files or Communicate Adequately - 22 CFR 226 - FAR 4.801 (b)

USAID is responsible for monitoring the use of its support for projects and activities in accordance with 22 CFR 226. As part of the responsibility, the Federal Acquisition Regulation states that documentation in contract files shall be sufficient to constitute a complete history of the transaction to provide a complete background for decisions made, to support actions, and to provide information for reviews, investigations, litigation, or congressional inquiries (FAR 4.801 (b)).

Copies of communications with contractors must be provided to the contracting officer so that the contracting officer knows about the contractor’s performance and can avoid potential claims or disputes. Contract documentation is important to show that the mission is protecting the U.S. Government’s interests.

General Recommendations

  • Develop and implement a plan for periodic internal review of contract files for a complete history of contract transactions and all communications with contractors.

Source: AUDIT REPORT NO. G-391-11-005-P JUNE 20, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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21 Fixed-Amount Reimbursement Agreements Reduce Risk - ADS Supplemental 317

According to USAID’s Automated Directives System (ADS), a fixed-amount reimbursement agreement is the preferred method in financing multiple-unit construction activities, such as road construction (ADS Supplemental 317).

Disbursements for a fixed-amount reimbursement agreement are made for outputs rather than inputs, outputs being the physical completion of a project or subproject or a quantifiable element of the project. The output must meet previously agreed-upon specifications or standards before reimbursement is made to the host country. The amount of reimbursement is fixed in advance based on reasonable cost estimates reviewed and approved by USAID. To ensure compliance with agreed plans and specifications, the mission is required to conduct periodic inspections of the project, as well as to certify, upon completion, compliance with agreed-upon plans and specifications.

A fixed-amount reimbursement agreement can reduce common risks occurring in road reconstruction projects, such as extension of completion dates and increased costs, because the recipient is not reimbursed until subprojects are completed and the amount paid to the host government is fixed, limiting exposure to rising costs.

For road activities, the mission [can use] a separate fixed-amount reimbursement agreement for each segment of road, reducing the risk of missing target completion dates and allowing some flexibility to address price escalations for construction. A x percent escalation fee [can be] incorporated into the budget for road activities to cover any rising costs. However, the mission and implementers agreed that, at the time each agreement is signed, published construction price indexes relevant to the geographic area will be used instead. Using published price indexes will reduce the risk of unsupported price escalations.

A fixed-amount reimbursement agreement reduces risks because the approval process for reimbursement under such an agreement is extensive. Engineers and technical experts and USAID review all requests for reimbursements to ensure compliance with specifications and standards.

Source: AUDIT REPORT NO. G-391-11-005-P JUNE 20, 2011

This information is derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using this information.

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22 Strengthen Program Oversight - ADS 302

In USAID’s Automatic Directives System (ADS) Chapter 302, Procedures for Designating the Contracting Officer’s Technical Representative (COTR) for Contracts and Task Order states that the COTR is in a unique position to monitor the contractor’s performance and is delegated authorities that are otherwise vested in the contracting office.

The COTR is expected to monitor the contractor's performance, verify that it conforms to the technical requirements and quality standards, and document and elevate any material deficiencies in the contractor's performance to the contracting office.

Accordingly, the COTR’s approval of implementation plans, work plans, or monitoring or evaluation plans must be consistent with the terms and conditions of the contract

General Recommendations

  • Develop and document a checklist of required information to monitor completion of work plan activities.
  • Develop written procedures for access requirements, transfer, and maintenance of electronic program files.
  • Document and publicize requirements for  electronic records retention and link them to an official staff-departure checklist.

SOURCE: AUDIT REPORT NO. 6-268-10-006-P August 24, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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23 Contract Not Adequately Reviewed by Contract Review Board - (ADS) 302.3.1.2 - Contract Review Board Guidelines

Summary: USAID policy requires that contracts exceeding $10 million be reviewed at various stages of the procurement process. However, the contract for the [...] program was not reviewed in accordance with this policy. This occurred because mission officials initially believed that the threshold for review was higher than $10 million. As a result, the contract was not adequately reviewed, exposing the Agency to possible legal action and contributing to contract ambiguities.

Reviewing the legal aspects of contracts before their execution is a common business practice. Similarly, USAID’s Automated Directives System (ADS) 302.3.1.2 requires that acquisition actions, such as contracts, that exceed $10 million be reviewed by USAID’s Contract Review Board (CRB).

The CRB reviews these actions to minimize USAID’s vulnerability to potential legal action, provide senior-level advice on contracting actions, and to support contracting officers. As part of this effort, the CRB includes attorneys from the Office of General Counsel experienced in Government contracting.

ADS 302.3.1.2 also requires that contracting officers submit actions to the CRB at the presolicitation, competitive range determination, and preaward stages of the procurement process. In submitting actions, the Contract Review Board Guidelines (a mandatory reference to ADS 302) recommends that contracting officers allow ample lead time to accommodate CRB review and to respond to mandatory findings.

General Recommendations

  • Notify acquisition staff of USAID requirements related to the Contract Review Board and establish a management control to help ensure that all prospective awards that meet the requirements for review by the Contract Review Board are submitted in a timely manner to the Board.

Source: AUDIT REPORT NO. 4-674-11-004-P JANUARY 4, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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24 Questionable Spending Occurred - Federal Acquisition Regulations 52.216-7 and 52.216-8 USAID Acquisition Regulation 752.7003 FAR Subpart 31.2-Contracts with Commercial Organizations

Allowable costs are limited to those that are reasonable, allocable, and necessary, determined in accordance with Federal Acquisition Regulations 52.216-7 and 52.216-8 and with USAID Acquisition Regulation 752.7003.

Federal Acquisition Regulation 52.216-7 incorporates the cost principles of FAR Subpart 31.2-Contracts with Commercial Organizations, which defines a reasonable cost as one that “does not exceed that which would be incurred by a prudent person in the conduct of competitive business” and is “generally recognized as ordinary and necessary” for the conduct of the contractor’s business or for contract performance.

General Recommendations

  • Determine the allowability of ineligible questioned costs and recover any amounts determined to be unallowable.

Source: AUDIT REPORT NO. 4-674-11-004-P JANUARY 4, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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25 Contracting Mechanism Used for Program is not Appropriate - Federal Acquisition Regulation 16.505(a)(2) - supplemental policy to ADS 302, Indefinite Quantity Contract (IQC): Task Order Work Statement Development Checklist - Competition in Contracting Act

In the absence of an indefinite quantity contract (IQC) offering technical advisory services on [...] areas, [the mission] turned to an IQC that [provided different services].

According to Federal Acquisition Regulation 16.505(a)(2), “orders shall be within the scope” of an indefinite-delivery contract. As well, USAID’s supplemental policy to ADS 302, Indefinite Quantity Contract (IQC): Task Order Work Statement Development Checklist, states that the task order must fit within the scope of the IQC statement of work.

General Recommendations

  • Either re-compete the contract for technical services or prepare the appropriate justification required by the Competition in Contracting Act of 1984 for other than full and open competition.

Source:  AUDIT REPORT NO. 1-523-11-001-P JANUARY 12, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.


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26 Lack of Effective Program Oversight - ADS 302-Procedures for Designating the COTR for Contracts and Task Orders - ADS 303- Agreement Officer’s Technical Representative (AOTR) Designation – Cooperative Agreement Administration.

The contracting officer’s technical representative (COTR) and agreement officer’s technical representative (AOTR) each have key oversight responsibilities for directing and administering contracts and grants. USAID’s procedures for designating a COTR and AOTR outline those responsibilities.

For example, the COTR serves as the technical liaison between the contracting officer and the contractor because of the COTR’s unique responsibility to monitor the contractor’s performance in achieving the contract’s purpose. The AOTR is responsible for providing technical and administrative oversight to the implementer.

With respect to contracts especially, COTRs’ failure to carry out their duties and responsibilities effectively will impede the successor COTR’s ability to manage the contract and possibly jeopardize the program for which it was awarded.

General Recommendations

  • Update Performance Management Plan.
  • Strengthen internal controls so that technical officers implement their delegated duties in accordance with USAID policy.

Mandatory reference for ADS 302-Procedures for Designating the COTR for Contracts and Task Orders, and an additional help for ADS 303- Agreement Officer’s Technical Representative (AOTR) Designation – Cooperative Agreement Administration.  

Source:  AUDIT REPORT NO. 1-523-11-001-P JANUARY 12, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.


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27 Subcontracts Lacked Supporting Documentation and Were Susceptible to Fraud - (FAR) 31.201-2(d)

Federal Acquisition Regulation (FAR) 31.201-2(d) states:

A contractor is responsible for accounting for costs appropriately and for maintaining records, including supporting documentation, adequate to demonstrate that costs claimed have been incurred, are allocable to the contract, and comply with applicable cost principles in this subpart and agency supplements. The contracting officer may disallow all or part of a claimed cost that is inadequately supported.

To comply with requirements, each subcontract file should contain the following information:

  • The approved purchase requisition
  • The written solicitation (where required)
  • The written responses to requests for proposals or requests for quotations
  • A memorandum justifying sole-source procurement (if no competition)
  • A technical evaluation
  • A price and cost analysis
  • A memorandum of negotiations
  • The basis of the award form
  • A copy of purchase orders or subcontracts and all change orders
  • Insurance certifications
  • Copies of suppliers’ invoices
  • Correspondence, internal and external, related to the purchase order and subcontract
  • Other purchase order and subcontract documentation as required by the purchase orders and subcontracts’ terms and conditions
  • The final contractor release forms
  • A procurement documentation checklist indicating the documentation in the file

General Recommendations

  • Develop an adequate records system to support claimed subcontract costs and verify the contractor’s completed actions.

SOURCE: AUDIT REPORT NO. E-267-11-002-P MAY 16, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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28 Voluntary Population Planning Language Was Not Included in Subcontracts - USAID Acquisition Regulation (AIDAR) 752.7101, Voluntary Population Planning Activities

USAID Acquisition Regulation (AIDAR) 752.7101, Voluntary Population Planning Activities, requires insertion of contract clause stating that none of the funds made available under a contract shall be used to pay for the performance of involuntary sterilization as a method of family planning or to coerce or provide any financial incentive to any individual to practice sterilization.

It also prohibits abortion-related activities and identifies additional requirements for projects engaging in family planning activities.

General Recommendations

  • Provide documentation demonstrating the inclusion of the required voluntary population planning language in contracts for review.

SOURCE: AUDIT REPORT NO. 6-278-11-004-P January 10, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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29 Appropriate Records Were Not Retained - Federal Acquisition Regulation (FAR) 52.215-2, Audit and Records – Negotiation

According to the contract clause set forth in Federal Acquisition Regulation (FAR) 52.215-2, Audit and Records – Negotiation, records should generally be maintained for examination, audit, or reproduction until 3 years after final payment under a contract.

General Recommendations

  • Provide written guidance to contractors and subcontractors regarding required record retention periods and periodically verify source documents to database information.

SOURCE: AUDIT REPORT NO. 6-278-11-004-P January 10, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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30 Source Origin Requirements Were Not Met - ADS 310, Source, Origin, and Nationality of Commodities - the Foreign Assistance Act Section 604 - ADS 310.5.5

The contract documents the United States of America as the authorized geographic code for the procurement of goods and services under the award. Furthermore, ADS 310, Source, Origin, and Nationality of Commodities, requires that the goods and services financed by USAID meet the requirements of the Foreign Assistance Act (the Act) and provide benefit to the U.S. economy as well as fulfilling the needs of the foreign assistance program.

Similarly, Section 604 of the Act states that funds made available for assistance under this Act may be used in any other country, but only if the provision of such assistance requires commodities or services of a type that are not produced in and available for purchase in the United States, the recipient country, or developing countries.

As a remedy, ADS 310.5.5 states that USAID may expand the authorized geographic code only using an approved waiver.

General Recommendations

  • Request source origin waivers through the mission director or appropriate USAID agreement officer for project goods and services when needed.

SOURCE: AUDIT REPORT NO. 6-279-11-005-P February 28, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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31 Approval for Subawards Was Not Obtained - 22 CFR Part 226, Administration of Assistance Awards to U.S. Non-Governmental Organizations, Section 226.25(c)(8)

22 CFR Part 226, Administration of Assistance Awards to U.S. Non-Governmental Organizations, Section 226.25(c)(8), states that for nonconstruction awards the recipient shall request prior approvals from the USAID agreement officer for the subaward, transfer, or contracting out of any work under an award.

General Recommendations

  • Require implementer to provide a list of proposed or pending subawards and contracting out of any work under the project before the implementer hires a subcontractor to begin work.
  • Notify the agreement officer in writing of its proposed or pending subawards and contracting out of any work under the project before the implementer hires a subcontractor to begin work.

SOURCE: AUDIT REPORT NO. 6-279-11-005-P February 28, 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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1 Participant Training Requirement Not In Place - ADS 253.3.1

USAID agreement officers are required to include standard provisions in USAID grants, contracts, and cooperative agreements mandating that any participant training funded by the USAID agreement comply with Section 253 of USAID’s Automated Directives System.

 ADS 253 stipulates the requirements for USAID-sponsored learning activities, including those conducted outside the United States. These requirements include an agreement among participants, the mission, and other parties describing specific responsibilities for achieving USAID training objectives. In addition, ADS 253.3.2 states that missions or their implementers must enter selected data on in-country training programs into USAID’s Training Results and Information Network (USAID’s training management system database, also referred to as TraiNet)  for training under their respective strategic objectives or activities. These data are to include the following:

Subject area of training.

Start and end date.

Total trainees per training, with gender breakdown.

Total cost of training for each program (broken down by instruction, participant, and travel).

Moreover, ADS 253.3.1 states, among other things, that Sponsoring Units must (1) plan, track, manage for results, and report on their participant training activities as part of their broader performance measurement, evaluation, and reporting requirements; (2) develop indicators of planned participant training results; and (3) strictly follow the policy requirements, including those contained in the Conditions of Sponsorship form* for both program-related and legal obligations.

Finally, it states that Sponsoring Units and Implementers must use the Training Results and Information Network to document all USAID participants in all out-of-country and in-country participant training data.

* AID form 1381-6, dated August 2008. This form establishes an agreement between the trainee and USAID concerning key elements of the training experience, such as the requirement that the trainee return to his/her home country for 2 years after completing the USAID-funded training.

General Recommendations

  • Incorporate the appropriate training provision in each agreement/contract that is lacking that provision.

Source: AUDIT REPORT NO. 4-663-10-003-P  MARCH 30, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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2 Process for Evaluating Training Effectiveness is Inadequate - ADS 253.3 - ADS 203.3.2

ADS 253.3, “Policy Directives and Required Procedures,” require missions that expend USAID funds for participant training to design and implement the training for results and impact. Specifically, missions must report on their participant training activities as part of their broader performance measurement, evaluation, and reporting requirements.

According to ADS 203.3.2, “Performance Management,” USAID missions and offices and their assistance objective teams are responsible for measuring progress toward the results identified in the planning stage to achieve foreign assistance objectives.

General Recommendations

  • Establish and implement procedures for systematically following up with training participants to assess the impact and effectiveness of training.

Source: 1-521-11-005-P Year: 2011

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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3 Training Effectiveness is not Evaluated - ADS 253.3 - ADS 203.3.2

USAID policy ADS 253.3 requires missions that expend USAID funds for Participant Training design, implementation or evaluation activities to design and implement participant training for results and impact. Specifically, such missions must plan, track, manage for results, and report on their participant training activities as part of their broader performance measurement, evaluation, and reporting requirements.

ADS 203.3.2 also states that missions are responsible for measuring progress toward the desired results identified in the planning stage to achieve foreign assistance objectives.

General Recommendations

  • Establish procedures for systematically following up with training participants to assess the impact and effectiveness of training.

Source:  AUDIT REPORT NO. 1-523-11-001-P JANUARY 12, 2011

 

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.

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4 TraiNet Reporting Not Accurate - ADS 253.3 - ADS 253.3.4.5 (b)

ADS 253.3 states that sponsoring units must:

  • Design, implement, and track the training or program event for results and impact,
  • Design training programs that support USAID objectives or other USG initiatives,
  • Report on their participant training activities as part of their broader performance measurement, evaluation, and reporting requirements, and
  • Design and carry out participant training activities with cost control and cost-sharing practices whenever possible.

ADS 253.3.4.5 (b) requires sponsoring units to enter data in Training Results and Information Network (TraiNet) for any in-country training programs or subprograms of 2 consecutive class days or more in duration, or 16 contact hours or more scheduled intermittently.

The policy also states that sponsoring units should report any and all other in-country training events that are critical to their development efforts.

General Recommendations

  • Institute procedures to consistently collect and input training data into the USAID training network.

Source:  AUDIT REPORT NO. 1-523-11-001-P JANUARY 12, 2011

 

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations.  Please see the disclaimer of this site before using recommendations.


 

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