World Bank
© October 2008
TABLE OF CONTENTS
TABLE OF CONTENTS 2
ACKNOWLEDGMENTS 3
TABLES AND GRAPHS 3
abbreviations and acronyms 4
EXECUTIVE summary 5
BACKGROUND 8
II. GOVERNANCE STRUCTURE AND INTERVENTION MECHANISMS AT THE COMMUNITY 8
III. METHODOLOGY 9
IV. Survey data and analysis 12
A. CNLS and its subsidiary entities 12
1. Examination of existing institutional mechanisms 12
2. Examination of governance structure and accountability mechanisms 13
3. Examination of existing processes 14
4. Examination of fund utilization mechanisms 14
5. Examination of mechanisms governing the social obligation to inform the public and the management of corruption complaints 14
B. Project Management Unit (PMU) and Financial Management Agency (FMA) 12
1. Examination of governance structure and accountability mechanisms 15
2. Examination of existing processes 16
4. Examination of fund establishment and utilization mechanisms 17
5. Examination of accountability mechanisms, the obligation to inform the public, and the management of corruption complaints 17
C. Community Organizations (COs) and Civil Society Organizations (CSOs) 12
1. Examination of existing institutional mechanisms 17
2. Examination of governance structure and accountability mechanisms 19
3. Examination of existing processes 19
4. Examination of fund utilization mechanisms 19
5. Examination of accountability mechanisms, obligation to inform the public and management of corruption complaints Erreur ! Signet non défini.
V. RECOMMENDATIONS 17
A. Recommendations concerning the CNLS and its subsidiary entities 19
B. Recommendations on the PMU 19
C. Recommendations on the FMA 19
D. Recommendations concerning COs and CSOs 19
CONCLUSION 19
Annex 1: TEMPLATE OF THE CSO SUB-PROJECT Erreur ! Signet non défini.
ANNEX 2: COMPLIANCE REVIEW SHEET FOR THE CO SUB-PROJECT Erreur ! Signet non défini.
ANNEX 3: ROSTER OF COMMUNITY ORGANIZATIONS AND CIVIL SOCIETY ORGANIZATIONS IN WHICH HIV/AIDS CONTROL OPERATIONS HAVE BEEN CHARACTERIZED BY IRREGULARITIES OR FRAUD
TABLES AND GRAPHS
TABLES
Table 1: Nature and number of beneficiaries surveyed…………………………………….25
Table 2: Distribution of persons surveyed by beneficiary or entity………………..28
GRAPHS
Graph n°1: Examination of institutional profile of COs………………………………. 18
Graph n°2: Examination of accountability mechanisms……………………………… 19
Graph n°3: Examination of governance structure………………………………………… 19
Graph n°4: Examination of the process of awarding funding to CSOs and COs
19
Graph n°5: Examination of the fund utilization mechanism………………………… 19
Graph n°6: Examination of accountability mechanisms, obligation to inform the public and management of corruption………………………………………………. 19
abbreviations and acronyms
AGeFIB Agence de financement des initiatives à la base (Grassroots initiatives funding agency)
AIDS Acquired Immune Deficiency Syndrome
AOO AIDS Operations Officer
ARV Antiretroviral [drugs]
CALS Comité d’arrondissement de lutte contre le SIDA (Arrondissement-level AIDS Committee)
CCLS Comité communal de lutte contre le VIH/SIDA (Commune-level HIV/AIDS Committee)
CDLS Comité départemental de lutte contre le SIDA (Département-level AIDS Committee)
CLCAM Caisse locale de crédit agricole et mutuel (Credit Union)
CNLS Comité National de Lutte contre le SIDA (National AIDS Commission)
CO Community Organization
CSO Civil Society Organization
CVLS Comité villageois de lutte contre le SIDA (Village-level AIDS Committee)
FMA Financial Management Agency
FOO Financial Operations Officer
FPEB Fonds pour la Protection de l’Enfant au Bénin (Benin Child Protection Fund)
GAC Governance and Anti-Corruption Strategy
HIV Human Immunodeficiency Virus
IEC Information, Education and Communication
IGA Income-generating activities
IGE Inspection Générale d’Etat (State General Inspectorate)
IGF Inspection Générale des Finances (General Finance Inspectorate)
MAP Multisectoral Aids Program
MSP Ministère de la Santé Publique (Ministry of Health)
NGO Non-Governmental Organization
OAL Organisation d'appui au lancement (Project start-up assistance NGOs)
OVC Orphans and Vulnerable Children
PACLS Plan d'action de lutte contre le SIDA (AIDS Control Action Plan)
PADEAR Projet d’Assistance au Développement du Secteur de l’Alimentation en Eau et de l’Assainissement en Milieu Rural (Assistance Program for the Development of the Water Supply and Sanitation Sector in Rural Areas)
PDRT Programme de Développement des plantes à Racines et Tubercules (Roots and Tuber Development Project)
PEC Prise en charge (Healthcare coverage)
PLWA Person living with AIDS
PMLS-II Second Multi-sector AIDS Control Project
PMU Project Management Unit
PNDCC Projet National d’Appui au Développement Conduit par les Communautés (National Community Driven Development Support Project)
PNLS Programme national de lutte contre le SIDA (National AIDS Control Program)
PPLS Multi-sector AIDS Control Project
PSO Public Sector Organization
SP/CNLS Permanent Secretariat of the National AIDS Control Committee
STD Sexually Transmitted Diseases
SDR Special Drawing Rights
TOR Terms of Reference
UFLS Unité focale de lutte contre le SIDA (Focal Unit for AIDS Control)
UNDP United Nations Development Programme
WBG World Bank Group
WHO World Health Organization
ACKNOWLEDGMENTS
This self assessment was carried out with the support and cooperation of the following:
▪ Members of Community Organizations (COs) and Civil Society Organizations (CSOs);
▪ Leaders of the CNLS and its subsidiary entities;
▪ Members of the MAP 1 Management Unit;
▪ Members of the Administration of the Second Phase of the Multi-sector HIV/AIDS Prevention Project (PMLS-II);
▪ Members of the Financial Management Agency (FMA) at the central and decentralized levels;
▪ Members of the World Bank team in Cotonou and Washington.
The report is put together by the assessment team with significant inputs and guidance, from the consultant engaged by the World Bank, Edouard Houssou. The report has been shared with the Benin 10-man GAC team and discussed at a decision meeting at the World Bank in Washington. All inputs and recommendations have been incorporated.
EXECUTIVE summary
I INTRODUCTION
1. Good governance, effective and efficient management of public finances is an integral part of development and is viewed as central to poverty alleviation. The report is prepared in support of the CNLS agenda of reducing HIV/AIDS in Benin. Benin was supported by the World Bank as a pilot country for a self–assessment of governance arrangements in HIV/AIDS operations with primary focus on three main categories of actors: (a) Civil Society Organizations (CSOs) and Community Organizations (COs), in their capacity as project beneficiaries; (b) the CNLS and its subsidiary entities, in their capacity as entities approving the funds granted to beneficiaries; and the PMU and FMA at the central and decentralized levels, in their capacity as management support entities. It however has more focus and emphasis on the CSOs and COs.
2. The report aims at assisting CNLS, its subsidiary entities; PMU, CSOs and COs to develop a good understanding of the extent to which good governance, accountability and transparency which are critical elements of sound public resource management are conceptualized, internalized and applied in the context of the national response in the fight against HIV/AIDS in Benin. The assessment was carried out by a team made up of the staff of the CNLS, PMU, FMA and a consultant engaged by the World Bank. Guidance on the assessment including development of tools and methodology was done by the management of CNLS and the PMU.
II FINDINGS
3. Institutional Arrangements: A functional institutional framework exists, although its coordination and oversight functions need improvement. This framework ensures the orderly functioning of agencies, division of labor, transparency and an understanding of each actor's role. The establishment of the project administration in the CNLS, the coordinating body, has helped in addressing a number of weaknesses noted in HIV/AIDS implementation.
4. Implementation processes and Accountability arrangements: sub-projects and action plans submitted for financing are approved and reviewed for compliance by the appropriate agencies using the tools developed (appraisal sheets for approvals and compliance review sheets). Technical and financial monitoring sheets are used for monitoring and evaluation. There are some inadequacies in: dissemination of the results in respect of review results, compliance with laid down procedures and approvals to beneficiaries; procurement; and financial management. The assessment team observed improvements made through the rigorous planning of HIV/AIDS control activities, with the adoption, under the PMLS, of a five-year plan with budget and performance measurement indicators.
5. Funds flow: After a compliance review of proposals followed by approval and management training, funds are released to beneficiaries. The funds are provided in a transparent manner in the form of checks handed over to the beneficiaries in the presence of several members of the management committees (Chairperson, Secretary, and Treasurer). There are accounting records which documents the movements of funds and substantiate their intended use. Some cases of mismanagement were noted, including fraudulent fund withdrawals; orders paid for but not supplied; and interference of the OAL in fund management as was the case in Zongo and Oroukayo and some COs in the community of Kouandé.
6. Social Accountability, Public disclosure and anti-corruption complaints handling arrangements: Some encouraging practices were noted at the community level, including the use of local radio stations and the ‘report card’ system. At the level of the CNLS, PMU and FMA, periodic reports on project progress are prepared. However, the unified monitoring and evaluation system needs to be implemented to enable the CNLS to effectively disseminate HIV/AIDS prevention information at the central and decentralized levels.
III MAIN RECOMMENDATIONS
7. Institutional Arrangements: There is need to fully implement the provisions of the decree establishing the CNLS, and operationalize the ‘three ones’ unified monitoring and evaluation system in the National Strategic Framework for HIV/AIDS Control. This involves provision of sufficient funds in the national budget for the operations of the CNLS and its subsidiary entities in view of the scope of its role as coordinator of all HIV/AIDS control projects.
8. Implementation processes and Accountability Arrangements: Strengthen internal and external controls pertaining to all actors involved in HIV/AIDS prevention efforts and clearly outline in the procedures manual the measures to be implemented at each level, by whom, when, and to whom the report should be addressed. Also, there is need to conduct an in-depth assessment of the financial management system of the CSOs and put an adequate internal control mechanism in place prior to any funding. Also, improve the composition of community agencies so as to take into account recent developments in the decentralization process with the democratically elected village and neighborhood councils with respect to community development;
9. Funds Flow Mechanism: Establish, at the community level, management tools that are easily learned by grassroots beneficiaries. Rules and logistics of fund management should be described in an illustrated guide or manual prepared for Community Organizations. This guide must also set forth an internal control mechanism to be established within the Fund Management Committee.
10. Social accountability, public disclosure and anti-corruption complaints: Draw up, within the framework of projects, rules and procedures for managing complaints and recourse with consideration for reliability, fairness, confidentiality and ensure that they are broadly disseminated to all actors at all levels. This could be achieved through the preparation of notices for beneficiaries, which provide details on where to file complaints, the processing period for complaints, guaranteeing the confidentiality of the complaint, the criteria for the admissibility of complaints, for example complaints accompanied by supporting documentation without citing names, and/or complaints based on objectively observed acts, and means of recourse.
11. Provide mechanisms of recourse and organize a broad outreach effort to enable actors to familiarize themselves with them and use them as needed. This will entail informing the complainant in the notice, and following outreach efforts, of the procedure to be followed including review at a higher level if the desired result is not achieved within a specified timeframe;
IV NEXT STEPS
The self-assessment report has shared with other partners in Benin including UNAIDS, UNDP, Global Funds, and their local representatives in Benin. In addition, a well facilitated stakeholder consultation was organized to validate the assessment findings; review the suggested recommendations and agree on a time based action plan.
The World Bank Institute’s Governance Learning Program (GLP), in collaboration with the national and regional bodies, will develop and build institutional and human capacity based on the assessment findings and the stakeholders’ consultation.
I BACKGROUND
1. Benin is located in West Africa and has a surface area of 114,763 square kilometers and an estimated population of 7,198,618 inhabitants (2004). HIV/AIDS infection is a critical development issue in Benin, which is one of the countries where this infection is a low-level generalized epidemic. Since 2002, the national average for the prevalence of HIV infection measured by the sentinel surveillance system at antenatal consultant clinics appears to have stabilized at around two percent (National Strategic Framework for HIV/AIDS/STI Control for the 2007-2011 period). HIV/AIDS prevention in Benin is based on a multisectoral and partnership approach involving ministries and State institutions, the private sector, civil society, NGOs, and technical and financial partners.
2. At the institutional level, the National AIDS Commission (CNLS) is chaired by the President of the Republic, with a permanent secretariat responsible for leadership, guidance, and coordination of all HIV/AIDS control activities in Benin. The CNLS also has subsidiary entities in all regions and communities. HIV/AIDS control activities in Benin are currently part of the Second National Strategic Framework for HIV/AIDS/STI Control for the 2007-2011 period, which is being implemented with assistance from several technical and financial partners such as UNAIDS, UNDP, the World Bank, the Global Fund, and the African Development Bank, as well as the Government of Benin.
3. Despite many interventions since the 1980s to combat HIV/AIDS, the country has experienced a worrisome trend with the epidemic. The Multi-sector AIDS Prevention Project (Projet plurisectoriel de lutte contre le SIDA, PPLS) launched with World Bank assistance is one of the efforts of government to preserve human capital by slowing down the spread of the HIV/AIDS epidemic in Benin and mitigate its impact on persons infected with or affected by HIV. Specifically, the PPLS aims to (a) accelerate, intensify and diversify HIV/AIDS prevention measures; (b) make resources to combat the HIV/AIDS epidemic available to civil society and the public sector; and ( c) build the capacities of civil society and the public sector to establish and maintain intervention measures. The PPLS received funding of SDR 17,800,000 (about CFAF seventeen billion, or 17,000,000,000), from the World Bank to carry out a sustained multisectoral HIV/AIDS prevention response that was supported collectively by all segments of society, including the government, private sector, NGOs, CSOs, and local communities.
II GOVERNANCE STRUCTURE AND INTERVENTION MECHANISMS FOR THE COMMUNITIES IN HIV/AIDS OPERATIONS
4. The governance structure in Benin is characterized by the separation of the three powers, namely: (a) the executive power, which defines and implements policies; (b) the legislative power, which passes laws and oversees the activities of the Government; and (c) the judicial power, which ensures compliance with the law by the Government and the citizens.
5. Government administration in Benin is characterized by the decentralization of power and deconcentration of public services. Local government, which comprises locally elected members, carries out actions that are related to the communities, with support from deconcentrated State services, particularly in social sectors such as education and health. The national HIV/AIDS control programs, reveals an existing governance structure and interaction between the local administrative authorities and community groups. Intervention at the community level for HIV/AIDS control activities in Benin is mainly through capacity building for COs and CSOs; support for CO initiatives; and support for CSO initiatives.
6. Support for CO and CSO initiatives is provided through financing of village-level action plans or sub-projects which are coherent activities or actions identified by the beneficiaries, the implementation of which is intended to prevent or mitigate the effects of the disease in their community or within their target groups. These sub-projects are included in a request for financing addressed to the various structures responsible for local HIV/AIDS response.
7. Capacity building for COs and CSOs involves strengthening the institutional and technical capacities of COs and CSOs. It was implemented by the Project Management Unit (PMU), the Financial Management Agency (FMA) (during the implementation of the AGeFIB), the start-up support organizations (OALs), and service providers.
8. Support for Community Organization (CO) initiatives was implemented in six (6) phases. These involves community orientation by OAL facilitators; Preparation of the Community Action Plan for HIV/AIDS Control (PACLS) on the basis of templates provided by the PPLS; submission to and approval of the plan by CCLS; Compliance and funding review using standardized tools; implementation of sub-projects and action plans handled by the management committee established by the CO; and monitoring and evaluation. Technical and financial monitoring is carried out by the AIDS specialist and the financial specialist recruited for this purpose, using appropriate technical monitoring tools (CO and CSO sub-project technical monitoring sheets) and financial monitoring sheets (CO and CSO sub-project financial monitoring sheets) to ensure that fund management complies with the financing agreement. In practice, this monitoring takes the form of advisory consulting to bring about self-management by the beneficiaries. A new self-assessment technique, the ‘report card’, has been introduced and has proved very effective in practice. It has also been very readily accepted by beneficiary communities and is a technique that fosters transparent management.
9. Support for Civil Society Organization (CSO) initiatives is implemented in five (5) phases involving: (a) sub-project development by CSOs based on the template provided by the PPLS; (b) sub-project approval by the relevant CDLS or SP/CNLS based on standard approval tools (evaluation sheets) developed by the project; (c) compliance and financing review conducted using standardized tools and involving review of compliance with technical criteria by the AIDS Operations Officer (AOO), review of conformity with financial criteria by the Financial Operations Officer (FOO), and joint validation session which brings together technical managers and the branch manager; (d) confirming sub-projects are financed by means of a financing agreement signed by the CSO representatives, the financing entity (PMU or FMA) and the regional prefect representing the CDLS or the SP/CNLS; and (e) release of funds in two or three tranches. This is followed with implementation by the management committee put in place by the CSO, who produces technical and financial reports as well as monitoring and evaluation with the help of the FMA and the facilitators.
III METHODOLOGY
10. Consultations and desk-review: This involved preparatory meetings with the World Bank, the CNLS and all the self-assessment team and consultant. The concept note for the assessment had been exposed at a review meeting in the World Bank and shared with other donors. Series of video and audio conferences, email correspondence, documentary review of related work in Benin, as well as other logistics were also carried out. Documents reviewed included implementation guidelines; laws; decrees; the national framework document - ‘Cadre stratégique national de lutte contre le VIH et le SIDA 2007-2011’, the operational plan - ‘Plan opérationnel du cadre stratégique national de lutte contre le VIH et le SIDA 2007-2011’; and the monitoring and evaluation manual. There were various meetings on refinement of the methodology, validation of the sampling technique, review of the structure of the data collection, agreement on the sample size and the choice of target beneficiaries to be evaluated as well as the main themes of the evaluation questionnaires.
11. Questionnaires: Three sets of questionnaire were developed, each focusing on the CSOs, COs and the CNLS and its subsidiary entities including the PMU and FMA. The field program was designed, teams were set up and logistics for meetings were agreed on.
12. Sampling: Geographic coverage comprised 10 of Benin’s 12 regions, i.e. 83.33 percent of the country. In these 10 regions, 31 rural and urban communities were chosen at random. Beneficiaries such as the CSOs and COs were selected from within these regions and communities. The assessment also included the CNLS and its subsidiary entities, the PPLS Management Unit, and the Financial Management Agency at the central and decentralized levels. In choosing the beneficiaries to be evaluated, the mission used the database of sub-projects or action plans financed under the PPLS. Given the time available for field work and discussions with the World Bank, sampling involved an average of 15 beneficiaries per region for grassroots organizations, and an average of four civil society organizations per region selected. In addition, four NGOs that had the specific characteristics of being health structures and in partnership with the PPLS were included in the sample size. In the 10 regions selected, FMA staffers were also interviewed. The following table summarizes the number and proportion of beneficiaries in the sample:
Table 1: Nature and number of beneficiaries surveyed
|N° |Type of beneficiary |Number |% |
|1 |CSO and CO |74 |79.56 |
|2 |CNLS and subsidiary entities |14 |15.06 |
|3 |PMU |1 |1.08 |
|4 |FMA at central and decentralized levels |4 |4.30 |
| |TOTAL |93 |100 |
Source: Evaluation database
13. Data collection: The data gathering process involved a pro-active approach involving two 4-man teams, each made up of a representative each of the consultant; the CNLS; the FMA at the central level; and the FMA at the regional level. During the field-level data collection phase, the entire evaluation team first pre-tested collection guides with each type of beneficiary for the first two days. Thereafter, the questionnaires were changed and re-validated for the field-level data collection phase. Structured and planned interviews as well as unstructured ones were used essentially to collect qualitative data on implementation of the action plans. This qualitative data could, as needed, be converted into quantitative data through extrapolation. In the various field-level working sessions with the actors, the interviews were conducted on the basis of supporting materials designed for the purpose. The interviews also made it possible to gather information for purposes of analysis from the three main target groups.
14. Data processing and analysis: The first stage in data processing and analysis was the inputting of data collected by the members of the various teams. Filled-out collection sheets were shared among the members of each team to ensure a concordance with the reality observed by each team member in the field. The questionnaires used for data collection in the field consist of both closed and open-ended questions. To facilitate the processing of the data collected, the consultant developed data analysis grids. For each theme to be studied, proposals were made and validated by the team. Depending on the nature of each question, weak and strong points were identified and matched up with recommendations. In order to present the collected data in statistical form, indicators were defined; these were processed, by beneficiary, using Excel spreadsheet software.
15. Nature of operations subject to evaluation: The evaluation mission covered financing packages put in place for the CSOs and the COs. Financing benefiting Public Sector Agencies and the Ministry of Health were not considered. Sub-projects or action plans financed for the benefit of the beneficiaries (CSOs and COs) covered several fields within the framework of AIDS control operations including access to information for concrete behavioral change; social marketing of condoms; access to voluntary screening; support to infected and affected persons; and Support and nutritional assistance to OVCs. The assessment team met with community organizations which implemented one or more action plans based on the results of the evaluation.
16. COs cover several types of beneficiaries, including village populations and city neighborhood dwellers; group of artisans; practitioners of traditional religions; practitioners of traditional healing techniques; organized groups; women’s associations; and young people’s associations.
17. CSOs include NGOs established in Benin and governed by the Law of July 1, 1901; NGOs devoted specifically to HIV/AIDS control; associations and networks of persons living with, and affected by, HIV/AIDS; and associative healthcare structures involved mainly in psychosocial, health and nutritional assistance to persons living with or affected by HIV/AIDS. These structures are authorized by the National AIDS Control Program (Programme national de lutte contre le SIDA, PNLS).
18. Distribution of persons surveyed: The evaluation involved 788 persons, made up of beneficiaries or actors ( as analysed in Table 2 below). The evaluation focused on beneficiaries of the local HIV/AIDS control response, namely CSOs and COs, representatives of which comprise 85.03 percent of persons interviewed. Over one third of the persons met were women. Among the 19 CSOs surveyed, six were associations of persons living with HIV/AIDS. These two target groups (CSOs and COs) were actually the primary beneficiaries of funding to establish HIV/AIDS control operations. The persons met are generally grassroots populations and CO members who work in agriculture, handicrafts and fisheries. They also include community development agents, teachers, healthcare workers, and students. For CSOs, persons met include attorneys, magistrates, physicians, economists and sociologists.
Table 2: Distribution of persons surveyed by beneficiary or entity
|N° |Nature of beneficiary |Number of |Number of persons |Number of persons met |
| | |sub-projects/entities |met |(as %) |
|1 |CSOs |19 |91 |11.55 |
|2 |COs |55 |579 |73.48 |
|3 |CNLS and its subsidiary entities |14 |102 |12.94 |
|4 |PMU |1 |3 |0.38 |
|5 |FMA at central and decentralized levels |4 |13 |1.65 |
| |TOTAL |93 |788 |100 |
Source: Evaluation database
IV Survey data and analysis
19. The main observations emerging from the processing of collected data are presented by outlining the strengths and weaknesses of each actor assessed, in accordance with the guidelines of the terms of reference. A number of the weaknesses identified below were taken into account during the design of the MAP 2, particularly with respect to the introduction of the unified monitoring and evaluation system and the recognition of the role of the CNLS as the coordinating body. The presentation of these weaknesses seeks to facilitate their operationalization, given that during the conduct of the assessment, the new project was only in the start-up phase. The results of the assessment and their analysis are as follows:
20. CNLS and its subsidiary entities
Existing institutional mechanisms
Strengths
▪ The CNLS is the lead agency for the design and monitoring of HIV/AIDS control policies.
▪ The CNLS has subsidiary entities throughout the national territory, i.e., the CDLS, CCLS, and CALS.
▪ There is a strategic framework and an operational plan (2001-2005) as well as a monitoring/evaluation manual to ensure better implementation of AIDS control activities.
▪ A legal and institutional framework exists for HIV/AIDS/STI control in Benin (Decree n°2002-273 dated June 18, 2002). This framework stipulates the involvement of actors at the highest level, thus strengthening the leadership of the CNLS in HIV/AIDS control. This legal and institutional framework has been enhanced through: (i) development and approval of an Operational Plan of the National Strategic Framework for HIV/AIDS Control for the 2007-2011 period; (ii) approval and promulgation of the law on HIV/AIDS, which completes the existing legal framework pertaining to discrimination against, and stigmatization of, persons living with and affected by the disease.
▪ Implementation of the PPLS has greatly enhanced the institutionalization of the CNLS and its subsidiary entities, for which support (in the form of equipment, the financing of activities, etc.) has been provided, although such support is inadequate.
Weaknesses
▪ The SP/CNLS has not been allowed to control the PPLS and PMU in the implementation of HIV/AIDS control policies. In the MAP 2, this weakness was corrected with the recognition of the CNLS as the coordinating body. The PMU was replaced by a Project Administration (PA) placed under the authority of the CNLS;
▪ The CNLS does not coordinate all AIDS control activities, contrary to the provisions of the Decree creating the institution and its subsidiary entities. Of about twenty categories of projects underway throughout Benin, the CNLS only coordinates three, namely, the projects of the World Bank (MAP 2), the African Development Bank, and DANIDA;
▪ The funds allocated to CNLS and its subsidiary entities are been sufficient to ensure smooth functioning. The subsidiary entities of the CNLS do not have an operations budget to cover the costs associated with the organization of sub-project review and approval meetings and field supervision activities, so as to ensure the proper execution of the approved sub-projects. The State’s failure to free up its counterpart funds has handicapped the CNLS and its subsidiary entities operationally, thereby weakening the oversight mechanism. It should be noted, however, that additional funds were budgeted under MAP 2, with a view to strengthening the leadership of the CNLS and its subsidiary entities;
▪ Not all of the subsidiary entities called for at the municipal level (e.g. CALS and CVLS) have been created, except in the six communities financed by the AfDB (Natitingou, Ouidah, Porto-Novo, Savalou, Comé and Parakou);
▪ The instability of the SP/CNLS’s anchoring to a fixed oversight entity, which would ensure strong leadership, is a handicap for the CNLS in the execution of its mission. The SP/CNLS has been moved from the Ministry of Plan to the Ministry of Finance, and then to the Ministry of Health.
Governance structure and accountability mechanisms
Strengths
▪ The CNLS is chaired by the Head of State, which means that there is high-level involvement of authorities in HIV/AIDS control;
▪ The CNLS has an orientation body and an implementation body, the latter being the SP/CNLS;
▪ The CNLS has a framework for consulting technical and financial partners in the sector;
▪ The SP/CNLS reports to the government on implementation of its activities;
▪ Projects under CNLS coordination are subject to annual outside audit.
Weaknesses
▪ The framework for consultation with technical and financial partners in the sector is non-functional; apart from the group widened set of themes ONUSIDA which meets regularly;
▪
▪ The CNLS lacks an internal audit region enabling it to perform the necessary due diligence throughout the duration of the PPLS;
▪ There is no clear procedure (mode of designation and capacity) for designating representatives of the various structures in the Decree concerning the creation of the CNLS and its subsidiary entities;
▪ Turnover is high among persons working in the subsidiary entities of the CNLS due to their civil service status and the lack of a term of office or mandate;
▪ There is no external audit of the SP/CNLS and its subsidiary entities as AIDS control structures;
▪ The CNLS, contrary to the provisions of its founding texts, lacks a procedures manual and internal regulations;
▪ The intervals for CNLS meetings (i.e. once per half-year) and those of the consultative body (i.e. at least once per year) have not been observed. Indeed, the CNLS has met three (3) times since its creation in 2001; the most recent meeting occurred in 2005. The consultative body has met only once, in 2007.
Existing processes
Strengths
▪ The existence of approval committees and committees to monitor sub-project funding for COs and CSOs;
▪ Existence of a harmonized approval grid at the level of the SP/CNLS and its subsidiary entities;
▪ Implementation of mechanisms for convening meetings that ensure participation by the greatest number, and collegial decision-making (calling of meetings at least 72 hours in advance and decision-making by unanimous vote);
▪ Good knowledge and application of approval rules and procedures on the part of members of approval bodies.
Weaknesses
▪ The SP/CNLS only makes recommendations to the PMU concerning sub-projects and action plans submitted for funding, instead of playing its role of approval body more fully;
▪ Beneficiaries have no recourse against decisions taken by the approval bodies;
▪ Specific intervals are not stated for meetings of the approval committees;
▪ Zones of intervention are not targeted on the basis of prevalence rates, to permit efficient use of resources.
Funds flow mechanisms
Strength
▪ The existence of standards to which dossiers must conform in order to be approved and funded (approval grid). These standards are known to beneficiaries.
Weakness
▪ For lack of financial resources, approval structures have not sufficiently played their role of supervising and monitoring the technical and financial aspects of sub-projects.
Social Accountability, funds disclosure and management of complaints
Strength
Not applicable.
Weaknesses
▪ Lack of a clear and well-known procedure for management of complaints;
▪ Lack of a known grid of sanctions applicable in the event of non-transparent management.
21. Project Management Unit (PMU) and Financial Management Agency (FMA)
a. Examination of existing institutional mechanisms
Strengths
▪ The PMU has been able to enhance its intervention capacities by using supporting NGOs (OALs) to launch and sign a service agreement with AGeFIB as Financial Management Agency;
▪ Use of OAL services to launch the PPLS for the establishment of CO sub-projects;
▪ Regional branches of the AGeFIB ensure grassroots contact with beneficiaries;
▪ Oversight within these units is exercised with regard to both technical and financial aspects of the submitted sub-projects;
▪ External financial/technical audit missions have been organized on a regular basis within these two units;
▪ The compliance review within the PMU and FMA is done using a harmonized tool;
▪ Before funding is put in place, beneficiaries are trained to use management tools;
▪ There are two types of monitoring: documents-based monitoring (i.e. the study of contracts and reports of promoters), and grassroots field monitoring (to ensure that beneficiaries have received the funds and carried out the activities);
▪ AIDS control focal units (Unités focales de lutte contre le SIDA, UFLS) have been established and operationalized in the ministries, prefectures, and certain institutions such as the army.
Weaknesses
▪ Throughout execution of the PPLS, the PMU lacked its own internal audit region that would have enabled it to perform the due diligence needed to ensure proper management of resources;
▪ The project’s computerized monitoring/evaluation system only became functional at the end of the PPLS.
b. Governance structure and accountability mechanisms
Strengths
▪ The PMU and AGeFIB have a procedures manual, a monitoring/evaluation system, and a functioning financial management system;
▪ AGeFIB submits periodic project execution reports to the PMU;
▪ The PMU submits periodic reports to the World Bank and the oversight ministry;
▪ Responsibilities are clearly defined and well distributed between the FMA and PMU.
Weakness
▪ The lack of monitoring/evaluation of the UFLSs explains their poor performance.
c. Existing processes
Strengths
▪ The Project Management Unit has been proactive in taking corrective steps as a result of the financing of the first spontaneous action plans. Important modifications made to the community action plans include: (i) the use of resource persons (persons living with AIDS) to develop action plans; (ii) involvement of OALs in the implementation process; (iii) the establishment of budget allocation quotas for PACLS activities and the capping of PACLS funding; (iv) the self-assessment system. This reorientation of activities is aimed at achieving greater impact through better organization of activities, and through the implementation of activities within a community, by and for the entire community;
▪ Prior to any funding, sub-projects are subject to a compliance review;
▪ Accounting documents exist that track fund movements;
▪ In each region, an account is opened to receive funds intended for the COs and CSOs. These accounts operate in the manner of 30-day advance accounts;
▪ Regional AGeFIB agencies provide documentary evidence for these funds every two weeks;
▪ In the PMU, a special account is provisioned and replenished by the amount consumed and documented;
▪ The OALs advise and assist the COs in setting up their sub-projects.
Weaknesses
▪ Projects have not been funded based on zones with high HIV/AIDS prevalence rates;
▪ Non-participatory selection and inadequate monitoring of OALs are the cause of some embezzlement observed and documented in Annex n°1;
▪ Communities that have not received OAL assistance have been unable to submit their sub-projects for funding;
▪ The triennial funding commitment for actions contained in the community-level HIV/AIDS action plans has not been honored. Indeed, the approved triennial plans were only financed, in several community organizations, for the first or second phase, compromising important activities contained in subsequent phases;
▪ The SP/CNLS and its subsidiary entities have failed to define sub-project approval thresholds.
d. Funds Flow mechanisms
Strengths
▪ Funds are made available through the hand-over of checks to beneficiaries in the presence of several members of the management committees (Chairperson, Secretary, and Treasurer), thus ensuring transparency in the transfer of funds;
▪ All funds go into beneficiaries’ accounts, with the exception of one instance of loss noted in the CO Matéri Centre (commune of Matéri) (see Annex 3);
▪ Measures of conservation (e.g. freezing of the account) are taken as soon as a management problem arises.
Weaknessess
▪ In most cases, the establishment of the counterpart funds demanded of beneficiaries has been difficult, and this has delayed sub-project implementation;
▪ Some cases of mismanagement have been recorded (see Annex 3) including:
Fraudulent fund withdrawals;
Orders paid for but not delivered;
Interference of OALs in fund management (e.g. in COs of Zongo and Oroukayo in the commune of Kouandé).
e. Social Accountability, funds disclosure and management of complaints
Strengths
▪ Beneficiaries have systematically conducted a mid-term self-assessment, providing a technical and financial report before receiving the second tranche. All of this is done using tools developed and made available to them;
▪ Complaints received about corruption and mismanagement are investigated and corrective measures taken if the evidence warrants. This is the case in particular with the COs of Aholouyèmè (commune of Seme-Podji) and Lotodénou (commune of Allada) (reimbursement of funds, suspension of the guilty parties; see Annex 3.)
Weakness
▪ The accountability mechanisms put in place by the PMU and FMA was ineffective in the cases of the CO and CSOs. Indeed, it was noted that latest reports (completion reports) have not been submitted.
22. Community Organizations (COs) and Civil Society Organizations (CSOs)
Existing institutional mechanisms
The examination of institutional mechanisms put in place by the COs and CSOs in conducting HIV/AIDS control operations was done on the basis of the following criteria:
i) composition of management bodies;
ii) decision-making modalities;
iii) profile of members;
iv) criteria for election of members of bodies;
v) social groups represented in management bodies;
vi) incorporation of gender issues into management bodies;
vii) definition of terms of office; and
viii) links of kinship among members of implementing bodies.
Trends in the data gathered on these criteria, as applied to the COs and CSOs, are presented in Graph n°1:
Graph n°1: Examination of institutional profile of CSOs & COs
[pic]
Source: survey data
The strength/weakness analysis of these trends is as follows:
Strengths
▪ The intervention strategy places the beneficiary COs at the center of the activities contained in the HIV/AIDS Action Plans (PACLS). Responsibility for financial management and procurement is generally borne by the beneficiaries themselves. Financial management is handled by 100 percent of verified COs and CSOs, while procurement is handled by 74.1 percent of COs and 84.2 percent of CSOs in the sample;
▪ Over 72 percent of COs surveyed have one-third representation of women on management bodies. This situation confirms the project’s commitment to ensuring the involvement of all segments of society and of women in particular in decision-making bodies within COs. The gender aspect is therefore being incorporated into the establishment of CO bodies;
▪ Some 90.9 percent of COs have a make-up that complies with project guidelines. The installed bodies are functional in terms of organizing and managing efforts to combat the pandemic. These include: (i) the Village General Assembly, which helps develop the PACLS and sets up the 9- or 11-member Management Committee; (ii) the Management Committee coordinates actions and manages resources made available to beneficiaries; (iii) community relays, which serve to educate about positive behaviors to avoid STDs and HIV/AIDS. In addition to all of these bodies, various collectives or specific groups organize anti-AIDS efforts within their own confines. These include the village young boys’ group, the girls’ group, the elders’ group, the women’s group and practitioners of traditional medicine. This degree of representativeness exists in 92.7 percent of COs in this study’s sample. Implementation of the PACLS has further empowered local actors in particular and the community in general;
▪ Some 94.7 percent of the CSOs surveyed observe the provisions of the Law of 1901 concerning associations with regard to the structure and operation of their constitutive bodies.
Weaknesses
• In 40 percent of the COs surveyed, there is a direct kinship link between at least two members of the Management Committee. In the CO of Agada-Hounmé (commune of Sakété), for example, the posts of chairperson (payment authorizer) and treasurer (accountant) are held by a married couple. This situation poses a high risk that can affect transparency of management of the funds made available;
• In over 50 percent of COs surveyed, the terms of office of the members of the management committee are either indeterminate or are determined by the duration of the sub-projects. This situation makes it impossible to ensure the sustainability of actions upon completion of the sub-projects, and prevents transparency in fund management;
• In over 90 percent of CSOs and COs in the study sample, the absence or non-functionality of internal CO and CSO monitoring and oversight structures was noted.
Governance structure and accountability mechanisms
The examination of governance structures and accountability mechanisms put in place within COs and CSOs in the conduct of HIV/AIDS control operations was done on the basis of the following criteria:
ix) assessment by the beneficiaries of their own management;
x) level of knowledge of their sub-projects;
xi) number of meetings and time allowed in convening them to ensure the widest possible participation; and
xii) mechanisms for organizing reporting sessions and number of sessions held in the context of their sub-projects.
Trends in the data gathered relative to these criteria, as applied to COs and CSOs, are presented in Graphs n°2 and n°3 below.
The graph below shows the trends regarding accountability mechanisms based on the above-enumerated criteria.
Graph n°2: Examination of accountability arrangements
[pic]
Source: survey data
The general analysis of the accountability arrangements indicates that communities gained a slight upper hand over the CSOs in terms of all evaluation criteria. It is obvious that the accountability obligation is a major asset that fostered diligent implementation of action plans. It could hardly have been otherwise, since self-assessment is a prerequisite for access to funding for a new village-level action plan.
In addition to the analysis of accountability mechanisms, the mission analyzed the structure of governance put in place to manage CSO sub-projects and community HIV/AIDS control action plans.
Analysis of the governance structure was based on the following criteria:
i) the role of members of the bureau and separation of tasks;
ii) possible risk of interference between the essential functions of payment authorizer and accountant;
iii) oversight mechanism;
iv) examination of the process of expenditure payment; process of acquisition of goods and services;
v) quality of social intermediation of NGOs on behalf of Cos
vi) prior training in procedures for implementation of sub-projects and action plans.
Graph n°3 below highlights the level of accomplishment observed, by type of beneficiary (CSO and CO).
Graph n°3: Examination of governance structure
[pic]
Source: survey data
The examination of the governance structure put in place within the COs and CSOs shows a great similarity to observed trends. In the following graph, it is also easy to see that the governance structure established in the COs presents a comparative advantage based on a maximum of criteria. Indeed, implementation of the community component was supported by the development, and provision to the grassroots communities, of an evaluation guide emphasizing the governance structure and the management of action plans. Operationalization of the community action plan was included in this evaluation guide, which generally served as a guideline for the implementation of most activities at the community level.
Civil Society Organizations also put in place a governance structure meeting minimal requirements.
Analysis of the trends, in terms of strengths and weaknesses, of the accountability mechanisms and governance structure, yields the following:
Strengths
▪ Good knowledge and accurate perception, by members of the management committees, of HIV/AIDS control activities being financed;
▪ The mechanisms used to convene meetings ensure participation by the greatest number possible and a collegial style of decision-making (at least 72 hours’ prior notice, decisions taken by consensus, and use of appropriate means of communication, such as town criers). Indeed, for 92.7 percent of COs and 68.4 percent of CSOs, the minimum of 72 hours’ notice of meetings of committee bodies is observed;
▪ In 89.1 percent of COs, members of the management committees (Chairperson, Treasurer, and Secretary) understand their roles, whereas in the CSOs, the rate is 78.9 percent. These rates may be explained by the fact that 96.4 percent of COs and 94.7 percent of CSOs confirm that they have received, in addition to training provided by the OALs (which is the case with the COs),training, prior to disbursements, from the Financial Management Agency;
▪ Despite the interference of some OALs in procurement, 85.5 percent of COs have a good opinion of the technical assistance provided by OALs. This technical assistance ensured the set-up and execution of a large number of sub-projects in the HIV/AIDS control category;
▪ The existence of an embryonic form of internal and external control provided by the OALs, the FMA and the CCLS (as in the case of the communities of Tanguiéta and Copargo).
Weakness
▪ In 20 percent of the sub-projects surveyed, one sees interference of start-up support NGOs (ONG d’Appui au Lancement, OAL) in fund management and in procurement, contrary to applicable procedure. This involvement was often the cause of instances of mismanagement noted (see Annex 3).
Existing processes
Good governance assumes that all actors are familiar with existing processes, from the expression of a funding need to the satisfaction of that need and the diligent execution of activities according to the planned cycle agreed upon in the implementation timetable. The mission examined the structure of existing processes on the basis of the following criteria:
xiii) existence of a manual intended for beneficiaries;
xiv) knowledge of the fund award process;
xv) existence of a recourse mechanism;
xvi) awareness of the place where dossiers are filed;
xvii) knowledge of the time needed to process sub-project or action plan dossiers;
xviii) familiarity with the approval system;
xix) knowledge of the compliance review mechanism; and
xx) mobilization of beneficiaries’ counterpart funds and its impact on financing. In addition to these criteria, the mission examined the difficulties encountered by beneficiaries in executing their sub-project or action plan dossiers.
The trends emerging from the processing of data gathered on these criteria, as applied to COs and CSOs, are presented in Graph n°4:
Graph n°4: Examination of existing process of funding CSOs and COs
[pic]
Source: survey data
Analysis of trends in terms of strengths and weaknesses yields the following:
Strengths
▪ Project implementation at the community level was essentially participatory. Strong involvement by beneficiaries occurred at several levels: first they participate in the funding of their action plans by providing 5 percent of total financing. They then monitor the action plans, thereby guaranteeing the sustainability of actions after project completion. To reduce consultancy costs, the project uses local skills in various sectors (e.g., social worker, healthcare worker, communications specialist, etc.);
▪ Regarding capacity building for CSOs and COs, one particularity of the PPLS is the prior training before disbursement of the first financing tranche provided to members of the Management Committee by the Financial Management Agency (FMA). The principle of prior training, which was respected in the implementation of the COs’ and CSOs’ sub-projects, is intended among other things to enhance familiarity with the project and especially with its financial management procedures;
▪ Examination of fund utilization mechanisms reveals that disbursements were often carried out according to the following procedure: (i) planning of activities and determination of the budget by the management committee; (ii) disbursement of funds on the basis of co-signatures; (iii) purchase of goods and services at the best price after scouting the market; (iv) payment of services after they are rendered and against receipt or invoice;
▪ In the COs, 94.5 percent have appropriate management documents (cash ledgers, bank books, supply registers, activity notebooks), while the rate for CSOs is 89.5 percent. This situation undoubtedly facilitates the tracing of funds and the utilization of resources. The management documents observed are fairly well maintained;
▪ The use of community radio stations to disseminate information about sub-project approval and financing. This measure was introduced after the second year of the project;
▪ Some 100 percent of the COs surveyed have an operational plan to combat HIV/AIDS. This situation causes coherence and greater efficiency of activities financed under the action plans.
Weaknesses
▪ The lack of mechanisms for seeking recourse against decisions taken by the approval and compliance review bodies, although cases of rejection are fairly rare;
▪ Lack of a procedures manual for beneficiaries;
▪ Ignorance on the part of beneficiaries of rules and procedures for approval and compliance review;
▪ The requirement of 5 percent of counterpart funds significantly slowed the execution of sub-projects and even had a negative impact on the transparency of fund management (usurious loans, pre-financing of the counterpart funds, and take-over of sub-project implementation). Indeed, in more than 75 percent of COs, more than one month, and sometimes over six months, was needed to mobilize the counterpart funds. For the CSOs, the percentage is 47.4 percent. Over 65.5 percent of COs confirmed that mobilization of counterpart funds was a major obstacle to implementation of their sub-project.
Funds flow mechanisms
The fourth analysis theme – good governance in HIV/AIDS control operations – was the mechanism for utilizing funds made available to beneficiaries, i.e. the CSOs and COs. This was analyzed on the basis of the following criteria:
xxi) existence of management documents deemed acceptable;
xxii) existence and application of recourse mechanisms against the decisions of approval and compliance review structures;
xxiii) actual separation of tasks with regard to payment of expenditures;
xxiv) existence of a single bank account operating via co-signature;
xxv) existence of a reliable fund transfer circuit;
xxvi) eligibility of expenditures made for members of management bodies; and
xxvii) involvement of approval, compliance review, and technical assistance structures in the procurement of goods and services.
Trends in data gathered on these criteria, as applied to the COs, are shown in Graph n°5:
Graph n°5: Examination of the funds flow mechanism
[pic]
Source: survey data
Analysis of these strengths and weaknesses is as follows:
Strengths
▪ Some 94.5 percent of COs are familiar with disbursement procedures provided for under the PPLS, and have applied them. This is not the case of the CSOs, only 57.9 percent of which have a good understanding of said disbursement procedures;
▪ Knowledge of procurement procedures;
▪ Some 100 percent of COs and CSOs have opened a specific account to manage financial operations pertaining to their sub-projects. These accounts operate via co-signature, which limits the risk of fraudulent disbursement. The dedicated account procedure also ensures the traceability of the resources transferred.
Weaknesses
▪ Interference of some OALs in CO management;
▪ Use, in some cases, of funds for ineligible expenditures, and some instances of over-billing;
▪ Cases of fund mismanagement by some members of Management Committees (see Annex 3).
Social Accountability, funds disclosure and management of complaints
▪ Accountability mechanisms: This relates to the obligation to account to management bodies and to the populace for the management and implementation of sub-projects and action plans. The criteria used are:
xxviii) sessions at which reports are provided to the population; and
xxix) self-assessments and the option of oversight by persons who are not members of management bodies;
▪ The existence and application of sanctions: since the existence and application of grids of sanctions is an indicator of proper management of the funds made available to beneficiaries, the mission focused particularly on:
i) the existence of a grid of sanctions and its application;
ii) the imposition of some inconvenience??? upon beneficiaries before they can obtain funding; and
xxx) the match-up between the funding granted and the amount requested or the amount approved.
The results of data gathered on these criteria, as applied to COs and CSOs, are presented in Graph n°6:
Graph n°6: Examination of accountability mechanisms, public disclosure and anti corruption handling arrangements
[pic]
Source: survey data
Analysis of these results in terms of strengths and weaknesses reveals the following:
Strengths
▪ In 85.5 percent of COs surveyed, a self-assessment was conducted. Communities evaluate their action plans in a self-assessment session in which implementation of plans is evaluated. The project used the ‘report card’ evaluation technique, which enables communities to express themselves by means of report cards to gauge the quality of implementation of their community action plans. It uses pre-designed cards corresponding to scales of value. For each activity under the plan, each beneficiary target group expresses its opinion on a report card, and the general result emerging indicates the level of implementation and degree of beneficiary satisfaction. The report card has been an effective catalyst of good governance in communities, enabling communities to oversee management and the level of implementation of tasks planned under the community action plan. With this tool, action plan management committees that have committed mismanagement have been publicly sanctioned and replaced. The committees’ obligation to obtain results and to be accountable has become a matter of course;
▪ In 75.9 percent of COs, non-members of the Management Committees have the ability to exercise oversight, a situation that confirms the existence and functionality of popular oversight (organization of accountability sessions in the local language);
▪ To ensure better circulation of information and to facilitate accountability mechanisms, the project has entered into contracts with 52 local (grassroots) radio stations, which have played a significant role in project implementation and especially in transparency. During implementation, the project recommends, especially to CSOs, the dissemination of best practices to be promoted as well as of practices to be prohibited. The key messages disseminated concern (i) the list of beneficiary communities, and of amounts granted to each community, and (ii) best practices and practices to be discouraged. The Management Committees’ fear of public broadcasting of bad practices has had a dissuasive effect, and has to some extent enhanced governance within the COs.
Weakness
▪ In COs, lack of a known procedure for addressing complaints.
V RECOMMENDATIONS
23. At the end of this evaluation mission, recommendations are formulated to improve governance in HIV/AIDS control operations in Benin. These recommendations are directed at the primary beneficiaries, i.e. the COs and CSOs, as well as at the coordinating agencies (i.e. CNLS and its subsidiary entities) and financing structures (PMU and FMA).
CNLS and its subsidiary entities
▪ Existing institutional mechanisms
✓ Implement the provision of the Decree creating the CNLS, and operationalize the ‘three ones’ principle contained in the National Strategic Framework for HIV/AIDS Control, namely:
- Operationalization of a single framework of actions;
- A single coordination authority at all levels (CNLS and its subsidiary entities);
- Development and operationalization of a single monitoring/evaluation systems for all actors involved in HIV/AIDS control;
✓ Place the SP/CNLS under the direct authority of the President of the Republic;
✓ Make provision for sufficient funds in the national budget for the smooth functioning of the CNLS and its subsidiary entities, and thus, ensure the proper use of funds from partners through an effective oversight mechanism;
✓ Validate without delay the draft procedures manual that has been developed, and implement it along with the internal regulations;
✓ Hold periodic meetings between the consultative body and the technical and financial partners. This will facilitate the coordination of resources by the CNLS and collaborative problem-solving;
✓ Ensure that the CNLS and its subsidiary entities actually hold their meetings;
▪ Governance structure and accountability mechanisms
✓ Designate in a democratic manner the representatives of non-governmental bodies that are part of the CNLS subsidiary entities;
✓ Avoid assigning members of the CNLS and its subsidiary entities to too many different functions;
✓ Carry out a biennial audit or evaluation of the national strategic framework;
✓ Inform sub-project beneficiaries of the approval criteria during the sub-project set-up phase, thereby enabling them to comply and to familiarize themselves with the results of the approval sessions.
▪ Existing processes
✓ For projects, draw up rules and procedures for managing complaints and recourse (reliability, fairness, confidentiality) and see that they are broadly disseminated to all actors at all levels. This could be achieved with the preparation of notices for actors specifying the place at which complaints are to be filed, the processing period for complaints, pointing out the confidential nature of the complaint, the criteria for admissibility of complaints (complaints accompanied by supporting documentation without citing names for example, complaints based on objectively observed acts), and means of recourse;
✓ Specify, in the legal texts creating the approval bodies, reasonably closely spaced meeting dates (every two weeks, for example), and make provision for extraordinary sessions depending on the number of dossiers;
✓ State the make-up of the approval bodies and define the quorum;
✓ Define authority thresholds (amount, type, scope, type of beneficiary) regarding sub-project approvals within the CNLS and its subsidiary entities;
✓ Publish the results of sub-project approvals by poster, radio and mail;
✓ Conduct a targeting process prior to financing aimed at identifying zones with high disease prevalence, at-risk populations, and appropriate actions, to ensure efficient resource use;
✓ Conduct an annual beneficiary satisfaction survey.
▪ Social Accountability mechanisms, funds disclosure and management of complaints
✓ Provide recourse mechanisms and organize broad outreach efforts to enable actors to be familiar with and use these mechanisms as needed. To this end, bodies responsible for coordinating HIV/AIDS control operations, and especially the CNLS, must:
i. Draw up a grid of sanctions for all levels of actors involved in sub-project implementation;
ii. See that the grid of sanctions is widely disseminated;
iii. Enforce the grid of sanctions;
iv. Publish, on a regular basis, a ‘black list’ of OALs, COs, CSOs and other parties committing infractions.
Project Management Unit
1. Governance structure and accountability arrangements
✓ Enhance the capacities of the UFLS and introduce a monitoring/evaluation and oversight mechanism for them;
✓ Improve the quality of procurement. To do this, it will be necessary to:
i. Prepare a procurement manual for COs and CSOs;
ii. Train members of COs and CSOs in the use of this procurement manual;
iii. Require that CO and CSO bodies include a technical committee charged with procurement;
iv. Require that the management committee or executive bureau approve the results of the procurement committee;
v. Draw up and implement sanctions for failure to comply with procurement procedures.
2. Existing processes
✓ Maintain specific accounting at all levels on management of funds involved in HIV/AIDS control;
✓ Conduct annual audits on all project accounts managed by contractors (FMA and others);
✓ For better monitoring of key financing steps, and given the sensitive nature of the HIV/AIDS issue, it is necessary to define and monitor the duration of key steps in the processing of dossiers. For example, the following durations might be selected:
i. Support for project set-up by an OAL: at least one month;
ii. Approval of the dossier: maximum of two weeks;
iii. Compliance review and study of phase reports: maximum of one week;
iv. Signing of the agreement: maximum of one week;
v. Disbursement: maximum of one week.
The durations of various steps must be well known to the beneficiaries. The project’s monitoring/evaluation system must make it possible to document the duration of each stage so as to identify bottlenecks and the means of overcoming them.
✓ Involve the CNLS and its subsidiary entities in the selection and monitoring of OALs;
✓ Conduct an annual evaluation of OALs with the participation of the FMA and beneficiaries;
✓ Ensure broad dissemination of the OALs’ specifications to beneficiaries and local authorities;
✓ Renew OALs’ contracts on the basis of the results of the annual evaluations.
3. Funds flow mechanisms
✓ See that implementation times are monitored at all levels;
✓ Audit municipal solidarity funds.
FMA
This is aimed at improving existing processes.
✓ Maintain dedicated accounts at all levels involved in HIV/AIDS control efforts;
✓ Conduct an annual audit of all PPLS accounts;
✓ Participate in the annual evaluation of OALs;
✓ Improve the mechanism for close monitoring of the COs and CSOs being funded;
✓ Shorten the compliance review period to five days;
✓ Ensure that time limits are monitored;
✓ Apply the rules and procedures for managing complaints and recourse.
COs and CSOs
1. Existing institutional arrangements
a) For the COs
✓ COs should have a management committee that represents the group or community and acts in its name. The Target Group or village community must be formalized and must have a legal status enabling it to receive funding. The Management Committee will be responsible for: (i) preparation and submission, with or without the help of an OAL, of sub-project funding requests related to HIV/AIDS control; (ii) managing financing; (iii) mobilizing the contribution of the community or target group. The Management Committee will be entirely responsible to the community or target group, and to the structures providing funding for execution of the AIDS control sub-project;
✓ Management Committees must have one third of their members drawn from village councils. The Village Head will be an automatic member and must assume the role of Chairperson of the Management Committee, but other members of the village council may not fill posts of treasurer and secretary;
✓ Establish a technical committee (TC) of the Target Group to assist the Management Committee with technical implementation aspects, such as procurement. It must be made up of two or four persons with technical skills and know-how in areas relevant to HIV/AIDS control and procurement. It is preferable that these people not be simultaneously members of the Management Committee, in order to ensure proper separation of tasks and transparence in procurement. The technical committee will be responsible for technical aspects of sub-project implementation, procurement, reception of goods and services, etc.
✓ Place two agents in the target group to help the Management Committee with aspects related to communication. They will be charged with producing and circulating information through general assemblies. The Management Committee will establish a facilitation and community mobilization team responsible for circulating information, organizing facilitation sessions, and relaying external information through grassroots communications channels. The activities will occur during general assemblies, home visits, and association or group meetings.
✓ Designate two auditors with the necessary authority and broad powers to exercise, at any time and throughout the life of the sub-project, the function of monitoring the legitimacy of financial operations and procurement. They will be responsible for certifying the financial report prepared by the Management Committee and for preparing a special monitoring report at the conclusion of the sub-project.
b) For CSOs
✓ At this level, the goal will be to involve the CSOs’ auditors in sub-project implementation. Their role must be expressly and obligatorily extended to include the verifications required in connection with sub-project implementation. They must submit to the CSOs’ General Assemblies a specific report on the management of each sub-project.
2. Governance structure and accountability arrangements
✓ Incorporate, into the implementation manual of the next project, the following levels of oversight:
i. Internal controls at the CO (auditor and popular control) and CSO (government auditors);
ii. Oversight by supporting NGOs (OALs) in the case of the COs;
iii. Oversight by approval structures;
iv. Oversight by compliance review and financing structures;
v. Oversight by the independent auditor;
vi. Oversight by the State oversight body (IGF and IGE).
Each level of oversight must receive specific training, as needed, in the area of oversight and must receive the resources required to carry out its mission.
3. Funds flow mechanisms
✓ Provide management tools that can be easily learned by grassroots beneficiaries. Rules and modalities of fund management must be described in an illustrated guide or manual for Community Organizations. This guide must also describe the internal control mechanism to be put in place within the Management Committee;
✓ Carry out an in-depth evaluation of CSO financial management, along with an adequate internal control mechanism, prior to any funding.
VI CONCLUSION
The self-assessment reviewed the effectiveness of the mechanisms put in place to ensure transparency, good management and the achievement of results.
The assessment, based on a document review, a sampling methodology, a field-level data collection tool, and processing and analysis of the data collected, leads to the conclusion that the project was implemented under acceptable conditions of transparency and good governance, with the participation of grassroots communities organized and supported by appropriate structures (i.e. the OALs) so that they could develop their own sub-projects and action plans. The sub-projects, in turn, were approved by appropriate bodies that understood their roles (the SP/CNLS and its subsidiary entities, and the PMU). The approved sub-projects and action plans were subjected to compliance reviews prior to their financing.
Financing was made available after beneficiaries were trained in management and had received the management tools. This was released in tranches, and access to subsequent tranches required that beneficiaries account for their activities to the association to which they belong as well as to the project management agencies (PMU and FMA). The latter reported in turn to the World Bank on project management.
The processing of the data collected revealed some weaknesses in some institutional and fund-management mechanisms and in some processes.
At the institutional level, it is recommended that the PMU, now called Project Administration (PA), be placed under the oversight of the SP/CNLS. This has been a reality since the adoption of the new national strategic framework for HIV/AIDS control for the 2007-2011 period. It is also proposed that the SP/CNLS be placed under the authority of the Office of the President of the Republic. These recommendations have the advantage of encouraging the implementation of the ‘three ones’ rule: a single institution, a single strategic framework, and a single monitoring/evaluation system.
In terms of the governance structure, there is a need to strengthen internal controls within the SP/CNLS and in the COs and CSOs. For the latter specifically, there is a need for capacity-building in the areas of ordering and procurement. To this end, it would be beneficial to learn lessons from activities to build capacities and promote good governance, which were implemented in a number of community projects such as the PNDCC, the PADEAR, and the PDRT, in order to make improvements, by harmonizing the implementation environment for these projects. This could be covered in a specific study.
With respect to fund utilization, management tools should be put in place that are easily learned by beneficiaries, and especially by COs, providing them with an illustrated guide or manual of fund utilization rules and procedures.
Regarding social accountability, the ‘report card’ technique should be generalized.
Finally, it should be emphasized that beneficiaries have shown great interest in the program through their unstinting mobilization and total willingness to respond to questions in great detail. They are very eager to see the program continue with greater financial resources. Overall, implementation of all the recommendations will help optimize the use of human and financial resources under the MAP 2 now being established.
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SELF-ASSESSMENT OF GOVERNANCE AND ACCOUNTABILITY ARRANGEMENTS IN HIV/AIDS CONTROL OPERATIONS IN BENIN
70073 v1
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