President's Emergency Plan For AIDS Relief:

Partner Selection and Oversight Follow Accepted Practices but Would Benefit from Enhanced Planning and Accountability

GAO-09-666: Published: Jul 15, 2009. Publicly Released: Jul 15, 2009.

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The President's Emergency Plan for AIDS Relief (PEPFAR), first authorized in 2003 at $15 billion for 5 years, was reauthorized in 2008 at $48 billion through 2013. PEPFAR supports HIV/AIDS prevention, treatment, and care services, primarily in Africa as well as in Asia and the Caribbean. The Office of the U.S. Global AIDS Coordinator (OGAC) leads implementation of PEPFAR. The Department of Health and Human Services' Centers for Disease Control and Prevention (CDC) and the U.S. Agency for International Development (USAID) are among PEPFAR's primary implementing agencies. In this report, responding to a legislative directive, GAO examined practices used in (1) selecting organizations to implement PEPFAR activities and (2) overseeing these organizations' PEPFAR activities. GAO interviewed agency and implementing organization officials; reviewed key agency guidance; analyzed PEPFAR awards for fiscal years 2007 and 2008; and observed PEPFAR activities in Namibia, South Africa, and Zambia.

The selection of PEPFAR partner organizations to implement HIV/AIDS prevention, treatment, and care services generally follows accepted practices. GAO's review of PEPFAR guidance on annual interagency planning for program activities, including selection of implementing partners, found that the guidance calls for strategic assessments of overall program needs. GAO also found that the interagency plans for PEPFAR activities in Namibia, South Africa, and Zambia for fiscal year 2008 included such assessments, and CDC officials reported using these annual plans in planning their selection of PEPFAR implementing partners. However, the PEPFAR guidance that GAO reviewed does not call for the involvement of agency assistance and acquisition officials--officials with primary responsibility for making awards to implementing partners--although these officials possess expertise necessary to ensure that the selection process contributes to meeting program needs. Moreover, these officials were not involved in preparing the interagency PEPFAR plans for fiscal years 2008 and 2009. Further, although PEPFAR guidance on preparing the interagency plans is OGAC's key tool for coordinating the implementing agencies' partner selection processes, this guidance has not been integrated with the agencies' guidance. In making awards, CDC and USAID generally engaged in competitive selection processes, such as issuing solicitations and convening review panels, to select candidate organization proposals with the best approach for meeting program needs. In addition, CDC and USAID evaluated candidate organizations' technical, management, and financial capacities to ensure that candidates had the systems and resources needed to meet program needs. CDC and USAID have established a number of practices to oversee the activities of their PEPFAR implementing partners. For the awards that GAO reviewed, CDC and USAID required programmatic and financial reporting, reviewed implementing partners' expenditure data against their work plans, and documented site visits with checklists and reports. In addition, CDC and USAID provided technical assistance to improve implementing partners' capacities. However, several weaknesses have limited CDC's and USAID's ability to oversee partners' and subpartners' PEPFAR activities and thus ensure accountability for PEPFAR funds. First, according to OGAC data, about 29 percent of CDC and 7 percent of USAID direct-hire positions--including those with oversight responsibility--remained unfilled early in fiscal year 2009. Second, PEPFAR and agency award reporting time frames are not synchronized, exacerbating agencies' reporting burden and reducing time for oversight, including time for site visits. Third, GAO's assessments of 15 implementing partners' internal controls showed that one implementing partner and six subpartners were constrained in their ability to account for the use of PEPFAR funds, because they did not consistently carry out established policies and procedures. Fourth, CDC procedures for collecting audits and ensuring resolution of audit findings are unclear, limiting CDC's ability to help strengthen identified implementing partner weaknesses.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: In a May 2010 letter to Congressional committees about its actions related to the report, State agreed that assistance and acquisition officials need to be included in the preparation of country operation plans (COP). In its FY 2010 COP guidance, issued June 29, 2009 (shortly before the report was published), the Office of the Global Aids Coordinator (OGAC) cited the GAO report and stated the need to consult with all relevant agencies when preparing country plans. The FY 2010 COP guidance contained language specifying that acquisition and assistance officials who are part of country teams are to participate in planning and drafting of annual COPs and a section for acquisition and assistance officials emphasizing the importance of their participation throughout the funding year, for example, for the purposes of both changing existing contracts or awards in addition to planning new procurements for the following fiscal year. Similar language was contained in the FY 2011 COP guidance. We consider these actions to be responsive to the recommendation.

    Recommendation: To strengthen CDC's and USAID's ability to accomplish PEPFAR goals and ensure accountability for PEPFAR funds, the Secretary of State should direct OGAC to improve the process of partner selection by ensuring that the annual guidance on preparing the country operation plan (COPs) addresses the need to involve assistance and acquisition officials.

    Agency Affected: Department of State

  2. Status: Closed - Implemented

    Comments: In August 2013, State provided GAO a document describing the actions it has taken, in coordination with CDC and USAID, to improve the guidance on COP development process, the COP guidance, and partner selection and rationalization, including the following. OGAC and the PEPFAR Deputy Principals have made improvements to the annual planning guidance and processes that emphasize the importance of the interagency country-level planning, including partner performance reviews and partner consultation during COP deliberations. Furthermore, for USAID at both the field and headquarters levels, many operating units have updated their annual portfolio review processes to align procurement planning more systematically with PEPFAR guidance on COP preparation. In addition, since 2009, HHS/CDC has worked to include assistance and acquisition staff in funding planning discussions at the headquarters level. Furthermore, the next evolution in this process will be implemented in fall 2013 in which HHS/CDC will include CDC Program and Grants Office acquisition and assistance officials in individual country meetings to review and plan the agency's expected FY 2014 extramural funding portfolio, according to State.

    Recommendation: To strengthen CDC's and USAID's ability to accomplish PEPFAR goals and ensure accountability for PEPFAR funds, the Secretary of State should direct OGAC to improve the process of partner selection by working with Department of Health and Human Services (HHS) and USAID to clarify the relation between PEPFAR guidance on COP preparation and the agencies' guidance on assistance and acquisition awards.

    Agency Affected: Department of State

  3. Status: Closed - Implemented

    Comments: In August 2013, State provided a document describing a wide variety of actions it has taken with implementing agencies to address PEPFAR staffing shortages, including the following. In 2008, an interagency technical working group within OGAC began working on standardized framework job descriptions in order to harmonize and expedite hiring of core positions for locally-employed staff within agency offices. Since 2009, 26 framework job descriptions have been developed and approved, providing core position description elements that can be supplemented with country-specific elements. This effort has expedited the end-to-end process of requesting and filling a position vacancy, as well as ensuring that position descriptions for similar positions were consistent across countries and across agencies to ensure that similar positions across agencies were announced at the same pay grade. For several years pre-dating this effort, grade disparities across agencies for similar positions had been contributing to staff attrition. In 2011, CDC established and expanded a separate overseas hiring team within its Human Capital and Resources Management Office which solely focused on hiring and benefits for overseas staff. Concurrently, a CDC contractor assessed its overseas hiring to review the hiring process, from identification of a vacancy to the selected employee arriving for duty in country. According to State, this assessment quantified the timeframes for key steps in the process, identified bottlenecks and made a number of recommendations for improvement which are being addressed and reported in monthly meetings of the Center for Global Health's Global Staffing Group. CDC has established metrics and conducts ongoing data analysis to ensure timelines for the process are improving. One key recommendation of the assessment is to more actively use CDC's biennial Global Staffing Plan exercise, which reviews tour end dates for all overseas staff, as a planning tool for hiring. These efforts are expected to minimize gaps between an employee and his or her eventual successor and to ensure continuity of operations. Overall, according to State, the PEPFAR field vacancy rate dropped from 15.3% to 11.6% on average from FY 2011 to FY 2013.

    Recommendation: To strengthen CDC's and USAID's ability to accomplish PEPFAR goals and ensure accountability for PEPFAR funds, the Secretary of State should direct OGAC to strengthen oversight of PEPFAR implementing partners by working with CDC and USAID to develop a strategy to address staffing shortages identified by OGAC, CDC, and USAID.

    Agency Affected: Department of State

  4. Status: Closed - Implemented

    Comments: In August 2013, State provided a detailed description of the actions it has taken with implementing agencies to better align OGAC and agency reporting time frames. In particular, as part of a State/USAID Streamlining Initiative begun in 2010, OGAC moved the COP submission date from October to March of each year in order to align with the State and USAID annual planning cycles. The change in submission date provided an opportunity for PEPFAR country teams to better interact, align with and integrate program planning and implementation with non-HIV health programs, according to State.

    Recommendation: To strengthen CDC's and USAID's ability to accomplish PEPFAR goals and ensure accountability for PEPFAR funds, the Secretary of State should direct OGAC to strengthen oversight of PEPFAR implementing partners by working with implementing agencies to develop a plan to reduce PEPFAR country teams' reporting burden through better alignment of OGAC and agency reporting time frames.

    Agency Affected: Department of State

  5. Status: Closed - Implemented

    Comments: In August 2013, State provided a detailed description of the actions it has taken with implementing agencies to strengthen financial controls for partners and subpartners, including the following. In FY 2011, CDC established a Technical Assistance contract to improve business systems for partners that are determined to have weak financial controls. This contract has been used to provide specific technical assistance for Ministries of Health in the field upon request of the program office to CDC headquarters. The request could be triggered by site visit observations, Project Officer review of documentation, or a request from the partner for assistance in a specific area. The technical assistance contract reviews and assesses the partner's standard operating procedures, provides a recommended improvement plan, and assists the partner with correcting issues as they relate to cooperative agreement management, according to State.

    Recommendation: To strengthen CDC's and USAID's ability to accomplish PEPFAR goals and ensure accountability for PEPFAR funds, the Secretary of State should direct OGAC to strengthen oversight of PEPFAR implementing partners by assessing and addressing the degree to which weaknesses in PEPFAR partners' and subpartners' implementation of financial controls negatively affect CDC's and USAID's ability to ensure that program funds are used for their intended purposes.

    Agency Affected: Department of State

  6. Status: Closed - Implemented

    Comments: In a letter to Congress following the report's issuance, State indicated that OGAC would work with CDC to further develop procedures for collecting audit information and addressing audit findings. During a meeting on June 7, 2012, a CDC official stated that CDC had addressed GAO's recommendation about audit collection procedures by collecting the audits that were outstanding at the time of GAO's 2009 report and developing a standard operating procedure (SOP) for receipt, tracking, and retention of CDC foreign and international audit documents. The official also noted that GAO's recommendation influenced CDC's decision to establish the SOP. Among other things, the SOP requires foreign entities to submit audits to CDC for review and to resolve audit findings within a specified period of time. CDC approved and implemented the SOP, and provided GAO a copy. As such, we consider CDC?s actions to be responsive to our recommendation.

    Recommendation: To strengthen CDC's and USAID's ability to accomplish PEPFAR goals and ensure accountability for PEPFAR funds, the Secretary of State should direct OGAC to strengthen oversight of PEPFAR implementing partners by working with CDC to establish procedures for collecting PEPFAR implementing partners' audit information and addressing audit findings.

    Agency Affected: Department of State

 

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