Are CCMs Complying with the Global Fund Requirements Concerning the Selection of CCM Members?
Since April 1, 2005, the Global Fund has had six minimum requirements that CCMs must meet if their proposals to the Fund are to be considered. One of these is that CCM members representing the non-governmental sectors must be selected by their own sectors through a transparent process. Almost three years later, some questions remain about the extent to which CCMs are complying with this requirement.
This article (1) provides background information on this topic; (2) presents an analysis conducted by Aidspan (publisher of GFO) on Round 6 applications; (3) provides some additional information on the Round 7 experience; (4) briefly describes efforts by the Global Fund Secretariat to educate CCMs concerning this requirement; and (5) presents some concluding remarks.
1. Introduction and Background
The Global Fund's CCM Guidelines (“Revised Guidelines on the Purpose, Structure and Composition of Country Coordinating Mechanisms and Requirements for Grant Eligibility”) state that “CCM members representing the non-government sectors must be selected/elected by their own sector(s) based on a documented, transparent process, developed within each sector.” The Global Fund defines “non-government sectors” as including the academic and educational sector; the NGOs and community-based organisations sector; the people living with HIV/AIDS, TB and/or malaria sector; the private sector; and the religious and faith-based organisations sector.
The requirement concerning the selection process for members from the non-governmental sectors is one of what the Global Fund terms the “six minimum requirements” that CCMs must meet before their applications to the Fund will be considered.
For each new round of funding, the Global Fund Secretariat sets up a Screening Review Panel to review whether the CCMs submitting proposals are compliant with the six requirements (and also whether they are compliant with certain other technical requirements, such as the country's income level). If a CCM is regarded as not being compliant, any proposal that the CCM has submitted is "screened out" – that is, it is not presented to the TRP for consideration. All other proposals are "screened in" – that is, they are passed to the TRP for consideration. During the screening in or out, the Secretariat is not evaluating the proposals themselves, it is evaluating whether the CCMs are compliant with the requirements.
Most of the six CCM requirements were initially adopted by the Global Fund Board in November 2004. When Round 5 was launched several months later, the CCMs had not had much time to ensure that they met the new requirements. Consequently, it appears that the Secretariat exercised some discretion – that is, was far from strict – when it screened the applications for Round 5.
It is our understanding, however, that during grant negotiations for successful Round 5 proposals, the Secretariat started insisting on seeing documentation to prove that at least some efforts had been made to meet the requirements; and that, in fact, in many cases the signing of the grant agreement was held up while the necessary documents were produced.
By the time the call for proposals for Round 6 was issued on 5 May 2006, CCMs had had about 18 months to implement the new requirements. Consequently, one might have expected that the Secretariat would have been stricter about enforcing the requirements when it screened the applications for Round 6. Of the 96 Round 6 proposals submitted by CCMs, 93 were screened in, thus implying that the vast majority of CCMs were meeting the new requirements. However, it was not known just how strictly the Secretariat applied the new rules during the screening process for Round 6. Did the Secretariat continue to exercise some discretion? If it did, were there still a number of CCMs not meeting the new requirements?
One has to place this whole discussion in context. For many countries, the minimum requirements were a completely foreign concept. Even once the requirements were explained, these countries had to incorporate them into their own political and social context. In some ways, the requirements required a democratization of decision-making in the health field in countries that were used to an authoritarian public health system. Viewed in this context, it can be argued that 18 months was still a very short time to expect all countries to comply.
2. Aidspan's analysis of Round 6 proposals
The Round 6 proposal form required applicants to describe the selection processes used by the various sectors. An analysis conducted by Aidspan of about two-thirds of Round 6 proposal forms revealed that most CCMs failed to describe the selection processes followed by the non-government sectors. The results of this analysis are provided below.
Caution: It is not possible to draw definitive conclusions from this analysis concerning whether these CCMs complied with the Global Fund requirements, for two reasons: (1) the analysis that Aidspan undertook had several limitations (these are explained below); and (2) the Global Secretariat did not rely solely on the information provided in the applications. Nevertheless, the analysis raises some questions about compliance that should be pursued.
Aidspan examined what CCMs reported on 61 Round 6 applications concerning the selection process for CCM members from three of the non-governmental sectors – the NGOs and community-based organisations sector; the religious and faith-based organisations sector; and the people living with the diseases sector. (Of the 93 proposals that were screened in, only 61 were approved; Aidspan was able to access these proposals, but did not have access to proposals that were not approved.)
Round 6 applicants were required to describe on the proposal form itself the selection process used by each sector; applicants were also required to attach supporting documents providing more details on the selection processes.
The major findings of Aidspan's analysis were as follows:
- NGOs and community-based organisations sector: Just over half of the CCMs indicated on the proposal form that there was a selection process run by the sector itself. However, only a third of the CCMs actually described the process on the proposal form.
- Religious and faith-based organisations sector: Only a third of the CCMs indicated on the proposal form that there was a selection process run by the sector itself, and only one in eight CCMs actually described the process on the proposal form.
- People living with the diseases sector: Just over a quarter of the CCMs indicated on the proposal form that there was a selection process run by the sector itself, and less than one in nine CCMs actually described the process on the proposal form.
As can be seen from the above, a large number of CCMs did not even indicate on the proposal form that there was a process to select CCM members from these three sectors. And, of those CCMs that did indicate that there was a selection process, only a fraction actually described the process on the proposal form itself.
The following are two examples of selection processes for the NGO sector that were well described on the proposal forms:
- From a proposal submitted by Georgia: "[T]he rotational members of the NGO/CSOs sector are elected on an annual basis by the respective sectoral forums – coalitions. Elections are performed through a documented and transparent process – e-mail forums among the NGO coalition partners. In particular, the 2 NGOs representing HIV/AIDS NGO/CSO sector at the CCM have been elected through the open e-mail, transparent voting process led by the PTF [Prevention Task Force]. The NGO “Tanadgoma” and “Save the Children International Federation” have been elected as the rotational members starting for October 2004-December 2005. Subsequent elections in January 2006 determined a new member NGO “Bemoni” and has retained the mandate of “Save the Children” till end of 2006. Next round of elections is planned in January 2007."
- From a proposal submitted by the Maldives: "All 25 [NGOs] operating in the Maldives were invited to attend a meeting to discuss the submission of this proposal. At that meeting, expressions of interest to participate on the CCM were called for. Four nongovernment organizations nominated and were supported by the other organizations present at the meeting to join the CCM."
Most of the CCMs that said there was a selection process for the NGO sector, but that failed to describe the process on the proposal form, did one or both of the following: (a) they explained what the CCM had done to request that the NGO sector implement a selection process; and/or (b) they simply stated that the NGO sector had nominated its representatives. The following are two examples:
- "After a review in 2002, it was recommended that each civil society sector should nominate their own representatives, which would in turn be formally appointed by the Chairperson of the CCM. That process is as follows: 1. Sectors establish their own sectoral processes for elections, and submit a report and nominee to the Chair of CCM for appointment. 2. The CCM recommends that national stakeholders in a particular sector should be brought together in a summit to elect a representative. 3. If sectors request, the process of nominating a representatives may be financed by the CCM. 4. Notifications of the nominated candidate are submitted to the CCM secretariat in writing...."
- "In order to fulfill the latest Global Fund requirements, original CCM constituents from NGOs/civil society, faith-based organizations (FBOs), and the private sector nominated representatives for the streamlined CCM, using a transparent and democratic process."
Sometimes, it was not clear from the information on the proposal form whether there was a proper selection process in place. For example:
- "The [CCM] is composed of 36 members, including 12 from civil society…. These representatives were selected within their institution according to their internal procedure."
Limitations of the analysis
There are several limitations to the analysis that Aidspan performed:
- Aidspan did not have access to the supporting documents attached to the proposals. It is our understanding that some CCMs described their selection process in these supporting documents even though they did not include a summary of the process on the proposal form itself.
- The proposal form did not specifically instruct applicants to describe the selection process for the people living with the diseases sector, even though several Global Fund documents, including the FAQs (Frequently Asked Questions) that accompanied the Round 6 call for proposals, stated that the representatives of this sector must be chosen by the sector itself. Because of the way the proposal form was worded, some applicants may have concluded that they did not need to describe the selection process for this sector.
- Of the CCMs that had proposals approved in Round 6, there was no information whatsoever on the selection processes for five CCMs. Each of these CCMs submitted more than one component, but only one component was approved, and only the approved component was posted on the Global Fund website. It is possible that these CCMs provided information on the selection processes in a component that was not approved, and that this information was not repeated in the component that was approved and posted on the website.
As well, Aidspan has been informed that when the Round 6 applications were screened by the Secretariat and assessed for compliance with the selection process requirements, the Secretariat did not rely solely on the information provided on the proposal form or in supporting documents attached to the proposal. In fact, whenever the information contained in the application was inadequate to assess compliance, Secretariat staff took one or both of the following steps: (a) they asked for more information from the CCMs in question; and/or (b) they talked to in-country partners of the CCMs in question and the relevant Fund Portfolio Managers in the Secretariat.
Questions raised by the analysis
Despite its limitations, the analysis raises two questions that are worthy of further discussion.
Is the Secretariat being sufficiently transparent?
Transparency is one of the core philosophies of the Global Fund. Indeed, with respect to the requirement that CCM members from the non-government sectors be selected by the sectors themselves, the Fund requires that the selection processes be transparent and be documented. Wherever possible, therefore, the Secretariat should also operate in a transparent fashion. And yet:
- for the Round 6 applications that were approved, only the proposal form was made public (Aidspan was not able to access the supporting documents);
- Round 6 applications that were not approved were not made public; (Note: the Global Fund Board subsequently decided that beginning in Round 7, all proposals will be made public, whether or not they were approved.)
- no people from outside the Global Fund Secretariat were included on the team that screened the applications, including when the Secretariat took additional steps to determine whether the CCM applicants were in compliance with Global Fund requirements concerning the selection processes; and
- the Secretariat did not make public the report it prepared on the screening process, including the additional steps it undertook to determine compliance and the information it collected.
As a result, Aidspan has not been ably to fully assess whether the CCMs met the requirements concerning the selection process for CCM members.
Because the Secretariat did not include people from outside the Secretariat in the screening process, and did not report on the results of the additional steps it took to determine compliance, we have to take the Secretariat's word for it that 93 of the 96 Round 6 CCM applicants were indeed compliant.
In our view, the Secretariat ought to have at least issued a report. While it may not have been possible to prepare a report at the time the screening was done (due to time pressures), the Secretariat could have prepared a report after the screening was completed, while the applications were being reviewed by the Technical Review Panel (TRP).
The Secretariat should also have considered adding some people from outside the Secretariat to its screening team when it decided to take additional steps to verify compliance. Logically, these people should have been representatives of civil society.
Is there a need to review or better explain the requirements?
Despite the fact that 93 of the 96 applications from CCMs were screened in, it is likely that the Global Fund Secretariat exercised some discretion in Round 6 (as in Round 5) and that in reality some CCMs are struggling with some of the requirements. If this is indeed the case, one has to ask why they are struggling.
Perhaps some of the requirements are too strict, in which case consideration should be given to altering some of the language of the requirements to make them less onerous. It should be possible to do this while still respecting the spirit of the requirements.
On the other hand, perhaps the best approach is for the Secretariat to continue to exercise discretion in certain instances. As indicated above, for some countries, meeting the minimum requirements is a significant challenge. It may take these countries several years to fully comply. Perhaps allowing the Secretariat to take the country context into account and to interpret the minimum requirements with a certain degree of flexibility is an entirely appropriate way to proceed. But if that approach is taken, the Secretariat needs to be transparent concerning both its process and its decisions.
It may also be necessary for the Global Fund Secretariat and others to step up efforts to assist CCMs to better understand the requirements and to fully comply with them. (Some of the Secretariat's current efforts in this regard are described below.)
It is difficult to know which approach, or which combination of approaches, is best without knowing more about the extent to which some CCMs are struggling to meet the minimum requirements and why they are struggling.
3. The Round 7 experience
Of the 80 Round 7 proposals submitted from CCMs, 77 were screened in, again implying that the vast majority of CCMs are meeting the new requirements. Nevertheless, the “Report of the Technical Review Panel and the Secretariat on Round 7 Proposals” states that potential applicants in Round 8 are “strongly encouraged to work with partners, the Global Fund Secretariat, and specifically the Fund Portfolio cluster working in that region, to fully understand the minimum requirements for eligibility, including the minimum level of documentation that is required to demonstrate compliance with those requirements.” (The full report is available at www.theglobalfund.org/en/about/technical/report/.) This suggest that, at the very least, more work needs to be done to ensure that CCMs better understand what the minimum requirements are, how to comply with them, and how to prepare the required documentation..
As was the case in Round 6, the Secretariat did not include people from outside the Secretariat in the screening, and did not publicly issue a report on the screening process, including the results of the additional steps the Secretariat took to determine compliance.
4. Efforts by the Global Fund Secretariat to educate CCMs
The Global Fund Secretariat has made efforts to educate CCMs concerning the minimum requirements. The requirements are described in the CCM Guidelines and are further explained in the “Clarifications on CCM Requirements – Round 7 (both documents are available at www.theglobalfund.org/en/apply/mechanisms/guidelines/). Additional information on the CCM minimum requirements was included in the FAQs that the Fund prepared for Round 7; the information included a list of the materials that CCMs need to provide to demonstrate compliance with the requirements. The Fund will likely issue updated versions of the clarifications and FAQ documents for Round 8.
In addition, drawing on lessons learned from Round 6, the Secretariat participated in regional meetings between March and early May 2007 (soon after the launch of Round 7). As reported in the “Report of the Technical Review Panel and the Secretariat on Round 7 Proposals,” at these meetings the Secretariat, among other things, “further explain[ed] the Global Fund's minimum requirements for applicant eligibility, and (as relevant to the meeting attendees), review[ed] examples of the types of documents required to evidence compliance with those minimum requirements.”
Finally, the Secretariat recently established a global framework contract enabling it to engage the services of consultants who can help CCMs better understand the minimum requirements.
The bottom line is (a) that we do not really know to what extent CCMs are complying with the requirement that members representing the non-governmental sectors must be selected by their own sectors through a transparent process; and (b) that the Global Fund Secretariat has not been particularly transparent concerning its assessment of compliance during the proposal screening process.
Are most CCMs in compliance with this requirement and the other minimum requirements? Is there a need to step up efforts to educate CCMs concerning the requirements? Is there a need to re-visit the wording of some of the requirements? It is appropriate for the Secretariat to continue to exercise discretion in the screening process? These are all questions that merit further discussion.