OIG audit reveals significant weaknesses in how CCMs are managed, and how CCMs coordinate and oversee grants
The Office of the Inspector General has identified significant weaknesses in (a) the adequacy of the country coordinating mechanism model in coordinating and overseeing grants; and (b) the effectiveness of CCM policies and procedures at the Global Fund Secretariat level and at the country level.
The OIG has just released a report on the first-ever audit it conducted on CCMs. The audit work included:
- a desk review of documents from 50 CCMs;
- detailed in-country reviews of CCMs in seven countries as part of the audits of these countries conducted in 2015;
- reviews of the 800 responses to questionnaires the OIG sent to CCM members, CCM secretariats, technical assistance providers, Global Fund Secretariat staff, civil society organizations, and representatives of key populations; and
- interviews with a large number of people from Global Fund Board and committees, development partners, TA providers, and Global Fund Secretariat staff.
The seven countries that were audited in 2015 were Ghana, Honduras, Indonesia, South Sudan, Tanzania, Pakistan, and Uzbekistan.
Adequacy of the CCM model in coordinating and overseeing grants
Despite some progress, oversight continues to be weak in most CCMs, the OIG found. Its desk review identified various operational gaps, including the absence of oversight committees, weaknesses in oversight plans, lack of feedback from key populations, inadequate discussions on key grant issues, and no sharing of oversight reports with relevant stakeholders, including the Global Fund Secretariat.
- 10% of the 50 countries reviewed did not have the required oversight committee;
- more than half of the countries did not have specific information on roles, timelines, and budget in their oversight plans, or they had oversight plans that were outdated;
- 62% of the CCMs were non-compliant with the requirement of seeking feedback from non-CCM members and from people living with and/or affected with the disease;
- more than half of the 45 CCMs that have oversight bodies did not adequately discuss challenges with the PRs to identify problems and explore solutions;
- 58% of the CCMs had not shared oversight reports with country stakeholders and The Global Fund Secretariat in the previous six months; and
- 26% did not share the oversight reports with relevant stakeholders in a timely manner that could have ensured well-timed remedial action.
The OIG said that possible root causes of weak oversight included time constraints of members; poor planning, documentation and follow-up of oversight activities; inadequate resources; and weak CCM secretariat functions. Role ambiguity among different stakeholders on the nature and extent of CCM oversight was also a factor, the OIG said.
The OIG said that if the Global Fund were to strengthen its efforts to improve the oversight function of the CCMs, this would likely produce results. It cited a study by Grant Management Solutions which showed that 79% of grants that were rated B2 or C improved to B1 or better after training was conducted to strengthen the oversight by CCMs over these grants.
The OIG said that while some countries have had some success in integrating CCMs into the broader country health architecture, in all seven countries audited in 2015, the OIG noted weak coordination and stakeholder engagement with other health forums or structures, particularly for strengthening health systems. For five of these seven countries, the OIG added, the CCM was not integrated into national systems.
Effectiveness of CCM policies and procedures at Secretariat and country level
The OIG found that there are multiple issues in the overall performance management of CCMs by the Secretariat. For example:
- As of October 2015, only 9% of the CCMs assessed by the Secretariat were fully compliant with the relevant eligibility criteria (assessed as part of the performance appraisal of CCMs conducted before they can submit concept notes for each allocation period).
- There is no active measurement of the ongoing performance of CCMs in areas such as oversight, concept note preparation, and principal recipient selection.
- There is a lack of systematic evaluation of the role of CCMs in country portfolios.
- There are no documented terms of reference for the CCM Hub; and no one responsible for managing the performance of CCMs in the country team responsibility matrix.
One of the products of the performance appraisal is an improvement plan for the CCM. The OIG said that implementation of improvement plans for 88% of CCMs has been delayed for more than three months.
The OIG said that its analysis indicated a strong positive correlation between CCM performance and the level of country portfolio risk, with all of the 20 highest portfolio risk countries having non-compliant CCMs.
The OIG found that there were generally effective policies for managing conflicts of interest on CCMs, but that there were still gaps, particularly around compliance. The OIG noted that the Secretariat not yet developed the code of ethical conduct for CCM members which had been directed by the Board.
The OIG said that although significant improvement has been made in the involvement of civil society and affected communities in designing and implementing programs, some gaps remain. It said that membership and meaningful engagement of civil society and key populations is not optimal. Of the 50 CCMs reviewed, 12 did not meet the minimum civil society representation eligibility requirement. In addition, almost half of the 50 CCMs were not fully compliant with the requirement for nongovernmental constituencies to directly and transparently select their representatives. Further, 42 CCMs did not have clearly defined processes for soliciting inputs from and proving feedback to constituencies.
The OIG cited a recent study by Stop TB Partnership that found that half of TB high-burden countries had no civil society representative with TB expertise on their CCMs.
The OIG noted that of the nine countries from which the Global Fund has withdrawn, only one has retained its CCM; that The Global Fund does not have a policy on sustainability and the role of CCMs in post-transition disease programs; and that the Fund has recently identified about 30 countries where transition is expected to occur in at least one of the disease components over the next ten years. “Without CCMs,” the OIG said, “this might adversely impact advocacy for the three diseases, resource mobilization and continued meaningful engagement of civil society and affected communities in those countries post-transition.”
Management actions agreed by the Secretariat
The OIG report described actions that the Secretariat has agreed to take by 31 December 2016 in response to the audit findings. These included the following:
- assign and document clear responsibilities relating to CCMs;
- develop mechanisms to strengthen CCM oversight, including revising its CCM oversight guidance paper; and analyzing options for an effective engagement of CCM members in oversight;
- strengthen the management of conflict of interest by developing principles for ethical conduct and integrity in CCM operations;
- develop a plan to enhance civil society and key populations engagement and accountability in CCMs; and
- once a sustainability and transition policy is approved by the Board, update the CCM guidelines and procedures to reflect key principles of the policy, including evaluating, on a differentiated basis, the need for continuing CCMs (or alternative mechanisms) post-transition along with alternative options.
See also separate GFO article on reactions to the OIG’s audit on CCMs.