GFO Issue 465, Article Number: 7
ABSTRACT
The Global Fund’s Additional Safeguard Policy (ASP), established in 2004, acts as a last-resort risk mitigation tool to protect health investments in politically unstable and institutionally weak countries, particularly in Africa, where 17 of the 29 ASP-listed nations face prolonged oversight, some for over 15 years. While designed to prevent grant disruptions and ensure accountability, the ASP has drawn criticism for its perceived lack of clear exit strategies, slow processes, and limited capacity-building, prompting an OIG audit in 2024 that called for reforms. In response, the Global Fund is now refining exit criteria, strengthening local systems, and improving transparency to transition countries out of ASP, balancing financial safeguards with the urgent need for sustainable, country-led health programs."
Introduction
The Additional Safeguard Policy is a mitigation measure put in place by the Global Fund in 2004 to “protect” its investments in the areas of grant implementation. It is an important risk management tool for the Global Fund, providing several safeguards to mitigate identified risks in specific contexts. The ASP is typically implemented in countries experiencing political, geopolitical, and institutional instability, characterised by weak accountability systems.
After several years of unreviewed implementation, the ASP was audited by the OIG at the request of the African Constituency Bureau on behalf of the African constituencies of the Global Fund. The advisory report related to this matter was released in October 2024, with key findings and recommendations for the Global Fund, which responded and has started to implement some recommendations.
The paper discussed at the 28th Global Fund Strategy Committee aimed to update the committee members on the progress made so far.
The Additional Safeguard Policy: the principle and its implementation
As previously mentioned, the ASP is a risk management tool employed by the Global Fund as a last resort when the portfolio and/or disease-specific risks necessitate the Secretariat taking the lead in determining implementation arrangements during a crisis. This provision aims to ensure accountable use of Global Fund investments, prevent grant interruptions, and protect gains in fighting three diseases and building resilient health systems in our countries.
ASP allows the Global Fund to select implementing entities, in a very exceptional way, and may apply “additional risk mitigation” such as the introduction of the fiscal agent, restricted or cash policy, which is not specific to ASP countries. Rightly or wrongly, the ASP is associated with the Challenging Operating Environment Policy because many of the COE countries are usually affected by the ASP.
Fig 1 ASP countries worldwide Source : The Global Fund
Examples of the invocation of the ASP in some African countries.
Burundi
- Under ASP since December 2016 one year after a political crisis
- Reasons invoked by the GF for applying for the ASP: important weaknesses in programmatic management characterized by delays in the implementation of activities
- Low absorption capacity
- Weak governance of CCMs
Congo
- Under ASP since December 2017 due to non-compliance with the co-financing commitment, resulting in ARV and anti-tuberculosis medicines stockouts.
- Important weaknesses identified in the supply chain
This policy impacts 29 countries, with Africa having the highest burden of ASP countries worldwide, characterised by 17 countries, and some countries perceive this policy as a life sentence, and with good reason, as there are countries that have been subject to it for twenty years or more.
#
Countries
Date of introduction
Years under ASP
1
Soudan du Sud
2005
20
2
Zimbabwe
2008
17
3
Mali
2009
16
4
Tchad
2009
16
5
Mauritanie
2010
15
6
Congo (République démocratique)
2011
14
7
Guinée-Bissau
2012
13
8
Niger
2012
13
9
Guinée
2013
12
10
République centrafricaine
2013
12
11
Nigéria
2015
10
12
Burundi
2016
9
13
Congo
2017
8
15
Angola
2018
9
16
Burkina Faso
2022
3
17
Liberia
2023
2
The Global Fund is willing to support countries
Even if the policy had not been reviewed or updated since then, it was reinforced and framed with some disposals. Below is an overview of how the policy has evolved over the years.
Fig 2 : Progress in the ASP deployment and review Source The Global Fund
As stated earlier, the APS is used as a mitigation tool, not to punish countries.
Since the African constituencies requested a review of the policy, the secretariat is committed to implementing the OIG's recommendations. Below is a quick summary.
Findings and recommendations
The OIG highlighted four areas. They are the following:
1. Invocation of ASP relies on risk assessment and approval: Countries understand the rationale but not the implications. As of August 2024, only 10 of 235 countries had met the exit criteria, limiting exit planning and monitoring.
2. ASP measures in selecting implementers : ASP grants are mostly managed by international Principal Recipients, with fiscal and cash controls to protect investments but increase costs. Operational processes are slow, and capacity-building is limited.
3. Monitoring roles are clear, but a lack of exit criteria and controls hampers effectiveness. Only three portfolios were revoked, with few lessons learned.
4. Cross-cutting issues include ineffective communication using stigmatising language and fragmented governance, addressed by appointing the ICOE team.
Recommendations include providing clear exit criteria, strengthening monitoring, using simple language, and clarifying the Implementation and Challenging Operating Environments team (ICOE) roles.
As response to the OIG findings…
The Global Fund Secretariat recognised the important role of the Additional Safeguard Policy (ASP) in ensuring responsible use of investments and safeguarding progress against the three diseases. Following an advisory review by the Office of Inspector General (OIG), the Secretariat identified key areas for improvement in ASP's application and execution, including monitoring, transition planning, capacity building, and internal governance. A comprehensive review of countries under ASP was recently in progress to clarify the reasons for their inclusion, establish clear exit criteria with milestones, and develop relevant exit strategies. This review involves extensive consultation across the Secretariat and is slated for completion by Q4 2024.
To effectively oversee the ASP exit process, the Secretariat intends to actively involve country stakeholders by working with them to create customised ASP exit plans that meet these exit criteria. They will strengthen communication protocols to improve transparency and clarity throughout the grant's duration, establishing agreed milestones for stakeholder engagement. Priority will be given to capacity-building activities, with close collaboration between the Country Coordinating Mechanism (CCM) and Principal Recipients (PRs) to provide technical and coordination support tailored to each country's specific context. These initiatives demonstrate the Secretariat’s dedication to enhancing ASP governance and assisting countries in a smooth transition out of ASP.
The Secretariat is collaborating with each ASP country to establish a foundation for effective grant implementation, aiming for a sustainable transition to country PR-ship.
Fig 3 Prioritized actions for 2025 source The Global Fund
To date, the Secretariat has improved ASP exit monitoring by conducting regular assessments and enhancing communication with stakeholders to promote transparency and accountability. It provides tailored technical assistance to build national capacities, including establishing management units and developing exit strategies, to hasten the transition to national Principal Recipients (PRs). Exit criteria are being revised to be specific, measurable, and risk-based, with clear verification means and timelines reviewed by Secretariat teams to ensure robust decisions. The Secretariat supports countries with tailored exit strategies, enabling those with sustained capacity to transition out of ASP and assume national ownership. Applying ASP involves balancing risks while ensuring program continuity, especially in fragile settings. The strategy includes monitoring implementation and supporting transitions based on risk and efficiency, requiring strong national ownership.
According to the African constituencies statement for the Strategy Committee, which we became acquainted with, the majority of ESA and WCA constituencies have received their ASP exit criteria. However, the sentiment of a life sentence remains, especially since the Global Fund will continue to select the implementing entities in those countries. However, they “strongly support the commitment from the Secretariat to support transitions to country systems and for regular engagement around ASP progress, noting that all relevant national stakeholders (Ministries, CCM, and PRs) and accountability institutions must be engaged in this process.”
Given the ongoing funding constraints worldwide, is this a prudent disposal, especially considering that INGOs' management fees could be used as potential/ additional resources for grant implementation? These global financial constraints should serve as a call for greater country ownership and closer relations with National Supreme Audit Institutions.
Let’s wait and see…
Introduction
The Additional Safeguard Policy is a mitigation measure put in place by the Global Fund in 2004 to “protect” its investments in the areas of grant implementation. It is an important risk management tool for the Global Fund, providing several safeguards to mitigate identified risks in specific contexts. The ASP is typically implemented in countries experiencing political, geopolitical, and institutional instability, characterised by weak accountability systems.
After several years of unreviewed implementation, the ASP was audited by the OIG at the request of the African Constituency Bureau on behalf of the African constituencies of the Global Fund. The advisory report related to this matter was released in October 2024, with key findings and recommendations for the Global Fund, which responded and has started to implement some recommendations.
The paper discussed at the 28th Global Fund Strategy Committee aimed to update the committee members on the progress made so far.
The Additional Safeguard Policy: the principle and its implementation
As previously mentioned, the ASP is a risk management tool employed by the Global Fund as a last resort when the portfolio and/or disease-specific risks necessitate the Secretariat taking the lead in determining implementation arrangements during a crisis. This provision aims to ensure accountable use of Global Fund investments, prevent grant interruptions, and protect gains in fighting three diseases and building resilient health systems in our countries.
ASP allows the Global Fund to select implementing entities, in a very exceptional way, and may apply “additional risk mitigation” such as the introduction of the fiscal agent, restricted or cash policy, which is not specific to ASP countries. Rightly or wrongly, the ASP is associated with the Challenging Operating Environment Policy because many of the COE countries are usually affected by the ASP.
Fig 1 ASP countries worldwide Source : The Global Fund
Examples of the invocation of the ASP in some African countries.
Burundi
- Under ASP since December 2016 one year after a political crisis
- Reasons invoked by the GF for applying for the ASP: important weaknesses in programmatic management characterized by delays in the implementation of activities
- Low absorption capacity
- Weak governance of CCMs
Congo
- Under ASP since December 2017 due to non-compliance with the co-financing commitment, resulting in ARV and anti-tuberculosis medicines stockouts.
- Important weaknesses identified in the supply chain
This policy impacts 29 countries, with Africa having the highest burden of ASP countries worldwide, characterised by 17 countries, and some countries perceive this policy as a life sentence, and with good reason, as there are countries that have been subject to it for twenty years or more.
|
# |
Countries |
Date of introduction |
Years under ASP |
|
1 |
Soudan du Sud |
2005 |
20 |
|
2 |
Zimbabwe |
2008 |
17 |
|
3 |
Mali |
2009 |
16 |
|
4 |
Tchad |
2009 |
16 |
|
5 |
Mauritanie |
2010 |
15 |
|
6 |
Congo (République démocratique) |
2011 |
14 |
|
7 |
Guinée-Bissau |
2012 |
13 |
|
8 |
Niger |
2012 |
13 |
|
9 |
Guinée |
2013 |
12 |
|
10 |
République centrafricaine |
2013 |
12 |
|
11 |
Nigéria |
2015 |
10 |
|
12 |
Burundi |
2016 |
9 |
|
13 |
Congo |
2017 |
8 |
|
15 |
Angola |
2018 |
9 |
|
16 |
Burkina Faso |
2022 |
3 |
|
17 |
Liberia |
2023 |
2 |
The Global Fund is willing to support countries
Even if the policy had not been reviewed or updated since then, it was reinforced and framed with some disposals. Below is an overview of how the policy has evolved over the years.
Fig 2 : Progress in the ASP deployment and review Source The Global Fund
As stated earlier, the APS is used as a mitigation tool, not to punish countries.
Since the African constituencies requested a review of the policy, the secretariat is committed to implementing the OIG's recommendations. Below is a quick summary.
Findings and recommendations
The OIG highlighted four areas. They are the following:
1. Invocation of ASP relies on risk assessment and approval: Countries understand the rationale but not the implications. As of August 2024, only 10 of 235 countries had met the exit criteria, limiting exit planning and monitoring.
2. ASP measures in selecting implementers : ASP grants are mostly managed by international Principal Recipients, with fiscal and cash controls to protect investments but increase costs. Operational processes are slow, and capacity-building is limited.
3. Monitoring roles are clear, but a lack of exit criteria and controls hampers effectiveness. Only three portfolios were revoked, with few lessons learned.
4. Cross-cutting issues include ineffective communication using stigmatising language and fragmented governance, addressed by appointing the ICOE team.
Recommendations include providing clear exit criteria, strengthening monitoring, using simple language, and clarifying the Implementation and Challenging Operating Environments team (ICOE) roles.
As response to the OIG findings…
The Global Fund Secretariat recognised the important role of the Additional Safeguard Policy (ASP) in ensuring responsible use of investments and safeguarding progress against the three diseases. Following an advisory review by the Office of Inspector General (OIG), the Secretariat identified key areas for improvement in ASP's application and execution, including monitoring, transition planning, capacity building, and internal governance. A comprehensive review of countries under ASP was recently in progress to clarify the reasons for their inclusion, establish clear exit criteria with milestones, and develop relevant exit strategies. This review involves extensive consultation across the Secretariat and is slated for completion by Q4 2024.
To effectively oversee the ASP exit process, the Secretariat intends to actively involve country stakeholders by working with them to create customised ASP exit plans that meet these exit criteria. They will strengthen communication protocols to improve transparency and clarity throughout the grant's duration, establishing agreed milestones for stakeholder engagement. Priority will be given to capacity-building activities, with close collaboration between the Country Coordinating Mechanism (CCM) and Principal Recipients (PRs) to provide technical and coordination support tailored to each country's specific context. These initiatives demonstrate the Secretariat’s dedication to enhancing ASP governance and assisting countries in a smooth transition out of ASP.
The Secretariat is collaborating with each ASP country to establish a foundation for effective grant implementation, aiming for a sustainable transition to country PR-ship.
Fig 3 Prioritized actions for 2025 source The Global Fund
To date, the Secretariat has improved ASP exit monitoring by conducting regular assessments and enhancing communication with stakeholders to promote transparency and accountability. It provides tailored technical assistance to build national capacities, including establishing management units and developing exit strategies, to hasten the transition to national Principal Recipients (PRs). Exit criteria are being revised to be specific, measurable, and risk-based, with clear verification means and timelines reviewed by Secretariat teams to ensure robust decisions. The Secretariat supports countries with tailored exit strategies, enabling those with sustained capacity to transition out of ASP and assume national ownership. Applying ASP involves balancing risks while ensuring program continuity, especially in fragile settings. The strategy includes monitoring implementation and supporting transitions based on risk and efficiency, requiring strong national ownership.
According to the African constituencies statement for the Strategy Committee, which we became acquainted with, the majority of ESA and WCA constituencies have received their ASP exit criteria. However, the sentiment of a life sentence remains, especially since the Global Fund will continue to select the implementing entities in those countries. However, they “strongly support the commitment from the Secretariat to support transitions to country systems and for regular engagement around ASP progress, noting that all relevant national stakeholders (Ministries, CCM, and PRs) and accountability institutions must be engaged in this process.”
Given the ongoing funding constraints worldwide, is this a prudent disposal, especially considering that INGOs' management fees could be used as potential/ additional resources for grant implementation? These global financial constraints should serve as a call for greater country ownership and closer relations with National Supreme Audit Institutions.
Let’s wait and see…
