Because of reporting requirements that are too stringent and time consuming, some Global Fund principal recipients (PRs) have had to overhaul their organizations and have had to reject potential sub-recipients (SRs) who could not meet the reporting standards.
“PRs have regularly found that they spend more time writing and responding to requests for reports and [local fund agent] verifications than actually implementing their grants,” Barbara Rieckhoff, the co-chair of the Civil Society Principal Recipients Network, told Aidspan in an email.
Even among recipients who have the capacity to meet the requirements, some said as reporting obligations evolve they do not receive enough support from the Global Fund, and so the responsibility for figuring out how to integrate these changes falls to them.
Setting the reporting requirements
The Country Coordinating Mechanism nominates a PR during the process of drafting its concept note, but the work of the PR really begins in earnest after that concept note is approved and the grant-making process starts.
At that point, the PR is responsible for crafting or contributing to several tools that help set their later reporting requirements. This includes an implementation arrangements mapping that is essentially an overview, showing “who will be doing what, and with what portion of grant funds,” according to the Global Fund website. PRs must also construct a performance framework that outlines the indicators and targets to be achieved through the grant and details how the PR intends to collect, collate and analyze data from its programs.
PRs are also expected to submit a list of all the products they intend to purchase with the grant, a detailed budget and a dossier of basic information on their organization.
These tools are key components of a final grant, which the Grant Approval Committee reviews first before submitting it to the Global Fund Board for final authorization. It is then signed and a first disbursement is made to the PR, which is when the reporting process kicks in.
The reporting requirements
The specifics of the reports vary based on the tools a PR developed during the grant-making process, but the basic requirements are fairly consistent. A PR is usually obligated to report every six months on the progress made toward the targets that were laid out in the performance framework, to elaborate on its procurement and supply management process and to offer an overall self-evaluation of the grant’s performance.
A PR must also include a detailed evaluation of its financial performance and needs and when the grant is still ongoing, it must also identify cash needs for the next year of implementation.
“The Global Fund has an obligation to all stakeholders to report about impact as extensively as possible,” said Seth Faison, the head of communications at the Global Fund. “That often requires every PR to submit significant amounts of data.” Some PRs complain, though, that the amount is simply too much.
Mokhothu Makhalanyane is the deputy coordinator of the Global Fund Coordinating Unit in Lesotho’s ministry of finance. The ministry is the PR for three active grants, according to the Global Fund database.
“The reporting requirements for the Global Fund, I think they are too much,” he said, comparing them to other grants he has worked on for organizations and companies including the World Bank, Irish Aid, and Bristol-Myers Squibb. The reports “are so time consuming. I would not say they are meant for the countries which are still developing their capacity.”
This is especially true, he said, in working with SRs to collect the performance and financial information necessary for the reports. In some communities, the ministry has failed to identify SRs that can implement programs, because there is simply not the infrastructure in place to provide the documentation, like receipts, needed to meet the Global Fund’s standards.
During a recent visit from Global Fund officials, he was able to show them some of the reporting challenges his team faces and is hopeful that might prompt some change.
In the past, the National Emergency Response Council on HIV and AIDS (NERCHA) in Swaziland has also had some challenges keeping up with the Global Fund reporting requirements. Dumisani Kunene, the director of financial services, said in 2011 NERCHA had to establish a separate Grants Management Unit because the Global Fund requirements threatened to overwhelm the organization’s general program coordination team.
They have also received money from the Global Fund, itself, to overhaul their accounting and reporting system. Faison said this is in line with a broader Global Fund effort to hold in-country trainings on reporting requirements and to fund capacity-building efforts and strengthen monitoring and evaluation systems.
NERCHA is now easily able to manage its grants, but Kunene said his team still has an obligation to stay on top of and then prepare for any new requirements. That includes recently introduced obligations to report on program activities that, while not paid for by the Global Fund, are necessary for the successful implementation of Global Fund grants. As an example, he pointed to a new malaria insectary that is currently under construction. The Global Fund is paying to procure commodities and equipment, but Swaziland’s government is funding the building’s actual construction. Nevertheless, NERCHA was obligated to report on the process of finding a site, the appointment of designers and approval of design plans and the commissioning of the insectary.
The requirements are important, Kunene said, “as it gives a clear picture of what caused delays in implementation,” but he worried the additional work could strain a PR’s resources.
This underscores one of the major concerns for Rieckhoff, the co-chair of the civil society group – that while the Global Fund does offer capacity building assistance, it is not enough and it is often not rolled out in tandem with new reporting requirements.
Her solution? “Prevention is the best cure!” she wrote. “In other words, investing a bit more time up front with PRs (especially those that are new or are smaller, national-level NGOs) to ensure they understand and can fulfill adequately the reporting requirements.”