GAO-22-104431, COVID-19: Better USAID Documentation and More-Frequent Reporting Could Enhance Monitoring of Humanitarian Efforts
- Issuer
- Government Accountability Office
- Document type
- Report
- Date
- 2022-01-26
Summary
GAO-22-104431, a U.S. Government Accountability Office report to congressional addressees dated January 26, 2022, on how the Department of State and USAID monitored humanitarian assistance funded by $908 million in fiscal year 2020 COVID-19 supplemental appropriations. GAO reports that both agencies shifted to remote monitoring, that State consistently documented oversight of two NGO awards reviewed, and that USAID did not consistently document field-level oversight of five NGO awards. It reports that USAID reverted from monthly to semiannual reporting for new awards in March 2021 without fully assessing the trade-offs. GAO recommends that USAID communicate expectations for documenting field-level oversight and assess the trade-offs of more-frequent reporting, and USAID concurred.
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United States Government Accountability Office
Report to Congressional Addressees
COVID-19
January 2022
Better USAID
Documentation and
More-Frequent
Reporting Could
Enhance Monitoring
of Humanitarian
Efforts
GAO-22-104431
January 2022
COVID-19
Better USAID Documentation and More-Frequent
Reporting Could Enhance Monitoring of Humanitarian
Highlights of GAO-22-104431, a report to
Efforts
congressional addressees
Why GAO Did This Study What GAO Found
The COVID-19 pandemic has created The Department of State (State) and the U.S. Agency for International
new humanitarian needs and Development (USAID) shifted to remote monitoring of their humanitarian
exacerbated existing vulnerabilities assistance awards in response to COVID-19, but USAID documented field-level
around the world. In response to the oversight inconsistently. State and USAID officials reported using technology,
pandemic, Congress appropriated and such as video conferencing, to communicate with agency staff and with
State and USAID obligated $908 organizations implementing the awards but generally ceased in-person meetings
million in supplemental funding in fiscal as well as site visits by headquarters-based staff. State used a standardized
year 2020 for international template to consistently document oversight of two nongovernmental
humanitarian assistance activities.
organization (NGO) awards GAO reviewed. However, USAID did not consistently
The CARES Act includes a provision document field-level oversight of five NGO awards GAO reviewed. USAID staff
for GAO to monitor the federal were either unaware of the relevant guidance on field-level oversight or believed
government’s efforts to respond to the it was no longer in effect. Communicating to staff the expectations for
COVID-19 pandemic. This report documentation would help USAID preserve institutional knowledge and ensure
examines how State and USAID management has information needed to make programming decisions.
adapted their monitoring of
humanitarian assistance activities USAID required implementers using fiscal year 2020 COVID-19 supplemental
supported by COVID-19 supplemental funds to submit monthly reports, which contributed to lessons learned and
funding. This report also describes how informed headquarters staff. In March 2021, USAID reverted to semiannual
implementing organizations adapted reporting for new awards but did not fully assess the trade-offs of doing so. Such
their projects to the COVID-19 context an assessment could help USAID weigh competing factors, such as increased
and the challenges they faced. risks while monitoring remains curtailed by the pandemic versus the burden
GAO reviewed State and USAID
placed on implementing organizations by more frequent reporting.
planning, funding, and guidance Organizations implementing State and USAID humanitarian assistance awards
documents and interviewed officials; adapted to COVID-19 chiefly through low-tech remote solutions and faced
obtained data on all humanitarian implementation and monitoring challenges. These adaptations included (1)
assistance awards funded from increased use of social distancing and personal protective equipment (see
COVID-19 fiscal year 2020 figure), (2) teleconferences or video conferences instead of in-person meetings,
supplemental appropriations. GAO and (3) increased use of remote tools, such as telephone surveys. Implementers
also reviewed relevant documents for a
faced related procurement, technology, and logistics challenges, which delayed
nongeneralizable sample of 12 awards
program implementation.
(seven to NGOs, five to public
international organizations), selected Masked and Socially Distanced Humanitarian Assistance Training in Honduras
on the basis of factors such as
geographic representation and type of
implementer.
What GAO Recommends
GAO recommends USAID better
communicate expectations for
documentation of field-level oversight,
and assess the tradeoffs of more-
frequent reporting. USAID concurred
with the recommendations.
View GAO-22-104431. For more information,
contact Chelsa Kenney at (202) 512-2964 or
kenneyc@gao.gov.
United States Government Accountability Office
Contents
Letter 1
Background 4
Agencies Shifted to Remote Monitoring, but USAID Documented
Oversight Inconsistently and Ended Beneficial Monthly
Reporting 8
Implementers Adapted to COVID-19 Chiefly through Low-
Technology Remote Solutions and Faced Implementation and
Monitoring Challenges 19
Conclusions 26
Recommendations for Executive Action 27
Agency Comments 27
Appendix I Objectives, Scope, and Methodology 31
Appendix II Comments from the U.S. Agency for International Development 33
Appendix III GAO Contact and Staff Acknowledgments 37
Tables
Table 1: USAID Obligations of Supplemental International
Disaster Assistance Funding, by Programming Sector,
Fiscal Year 2020 6
Table 2: USAID Bureau for Humanitarian Assistance’s Mandatory
Indicators for COVID-19 Awards of International Disaster
Assistance Funding, by Activity 10
Figures
Figure 1: Socially Distanced Cash Distribution in South Sudan 21
Figure 2: Murals on COVID-19 Prevention in South Sudan 22
Figure 3: Volunteer Training in Honduras Using Personal
Protective Equipment and Social Distancing 24
Figure 4: Examples of Emergency Relief Supplies Provided by
USAID 26
Page i GAO-22-104431 CARES Act Humanitarian Assistance
Abbreviations
AOR agreement officer’s representative
ARPA American Rescue Plan Act of 2021
BHA Bureau for Humanitarian Assistance
COVID-19 Coronavirus Disease 2019
FFP Office of Food for Peace
IDA International Disaster Assistance
MPR monitoring plan and report
NGO nongovernmental organization
OFDA Office of U.S. Foreign Disaster Assistance
OIG Office of Inspector General
PIO public international organization
PPE personal protective equipment
PRM Bureau of Population, Refugees, and Migration
State Department of State
UN United Nations
USAID U.S. Agency for International Development
WASH Water, Sanitation, and Hygiene
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Page ii GAO-22-104431 CARES Act Humanitarian Assistance
Letter
441 G St. N.W.
Washington, DC 20548
January 26, 2022
Congressional Addressees
The Coronavirus Disease 2019 (COVID-19) pandemic has created new
humanitarian needs and exacerbated existing vulnerabilities around the
world. The United Nations (UN) estimates that over 270 million people
worldwide suffered acute food insecurity by the end of 2020—an increase
from 149 million before the COVID-19 pandemic. The UN also estimated
there were more than 82 million forcibly displaced people as of the end of
2020, with those numbers expected to continue rising. Further, worldwide
economic contractions resulting from the pandemic brought about the first
increase in extreme poverty since 1998.
Congress appropriated $908 million in supplemental funding in fiscal year
2020 for international humanitarian assistance activities. 1 Specifically, the
Coronavirus Preparedness and Response Supplemental Appropriations
Act and the CARES Act provided $350 million for Migration and Refugee
Assistance programming, managed by the Department of State’s (State)
Bureau of Population, Refugees, and Migration (PRM). The acts also
provided $558 million for International Disaster Assistance (IDA)
programming, which is managed by the U.S. Agency for International
Development’s (USAID) Bureau for Humanitarian Assistance (BHA). 2
The CARES Act includes a provision for us to monitor and oversee the
federal government’s efforts to prepare for, respond to, and recover from
1The Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020,
and the CARES Act appropriated about $2.3 billion for diplomatic and foreign assistance
programming administered by State and USAID, to respond to COVID-19 abroad. This
supplemental funding included $908 million appropriated to the International Disaster
Assistance account and the Migration and Refugee Assistance account. See Pub. L. No.
116-123, tit. IV, 134 Stat. at 153; Pub. L. No. 116-136, div. B, tit. XI, 134 Stat. at 590.
2In March 2021, the American Rescue Plan Act of 2021 (ARPA) appropriated funds for
global response and humanitarian response. See Pub. L. No. 117-2, tit. X, §§ 10003-04,
135 Stat. at 239. According to State officials, all $500 million appropriated for humanitarian
response went to the Migration and Refugee Assistance account. According to USAID
officials, BHA was allocated $1.3 billion of the $3.09 billion that the ARPA appropriated for
global response. Discussion of funding in this report does not include the funds
appropriated by the ARPA.
Page 1 GAO-22-104431 CARES Act Humanitarian Assistance
COVID-19. 3 This report (1) examines how State and USAID adapted
program monitoring for humanitarian assistance activities supported by
supplemental funding in response to the COVID-19 pandemic and (2)
describes efforts that organizations implementing this funding made to
adapt their projects to conditions during the pandemic as well as the
challenges these implementers faced.
To address both of these objectives, we obtained information from
agency planning, funding, and guidance documents and interviewed
officials at State and USAID. 4 We obtained financial data on all
humanitarian assistance awards funded from the Coronavirus
Preparedness and Response Supplemental Appropriations Act and the
CARES Act. 5 From this universe of 209 awards, we selected a
nongeneralizable sample of 12 awards to nongovernmental organizations
(NGO) and public international organizations (PIO)—three awards
provided by State (two NGO awards and one PIO award) and nine
awards provided by USAID (five NGO awards and four PIO awards). 6
In selecting these awards, we used a mixture of random and judgmental
sampling to maximize coverage of features such as geographic
representation, implementation by NGOs and PIOs, permissive and
nonpermissive environments before the pandemic’s onset, obligation
3Pub. L. No. 116-136, div. B, § 19010. We regularly issue government-wide reports on the
federal response to COVID-19. For the latest report, see GAO, COVID-19: Additional
Actions Needed to Improve Accountability and Program Effectiveness of Federal
Response, GAO-22-105051 (Washington, D.C.: Oct. 27, 2021).
4We evaluated each agency according to its own policies and requirements.
5We obtained these data from State’s State Assistance Management System and
USAID’s Phoenix database. To assess the data’s reliability, we reviewed agency
responses to questions about data reliability, noting the specific tagging required for
COVID-19-supplemental funding. We also compared the data we received with the data
State and USAID reported to Congress and with original approval documentation. We
found that the data we received were sufficiently reliable for describing obligation and
programming information for COVID-19 supplemental funding.
6In total, State obligated funding through 21 awards and USAID obligated funding through
188 awards.
Page 2 GAO-22-104431 CARES Act Humanitarian Assistance
amounts, and program sectors. 7 We selected more NGO awards than
PIO awards because State and USAID generally impose fewer
programmatic monitoring requirements on PIOs than on NGOs. 8
Accordingly, we focused on NGO awards when evaluating agency
monitoring practices. For implementer adaptations to COVID-19, we
looked at both NGO and PIO awards.
For each award, we examined relevant award file documents, including
implementer reporting and agency oversight documentation. We
compared this documentation with agency policies and standards. We
determined that standards for internal control related to identifying,
analyzing, and responding to significant changes that could affect the
internal control system were relevant to our audit objectives. 9 We also
interviewed field-level USAID and implementer officials for three of the
awards. As part of this work, we reported in March 2021 on State’s and
USAID’s obligations of COVID-19 supplemental funding, including policy
changes that delayed USAID’s obligations. 10 For a more detailed
description of our scope and methodology, see appendix I.
We conducted this performance audit from July 2020 to January 2022 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
7USAID defines nonpermissive environments as contexts, at the national or subnational
level, in which uncertainty, instability, inaccessibility, or insecurity constrains USAID's
ability to operate safely and effectively. According to USAID, the vast majority of the
countries in which USAID provides humanitarian assistance have experienced some
degree of nonpermissiveness over the last 20 years, with backsliding, dramatic
downturns, and disruptive shocks not uncommon.
8According to Automated Directives System (ADS) 308.3.1, as a result of their
intergovernmental composition, PIOs are not generally subject to U.S. laws or business
standards.
9GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: September 2014).
10GAO, COVID-19: Sustained Federal Action Is Crucial as Pandemic Enters Its Second
Year, GAO-21-387 (Washington, D.C.: Mar. 31, 2021).
Page 3 GAO-22-104431 CARES Act Humanitarian Assistance
Background
Humanitarian Impact of The COVID-19 pandemic dramatically increased the need for
COVID-19 humanitarian assistance throughout the world. Humanitarian assistance—
including the provision of food, water, shelter, emergency health care,
support for sanitation and hygiene, and critical nutrition services—is
directed to the world’s vulnerable populations. These populations—
including refugees, conflict victims, internally displaced persons, stateless
populations, and vulnerable migrants—can be highly vulnerable to
COVID-19 because of their reduced access to health care and, often,
their location in congested areas such as refugee camps.
The UN estimated that 235 million people worldwide—one in 33 people
globally—would require humanitarian assistance and protection in 2021.
This represents an increase from the estimate for 2020—one in 45 people
globally—which was the highest in decades. Additionally, the global
recession that resulted from the pandemic deepened humanitarian needs
across the globe. The UN reported, “For the first time since the 1990s,
extreme poverty will increase. Life expectancy will fall. The annual death
toll from HIV, tuberculosis and malaria is set to double. We fear a near
doubling in the number of people facing starvation.” 11
State and USAID Within State, PRM manages humanitarian assistance funds in the
Humanitarian Response to Migration and Refugee Assistance account, to address the needs of
refugees and internally displaced persons. Within USAID, BHA manages
COVID-19
humanitarian assistance funds in the IDA account, to provide relief and
rehabilitation to victims of human-induced and natural disasters. 12 State
and USAID provide humanitarian assistance through funding awards to
implementers, including NGOs and PIOs such as UN organizations.
In March 2021, we reported that State and USAID had fully obligated the
fiscal year 2020 supplemental funding allocated to the Migration and
Refugee Assistance and IDA accounts, respectively, by August 2020. 13
11United Nations, Office for the Coordination of Humanitarian Affairs, Global Humanitarian
Overview, 2021 (Geneva: Dec. 10, 2020).
12USAID established BHA in 2020, consolidating the former Office of U.S. Foreign
Disaster Assistance and Office of Food for Peace.
13GAO-21-387.
Page 4 GAO-22-104431 CARES Act Humanitarian Assistance
State funding and activities. According to State data, State obligated
the $350 million in supplemental Migration and Refugee Assistance
funding through 21 awards for programs in 68 countries. State data show
that the vast majority of PRM’s supplemental funding (about $339 million,
or 97 percent) were voluntary contributions to PIOs. 14 According to PRM,
the remaining funding (about $11 million, or 3 percent) went primarily to
NGOs with which PRM had preexisting programs.
Because voluntary contributions to PIOs support multisectoral activities
and are designed to provide flexibility to the organizations, PRM officials
said it is not possible to itemize the humanitarian assistance obligations
by programming sector. However, according to PRM, its awards
supported humanitarian partners as they pivoted to undertake COVID-19
prevention, mitigation, and response measures on behalf of PRM’s
populations of concern—refugees, conflict victims, internally displaced
persons, stateless populations, and vulnerable migrants. PRM funding
also supported broader community and national public health systems’
pandemic responses.
USAID funding and activities. According to USAID data, USAID
obligated the $558 million in supplemental IDA funding through 188
awards in 43 countries. USAID data show that PIOs received the majority
of BHA’s supplemental funding (about $339 million, or 61 percent) and
NGOs received the remaining funding (about $219 million, or 39 percent).
According to USAID data and officials, initial programming primarily
focused on augmenting ongoing health interventions and providing water,
sanitation, and hygiene support to mitigate widespread transmission of
COVID-19, address public health consequences, and maintain essential
health services for crisis-affected populations. Subsequent programming
aimed to address the pandemic’s longer-term food-security and economic
impacts in humanitarian settings to prevent a further deterioration of
preexisting crises, according to USAID data and officials.
14According to State guidance, voluntary contributions are discretionary financial
assistance provided to public international organizations, among other institutions, which
are meant to directly support the activities of the organization or to sustain its general
budget and operations. While the funds may be used to advance specific activities and
goals of the U.S. government, the central purpose of the funds is to enable the recipient to
carry out its activities. According to State officials, this means that generally U.S. voluntary
contributions cannot be traced to specific activities within a given country, since the
funding is pooled with resources from other donor countries.
Page 5 GAO-22-104431 CARES Act Humanitarian Assistance
Table 1 shows USAID’s total obligations of fiscal year 2020 supplemental
funding for humanitarian assistance, by programming sector.
Table 1: USAID Obligations of Supplemental International Disaster Assistance
Funding, by Programming Sector, Fiscal Year 2020
Total obligated,
Sector in dollars
Nutrition and Food Assistance 189,342,490
Health 136,890,850
Water, Sanitation, and Hygiene 115,270,666
Logistics 59,863,966
Protectiona 23,568,653
Multipurpose Cash Assistance 13,734,813
Humanitarian Coordination and Information Management 8,719,255
Agriculture and Food Security 5,218,735
Humanitarian Policy, Studies, Analysis, or Applications 1,644,836
Shelter and Settlements 1,564,664
Economic Recovery and Market Systems 1,490,034
Risk Management Policy and Practice 691,038
Total 558,000,000
Source: GAO analysis of U.S. Agency for International Development (USAID) data. | GAO-22-104431
a
USAID defines protection programming as activities that support the needs of vulnerable populations
such as women, children, persons with disabilities, and elderly-headed households.
State and USAID Monitoring—the ongoing and systematic tracking of data and information
Monitoring Practices relevant to policies, strategies, programs, projects, or activities—is used
to determine whether desired results are occurring as expected during
program, project, or activity implementation. Monitoring often relies on
indicators—that is, quantifiable measures of a characteristic or condition
of people, institutions, systems, or processes that may change over time.
Data collected through monitoring can be used to make programmatic
adaptations, support program evaluations, and contribute to the
development of lessons learned.
State and USAID both designate agency personnel to be responsible for
monitoring their respective awards. For State PRM awards, a
Washington, D.C.–based program officer conducts oversight in concert
with field-based refugee coordinators, acting as the grant officer’s
representative for the awards. Similarly, for USAID BHA awards, a
Washington, D.C.–based agreement officer’s representative (AOR) is
Page 6 GAO-22-104431 CARES Act Humanitarian Assistance
responsible for providing programmatic and administrative oversight.
AOR duties include conducting site visits and communicating with
implementing partners as well as reviewing reports and monitoring
compliance with reporting requirements. Activity managers based in
Washington or the field can provide support to the AOR in performing
monitoring functions—for example, collaborating with the AOR to conduct
site visits, verify monitoring data, conduct data-quality assessments, and
upload required documentation to the official award file.
State and USAID incorporate monitoring requirements into their awards.
For NGO awards, both PRM and BHA typically require quarterly financial
reports as well as periodic progress reports. In general, while PRM and
BHA apply reporting requirements to their PIO awards, they do not
require the same level or frequency of programmatic reporting from PIOs
as they do from NGOs. PRM monitors PIO awards differently than NGO
awards because its PIO awards are voluntary contributions (i.e., awards
of discretionary financial assistance). Because U.S. voluntary
contributions to PIOs are often combined with contributions from other
donors for very large global or regional projects, they generally cannot be
traced to specific activities in a given country, according to State officials.
Similarly, although PIOs that receive BHA awards are required to provide
quarterly and final financial reports and biannual program performance
reports, BHA does not require the same level or frequency of
programmatic reporting from PIOs as it does from NGOs.
For PIO oversight more broadly, both PRM and BHA engage with these
organizations at multiple levels. For example, PRM and BHA officials
participate in PIOs’ executive boards and engage frequently with
humanitarian organizations’ governing bodies and headquarters staff at
U.S. missions in Geneva, New York, and Rome as well as with European
Union counterparts in Brussels.
The COVID-19 pandemic substantially affected U.S. agencies’ and their
implementing partners’ ability to conduct project monitoring. According to
the USAID Office of Inspector General (OIG), by October 2020, over 90
percent of USAID missions reported that their capability to monitor foreign
assistance programs was reduced or significantly restricted because of
the impacts of COVID-19. 15 In recent analyses, USAID has also noted
that the operational adjustments that it and its implementing partners
15U.S. Agency for International Development, Office of Inspector General, USAID Adapted
to Continue Program Monitoring during COVID-19, but the Effectiveness of These Efforts
Is Still to Be Determined, Audit Report 9-000-21-007-P (Washington, D.C.: May 21, 2021).
Page 7 GAO-22-104431 CARES Act Humanitarian Assistance
have made in response to the pandemic have limited their ability to
monitor programs as they normally would and have increased program
risks.
Agencies Shifted to
Remote Monitoring,
but USAID
Documented
Oversight
Inconsistently and
Ended Beneficial
Monthly Reporting
State Relied on Existing State relied on preexisting processes and requirements to program and
Requirements, while implement COVID-19 supplemental funding, while USAID issued new,
COVID-19-specific requirements to NGO implementers.
USAID Issued New
Pandemic-Specific State’s process and requirements for COVID-19 supplemental
Requirements to funding. State programmed supplemental Migration and Refugee
Implementers Assistance funding through PRM’s Policy and Program Review
Committee process—a preexisting, PRM-specific process that seeks to
engage bureau-level stakeholders in strategy and funding decisions.
According to PRM, the process includes specific procedures for
emergency response. For COVID-19 supplemental funding, the
committee approved 11 funding memorandums, each detailing proposed
implementers, programming, and monitoring approaches, including how
the implementer’s program would respond to COVID-19. PRM did not
issue new guidance or requirements to its PIO or NGO implementers for
adapting to COVID-19 and instead relied on its preexisting internal
controls, such as required risk assessments, to identify and address
COVID-19-related risks.
USAID’s process and requirements for COVID-19 supplemental
funding. USAID programmed COVID-19 supplemental funding through a
new, centralized process unique to this funding. Concurrently, BHA
issued new risk assessment and reporting requirements to its NGO
Page 8 GAO-22-104431 CARES Act Humanitarian Assistance
implementers. 16 BHA required NGOs receiving fiscal year 2020 COVID-
19 supplemental funding to include risk-mitigation measures for the
pandemic in their award applications’ safety and security plans. These
plans were to describe in detail how emergency medical care and
evacuation would be executed from all of the proposed activity locations
in light of border closures and limitations in air travel and local medical
care capacity and capability. BHA also recommended that applications
include monitoring practices appropriately adapted for staff and
beneficiary safety, including data collection safety and security protocols.
Further, BHA established a monthly reporting requirement for NGO
implementers receiving fiscal year 2020 COVID-19 IDA supplemental
funding. Specifically, the additional reporting required implementers to
provide updates of applicable COVID-19 mandatory indicators through
USAID’s online reporting tools. These mandatory indicators included
several new indicators as well as preexisting standard indicators required
by the Office of U.S. Foreign Disaster Assistance (OFDA) and the Office
of Food for Peace (FFP)—predecessors to BHA. 17 While NGOs were
required to update these indicators monthly, their monitoring and
evaluation plans that we examined also included various other indicators
to be addressed in semiannual and final reports. 18 Table 2 lists BHA’s
mandatory COVID-19 indicators for NGOs.
16U.S. Agency for International Development, USAID/Bureau for Humanitarian Assistance
Interim Guidance for Applicants Engaging in COVID-19 Humanitarian Response (June 11,
2020).
17In June 2020, USAID created BHA by consolidating OFDA and FFP into a single
bureau.
18According to BHA documentation, PIOs were requested, but not required, to report
monthly on the COVID-19 mandatory indicators for NGOs.
Page 9 GAO-22-104431 CARES Act Humanitarian Assistance
Table 2: USAID Bureau for Humanitarian Assistance’s Mandatory Indicators for COVID-19 Awards of International Disaster
Assistance Funding, by Activity
Category Indicator New or preexisting
Non-food assistance
Health, Public Health Emergency of Number of outpatient health facilities supported New
International Concern
Health, Public Health Emergency of Number of inpatient health facilities supported New
International Concern
Health, Public Health Emergency of Number of hospitalizations New
International Concern
Health, Public Health Emergency of Number of individuals screened or triaged for COVID-19 New
International Concern at supported health facilities
Health, Public Health Emergency of Number of people reached through risk communication New
International Concern activities by channel
Health, Public Health Emergency of Number of health care staff trained Preexisting
International Concern
Protection, Psychosocial Support Services Number of individuals participating in psychosocial Preexisting
support services
Protection, Child Protection Number of individuals participating in child protection Preexisting
services
Protection, Gender-Based Violence Number of individuals accessing gender-based violence Preexisting
response services
Protection, coordination, advocacy, and Number of individuals trained in protection Preexisting
information
Water, Sanitation, and Hygiene (WASH) Non- Total number of people receiving WASH non-food items Preexisting
Food Items through all modalities.
Food assistance
Food assistancea Number of individuals participating in U.S. food security Preexisting
programs
Local, Regional, and International Quantity distributed (metric tons), by commodity Preexisting
Procurement Commodity
Local, Regional, and International Number of unique participants receiving in-kind food Preexisting
Procurement Commodity
Cash Transfers and Food Vouchers Total amount distributed (US$), by modality (cash and Preexisting
voucher)
Cash Transfers and Food Vouchers Number of unique participants receiving support, per Preexisting
modality (cash and voucher)
WASH Non-Food Items Total number of people receiving WASH non-food items Preexisting
through all modalities
Source: U.S. Agency for International Development (USAID). | GAO-22-104431
a
The USAID/Bureau for Humanitarian Assistance Interim Guidance for Applicants Engaging in
COVID-19 Humanitarian Response, June 11, 2020, named this category “E1”. According to BHA, this
label was from a legacy indicator list. For clarity, we have named it food assistance.
Page 10 GAO-22-104431 CARES Act Humanitarian Assistance
In addition, BHA required NGO implementers to submit monthly, two-
page maximum narrative summaries of any recent challenges or
successes as well as activities the implementer planned to prioritize for
the next month. 19
USAID issued guidance to implementers that addressed various
considerations and potential tools for remote monitoring. 20 For example,
in areas with sufficient mobile coverage and phone ownership,
implementers could consider gathering data through text messaging,
phone surveys, or computer-assisted phone interviewing. Similarly, the
guidance suggested web surveys and mobile apps could be used in
areas with sufficient internet connectivity. In addition, the guidance
discussed potential application of geospatial tools, such as satellite
imagery, in contexts where changes in the physical landscape at the
location of USAID activities were particularly relevant.
State and USAID Shifted After the pandemic began, PRM and BHA shifted to remote monitoring of
to Remote Monitoring of awards implemented by partners. To facilitate this transition, both PRM
and BHA issued guidance to their staff on potential adjustments to
Implementer Activities operations during the COVID-19 pandemic. 21 This guidance included
recommendations for adjusting monitoring of implementers. For example,
the BHA guidance stated that a “do no harm” approach should be
prioritized, and the PRM guidance reminded staff to keep the “do no
harm” principle in mind in their monitoring. 22 Both sets of guidance
recommended alternative oversight activities for agency staff as well as
potential adaptations to implementers’ data collection tools. The agencies’
guidance also recommended against any activities that could endanger
the health of implementers’ staff or program beneficiaries.
19According to BHA documentation, although PIO partners were exempt from these
requirements, they were encouraged to submit monthly updates.
20U.S. Agency for International Development, Guide for Adopting Remote Monitoring
Approaches during COVID-19 (May 2020).
21Department of State, PRM Program Monitoring during COVID; U.S. Agency for
International Development, Adaptations to Partner M&E for Humanitarian Assistance
Activities due to COVID-19—Guidance to AORs and Program Staff for OFDA/FFP
Partners.
22“Do no harm” is a general principle whereby actors endeavor not to cause further
damage and suffering as a result of their actions.
Page 11 GAO-22-104431 CARES Act Humanitarian Assistance
In practice, PRM and BHA officials’ remote monitoring generally involved
greater use of video conference software as well as continued use of
phone and email communications, according to officials we contacted.
The officials told us that because of agency restrictions on travel due to
the COVID-19 pandemic, in-person meetings generally ceased and site
visits by AORs and other headquarters staff were put on hold.
Headquarters staff stated that because most monitoring interaction with
implementers occurs in the field, remote monitoring did not significantly
change their level of contact with field staff and implementers, apart from
the cancellation of in-country site visits. 23
Field-level oversight of implementing partners initially shifted largely to
remote monitoring, particularly in countries where either the host
government or the U.S. embassy restricted movement. In the interim, field
staff continued reviewing progress reports and holding conference calls
with implementing partners. Some field-level site visits by agency staff
resumed later where local context allowed. However, both PRM and BHA
officials stated that conducting such site visits remained challenging. In-
person site visits by BHA-funded third-party monitoring firms were also
initially suspended.
State Consistently PRM consistently documented field-level oversight activities for its NGO
Documented Field-Level awards that we reviewed, but BHA did not. To examine agency
monitoring practices during the pandemic, we examined award file
Oversight of NGO Awards
documentation for two PRM and five BHA awards to NGO
We Reviewed, but implementers. 24 We focused our analysis on oversight activities
USAID’s Documentation conducted by agency personnel in the field, because according to agency
Was Inconsistent officials, primary oversight takes place in the field, particularly during the
pandemic when travel from headquarters to the field was curtailed. Both
agencies’ award files consistently documented award modifications, such
as the granting of a no-cost extension, and generally included required
reports from implementing partners.
23According to BHA, AORs may be unable to monitor activities in person in complex
operating environments where there are security and access constraints. Officials said
these constraints to in-person monitoring are not exclusively a result of the pandemic. To
mitigate constraints in conducting field-based oversight activities, BHA may utilize third-
party monitoring mechanisms to assist AORs in fulfilling field-based oversight activities.
24We also reviewed one PRM award and four BHA awards to PIOs. However, we did not
include them in our analysis of agency monitoring practices during the pandemic because
the oversight context differs for PIO awards and because State and USAID place fewer
programmatic monitoring requirements on PIO awards.
Page 12 GAO-22-104431 CARES Act Humanitarian Assistance
Both of the PRM NGO award files we examined contained a monitoring
plan and report (MPR), which PRM uses to document its oversight for all
PRM NGO awards. The MPR is a standard template that lays out basic
expectations of the grants officer’s representative regarding monitoring
and is to be filled in by PRM staff as they complete oversight activities.
For example, the MPR contains specific sections for documenting receipt
and review of quarterly project and financial reports, notation of site visits,
and monitoring observations by headquarters and field staff. The template
also contains guidance on timelines, suggested content, and supporting
documentation. According to PRM officials, the MPR serves as a “one
stop shop” summarizing all required monitoring of an NGO award and is
part of the official award file.
Both PRM NGO award files we examined contained documentation of
field-level oversight activities, such as PRM monitoring plans,
implementer meeting notes, email correspondence, and notation of site
visits in the MPR. For example, one award’s MPR noted two site visits
conducted by a PRM-funded third-party monitor; the MPR also included
meeting notes and email exchanges with the implementer that addressed
implementation delays and the need for a no-cost extension. The other
award’s MPR explicitly ruled out site visits for the award because of
movement restrictions related to insecurity and the pandemic. That MPR
also contained updates from the refugee coordinator in the country as
well as progress evaluations from the program officer.
Our review of BHA documentation of field-level oversight activities
identified inconsistency in the documentation for NGO awards.
Specifically:
• The official award files for two of the five USAID NGO awards we
reviewed contained no documentation of field-level oversight.
• The contents of the other three files ranged from two email updates
from the field to extensive field-level materials, including field-based
implementer presentations and meeting or call notes.
• None of the five awards’ official files contained documentation of any
field-level site visits. 25
25Because all site visits by Washington-based BHA staff were put on hold, none of the
award files for the five NGO awards we reviewed contained records of AOR site visits.
Page 13 GAO-22-104431 CARES Act Humanitarian Assistance
When we asked about field-level oversight, BHA staff in the field
subsequently confirmed that they had conducted site visits for three
awards and provided relevant documentation from informal files. 26
However, this documentation was also inconsistent. For one award, BHA
field staff documented their site visit with a full trip report. For another
award, the site visits were described in a larger email update. For the
third award, field staff noted that instead of recording site visit notes, they
orally informed Washington-based staff of the site visit through a phone
call. The staff provided us with related email correspondence with the
implementer regarding logistics and follow-up from the site visit.
Further, nearly all BHA AORs and field staff we spoke with were unaware
of—and therefore did not follow—applicable legacy guidance issued by
BHA’s predecessors, OFDA and FFP, relating to field-level site visit
documentation. The USAID OIG had previously identified similar issues.
Specifically, in December 2015, a USAID OIG review of the agency’s
response to Ebola in Liberia identified weaknesses in documentation of
local site visits. 27 The OIG recommended that OFDA implement standard
operating procedures for sharing program information, including
documenting site visits and other efforts to verify program activities.
OFDA and FFP subsequently developed standardized guidance for field-
level site visits that included documentation standards. 28 Notably, this
legacy guidance includes documentation expectations. The legacy
guidance states, among other things, that “it is important to clearly and
systematically document” site visits and “it is also very important to file the
information in official files” to ensure successor staff have access to site
visit information.
However, when we initially inquired about BHA standards for
documentation of field-level oversight, BHA headquarters officials
responded that no such guidance existed and that they planned to
26BHA confirmed there were no site visits for one of the remaining two NGO awards. For
the other award, BHA clarified that a third-party monitor visited some sites as part of
oversight for a non-COVID BHA award. Furthermore, BHA determined that visiting other
sites would have been invasive and unsafe to both implementing partner and third-party
monitoring staff.
27U.S. Agency for International Development, Office of Inspector General, Audit of
Selected Ebola-Response Activities Managed by USAID’s Office of U.S. Foreign Disaster
Assistance In Liberia, Audit Report 7-669-16-002-P (Dakar, Senegal: Dec. 4, 2015).
28U.S. Agency for International Development, Monitoring, Evaluation, Accountability, and
Learning Policy, Guidance, and Tools; Annex 5: OFDA/FFP Site Visit Guidance
(November 2019).
Page 14 GAO-22-104431 CARES Act Humanitarian Assistance
develop such guidance in the future. In the interim, according to these
officials, BHA was identifying lessons learned from its first year of
operating as a consolidated bureau. Officials also said that, given the
effects of the COVID-19 pandemic on the bureau’s already complex
operating environments, BHA had prioritized the development of
guidance for implementing partners, such as the recommendations for
conducting remote monitoring, rather than in-person site visit guidance for
BHA staff.
Subsequently, one BHA field staff member informed us about the OFDA–
FFP legacy guidance, stating that it had once—but no longer—governed
field-level oversight. When we asked BHA headquarters officials about
the legacy guidance, they stated that all legacy guidance remains in effect
until BHA is able to develop new, updated tools and guidance. Further,
they stated that this legacy site-visit guidance represents best practices
and, although it is not considered an official requirement, staff should
follow it until it is superseded by updated BHA guidance.
However, BHA AORs and field staff we spoke with were not aware that
they were expected to follow this guidance. None of the BHA staff we
interviewed who were responsible for oversight of the awards we
reviewed identified the legacy guidance as current operating procedure.
In one case, BHA staff explicitly told us they believed the guidance was
defunct.
As a result, site visits for the awards we reviewed were not consistently
documented in accordance with the best practices outlined in the legacy
guidance. For example, one award lacked any site visit documentation,
and BHA field staff stated that they had provided only an oral report to the
headquarters-based AOR. In addition, although the legacy guidance
emphasizes the importance of saving these field-level site visit
documents in official files, none of the field-level site visits for the BHA
awards we reviewed were documented in the official award file. Because
they were unaware of this guidance, some AORs we interviewed said
that, absent clear expectations, documentation included in the official
award file depended primarily on the professional judgement of the AOR.
Both BHA’s standard AOR designation letter and the legacy OFDA–FFP
site-visit guidance emphasize the importance of documentation to ensure
that successor staff with field or headquarters oversight responsibilities
have full information about USAID’s oversight activities.
Ensuring that all staff are aware of their responsibilities to document field-
level oversight activities in official award files would help USAID preserve
Page 15 GAO-22-104431 CARES Act Humanitarian Assistance
institutional knowledge of actions taken to assure accountability, and
standardize the collection and documentation of field-oversight monitoring
reports. In addition, such documentation would ensure BHA management
has the information needed to assess program progress toward goals,
and make decisions about program direction and operation. This
information is especially significant in an emergency context such as the
COVID-19 pandemic, where programmatic responses must often be
rapidly adapted to unforeseen and changing circumstances. Furthermore,
in a context where normal oversight activities are curtailed—particularly
when AORs cannot conduct their own site visits—clear and consistent
documentation of field-level site visits and other oversight activities is
essential to ensure accountability for award funding.
Monthly Reporting We found that BHA’s monthly reporting requirement for NGOs
Enhanced Lessons- implementing awards of fiscal year 2020 COVID-19 IDA supplemental
funding produced several benefits. However, in March 2021 BHA decided
Learned Activities and
not to apply this requirement to awards of new COVID-19 relief funds.
Informed Staff, but USAID
Did Not Require It for The monthly indicator updates and narrative summaries enabled BHA to
Later Awards produce a series of summary and lessons-learned documents. According
to BHA, over time its monitoring and evaluation staff produced seven
overviews of COVID-19 award progress based on 8 months of NGO
reporting. These overviews generally summarized monthly indicator data
from all NGO awards and some PIO awards funded with fiscal year 2020
COVID-19 IDA supplemental funding. The intent of these monthly
overviews was to provide a comprehensive view of BHA’s COVID-19
response to date and of award implementation status. The overviews
generally contained monthly and cumulative BHA-wide indicator values
for targets related to all awards of fiscal year 2020 COVID-19 IDA
supplemental funding and included disaggregated data by activity and
geographic region. The overviews also contained more-detailed progress
information for several individual indicators, monthly reporting compliance
tables, and data quality updates.
In addition, the monthly reporting directly informed a lessons-learned
analysis of BHA Water, Sanitation, and Hygiene (WASH) programming
stemming from the COVID-19 IDA supplemental funding. This analysis
found that 42 percent of BHA’s implementing partners had not begun
distributing non-food items—essentially, hygiene kits—5 months after
their awards’ start dates. In addition, the analysis determined that,
because of the time required for internal BHA processing, even with
accelerated technical reviews, WASH kits may not have reached most
beneficiaries until 6 or more months after the need for emergency
Page 16 GAO-22-104431 CARES Act Humanitarian Assistance
assistance began. According to USAID, this delay was of particular
concern because generally in a rapid-onset response, material support
becomes less relevant for affected populations as more time passes.
According to BHA officials, the bureau incorporated these and other
lessons learned into subsequent programming of American Rescue Plan
Act of 2021 (ARPA) supplemental funding for the COVID-19 response.
Monthly reporting also increased BHA headquarters staff’s access to
information about award implementation. BHA AORs and Washington-
based staff assigned to oversee the three NGO awards for which we
conducted interviews stated that the monthly reports had provided useful
information. For example, Washington-based oversight staff assigned to
the Honduras award stated that although they normally would not
interface often with implementers absent a formal request (e.g., a request
for a no-cost extension), the monthly reports provided more real-time
visibility on implementation. For example, the monthly narratives
essentially telegraphed ahead of time the need for an upcoming no-cost
extension and for program adaptation due to hurricanes Eta and Iota.
According to BHA, the monthly reporting requirement was designed to
align with USAID’s monthly financial reporting requirements outlined in
the CARES Act. 29 When BHA adopted the requirement in spring 2020, it
anticipated the COVID-19 pandemic response to be acute and short-term,
and it intended to obligate COVID-19 supplemental funding through 6-
month awards to rapidly respond. BHA typically requires NGO
implementing partners to submit standard semiannual and final reports on
program progress and to also submit quarterly financial reports. 30 Monthly
reporting provided BHA information on implementation progress before
these 6-month awards ended. According to BHA, given the potential need
for more-frequent reporting, the absence of USAID Task Force or agency
29The CARES Act states that “[o]n a monthly basis until September 30, 2021, each
agency shall report to the Director of the Office of Management and Budget, the Bureau of
Fiscal Service in the Department of the Treasury, the Committee, and the appropriate
congressional committees on any obligation or expenditure of large covered funds,
including loans and awards.” Pub. L. No. 116-136, § 15011 (b)(1)(A).
30For example, in BHA NGO awards we examined, semiannual reports were due no later
than 30 days after the end of each of two 6-month, semi-annual reporting periods
(October 1–March 31 and April 1–September 30). The recipients had to provide a report
for the reporting period in which the award began, unless the performance start date was
within 60 days of the end of the reporting period. Results from the final period were to be
included in the final program results report no later than 90 days after the estimated
completion date.
Page 17 GAO-22-104431 CARES Act Humanitarian Assistance
guidance on exact reporting frequency, and the need for rapid obligation
of emergency funding, BHA decided to require monthly reporting for
selected mandatory COVID-19 indicators in key programming areas. BHA
reported that this increased the information available about the COVID-19
NGO awards while also aligning with USAID’s CARES Act monthly
financial reporting requirements.
Conversely, BHA did not require monthly reporting for NGOs
implementing awards of COVID-19 relief funding provided by the ARPA,
which was enacted in March 2021. 31 BHA officials cited several reasons
for reverting to standard reporting requirements for ARPA-funded awards.
First, according to the officials, the ARPA, unlike the CARES Act, did not
include a monthly financial reporting requirement for USAID. Second, the
officials said BHA was concerned that the monthly reporting requirement
might have been burdensome to implementers and affected populations.
Finally, according to BHA, USAID has also made commitments through
international donor coordination initiatives to harmonize and simplify
reporting requirements. 32
The implementer representatives we interviewed described varied
experiences with the monthly reporting requirement. One implementer
representative stated that the monthly reporting was not particularly
onerous, as the implementer typically prepared to report monthly to BHA
field staff regardless of the requirement. Representatives of the other two
implementers stated that the reporting itself was not necessarily onerous
but that unclear guidance from BHA made it more challenging. For
example, according to one representative, the implementer did not fully
understand the nature of the information needed in the monthly
narratives, the format required, or the purpose for which the information
would be used. BHA continues to require NGO implementing partners to
submit standard semiannual and final reports about program progress as
well as quarterly financial reports.
Before choosing not to apply monthly reporting requirements to ARPA-
funded awards, BHA officials did not fully assess the costs or benefits of
enhanced reporting given the limits to USAID’s monitoring capabilities
31Pub. L. No. 117-2, 135 Stat. 4.
32According to BHA officials, USAID has made commitments through international donor
coordination initiatives, including the Grand Bargain and the Good Humanitarian
Donorship Initiative, to improve the effectiveness and efficiency of humanitarian action—
specifically with respect to harmonizing and simplifying reporting requirements.
Page 18 GAO-22-104431 CARES Act Humanitarian Assistance
during COVID-19, which have continued well into 2021. According to
standards for internal control in the federal government, agency
management should identify, analyze, and respond to significant changes
that could affect the internal control system. 33 Such analysis includes
assessing whether existing controls are sufficient or additional controls
are needed in response to external changes, such as during the COVID-
19 pandemic. These standards also state that weighing both costs and
benefits can help management design and implement an effective internal
control system.
Thoroughly assessing the tradeoffs of requiring more-frequent NGO
reporting—particularly in a pandemic where normal monitoring, such as
site visits, is curtailed—could help BHA ensure it receives timely updates
on program implementation that would allow for rapid adaptation and real-
time analysis of lessons learned. USAID could use such an assessment
to weigh multiple factors—including the increased monitoring risks while
the COVID-19 pandemic persists as well as international donor
coordination initiatives to reduce reporting burdens—to determine the
most appropriate frequency of reporting. For example, USAID might
consider whether quarterly reporting would provide sufficient benefits to
balance the administrative burden placed on NGOs. Furthermore, such
an assessment could help determine whether specific program activities
or award types (e.g., 6-month awards) would particularly benefit from
more-frequent reporting than the semiannual reporting BHA currently
requires.
Implementers
Adapted to COVID-19
Chiefly through Low-
Technology Remote
Solutions and Faced
Implementation and
Monitoring
Challenges
33GAO-14-704G.
Page 19 GAO-22-104431 CARES Act Humanitarian Assistance
Implementer Adaptations Implementers for the 12 awards we reviewed largely relied on low-tech
to the COVID-19 remote solutions to adapt programming and monitoring in light of COVID-
19. Implementers we interviewed stated that such adaptations did not
Environment Largely Used
differ significantly from their typical programming and monitoring
Low-Technology Remote practices.
Solutions
Implementer adaptations for the awards we reviewed included (1)
increased use of social distancing and personal protective equipment
(PPE); (2) teleconferences or video conferences instead of in-person
gatherings; and (3) increased use of remote tools, such as telephone
surveys.
Social distancing and PPE. Almost all of the 12 implementers for the
awards we reviewed reported they had some COVID-19 protocols in
place for monitoring and implementation. The protocols that the
implementers used varied, but most incorporated social distancing or the
use of PPE into program implementation and monitoring. For example,
one implementer continued in-person household surveys but used masks,
gloves, and social distancing. Other implementers integrated social
distancing and handwashing into their distribution efforts. For a USAID
award in Honduras, implementer officials stated that instead of physically
inspecting handwashing stations in homes that received WASH kits,
monitoring staff stood outside the homes and asked residents to self-
report.
Page 20 GAO-22-104431 CARES Act Humanitarian Assistance
Figure 1: Socially Distanced Cash Distribution in South Sudan
Teleconferences and videoconferences in lieu of in-person
gatherings. Implementers used teleconferencing and videoconferencing
for meetings and training sessions that would typically be held in person.
Although implementer staff we interviewed said virtual training for
beneficiaries was somewhat less effective than in-person training, they
also reported benefits of virtual meetings and training sessions. For
example, implementer staff said virtual meetings enabled participation by
some beneficiaries who typically would not be able to attend in-person
sessions.
Remote tools. Implementers also shifted to using remote tools, such as
phone surveys and text messaging, to communicate, gather information,
and monitor projects. For example, for a State award in Afghanistan, the
implementer reported that it had prioritized the use of phone interviews
and substituted key informant interviews for focus groups. For a USAID
award in the Pacific Islands, the implementer reported that it had not
collected any in-person data for its baseline survey, in keeping with
USAID’s “do no harm” principle. Instead, the implementer conducted
remote interviews with key informants and leveraged a variety of
secondary data sources, including data collected for other projects. For a
USAID award in West Africa, the implementer reported that it had
solicited and received feedback from community members via online
platforms, national hotlines, and text messaging. Figure 2 shows another
Page 21 GAO-22-104431 CARES Act Humanitarian Assistance
type of remote tool used to communicate with local communities—murals
painted in South Sudan as part of one project’s community messaging
about how to prevent the spread of COVID-19.
Challenges Related to Implementers reported that challenges related to procuring PPE,
PPE Procurement, accessing technology, and moving staff and supplies within and between
countries during the COVID-19 pandemic delayed implementation and
Technology, and
made monitoring more difficult. Because of these types of challenges, the
Movement of Staff and implementers of all but two of the 12 awards we reviewed requested and
Supplies Delayed obtained no-cost extensions of their award agreements.
Implementation and Made
Monitoring More Difficult Challenges related to PPE procurement. In March 2021, we reported
that a policy decision restricting the use of USAID funds for procuring
Page 22 GAO-22-104431 CARES Act Humanitarian Assistance
PPE had delayed the obligation of BHA supplemental funding. 34 Our
review showed that this PPE-related prohibition also slowed project
implementation in some cases where implementers struggled to find PPE
manufacturers in the country or regionally. If there were no local or
regional manufacturers, implementers had to appeal to USAID to be
allowed to buy PPE for their beneficiaries.
For a USAID award in Syria, after attempting unsuccessfully to find PPE
in Syria or Turkey, the implementer purchased PPE on the international
market, where prices were higher, to avoid implementation delays. In
Honduras, project implementation was delayed while implementer staff
tried to identify local or regional sources of PPE for community volunteers
and beneficiaries. According to implementer documentation, when the
implementer was unable to identify local or regional PPE sources, it
requested a waiver from USAID’s PPE requirements. The implementer
reported that it received the waiver in October 2020, approximately 3
months after project implementation began. (Fig. 3 shows an example of
PPE in use on this project.)
34On March 20, 2020, the USAID COVID-19 Task Force notified BHA that no USAID
funds could be used to procure PPE. According to BHA officials, it was initially unclear
how to handle applications that had already been submitted with PPE components, which
constituted most applications. Specifically, the restriction notice did not specify which
types of PPE were covered or whether USAID would make exceptions for emergency
humanitarian programming. On June 9, 2020, the USAID COVID-19 Task Force approved
revised guidance on award language that loosened the restriction by allowing
procurement of PPE without prior USAID authorization under specified conditions. The
revised guidance allowed implementers to procure PPE from any source if it was to be
used by the implementers’ staff. However, any PPE intended for beneficiaries had to be
procured locally or not otherwise intended for the U.S. market.
Page 23 GAO-22-104431 CARES Act Humanitarian Assistance
Figure 3: Volunteer Training in Honduras Using Personal Protective Equipment and
Social Distancing
Challenges related to technology. Implementers reported that greater
use of technology presented challenges, even while it became
increasingly critical for operating in a COVID-19 environment. For
example, although video conference technology allowed greater access
to beneficiaries in Ukraine who would otherwise have been unreachable,
implementer representatives reported that they were not always able to
successfully use such technology because of spotty reception or internet
access. Additionally, some beneficiaries were not conversant in the
technology, requiring implementer staff to schedule in-person visits to
deliver training or help with technological challenges.
Implementers noted that using the telephone provided some access to
beneficiaries but also presented challenges. For example, for a USAID
award in South Sudan, implementers said that conducting interviews over
the phone worked fairly well in an urban setting where cell phone
ownership was relatively high. However, they reported encountering
difficulties such as lack of connectivity, incorrect phone numbers, loss of
battery power during interviews, and, in some cases, language barriers.
In Sierra Leone, cash transfers via cell phones to recipients in remote
areas were delayed because of challenges related to the use of special
cell-phone SIM cards for the cash transfers. In particular, fewer recipients
than expected owned cell phones, and some recipients lost their SIM
cards, necessitating reissuance of the SIM cards.
Page 24 GAO-22-104431 CARES Act Humanitarian Assistance
In general, implementers for the awards we reviewed did not use higher-
tech remote monitoring solutions such as virtual site visits or computer-
assisted surveys. Implementers we spoke with stated that many of these
options required reliable cell or high-speed internet service, which is often
not available in the places where disaster responses take place.
Challenges related to moving staff and supplies. Some
implementation challenges stemmed from in-country COVID-19
restrictions on movement of personnel. Because of these movement
restrictions, implementer staff were sometimes locked down in their office
or home locales, which hampered their ability to access project sites or
implement programs. In some instances, closed borders prevented
implementer personnel outside the country from entering. By contrast, the
implementer in Honduras reported it had acquired an emergency services
exemption from local government movement restrictions; otherwise,
programming would have been much more difficult, according to
implementer staff.
Supply chain issues also prevented implementers from procuring and
transporting materials. For example, implementer staff in Ukraine
reported being unable to import medical supplies because of supply chain
issues. Moreover, implementer staff reported that supply chain issues
significantly delayed the procurement and shipping of handwashing kits in
several locations for a USAID Pacific Islands project. (Fig. 4 shows
examples of emergency relief supplies provided by BHA.)
Page 25 GAO-22-104431 CARES Act Humanitarian Assistance
Figure 4: Examples of Emergency Relief Supplies Provided by USAID
In addition to endangering lives, the COVID-19 pandemic has disrupted
Conclusions economies as well as the availability of food and medical supplies
worldwide. According to the UN, these and other secondary effects of the
pandemic have exacerbated humanitarian crises on a global scale. As the
global community attempts to address these needs, the pandemic also
challenges the ability of donors and implementers to effectively monitor
the assistance they are providing.
State PRM, USAID BHA, and their implementing partners have taken
steps to adapt their programming and monitoring during the pandemic.
While those steps have allowed programming of emergency funding to
continue, they have also brought significant challenges. The challenges to
monitoring encountered by USAID and its implementers have not abated.
The reliance of USAID staff in Washington, D.C., on field-based oversight
for site visits and oversight of agency programming heightens the
importance of documenting field-based oversight in a central location
such as award files. Without clear guidance regarding field-level site visits
and other oversight, USAID risks losing institutional knowledge about its
programs and may lack timely information needed to assess program
progress and make decisions about program direction and operation.
Page 26 GAO-22-104431 CARES Act Humanitarian Assistance
BHA mitigated some of the challenges associated with reduced
monitoring capabilities by requiring more-frequent reporting from
implementers, which also enabled the bureau to identify lessons learned
and incorporate them into subsequent programming. However, BHA
decided not to apply the requirement on more recent awards without fully
assessing the benefits and costs of enhanced reporting. Such an
assessment could allow BHA to potentially adapt what was beneficial and
mitigate any burdensome aspects. Doing so could help ensure that BHA
receives timely information that allows for rapid adaptation and real-time
analysis of lessons learned, which are particularly important in emergency
contexts where normal implementation and monitoring are curtailed.
We are making the following two recommendations to USAID:
Recommendations for
Executive Action The USAID Administrator should ensure that BHA clearly communicates
to staff the expectations for documentation of field-level oversight, such
as site visits, in each award file, such as by educating staff about legacy
guidance or issuing new BHA guidance. (Recommendation 1)
The USAID Administrator should ensure that BHA assesses the costs
and benefits of requiring more-frequent reporting from implementers in
contexts where normal operations and monitoring are curtailed.
(Recommendation 2)
We provided a draft of this report to State and USAID for comment.
Agency Comments During the draft review period, and in consultation with USAID, we
modified our recommendations to address them to the USAID
Administrator.
USAID provided comments that we have reproduced in appendix II. In its
comments, USAID concurred with our recommendations and stated that it
will take actions to implement them. State and USAID also provided
technical comments that we incorporated as appropriate.
We are sending copies of this report to the appropriate congressional
committees, the Secretary of State, and the Administrator of USAID. In
addition, the report will be available at no charge on the GAO website at
http://www.gao.gov.
Page 27 GAO-22-104431 CARES Act Humanitarian Assistance
If you or your staff have any questions about this report, please contact
me at (202) 512-2964 or at kenneyc@gao.gov. Contact points for our
Office of Congressional Relations and Office of Public Affairs can be
found on the last page of this report. GAO staff who made key
contributions to this report are listed in appendix III.
Chelsa Kenney
Director, International Affairs and Trade
Page 28 GAO-22-104431 CARES Act Humanitarian Assistance
Congressional Addressees
The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Robert Menendez
Chairman
Committee on Foreign Relations
United States Senate
The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Rosa L. DeLauro
Chair
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives
Page 29 GAO-22-104431 CARES Act Humanitarian Assistance
The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives
The Honorable Gregory W. Meeks
Chairman
The Honorable Michael T. McCaul
Ranking Member
Committee on Foreign Affairs
House of Representatives
The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives
The Honorable Richard E. Neal
Chairman
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives
Page 30 GAO-22-104431 CARES Act Humanitarian Assistance
Appendix I: Objectives, Scope, and
Appendix I: Objectives, Scope, and
Methodology
Methodology
This report (1) examines how State and USAID adapted program
monitoring for humanitarian assistance activities supported by
supplemental funding in response to the COVID-19 pandemic and (2)
describes efforts that organizations implementing this funding made to
adapt their projects to conditions during the pandemic as well as the
challenges these implementers faced.
To address both of these objectives, we obtained information from
agency planning, funding, and guidance documents and interviewed
officials at State and USAID. 1 We obtained financial data on all
humanitarian assistance awards funded from the Coronavirus
Preparedness and Response Supplemental Appropriations Act and the
CARES Act. 2 We obtained these data from State’s State Assistance
Management System and USAID’s Phoenix database. To assess the
data’s reliability, we reviewed agency responses to our questions about
data reliability, noting the specific tagging required for COVID-19-
supplemental funding. We also compared the data we received with the
data State and USAID reported to Congress and with original approval
documentation. We found that the data we received were sufficiently
reliable for describing obligation and programming information for COVID-
19 supplemental programming.
From this universe of 209 awards, we selected a nongeneralizable
sample of 12 awards. 3 In selecting these awards, we used a mixture of
random and judgmental sampling to maximize coverage of features such
as geographic representation; implementation by nongovernmental
organizations (NGO) and public international organizations (PIO);
permissive and nonpermissive environments 4 before the onset of the
pandemic; obligation amounts; and program sectors. In general, we
selected more NGO awards than PIO awards because State and USAID
1We evaluated agency actions independently of one another and did not directly compare
the agencies’ respective performance.
2 See Pub. L. No. 116-123, tit. IV, 134 Stat. at 153; Pub. L. No. 116-136, div. B, tit. XI, 134
Stat. at 590.
3Specifically, State obligated funding to 21 awards and USAID obligated funding to 188
awards.
4USAID defines nonpermissive environments as contexts, at the national or subnational
level, in which uncertainty, instability, inaccessibility or insecurity constrains USAID's
ability to operate safely and effectively. According to USAID, the vast majority of the
countries in which USAID provides humanitarian assistance have experienced some
degree of nonpermissiveness over the last 20 years, with backsliding, dramatic downturns
and disruptive shocks not uncommon.
Page 31 GAO-22-104431 CARES Act Humanitarian Assistance
Appendix I: Objectives, Scope, and
Methodology
generally impose fewer programmatic monitoring requirements on PIOs
than on NGOs. We selected three State awards, including two NGO
awards (for projects in Kenya and Afghanistan) and one PIO award (for a
project covering multiple countries). We selected nine USAID awards,
including five NGO awards (for projects in Honduras, Pacific Islands,
South Sudan, Syria, and Ukraine) and four PIO awards (for projects in
Colombia, Philippines, Sierra Leone, and West Africa).
To examine these awards, we developed a data collection instrument to
identify adaptive measures for data collection and site visits as well as
challenges to implementation and monitoring. For each award, we
examined relevant award file documents, including risk assessments,
award modifications, implementer reporting, and agency oversight
documentation. We compared this documentation with agency policies
and standards. We determined that federal internal control standards
related to identifying, analyzing, and responding to significant changes
that could affect the internal control system were relevant to our audit
objectives. 5 To further explore variability in USAID monitoring
documentation, we selected three USAID NGO awards (for projects in
Honduras, South Sudan, and Ukraine) to conduct remote meetings with
agency oversight staff and implementer officials based in Washington,
D.C., and the field.
We conducted this performance audit from July 2020 to January 2022 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
5GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: September 2014).
Page 32 GAO-22-104431 CARES Act Humanitarian Assistance
Appendix II: Comments from the U.S.
Appendix II: Comments from the U.S. Agency
for International Development
Agency for International Development
Page 33 GAO-22-104431 CARES Act Humanitarian Assistance
Appendix II: Comments from the U.S. Agency
for International Development
Page 34 GAO-22-104431 CARES Act Humanitarian Assistance
Appendix II: Comments from the U.S. Agency
for International Development
Page 35 GAO-22-104431 CARES Act Humanitarian Assistance
Appendix II: Comments from the U.S. Agency
for International Development
Page 36 GAO-22-104431 CARES Act Humanitarian Assistance
Appendix III: GAO Contact and Staff
Appendix III: GAO Contact and Staff
Acknowledgments
Acknowledgments
Chelsa Kenney, (202) 512-2964 or kenneyc@gao.gov
GAO Contact
In addition to the contact named above, Kara Marshall (Assistant
Staff Director), David Hancock (Analyst-in-Charge), Eugene Beye, Neil
Acknowledgments Doherty, Justin Fisher, Reid Lowe, Jason Marshall, and Nicole Willems
made key contributions to this report.
(104431)
Page 37 GAO-22-104431 CARES Act Humanitarian Assistance
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