Audit of USAID/Paraguay's Democracy and Governance Program

USAID/Paraguay complete an analysis of Centro de Estudios Ambientales y Sociales that meets the requirements for a Non-U.S. Organization Preaward Survey, assessing areas not covered by the preaward survey or this audit, which will also serve as a learning experience on how to conduct a Non-U.S. Organization Preaward Survey.

USAID/Paraguay determine whether to add specific conditions to the award for the Democracy and Governance Program and whether to extend timelines for specific conditions already imposed, and have the agreement officer modify the award as necessary.

USAID/Paraguay develop a formal plan for facilitating and monitoring progress by Centro de Estudios Ambientales y Sociales on specific conditions to improve the program's financial and administrative control environment, or terminate the agreement with Centro de Estudios Ambientales y Sociales.

USAID/Paraguay instruct Centro de Estudios Ambientales y Sociales in writing to revise its procurement practices to meet requirements for competition, including proper advertising and unbiased selection of vendors.

USAID/Paraguay determine the allowability of $406,910 in ineligible questioned costs related to the lack of competitive bidding and recover from Centro de Estudios Ambientales y Sociales the amount determined to be unallowable.

USAID/Paraguay, in coordination with Centro de Estudios Ambientales y Sociales, mitigate the impact of the conflict of interest, calculate the fair value of office space funded by USAID for the Democracy and Governance Program that the subcontracted consulting firm occupied rent-free, have the agreement officer determine the allowability of the calculated amount, and recover from Centro de Estudios Ambientales y Sociales any amount determined to be unallowable.

USAID/Paraguay work with Centro de Estudios Ambientales y Sociales to revise its payroll process to track payroll hours for employees not fully dedicated to the program.

USAID/Paraguay, in coordination with Centro de Estudios Ambientales y Sociales, review the subaward between Management Systems International and Centro de Estudios Ambientales y Sociales, document and calculate the costs of any subaward requirements that Management Systems International did not meet and have the agreement officer determine the allowability of the calculated amount, and recover from Centro de Estudios Ambientales y Sociales any amount determined to be unallowable.

USAID/Paraguay develop a formal plan for monitoring and supporting Centro de Estudios Ambientales y Sociales that provides appropriate oversight through coaching and regular financial reviews to ensure proper accountability for funds provided to the organization.

USAID/Paraguay instruct Centro de Estudios Ambientales y Sociales, in writing, to pay employees at the rates in the award budget.

USAID/Paraguay work with Centro de Estudios Ambientales y Sociales to determine and document the most cost-effective method for staffing program positions that complies with local labor law.

USAID/Paraguay have the agreement officer amend the Democracy and Governance Program agreement to include the latest mandatory standard provisions for non-U.S. nongovernmental organizations as noted in the mandatory reference to Automated Directives System 303, "Standard Provisions for
Non-U.S. Nongovernmental Organizations."

USAID/Paraguay have the agreement officer amend the award for the Democracy and Governance Program to cover the indirect costs of the Centro de Estudios Ambientales y Sociales or require Centro de Estudios Ambientales y Sociales to seek new funding sources so that costs associated
with doing so would become direct costs.

USAID/Paraguay evaluate and document whether to adjust the cost-share percentage for the Centro de Estudios Ambientales y Sociales in light of its circumstances, and have the agreement officer modify the award as necessary.