Review of USAID's Cuban Civil Society Support Program

The USAID Office of Transition Initiatives, in collaboration with the Office of Acquisition and Assistance and the Office of the General Counsel, develop and implement a plan in which future class deviations from acquisition policies and/or procedures clearly state the conditions for which the deviation will apply.

The USAID Office of Transition Initiatives, in collaboration with the Office of Acquisition and Assistance, review all deviations from Automated Directives System or acquisition regulations for its active awards, and determine whether they comply with Title 48 of the Code of Federal Regulations, Subpart 701.4, and correct any instances of noncompliance.

The USAID Office of Acquisition and Assistance review its procedure for approving and managing deviations, and determine whether it needs to be updated to comply with Title 48 of the Code of Federal Regulations, Subpart 701.4, and make any corrections necessary.

The USAID Office of Transition Initiatives establish and implement procedures that require oversight of implementing partners' proper compliance with exception to competition requirements.

The USAID Office of Acquisition and Assistance review the control procedures for the Office of Transition Initiatives' grants under contract and implement a plan to conduct periodic monitoring of the Office of Transition Initiatives' grants under contract.

The USAID Office of Acquisition and Assistance establish Automated Directives System guidance to identify and prevent personal conflicts of interest, including by contractor staff when executing grants under contract.

The USAID Office of Transition Initiatives develop a plan to implement the new requirements that prohibit personal conflicts of interest, including how to identify and avoid them.

The USAID Office of Transition Initiatives, in collaboration with the Office of General Counsel and the Office of Acquisition and Assistance, develop and implement a policy that requires including clearly delineated legal responsibilities in its awards in the context of the Office of Transitive Initiatives unique business model, and communicating legal responsibilities to its partners.

The USAID Office of Transition Initiatives and the Office of the General Counsel develop procedures on when and how the Office of Transition Initiatives country teams should seek legal counsel, which includes during implementation and administration of a program.

The USAID Office of Transition Initiatives develop and implement a policy to document actions taken to address recommendations stemming from program performance reviews, and, if a program performance review is not conducted or recommendations are not followed, that those decisions are documented.

The USAID Office of Transition Initiatives check that all Cuban Civil Society Support Program formal reviews and project deliverables are finalized properly and labeled accordingly.

The USAID Office of Transition Initiatives update its office guidance and inform current staff on the need to finalize project deliverables properly and to finalize deliverables of ongoing projects that were not done properly before.

The USAID Office of Transition Initiatives submit Cuban Civil Society Support Program documents, including the final program evaluation with lessons learned, to the Development Experience Clearinghouse in accordance with Automated Directives System, or obtain the appropriate waiver.

The USAID Office of Transition Initiatives inform current staff in writing and update office guidance on the requirement to document legal guidance, including correspondence, in project files and maintain these files in accordance with the Agency disposition schedule.

The USAID Office of General Counsel inform current staff in writing and update office guidance on the requirement to follow the Agency's disposition schedule and require attorneys to maintain appropriate documentation of legal opinions, including legal correspondence, in accordance with that schedule.

USAID Bureau for Management conduct an agency-wide analysis to determine whether a screening policy is needed to address intelligence and subversion threats that apply to USAID, and, if so, develop and implement one.