Recommendation Dashboard

We recommend that the Millennium Challenge Corporation's Vice President for Compact Implementation revise the Millennium Challenge Corporation's Guidelines for Environmental and Social Assessment to include assessing environmental risks broader than project activity risks, such as the risk presented by radioactive materials.

We recommend that the Millennium Challenge Corporation's Vice President for Compact lmplementation re-evaluate and document the risks surrounding the customs project activity to determine whether it will feasibly accomplish its objective and th"t the intervention will be sustainable.

We recommend that the Millennium Challenge Corporation's Vice Presidentfor Compact lmplementation amend the contract to remove the purchase of machine guns and patrol boats to ensure that the implementing partner does not purchase these items with Compact money.

We recommend that the Millennium Challenge Corporation's Vice President for Compact lmplemenultion revise its internal controls for procurement to include guidelines for preventing items prohibited by the Compact from being solicited.

We recommend that the Millennium Challenge Corporation's Vice President for Compact Developmmt revise the Guidance for Compact Eligible Countries to include under Risk Management Assessment a discussion for identifying risks associated with frequent changes in management when it could impact a project or component of a project, and to prepare a risk management plan to minimize the negative impact of such a risk.

USAID/Afghanistan establish a separate reconstruction program that will provide prompt implementation of reconstruction action plans for defective structures and ensure that all defective USAID-built structures are reconstructed.

USAID/Afghanistan take immediate action to secure and vacate the two occupied defective buildings constructed under the Accelerating Sustainable Agriculture Program.

USAID/Afghanistan complete an implementation plan for the demolition and retrofitting of the five buildings constructed under the Accelerating Sustainable Agriculture Program, either by compelling Chemonics to perform or by using a third party. If a third party is used, the implementation plan should include requirements to reduce Chemonics' future billings in accordance with Federal Acquisition Regulation 52.246-5(e) for the cost of demolishing or retrofitting the structures.

USAID/Afghanistan revise and reissue the November 2008 Office of Acquisition and Assistance notice on quality assurance to include requirements for quality assurance of construction performed under subcontracts and subagreements.

USAID/Afghanistan revise its contracting officer's technical representative designation letter to communicate the need to comply with construction oversight and quality assurance requirements.

USAID/Afghanistan develop written procedures covering the types of roads that require engineering oversight and quality assurance.

USAID/Afghanistan take appropriate action during each portfolio review to require that all in-progress and completed construction projects during the review cycle are documented and shared with the Office of Infrastructure, Engineering and Energy so that it can ensure that the
existing database of constructions projects is complete and provide engineering quality assurance oversight for those projects lacking it.

USAID/Afghanistan establish procedures to grant the mission engineers or their designated representatives the right to communicate directly with the construction contractors or subcontractors on deviations from approved engineering designs.

USAID/Afghanistan require that the final subcontract requirements for the design of the new campus for the American University of Afghanistan be reviewed for adherence to appropriate engineering standards.

USAID/Afghanistan require that all engineering drawings related to the American University of Afghanistan campus be reviewed for compliance with specified standards before the mission accepts delivery of the drawings.

USAID/Afghanistan require that the final statement of work clearly identify the continuation of the Afghan Infrastructure Data Center as a core aspect of the follow-on contract, to include training of Afghan Ministries in the maintenance and use of the data center.

USAID/Afghanistan complete all required contractor performance reviews of International Relief and Development, Inc., in accordance with Agency procedures.

USAID's Office of Foreign Disaster Assistance establish and implement a plan for both OFDA and partner staff to provide performance monitoring and oversight for its awards in Iraq. Such a plan should include, among other actions, regular reviews of partner reports, compliance with award requirements, and random checks to ensure that implementing partners have support for claimed results.

OFDA's agreement officer determine the allowability and collect, as appropriate, the $46,980 in questioned ineligible costs billed by International Medical Corps for Implementation Plan No. 11 under Cooperative Agreement No DFD-A-00-05-00030-00.

OFDA's agreement officer determine the allowability and collect, as appropriate, the $168,080 in questioned ineligible costs billed by Mercy Corps for Project Code DY/145 under Grant No. DFD-G-00-05-00027-00.

OFDA's agreement officer determine the allowability and collect, as appropriate, the $373,021 in questioned ineligible costs billed by Mercy Corps for Project Code DY/161 under Grant No. DFD-G-00-05-00027-00.

OFDA's agreement officer determine the allowability and collect, as appropriate, the $178,409 in questioned ineligible costs billed by Mercy Corps for Project Code DY/171 under Grant No. DFD-G-00-05-00027-00.

USAID's Office of Foreign Disaster Assistance provide clear guidance to its implementers on how to count beneficiaries.

USAID Office of Foreign Disaster Assistance perform an immediate review of its portfolio of awards in Iraq and ensure that each award, as appropriate, has an up-to-date, designated agreement officer's technical representative.

USAID Office of Foreign Disaster Assistance prepare an action memorandum to the Director, Office of Acquisition and Assistance, requesting the ratification of $3,150,751 in costs billed by the Agency for Technical Cooperation and Development during the period from June 30 to September 30, 2008, under Grant No. DFD-G-00-05-001-6-00.

USAID Office of Foreign Disaster Assistance prepare an action memorandum to the Director, Office of Acquisition and Assistance, requesting the ratification of $455,151 in costs billed by International Medical Corps during the period from March 31 to July 31, 2007, under Grant No. DFD-A-00-05-00030-00.

USAID Office of Foreign Disaster Assistance prepare an action memorandum to the Director, Office of Acquisition and Assistance, requesting the ratification of $1,864,831 in costs billed by International Medical Corps during the period from June 30 to September 30, 2008, under Grant No. DFD-G-00-05-00026-00.

USAID Office of Foreign Disaster Assistance prepare an action memorandum to the Director, Office of Acquisition and Assistance, requesting the ratification of $2,219,896 in costs billed by International Relief and Development, Inc., during the period from June 30 to September 30, 2008, under Grant No. DFD-G-00-05-00028-00.

USAID Office of Foreign Disaster Assistance prepare an action memorandum to the Director, Office of Acquisition and Assistance, requesting the ratification of $2,305,033 in costs billed by Mercy Corps during the period from June 30 to September 30, 2008, under Grant No. DFD-G-00-05-00027-00.

USAID/Ethiopia provide its staff with training regarding the requirements of its mission order addressing performance management and evaluation and document the training.

USAID/Ethiopia develop a written comprehensive performance management plan for its agricultural sector program.

USAID/Ethiopia (a) require that its partners' annual implementation plans include targets for the outputs to be achieved during the year and (b) approve these implementation plans in writing.

USAID/Ethiopia establish written procedures to ensure that site visits provide for data quality testing and adequate documentation of the test results.

USAID/Ethiopia correct the problems identified in the October/November 2007 data quality assessment of its agricultural program.

USAID/Ethiopia conduct a followup data quality assessment of its agricultural program.

USAID/Ethiopia require that negotiation memoranda be prepared for all awards.

USAID/Ethiopia (a) identify awards lacking current designation letters and (b) execute designation letters for those awards.

USAID/Ethiopia develop and implement the use of an award file checklist that includes the negotiation memorandum and technical officer designation letters as documents to be included in the award file (this checklist may be similar to that provided for USAID/Washington contracting officers in Procurement Executive's Bulletin No. 2005-06).

USAID/Ethiopia issue written guidance to all mission personnel and implementing partner staff reinforcing the Agency's branding requirements and their importance.

USAID/Ethiopia analyze its current branding practices and develop a written plan that makes the branding of USAID-funded activities, commodities, and other elements of its program in Ethiopia, more effective.

USAID/Ethiopia develop and implement a written plan to (a) identify USAID-funded commodities that have not been properly branded and (b) brand those commodities.

USAID/Ethiopia (a) require that its implementing partners verify and certify that all subawards include the required provision related to Executive Order 13224 and (b) that the mission's Office of Assistance and Acquisition confirm these certifications by selecting and verifying that a sample of subawards include the required provision.

USAID/Ethiopia require its environmental officer to provide annual training to its technical officers and to document and monitor mission compliance with the environmental regulations outlined in USAID's Automated Directives System 204.

USAID/Ethiopia (a) perform and document an environmental examination of its agricultural program and activities and (b) document the completion any actions identified in the environmental examination as necessary to safeguard the environment.

USAID/Ethiopia (a) review its agreements/contracts and document those omitting the required training provisions and (b) incorporate the appropriate training provision in each agreement/contract that is lacking that provision.

USAID/Ethiopia develop and implement a written plan with milestones to help ensure that technical representatives and implementing partners comply with Automated Directives System 253 and Mission Order 11-2.

We recommend that MCC requests and verifies that MCA-Tanzania corrects the internal control deficiency described in note 1 of the Findings section of this report.

We recommend that MCC verify that the questioned costs of $10,329 (TZS 13,939,340) are; (a) properly credited to the program, or (b) initiate action to recover the unallowable costs.

We recommend that the responsible MCC official make a management decision on the $51,706 in questioned costs due to noncompliance with the MCC Program Procurement Guidelines as described in Note 3 of the Findings section of this report, and recover any amounts determined to be unallowable.

We recommend that the responsible MCC official make a management decision on the $8,942 in questioned unallowable public relations costs as described in Note 4 of the Findings section of this report, and recover any amounts determined to be unallowable.

We recommend that MCC revise Chapter 4.2 x, Public Relations, of the Cost Principles, to clarify the definition, and provide specific examples of types of expenditures that constitute allowable and unallowable costs.

We recommend that MCC request MCA-Tanzania to submit a corrective action plan designed to adequately correct the internal control deficiencies described in Note 5 in the Findings section of this report.

USAID/East Africa coordinate with USAID/Ethiopia to develop and implement a plan with milestones to engage the Ethiopian Government so that the mission's implementing partner can conduct its conflict mitigation activities in Ethiopia.

USAID/East Africa, in conjunction with its implementing partners, develop and implement customized indicators to better measure and evaluate outcomes from its conflict mitigation activities.

USAID/East Africa develop and implement a plan with milestones to strengthen monitoring and evaluation of its conflict mitigation activities.

USAID/Rwanda develop and implement a plan, with milestones, to train all implementing partners and service outlets for treatment services on how to properly update patient records, maintain source documents, reconcile patient records at least once a year, and report program results.

USAID/Rwanda develop and implement a plan, with milestones, to train all implementing partners and service outlets providing treatment services to maintain inventory records and manage stocks effectively.

USAID/Rwanda develop and implement a plan, with milestones, to investigate and correct the problem of service outlets receiving insufficient quantities of treatment commodities from the national pharmaceutical procurement agency.

USAID/Rwanda develop and implement a plan, with milestones, to investigate and correct the problem of inadequate maintenance of test equipment by the national maintenance unit.

USAID/Rwanda establish written procedures that require performance management plans to be complete, containing all performance indicators and reference sheets, and provide for data-quality testing.

USAID/Rwanda revise its current performance management plan for the treatment program to include all five performance indicators.

USAID/Rwanda establish written procedures requiring that data-quality assessments be completed in a timely manner in accordance with applicable guidance.

USAID/Rwanda complete data-quality assessments for the five treatment program indicators in accordance with Automated Directives System requirements.

USAID/Rwanda establish written procedures requiring that site visits provide for data-quality testing and adequate documentation of the test results

We recommend that the acting Vice President for the Department of Policy and International Relations develop a formal policy and written procedures on anti-trafficking that at a minimum includes: Defining how Millennium Challenge Corporation will address the issue of trafficking in development and implementation phases; Defining how Millennium Challenge Corporation will comply with U.S. Government anti-trafficking policies; Identifying actions Millennium Challenge Corporation should take when a country's tier rating declines; Identifying how Millennium Challenge Corporation will monitor countries' tier ratings and anti-trafficking efforts; and Identifying how Millennium Challenge Corporation will coordinate with the Department of State on receiving information on countries'\' anti-trafficking efforts and tier ratings.

We recommend that the acting Vice President for the Department of Policy and International Relations develop written guidance on actions it plans to take when countries are designated as Special Watch for the first year and subsequent consecutive years.

M/OAA/CAS determine the allowability of $851,292 in questioned costs and collect, as appropriate, any disallowed amounts from CARE USA.

M/OAA/CAS follow up with CARE USA to ensure that the auditor's recommendations in Findings 2008-01 to 2008-73 (page nos. 60 to 251 of the Fiscal Year 2008 audit report of CARE USA) have been implemented.

M/OAA/CAS follow up with CARE USA to ensure that USAID accounts were credited for the funds embezzled in the fraud cases described in Finding 2008-06.

USAID/Dominican Republic, in conjunction with the Rural Economic Diversification project contractor, develop a written implementation plan to appropriately focus contractor efforts and resources on the original goal of cluster development.

USAID/Dominican Republic prepare and approve new written performance indicators that are more likely to determine the progress achieved by specific clusters assisted by the project and the sustainability of the clusters.

USAID/Dominican Republic develop, in conjunction with its implementing partner and the Development Credit Authority lender, a system to allow the mission to review proposed guaranteed loans to ensure that these loans are limited to diversified products supported by the project.

USAID/Dominican Republic develop, in conjunction with its implementing partner and the Development Credit Authority lender, a system to allow the mission to review proposed guaranteed loans to ensure that these loans have longer maturities and primarily support capital investment.