[Ce document extrait de "GLOBAL FUND OBSERVER (GFO), Issue 131: 8 October
2010. www.aidspan.org/gfo.)" résume les conclusions d'un rapport d'un audit du bureau
de l'inspection générale du Fonds Mondial réalisé en avril 2010. Plus de
détails dans www.theglobalfund.org/en/oig/reports. CB]
2. NEWS: OIG Report Documents Weaknesses in Oversight of Procurement and
Supply Management
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Deficiencies in the oversight of procurement and supply management (PSM)
arrangements may be exposing Global Fund grants to unnecessary and
unacceptable risks.
This is one of the conclusions of an audit report released by the Fund's
Office of the Inspector General (OIG) in April 2010.
In its 79-page report, "Review of Oversight of Grant Procurement and Supply
Chain Management Arrangements," the OIG said that it undertook this audit
for the following reasons:
* procurement of drugs and other health-related commodities represents
40-50% of the total expenditure of grant funds, and significant sums are
spent on distribution arrangements;
* the Global Fund Five-Year Evaluation raised concerns about the PSM
oversight standards;
* country audits undertaken by the OIG revealed common weaknesses in PSM
capacity and systems at the country level; and
* procurement is considered by several agencies in the development sector to
be one of the areas most likely to be subjected to irregular activities such
as corruption.
In addition, the OIG said, numerous procurement-related allegations have
been received by the OIG, and some grants have been suspended by the Global
Fund in part due to procurement-related irregularities.
The OIG said that its country audits reveal the following widespread
problems:
* weak forecasting of requirements for drugs and health product;
* weak technical specifications for procurement;
* absence of, or weak, procurement policies and procedures;
* high product prices;
* poor performance of third-party procurement agencies;
* poor inventory management;
* poor storage and transportation facilities at national and sub-national
level;
* drug stockouts and expiries;
* weak procurement planning resulting in frequent emergency procurements;
and
* inadequate management information systems.
The OIG said that these deficiencies "suggest that the [Global Fund's]
oversight arrangements have failed to spot and mitigate the risks that have
emerged" and that, in consequence, the OIG cannot at present give assurance
that the PSM arrangements are operating effectively in the countries
audited."
Principal recipients (PRs) have full responsibility for undertaking
grant-related PSM. The Global Fund's role in grant PSM has focused primarily
on establishing policy and assisting countries with interpreting policy
requirements. The Global Fund also provides limited oversight of the
procurement and supply management processes to ensure that PSM is undertaken
in a fair, transparent, objective and effective manner.
Within the Global Fund system, the Board, the Secretariat, country
coordinating mechanisms (CCMs) and local fund agents (LFAs) all have a role
to play in PSM oversight, as do some national drug or procurement regulatory
authorities. In its report, the OIG made the following observations
concerning these players:
PRs. Procurement agents are retained by PRs when the PR has capacity
limitations in undertaking procurement activities. However the contractual
responsibilities for PSM still rest with the PR in accordance with the grant
agreement. Most PRs do not have the capacity to contract, monitor and
evaluate the activities of procurement agents.
CCMs. CCMs have sometimes nominated PRs that do not meet the requisite PSM
capacity; and then, once programme implementation is underway, CCMs do not
have adequate oversight mechanisms in place to enable them to spot emerging
problems. In addition, many CCMs have not paid enough attention to their
role in strengthening coordination of PSM activities across PRs, diseases
and programmes funded by other donors.
LFAs. The role of LFAs in relation to PSM activities is clearly defined, but
many LFAs have difficulty fulfilling this role because they lack PSM
expertise. These LFAs rely on "fly in" consultants. In cases where these
consultants are unable to fly into a country to undertake an assessment, the
assessment is done by "desk review" - but these reviews do not allow the
consultant to verify some of the information provided by PRs. In addition,
periodic LFA monitoring does not always cover PSM activities (except in the
Latin America and Caribbean region, where the LFAs are requested once a year
to review the implementation of a sample of procurement processes undertaken
by each PR in that region).
National authorities. The country audits undertaken by the OIG revealed that
these national regulatory bodies have limited engagement with Global Fund
programmes and, unless their capacity is strengthened, cannot provide
effective oversight of these programmes.
Global Fund Secretariat. Procurement oversight at the Global Fund
Secretariat is undertaken through the Country Team Approach (CTA) where the
fund portfolio managers (FPMs) seek advice from the technical advisory
teams - i.e., Pharmaceutical Management Advisory Services (PMAS), Monitoring
and Evaluation (M&E),
Finance and Legal units - to support their decision-making. However, there
is no requirement for FPMs to consider and follow up on advice given. There
are also no mechanisms in place to ensure that action is taken on issues
raised by the advisory teams. Under the CTA, if there is no consensus on a
matter, it goes to the director of the relevant Country Programs unit, who
makes a decision in consultation with the Director of the Country Programs
Cluster. There is no input from the advisory teams at this stage. This
undermines the checks and balances established in the CTA.
The Pharmaceutical Management Unit (PMU) provides PSM oversight by
developing policy and assisting countries with interpreting policy
requirements. The PMAS, which is part of the PMU, has only eight staff,
which negatively affects its ability to support over 140 country grant
programmes.
The OIG commented as follows on some of the mechanisms set up to assist with
PSM:
Price and Quality Reporting (PQR) Mechanism. While the PQR tracks the prices
and suppliers of a few health products, it does not provide a comprehensive
database of information for decision-making. There is no evidence that
quality assurance issues observed through PQR data are followed up and
resolved in line with Global Fund policy. There is no mechanism in place to
provide assurance that PQR data is actually provided by PRs, and the
Secretariat continues to face challenges in this respect.
The penalty for failure to provide the data is, on paper, a freeze of
disbursements. However, the country audits undertaken by the OIG revealed
that PRs that have not entered data on the PQR were still able to get their
disbursements. The PQR's effectiveness is also reduced by the limited
selection of health products it covers.
PSM plans. PRs are supposed to complete a PSM plan prior to signing the
grant agreement, but this requirement is often deferred. In fact, in the
sample of 16 countries selected by the OIG for review, only one grant had a
PSM plan prepared prior to grant signature. When the PSM plan is deferred,
the Global Fund misses an opportunity to address issues upfront that could
potentially affect the timely implementation of programmes. And once grant
implementation is underway, there is no mechanism in place to ensure that
the PR complies with the PSM policies stipulated in the grant agreement and
the PSM plan.
Technical assistance. In many cases, capacity development has been piecemeal
and aimed at improving the ability of PRs to comply with a set of
procedures, as opposed to addressing systematic structural issues. In other
cases, the capacity development programmes only targeted PSM at low
functional levels (e.g., improvement of individual technical skills). This
did not address fundamental PSM issues and, sometimes, did not result in
sustainable improvements to the overall PSM control environment.
The OIG made the following additional observations:
Ineffective supply chain management systems have resulted in problematic
forecasting, drug stock outs and expiries.
There is no policy to regulate the selection and use of third-party
procurement agents.
While "conditions precedent" (CPs) are often included in grant agreements to
address capacity gaps identified during LFA assessments, there is no policy
at the Global Fund that regulates the implementation of CPs. This means that
CPs may be waived without addressing the risks they were set up to mitigate.
The OIG noted that the Global Fund is currently developing several
initiatives which, once implemented, should strengthen the PSM oversight
function. These include establishment by the Board of a Market Dynamics and
Commodities Ad-hoc Committee to oversee specific PSM activities; the rolling
out of the CCM dashboard, which draws attention to PSM as part of the CCM's
oversight function; revision of the Progress Update and Disbursement Report
(PU/DR) form used by LFAs to include, among other things, PSM-related
reporting; and the introduction of Country Profiles by the PMU.
The audit report contains 17 recommendations on ways in which the Global
Fund can address the problems identified by the OIG. Some of them, such as
the following two recommendations, raise issues that could impact the Global
Fund's core principle of country ownership:
The Global Fund should consider the benefits of playing a more active role
in resolving, or mobilising development partners at global and national
level to resolve, procurement problems, even if it comes at the cost of
bending the principles of the Global Fund as a "financing only" entity.
The Global Fund Secretariat should institute measures through which PR's PSM
activities are monitored in accordance with the grant agreement, approved
PSM plan and Global Fund procedures.
The OIG said that "it is for debate whether greater PSM oversight at a
country level would be in conflict with the Global Fund model. The important
question arises about how far procurement oversight structures established
by the Global Fund can go without overstepping its mandate as a financing
mechanism and interfering with the obligations of PRs in relation to PSM."
The Global Fund Secretariat said that it welcomed the recommendations, that
it agreed with all of them (fully or partially), and that many of the
recommended actions are covered in the Secretariat's 2010 workplan.
The information in this article was taken from "Review of Oversight of Grant
Procurement and Supply Chain Management Arrangements," Office of the
Inspector General, Global Fund, 22 April 2010, available at
www.theglobalfund.org/en/oig/reports.