The Global Fund Board established the Additional Safeguard Policy (ASP) in 2004 as an approach for alternative funding mechanisms where particular constraints about funding Principal Recipients (PRs) and sub-recipients (SRs) exist. Since its inception, the ASP has not been reviewed to determine its fit for purpose in an evolving environment. In 2023, the Global Fund requested the Office of the Inspector General (OIG), for an advisory review to better offer recommendations about the policy and enhance the forward-looking application and implementation of the ASP, which was released this week and available on OIG’s website.
Below, we discuss the issues identified in the review, focusing on OIG recommendations and how the recommendations could be taken forward from Africa’s perspective. Also provided at the end of this summary is a statement from the African perspective.
Finding 1: Invocation of the ASP status
Background: ASP is a prerogative of the Global Fund based on issues that pose a risk to the overall implementation of the grant. The rationale for invocation is shared with countries.
Issues: While country stakeholders are generally clear on the rationale provided by the Global Fund regarding the invocation of the ASP, they often lack an understanding of the implications and way forward.
OIG Recommendations
- ASP exit criteria and verification matrix be developed and shared with countries
- Factors within the control of the Country Coordinating Mechanisms (CCMs) or PRs should be spelt out
- ASP should be human in its approach to safeguard unintended consequences that may be introduced into the grant due to the measures
Our observations
- In the absence of an exit criteria, there is no incentive for a country to thrive for the exit. Therefore, an exit criteria must encompass an information sharing/sensitisation pack shared with all country stakeholders.
- Transparency be embedded in the exit criteria to promote openness and accountability. The process of developing the criteria should be consultative and inclusive.
- In assessing the fit for exit, an independent body must be engaged to offer an unbiased opinion that is not influenced by the GF or other interested parties.
Finding 2: Implementation of ASP measures
Background: GF leads PRs/SRs selection, with CCMs showing leadership in subsequent grants
Issues: ASP enables the Global Fund to closely select and control implementers, including PRs/SRs. However, this approach often results in reduced national control over grant management. Safeguards through INGO have led to lower financial risks but come at a cost to the grant due to high indirect costs. Capacity-building efforts, essential for enabling countries to exit ASP status eventually, have seen limited success in some portfolios.
OIG Recommendations
- The Secretariat should endorse and assist country-led development of an ASP exit plan, measured against the provided exit criteria
- Where risk levels have decreased, the Global Fund should support the gradual removal of ASP-related measures. This includes shifting responsibilities to national entities for grant management.
- Capacity-building activities should be planned, implemented, and monitored effectively to address challenges underlying ASP invocation
- Country Teams should empower CCMs to effectively monitor grants, ensuring PRs are accountable to the CCM and enhancing transparency in grant management.
Our observations
- More emphasis needs to be placed on ensuring that countries have the capacity and resources to develop exit plans effectively. Simply creating an exit plan without addressing systemic issues that led to ASP invocation in the first place might lead to superficial improvements without sustainable outcomes. The Secretariat’s role in guiding countries through this process should be strengthened.
- There must be specific timelines to address certain observations in order to move towards exiting. Additionally, there must be a framework for how to evaluate when a country is ready to manage grants independently. Concrete guidelines or success indicators would be helpful.
- Capacity-building is often mentioned in reports, but it remains unclear what specific strategies are needed to make it more effective. The Global Fund should consider a more targeted approach to capacity-building, focusing on the most critical gaps within national systems. Additionally, more attention should be paid to ensuring that capacity-building is a collaborative process involving implementer governments, civil society, and implementing partners.
- Many CCMs are under-resourced and may lack the technical expertise needed to monitor complex grant implementation effectively. Rather, we propose tangible ways to address the limitations, such as increasing financial or technical support through third part monitoring for CCMs, providing training, or enhancing their organisational capacity.
Finding 3: Monitoring and revocation of the ASP status and associated measures
Background
The Global Fund’s Operational Policy Note (OPN) provides clear requirements for the annual review of portfolios under the ASP, which should assess the rationale behind the ASP status, the effectiveness of the measures in place, and the progress towards meeting exit criteria.
Issues
The report identifies several gaps in the effective monitoring and management of the ASP. Key issues include the absence of specific exit criteria for many countries, which makes it difficult to determine when a portfolio is ready to transition out of ASP status.
OIG Recommendations
- The Secretariat should ensure that Country Teams comply with the existing requirement for annual reviews of ASP portfolios. These reviews should be detailed and conducted once per grant cycle, including updates on the ASP status, rationale, and exit criteria. Senior management should review these assessments.
- The Secretariat should hold regular discussions with country stakeholders about the ASP status and progress. Following the detailed review, formal communications should be sent to the CCMs and PRs to specify any changes in the portfolio’s status, risks, or exit criteria.
Our observations
- The GF could improve communication practices through regular workshops, detailed briefings, policy briefs, or capacity-building sessions with country stakeholders to ensure a full understanding of the ASP’s transient nature.
Finding 4: Cross-cutting issues
Background: The effectiveness of communication from the Secretariat to country stakeholders on the topic of ASP is suboptimal and has some undertones
Issues: There is a stigma attached to portfolios being subject to the ASP, often referred to as a “blacklist” by stakeholders. The ownership of ASP governance within the Global Fund Secretariat is fragmented across different teams, leading to delays, inconsistencies, and a loss of institutional knowledge. There is a lack of clear guidance and structured monitoring for the ASP process, which has resulted in delayed decision-making and inconsistent communication with countries regarding ASP status and progress.
OIG Recommendations
- The Secretariat should focus on the underlying risks and progress in risk mitigation. The aim is to change the perception about ASP as a “blacklist”.
- The Implementation and Challenging Operating Environments (ICOE) team should be empowered as the owner of the ASP processes and governance within the Secretariat. Clearer roles and responsibilities should be defined, and the team should develop resources to support Country Teams and other stakeholders in managing the ASP.
Our observations
- We suggest the ICOE team outline concrete steps to improve coordination between different teams within the Secretariat and establish clear accountability structures. For instance, there could be mechanisms to regularly review governance processes, share institutional knowledge, and reduce delays in decision-making.
Africa’s Perspective on the OIG Advisory Review
We commend the Office of the Inspector General (OIG) for this critical review of the Additional Safeguard Policy (ASP) and the thoughtful recommendations aiming to improve its application. From the perspective of East and Southern Africa (ESA) and West and Central Africa (WCA) constituencies where the ASP has been widely applied, this advisory review is timely and essential. Africa constitutes a significant portion of the Global Fund’s ASP portfolios, thus, the recommendations provide an opportunity to ensure ASP becomes more responsive to the needs and realities of countries. We are grateful that the report has captured what Africa has been calling for in the past.
Africa faces complex and unique challenges, including political instability, weak governance structures, and underfunded health systems. We appreciate the Global Fund’s use of the ASP to maintain critical health services in these high-risk environments. However, as highlighted in the report, many African countries under ASP have experienced difficulties in understanding the path forward, particularly in the absence of clearly communicated exit criteria. It is crucial that ASP measures safeguard Global Fund investments and empower African countries to build the capacity necessary to assume full responsibility for grant management. We are for an exit criteria that is developed through a consultative and inclusive process that leaves no one behind.
We advocate for clear exit criteria with clear monitoring mechanisms that meet different circumstances. The absence of exit criteria may contribute to a perception of “business as usual” with many African countries unclear about what is needed to exit ASP status. In the absence of an exit criteria, there is no incentive, after all, a country to thrive for the exit. We support the OIG’s recommendation to provide specific, measurable, and achievable exit criteria during ASP invocation. African countries need a clear roadmap and motivation to address the underlying risks, supported by capacity-building initiatives tailored to their specific contexts. Clear guidance will allow us to focus better our efforts on addressing the risks that led to ASP invocation, ultimately enabling us to regain control of grant management.
In addition, more emphasis needs be placed on ensuring that countries have the capacity and resources to develop exit plans effectively. Simply creating an exit plan without addressing systemic issues that led to ASP invocation in the first place might lead to superficial improvements without sustainable outcomes. The Secretariat’s role in guiding countries through this process should be strengthened. There must be a framework for how to evaluate when a country is ready to manage grants independently. Concrete guidelines or success indicators would be helpful. Many CCMs are under-resourced and may lack the technical expertise needed to monitor complex grant implementation effectively. Rather, we propose tangible ways to address the limitations, such as increasing financial or technical support through third part monitoring on behalf of CCMs, providing training, or enhancing their organisational capacity.
Africa’s experience with ASP has underscored the importance of national ownership. While international Principal Recipients (PRs) have played a valuable role in maintaining service continuity, their involvement has sometimes led to reduced national control and increased costs. CCMs are bypassed in a number of cases only to be called upon when a major issue arises in the country. We strongly support the recommendation to prioritize capacity-building for national implementers, ensuring that African governments and local entities effectively manage grants and reduce dependency on international PRs. Capacity-building efforts should be long-term, tailored to local needs, and rigorously monitored to ensure progress.
Improved communication and stakeholder engagement is a must if we are to win the battle against the three diseases. The OIG report highlights the need for improved communication between the Global Fund Secretariat and stakeholders regarding ASP status and progress. We believe that enhanced transparency and more regular updates on ASP status, risks, and exit plans are essential to fostering trust and collaboration. We suggest the Implementation and Challenging Operating Environments team outlines concrete steps to improve coordination between different teams within the Secretariat and establish clear accountability structures. For instance, there could be mechanisms to regularly review governance processes, share institutional knowledge, and reduce delays in decision-making.
The report identifies delays in decision-making and inconsistencies in the ASP process, which have been acutely felt by African countries. We welcome the steps being taken to streamline internal governance by empowering the Implementation and Challenging Operating Environments team. Ensuring that ASP processes are consistently applied across countries, with clear timelines and responsibilities, will greatly benefit African portfolios. Efficient governance is critical in ensuring that ASP measures are applied fairly, and that countries have the support needed to transition out of ASP status when risks are mitigated.
For Africa, the ASP must evolve into a tool that not only mitigates risks but also strengthens local capacities and systems. The recommendations outlined in the OIG report, if implemented earnestly and effectively, which the Global Fund coincidentally has begun to do, offer a pathway to greater national ownership of health programs in Africa. We look forward to seeing these recommendations put into action, with a focus on empowering African countries to address risks, build resilience, and eventually exit ASP status with stronger health systems and greater control over Global Fund investments.
Paul Nesara
