Risk Management & Prevention of Fraud and Corruption file

advertisement
This file is part of the online Capacity Development Toolkit to Strengthen National Entities to
Implement National Disease Responses for HIV and AIDS, Tuberculosis and Malaria.
January 2012.
Link: www.globalfundpartnership.org
Risk Management & Prevention of Fraud and Corruption file
Capacities
The risk management and anti-fraud capacity area consists of the following detailed capacities
to be assessed and developed, which are sub-divided into components.
Risk Management & Prevention of Fraud and Corruption
Capacities
Risk, anti-fraud, and anticorruption management
Scope: clear responsibilities for
managing and monitoring risk;
regular management review of risks
and mitigation; effective
implementation of risk management
actions
Components

Planning

Managing

Monitoring

Forecasting
Maintain and use adequate risk mgmt,
anti-fraud, and anti-corruption
accountability and oversight mechanisms

Accountability & Oversight

Transparency
Follow Global Fund risk mgmt, anti-fraud,
anti-corruption requirements as well as
organisation policies and procedures

Policies & Procedures
Recruit, maintain, and develop
knowledge of staff to implement risk
mgmt, anti-fraud, and anti-corruption
operations (National, Regional, &
District/Local)

Recruit Risk Mgmt Staff
Effectively plan, manage, monitor, and
forecast risk mgmt, anti-fraud, and anticorruption operations with clear
structures, roles, and responsibilities
1

Maintain & Develop Risk Mgmt
Staff
Risk Management & Prevention of Fraud and Corruption
Capacities
Risk identification and planning
Scope: policies and procedures to
identify, assess, and plan for
programme risks; effective risk
management plans
Fraud and corruption tracking
Components
Procedures to effectively identify risks
and plan mitigation strategies

Risk Identification & Mitigation
Track and identify fraud and corruption

Tracking & Identification
Investigate fraud and corruption
allegations

Investigation
Enforce necessary action and reforms

Enforcement
Adequate prevention measures and
mechanisms

Prevention Measures
Scope: adequate fraud detection
systems and software; adequate and
independent external auditors
Investigation and enforcement
Scope: clarity of accountability and
levels of enforcement; independent
investigation mechanisms
Prevention mechanisms
Scope: effective systems to provide
internal and external transparency of
operations; levels of civic
participation and oversight
Indicators
For the each of the capacity components in Risk Management & Prevention of Fraud &
Corruption, the following table outlines points for consideration and example indicators. This
table can be used as an initial confirmation or checklist when conducting a capacity
assessment or defining a capacity development plan.
2
Indicators are classified into four different categories: value for money (including sub
categories of effectiveness, efficiency and additionality), risk mitigation, organisational
management, and sustainability1.
Capacity
Components
Points to Consider
Indicator Type
Example Indicators
Capacity: Effectively plan, manage, monitor, and forecast risk mgmt, anti-fraud, and anti-corruption operations with clear structures, roles,
and responsibilities
Planning


Currency and use
of risk management plans
Value for Money
Currency and use
of fraud and corruption
detection plans

Risk Mitigation

Organisational
Management

Sustainability


Managing


Clarity in
definition and
understanding of risk
management roles and
responsibilities
Value for Money
Effectiveness

Efficiency

Additionality

Time and effort required in risk
management planning
Level of integration of Global
Fund risk planning with national risk
planning processes
Schedule of partner reviews of risk, anti-fraud and anticorruption plans
Availability of risk management, anti-fraud and anticorruption planning guidelines
Schedule of risk planning learning events
Number of external resources or amount of salary
supplements required to conduct risk planning activities
Effectiveness



Risk management
reviews included in
Currency and frequency of risk
management planning
Financial and material loss per
year from fraud and corruption
Number of fraud and corruption
allegations reported per year
Number of fraud and corruption
enforcement actions per year
These categories cover the scope of capacity measurement under the headings of stability (organisational
management and risk mitigation), performance (effectiveness and efficiency), and adaptability (sustainability) as defined
by UNDP in: Measuring Capacity, UNDP, July 2010.
3
Capacity
Components
Points to Consider
Indicator Type
Example Indicators
management meetings

Efficiency
How risk
management data
analysis is used in making
management decisions


Additionality



Risk Mitigation


Organisational
Management

Sustainability



Monitoring



Regularity of risk
assessments and reviews
Value for Money


4
Integration of Global Fund risk
management, anti-fraud and anticorruption functions with national
procedures and systems
Percentage of risk
management, anti-fraud and anticorruption activities performed through
government and other donor funding
Transparency of risk management and anti-fraud and anticorruption activities
Availability of risk management, anti-fraud and anticorruption policies and procedures
Number of external resources or amount of salary
supplements required to support risk management, anti-fraud and
anti-corruption functions
Schedule of risk management, anti-fraud and anticorruption learning
Percentage of unit staff with risk management, anti-fraud
and anti-corruption certification


Risk Mitigation
Number of staff and effort per
year per allegation for anti-fraud and
anti-corruption functions
Degree of involvement of external partners and
certification organisations in reviewing risk management, anti-fraud
and anti-corruption activities
Effectiveness
Risk management
reports and analysis
available for management
meetings
Number of staff and effort per
year required for risk management
functions
Efficiency

Additionality

Currency and frequency of risk
management monitoring
Integrated risk and
management reports
Time and effort required in
monitoring risks
Level of integration of Global
Fund risk monitoring with national risk
forecasting processes
Schedule of partner reviews of risk, anti-fraud and anticorruption monitoring
Schedule of risk reviews of Global Fund grants with LFA
and CCM coordination
Capacity
Components
Points to Consider
Indicator Type
Example Indicators
Organisational
Management

Sustainability


Forecasting

Use of historical
data analysis and
forecasting data in risk
management, anti-fraud,
and anti-corruption
management

Value for Money
Risk Mitigation

Organisational
Management

Sustainability


Availability of risk management, anti-fraud and anticorruption monitoring guidelines
Schedule of risk monitoring learning events
Number of external resources or amount of salary
supplements required to conduct risk monitoring activities
Effectiveness

Efficiency

Additionality

Currency and frequency of risk
forecasts
Time and effort required in
forecasting risks
Level of integration of Global
Fund risk forecasting with national risk
forecasting processes
Schedule of partner reviews of risk, anti-fraud and anticorruption forecasts
Availability of risk management, anti-fraud and anticorruption forecasting guidelines
Schedule of risk forecasting learning events
Number of external resources or amount of salary
supplements required to conduct risk forecast activities
Capacity: Maintain and use adequate risk mgmt, anti-fraud, and anti-corruption accountability and oversight mechanisms
Accountability &
Oversight




Independence of
external audits of risk
management and antifraud functions
Value for Money
Effectiveness


Quality of
external audits
Stakeholder risk
and anti-fraud working
groups


Coordination of
risk management, antifraud, and anti-corruption
activities with Global Fund
mechanisms (LFA, CCM,
Secretariat, Board, etc.)
Efficiency


Additionality
5

Clear risk management
accountability structures from National
to Regional to District/Local levels
Availability of defined
management accountability in
pharmaceutical supply chain and
distribution systems
Number of partners and
stakeholders involved in oversight
Percentage completion of risk
audits and reviews vs. plan
Number of risk management
oversight reviews per year
Number of audit staff and effort
per year to provide oversight
Percentage of oversight reviews
conducted that are integrated with
other oversight objectives (other
donors, internal audit, etc.)
Capacity
Components
Points to Consider
Indicator Type
Example Indicators

Risk Mitigation


Transparency

Publication and
stakeholder access to
reliable information of
health services
(pharmaceutical pricing,
budgets, procurement,
human resources, and
quality of care and patient
satisfaction)
Organisational
Management

Sustainability


Value for Money
Schedule of external reviews of risk management
accountability and oversight mechanisms
Existence of anti-corruption agency and national policies
Documented audit and accountability policies and
guidelines for risk management, anti-fraud and anti-corruption
Schedule of accountability reviews and updates
Turnover rates for audit staff
Effectiveness





Risk Mitigation

Organisational
Management

Sustainability

Efficiency

Additionality

Existence of key health sector
documents that are disseminated
regularly (such as budget documents,
annual performance reviews and health
indicators)
Availability of accurate and
timely pharmaceutical quantity
information from procurement to
receipt to storage to distribution to
delivery point
Public access to health services
information (pricing, budgets, HR, and
quality of care)
Amount of publicly available
health information
Time and effort required to
manage public information and access
Level of integration of
transparency systems for Global Fund
with national procedures and systems
Number of external reviews and audits of public
information and access
Availability of transparency and public access policies and
procedures
Number of external resources or amount of salary
supplements required to support public information and
transparency operations
Capacity: Follow Global Fund risk mgmt, anti-fraud, anti-corruption requirements as well as organisation policies and procedures
6
Capacity
Components
Points to Consider
Policies &
Procedures

Currency and use
of risk management, antifraud, and anti-corruption
policies and procedures
Indicator Type
Example Indicators
Value for Money
Effectiveness




Risk Mitigation

Organisational
Management

Sustainability

Efficiency

Additionality

Availability and use of risk
management, anti-fraud and anticorruption policies and procedures
National anti-corruption and
anti-fraud legislation and regulatory
agencies
Whistleblower protection
legislation
Time and effort required to
maintain policies and procedures
Level of integration of Global
Fund risk management and anti-fraud
procedures with national procedures
and systems
Frequency of audit and external reviews of risk
management and anti-fraud policies and procedures
Staff responsibilities to maintain risk management, antifraud, and anti-corruption policies and procedures
Schedule of updates for risk management, anti-fraud and
anti-corruption policies and procedures guidelines
Capacity: Recruit, maintain, and develop knowledge of staff to implement risk mgmt, anti-fraud, and anti-corruption operations (National,
Regional, & District/Local)
Recruit Risk
Mgmt Staff





Clarity and
simplicity of recruitment
procedures
Value for Money
Effectiveness


Recruitment
timelines and bottlenecks

Scope of
recruitment searches
Efficiency

Additionality

Staff contracts
and incentives to retain
Risk Mitigation
Organisational
Management
Sustainability

Percentage turnover per year
Percentage or number of
vacant posts
Timing from recruitment
posting to staffed positions
Average time and effort
required to recruit one staff member, by
level
Percentage or financial amount
of staff recruited through the grant
Schedule of external reviews of recruitment policies and
procedures

Availability of alternative staffing solutions

Availability of recruitment plans

Availability of recruitment policies and procedures

Schedule of recruitment policies and procedures reviews
7
Capacity
Components
Points to Consider
Maintain &
Develop Risk
Mgmt Staff




Experience levels
of risk management staff
Indicator Type
Example Indicators
Value for Money
Effectiveness


Experience in
managing risk for funded
programs similar to the
Global Fund

Staff
development approaches

Turnover
percentages

Staff satisfaction
levels

Efficiency

Additionality

Percentage turnover per year
Percentage of staff who are on
schedule with their individual Staff
Development Plan
Percentage of staff with
appropriate certification
Team ToRs defined and clearly
understood
Use of e-learning courses
Percentage or financial amount
of staff funded through the grant
Risk Mitigation

Plans in place for tracking and maintaining staff
Organisational
Management

Availability of mentoring programmes

Availability of staff development plans

Schedule of staff development

Schedule of peer-to-peer and external learning sessions

Staff satisfaction scores
Sustainability
Capacity: Procedures to effectively identify risks and plan mitigation strategies
Risk
Identification &
Mitigation



Regularity of
review and update of
identified risks
Value for Money
Effectiveness
Number of risks identified per
year

Review cycles for
tracking risk mitigation
activities
Management
review of risk mitigation
activities


Risk Mitigation

Organisational
Management

Sustainability

Capacity: Track and identify fraud and corruption
8
Efficiency

Additionality

Number of risk mitigation
activities per year
Cost of risk mitigation as a
percentage of grant funding
Level of integration of Global
Fund risk identification and mitigation
activities with national processes
Schedule of external reviews of risk identification and
mitigation processes and procedures
Availability of risk identification and risk mitigation policies
and procedures
Number of external resources or amount of salary
supplements required to support risk identification and mitigation
functions
Capacity
Components
Points to Consider
Tracking &
Identification



Responsibilities
for fraud detection
Indicator Type
Example Indicators
Value for Money
Effectiveness


Automated
systems and triggers for
fraud detection

Level of
independence of
responsible units for fraud
detection

Efficiency


Additionality



Risk Mitigation



Organisational
Management

Sustainability


Number of fraud cases
identified per year
Number of systems for tracking
and detection of fraud and corruption
Number of fraud and corruption
detection reviews/audits per year
Comprehensiveness of fraud
and corruption detection systems
Work hours required fraud and
corruption tracking and identification
activities
Availability of automated
systems to trigger possible fraud cases
Percentage of fraud and
corruption detection activities funded
through the grant
Percentage of Global Fund
fraud and corruption detection activities
that are integrated with organisation
fraud and corruption detection systems
and procedures
Availability of oversight and verification of fraud and
corruption detection activities
Clear roles and responsibilities for oversight and
information control
Level of civic involvement and transparency
Availability of fraud and corruption detection policies and
procedures
Schedule of staff development in anti-fraud and anticorruption functions
Number of external resources or amount of salary
supplements required to support fraud and corruption detection
functions
Capacity: Investigate fraud and corruption allegations
Investigation


Responsibilities
for investigating reported
frauds
Value for Money
Level of
independence of
9
Effectiveness

Efficiency

Percentage of fraud and
corruption allegations investigated per
year
Time and effort required for
fraud and corruption investigation
Capacity
Components
Points to Consider
Indicator Type
Example Indicators
responsible units for fraud
investigation

Additionality
Risk Mitigation



Organisational
Management

Sustainability



Percentage of Global Fund
fraud and corruption investigation
activities that are integrated with
organisation fraud and corruption
detection systems and procedures
Availability of oversight and verification of fraud and
corruption investigation activities
Clear roles and responsibilities for investigation
Level of civic involvement and transparency
Availability of fraud and corruption investigation policies
and procedures
Schedule of staff development in anti-fraud and anticorruption functions
Number of external resources or amount of salary
supplements required to support fraud and corruption investigation
functions
Capacity: Enforce necessary action and reforms
Enforcement




Responsibilities
for enforcement of action
when fraud is detected
Value for Money
Effectiveness


Level of
independence of
responsible units for fraud
enforcement

Evidence of action
and enforcement
Risk Mitigation

Efficiency

Additionality

Number of fraud and corruption
enforcement actions per year
Percentage of fraud and
corruption cases investigated and
detected that are acted upon
Percentage of fraud and
corruption cases acted upon that
generate reform
Time and effort required for
fraud and corruption enforcement
Percentage of Global Fund
fraud and corruption enforcement
activities that are integrated with
organisation fraud and corruption
enforcement systems and procedures
Availability of oversight and verification of fraud and
corruption enforcement activities

Clear roles and responsibilities for enforcement

Level of civic involvement and transparency
Organisational
Management

Sustainability

10
Availability of fraud and corruption enforcement policies
and procedures
Number of external resources or amount of salary
supplements required to support fraud and corruption enforcement
functions
Capacity
Components
Points to Consider
Indicator Type
Example Indicators
Capacity: Adequate prevention measures and mechanisms
Prevention
Measures




Levels of
operational transparency
in finance and
procurement
Value for Money
Effectiveness


Level of civic
involvement in monitoring

Level of
deterrence in legislation
and enforcement
Role of internal
audit in specific fraud and
corruption checking
Efficiency

Additionality



Risk Mitigation

Organisational
Management




Sustainability



11
Number of fraud and corruption
cases per year
Percentage of fraud and
corruption cases investigated and
detected that are acted upon
Number and distribution of
fraud and corruption detection systems
and activities
Time and effort required for
prevention activities
Percentage of prevention
activities funded through the grant
Percentage of prevention
activities integrated with organisationwide prevention policies and legislation
Level of operational transparency in financial resources and
procurement
Codes of conduct developed and signed by employees
Level of training and certification in fraud and corruption
detection in procurement and supply chain areas
Level of regulation of policies and procedures
Number of positive incentives for prevention
Codes of conduct developed and signed by employees
Level of regulation of policies and procedures
Number of positive incentives for prevention
Download