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