REQUEST FOR PROPOSALS (RFP)
RFP No.:
Issued on:
For:
Quotation Deadline:
Period of Performance:
I.
3959-01-02-RFP
October 25, 2013
Audit of Sub-Recipients
November 5, 2013 17:00 hours (Nairobi Time)
November 10, 2013 - December 25, 2013
BACKGROUND
Funded by the United States Agency for International Development (USAID) (hereinafter
referred to as “the client”) and managed by the Family Health International (FHI 360), the
Kenya Nutritional and HIV Program (NHP) works to strengthen nutritional therapy in and out
of hospital settings. The project is a five-year cooperative agreement. NHP is designed to
improve the nutritional status of HIV+ patients and malnourished orphans and vulnerable
children (OVCs). These groups receive supplemental nutritional support in the form of
nutrient-dense fortified blended foods and the first locally produced and distributed Ready-toUse-Therapeutic Food (RUTF). Through training, monitoring, quality assurance/improvement
approaches, and ongoing technical assistance, the project enhances the skills and capacity of
Ministry of Health (MOH) representatives at all levels to staff at comprehensive care centers.
The project also expands its reach by working through local community-based organizations
(CBOs) to provide nutritional support and a safety net to HIV+ individuals as well as OVCs.
Insta Products EPZ (“Insta”) has worked as a Subrecipient of the NHP Project since its
inception in April 2008 and is tasked with producing fortified blended foods and RUTF, as
described above. Insta is a locally-owned company and is a subsidiary of Chandaria Group,
which acquired the company in 2011.
Phillips Healthcare Services Limited (“PHSL”), a locally-owned Kenyan company, also works
with NHP as a Subrecipient and has been providing supply chain management services to the
project since September 2010.
II.
TITLE
Audit of the Fund Accountability Statement and Audit of Financial Statements of USAID
Resources managed by Insta received through FHI 360 for fiscal years ranging from April 2012
until November 2013 and audit of the Fund Accountability Statement and Audit of Financial
Statements of USAID Resources managed by PHSL received through FHI 360 for fiscal years
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ranging from April 2012 until October 2013.
III.
OBJECTIVES
The objective of this engagement is to conduct a financial audit of the USAID resources managed
by Insta and PHSL (hereinafter “Sub-recipients”) received through FHI 360 (“Prime Partner
Recipient”) under the NHP Project in accordance with U.S Government Auditing Standards and
the USAID Guidelines for Financial Audits Contracted by Foreign Recipients (Guidelines). Each
Sub-recipient will require a company-specific report; the reporting will be required to demonstrate
findings by fiscal year. Any general, repeat and non-financial observations can be combined and
presented together for each sub-recipient. During the periods listed above, Insta received
approximately KES 263,821,582.82 (about $3,159,850) in USAID funding through NHP and
PHSL received approximately KES 80,547,868.65 (about $964,740).
The financial audit must include (1) a specific audit of all the Sub-recipients’ USAID-funded
programs and (2) an audit of the Sub-recipients’ general-purpose financial statements on an
organization-wide basis (balance sheet, income statement, and cash flow statement).
The fund accountability statement is the basic financial statement to be audited that presents the
Sub-recipients’ revenues, costs incurred, cash balance of funds provided by USAID, and
commodities and technical assistance directly procured by USAID for the Sub-recipients’ use. All
currency amounts in the fund accountability statement, cost-sharing schedule, schedule of
computation of indirect cost rate, and the report findings, if any, must be stated in U.S. dollars.
The auditors must indicate the exchange rate(s) used in the notes to the fund accountability
statement. The fund accountability statement must be reconciled to the USAID funds included in
the general-purpose financial statements by a note to the financial statements or the fund
accountability statement.
A.
Audit of USAID Funds
A financial audit of the funds provided by USAID must be performed in accordance with U.S.
Government Auditing Standards and accordingly include such tests of the accounting records as
deemed necessary under the circumstances. The specific objectives of the audit of the USAID
funds are to:

Express an opinion on whether the fund accountability statement for the USAIDfunded programs presents fairly, in all material respects, revenues received, costs
incurred, and commodities and technical assistance directly procured by
USAID/Prime Partner Recipient for the period audited in conformity with the terms
of the agreements and generally accepted accounting principles or other
comprehensive basis of accounting (including the cash receipts and disbursements
basis and modifications of the cash basis).

Evaluate and obtain a sufficient understanding of the Sub-recipients’ internal
controls related to the USAID-funded programs, assess control risk, and identify
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reportable conditions, including material internal control weaknesses. This
evaluation must include the internal controls related to required cost-sharing
contributions.

Perform tests to determine whether the Sub-recipients complied, in all material
respects, with agreement terms (including cost sharing, as applicable to Insta) and
applicable laws and regulations related to USAID-funded programs. All material
instances of noncompliance and all illegal acts that have occurred or are likely to
have occurred must be identified. Such tests must include the compliance
requirements related to required cost-sharing contributions, if applicable.

Determine if the recipient has taken adequate corrective action on prior audit report
recommendations.
Auditors must design audit steps and procedures in accordance with U.S. Government Auditing
Standards, Chapter 4, to provide reasonable assurance of detecting situations or transactions in
which fraud or illegal acts have occurred or are likely to have occurred. If such evidence exists,
the auditors must immediately contact the relevant USAID Prime Partner Recipient and must
exercise professional judgment in pursuing indications of possible fraud and illegal acts so as not
to interfere with potential future investigations or legal proceedings.
IV.
AUDIT SCOPE
The auditor must use the following steps as the basis for the audit programs and the review. They
are not considered all-inclusive or restrictive in nature and do not constitute relief from exercising
professional judgment. The steps must be modified to fit local conditions and specific program
design, implementation procedures, and agreement provisions which may vary from program to
program. Any limitations in the statement of work must be communicated as soon as possible to
the USAID-funded Prime Partner.
A.
Pre-Audit Steps
Following is a list of documents applicable to different USAID-funded programs. The auditor
must review the applicable documents considered necessary to perform the audit:
1. The subagreements between the various USAID-funded Prime Partner Recipient and Subrecipients.
2. The sub-agreements between the Sub-recipients and other implementing entities, as
applicable.
3. Contracts and subcontracts with third parties, if any.
4. The budgets, implementation letters, and written procedures approved by USAID Prime
Partner Recipient.
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5. USAID Automated Directives System Chapter 636 – “Program Funded Advances.”
6. OMB Circular A-122 "Cost Principles for Nonprofit Organizations.”
7. USAID Acquisition Regulation (AIDAR), which supplement the FAR.
8. Mandatory Standard Provisions for Non-U.S. Nongovernmental Grantees (USAID
Automated Directives System, Series 300).
9. All program financial and progress reports; and charts of accounts, organizational charts;
accounting systems descriptions; procurement policies and procedures; and receipt,
warehousing and distribution procedures for materials, as necessary to successfully
complete the required work.
B.
Fund Accountability Statement
The auditor must examine the fund accountability statement1 for USAID-funded programs
including the budgeted amounts by category and major items; the revenues received from USAID
Prime Partner Recipient for the period covered by the audit; the costs reported by the Subrecipients as incurred during that period; and the commodities/technical assistance directly
procured by USAID for the Sub-recipients’ use. The fund accountability statement must include
all USAID assistance funds identified by each specific program or agreement. The revenues
received from USAID, less the costs incurred, after considering any reconciling items, must
reconcile with the balance of cash-on-hand and/or in bank accounts. The fund accountability
statement must not include cost sharing contributions provided from the Sub-recipients’ own funds
or in-kind. However, a separate cost sharing schedule must be included and reviewed to
determine whether cost sharing contributions were provided and accounted for in accordance with
the terms of the agreement (see section IV.C. of this statement of work).
The auditors may prepare or assist the Sub-recipients in the preparation of the fund accountability
statement from the books and records maintained by the Sub-recipients, but the Sub-recipients
must accept the responsibility for the statement’s accuracy before the audit commences.
The opinion on the fund accountability statement must be in accordance with SAS No. 62
(AU623). The fund accountability statement must separately identify those revenues and costs
applicable to each specific USAID-funded sub-agreement. The audit must evaluate program
implementation actions and accomplishments to determine whether specific costs incurred are
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A "fund accountability statement" is a financial statement that presents a USAID recipient's or Sub-recipient’s
revenues, costs incurred, cash balance of funds (after considering reconciling items), and commodities and
technical assistance directly procured by USAID or USAID Prime Partner Recipients that were provided by
USAID funded agreements. The fund accountability statement must be presented in U.S. dollars and the exchange
rate(s) used must be disclosed in a note to the fund accountability statement.
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allowable, allocable, and reasonable under the agreement terms, and to identify areas where fraud
and illegal acts have occurred or are likely to have occurred as a result of inadequate internal
control. At a minimum, the auditors must:
1.
Review direct and indirect costs billed to and reimbursed by USAID Prime Partner
Recipient, identifying and quantifying any questioned costs. All costs that are not
supported with adequate documentation or are not in accordance with the sub agreement
terms must be reported as questioned. Questioned costs that are pending reimbursement
by USAID Prime Partner Recipient must be identified in the notes to the fund
accountability statement as not reimbursed by USAID Prime Partner Recipient.
Questioned costs must be presented in the fund accountability statement in two separate
categories (a) ineligible costs that are explicitly questioned because they are unreasonable;
prohibited by the agreements or applicable laws and regulations; or not program related;
and (b) unsupported costs that are not supported with adequate documentation or did not
have required prior approvals or authorizations. All questioned costs resulting from
instances of noncompliance with agreement terms and applicable laws and regulations
must be included as findings in the report on compliance. Also, the notes to the fund
accountability statement must briefly describe the questioned costs and must be crossreferenced to the corresponding findings in the report on compliance.
2.
Review general and program ledgers to determine whether costs incurred were properly
recorded. Reconcile direct costs billed to, and reimbursed by, USAID Prime Partner
Recipient to the program and general ledgers.
3.
Review the procedures used to control the funds, including their channeling to contracted
financial institutions or other implementing entities. Review the bank accounts and the
controls on those bank accounts. Perform positive confirmation of balances, as necessary.
4.
Determine whether advances of funds were justified with documentation, including
reconciliations of funds advanced, disbursed, and available. The auditors must ensure that
all funding received by the sub-recipient from USAID Prime Partner Recipient was
appropriately recorded in the sub-recipient's accounting records and that those records
were periodically reconciled with information provided by USAID Prime Partner
Recipient.
5.
Determine whether program income was added to funds used to further eligible
program objectives, to finance the non-federal share of the program, or deducted from
program costs, in accordance with USAID regulations, other implementing guidance, or
the terms and conditions of the award.
6.
Review procurement procedures to determine whether sound commercial practices
including competition were used, reasonable prices were obtained, and adequate controls
were in place over the qualities and quantities received.
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7.
Review direct salary charges to determine whether salary rates are reasonable for that
position, in accordance with those approved by USAID Prime Partner Recipient when
approval is required, and supported by appropriate payroll records. Determine if overtime
was charged to the program and whether it is allowable under the terms of the
subagreements. Determine whether allowances and fringe benefits received by employees
were in accordance with the agreements and applicable laws and regulations. The auditors
must question unallowable salary charges in the fund accountability statement.
8.
Review travel and transportation charges to determine whether they are adequately
supported and approved. Travel charges that are not supported with adequate
documentation or not in accordance with agreements and regulations must be questioned
in the fund accountability statement.
9.
Review commodities (e.g., supplies, materials, vehicles, equipment, food products, tools,
etc.) procured by the recipient as well as those directly procured by USAID Prime Partner
Recipient for the recipient's use. The auditors must determine whether commodities exist
or were used for their intended purposes in accordance with the terms of the agreements,
and whether control procedures exist and have been placed in operation to adequately
safeguard the commodities. As part of the procedures to determine if commodities were
used for intended purposes, the auditors must perform end-use reviews for an appropriate
sample of all commodities based on the control risk assessment (see section IV.D. of this
statement of work). End-use reviews would normally include site visits to verify that
commodities exist or were used for their intended purposes in accordance with the terms of
the agreements. When conducting end-use reviews, the auditors must ensure that
commodities are marked in accordance with grant or contract requirements. The cost of all
commodities whose existence or proper use, in accordance with the terms of the
agreements, cannot be verified must be questioned in the fund accountability statement.
10.
Review technical assistance and services, whether procured by the recipient or directly
procured by USAID Prime Partner Recipient for the sub-recipient’s use. The auditors
must determine whether technical assistance and services were used for their intended
purposes in accordance with the terms of the agreements. The cost of technical assistance
and services not properly used in accordance with the agreements must be questioned in
the fund accountability statement.
In addition to the above audit procedures, if technical assistance and services were
contracted by the recipient from a non-U.S. contractor, the auditors must perform
additional audit steps of the technical assistance and services under this statement of work,
unless the recipient has separately contracted for an audit of these costs. When testing for
compliance with agreement terms and applicable laws and regulations, the auditors must
not only consider the agreements between the Sub-recipients and USAID Prime Partner
Recipient, but also the agreements between the Sub-recipients and non-U.S. contractors
providing technical assistance and services. The agreements between the recipient and the
non-U.S. contractors must be audited using the same audit steps described in the other
paragraphs of this section, including all tests necessary to specifically determine that costs
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incurred are allowable, allocable, reasonable, and supported under the agreement terms.
If technical assistance and services were not contracted by the Sub-recipients from a nonU.S. contractor, the auditors are still responsible for determining whether technical
assistance and services were used for their intended purposes in accordance with the terms
of the agreements. However, the auditors are not responsible for performing additional
audit steps for the costs incurred under the technical assistance and services agreements,
since either USAID or a cognizant U.S. government agency is responsible for contracting
for audits of these costs.
An illustrative fund accountability statement is included as Example 6.1 of the Guidelines. This
example illustrates how to report the results of a single audit that covers more than one USAID
agreement. In such cases, the fund accountability statement must separately disclose the financial
information (revenues, costs, etc.) for each agreement, and must identify the USAID Missions that
provided funding for each agreement. Questioned costs, and internal control and compliance
findings of any audits of subrecipients must be reported in the recipient’s financial audit using the
same treatment and procedures as the recipient’s own questioned costs and findings. This is
particularly important in audits of recipients covering grants from more than one USAID Mission,
so that each mission can identify its grants in the audit report for resolution of findings and
recommendations with the recipient. The same reporting principles apply when only one USAID
agreement is covered by the audit.
The auditors must generally express a single opinion on the fund accountability statement that
includes more than one sub-agreement with USAID Prime Partner Recipient. Auditors must not
express separate opinions on fund accountability statements of each agreement or program unless
specifically requested to do so by the USAID Mission.
C.
Internal Controls
The auditors must review and evaluate the Sub-recipients’ internal controls related to USAIDfunded programs to obtain a sufficient understanding of the design of relevant control policies and
procedures and whether those policies and procedures have been placed in operation. The U.S.
General Accounting Office's Standards for Internal Controls in the Federal Government
(GAO/AIMD-00-21.3.1; 1999) may be helpful in assessing recipient internal controls. The
auditor's understanding of the internal controls must be documented in the working papers.
Prepare the report required by the USAID Guidelines, identifying the reportable conditions that
are significant deficiencies in the design or operation of the internal controls, and the reportable
conditions considered to be material weaknesses. Material weaknesses are reportable conditions
in which the design or operation of the specific internal control elements do not reduce to a
relatively low level the risk that errors or irregularities in amounts that would be material in
relation to the fund accountability statement may occur and not be detected within a timely period
by management performing its normal functions. Reportable conditions, including material
weaknesses, must be set forth in the report as “findings” (see paragraph 5.1.d of the Guidelines).
Reportable conditions involve matters coming to the auditor’s attention relating to significant
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deficiencies in the design or operation of internal controls that, in the auditor’s judgment, could
adversely affect the recipient’s ability to record, process, summarize, and report financial data
consistent with the assertions of management in the fund accountability statement and cost-sharing
schedule. Nonreportable conditions must be included in a separate management letter to the
recipient and referred to in the report on the internal controls.
The major internal control components to be studied and evaluated include, but are not limited to,
the controls related to each revenue and expense account on the fund accountability statement.
The auditors must:
1.
Obtain a sufficient understanding of the internal controls to plan the audit and to determine
the nature, timing and extent of tests to be performed.
2.
Assess inherent risk and control risk, and determine the combined risk. Inherent risk is the
susceptibility of an assertion, such as an account balance, to a material misstatement
assuming there are no related internal control policies or procedures. Control risk is the
risk that a material misstatement, that could occur in an assertion, will not be prevented or
detected on a timely basis by the entity's internal control policies or procedures. Combined
risk (sometimes referred to as detection risk) is the risk that the auditor will not detect a
material misstatement that exists in an assertion. Combined risk depends upon the
effectiveness of an auditing procedure and its application by the auditor.
3.
Summarize the risk assessments for each assertion in a working paper. The risk
assessments must consider the following broad categories under which each assertion
should be classified: (a) existence or occurrence; (b) completeness; (c) rights and
obligations; (d) valuation or allocation; and (e) presentation and disclosure. At a
minimum, the working papers must identify the name of the account or assertion, the
account balance or the amount represented by the assertion, the assessed level of inherent
risk (high, moderate, or low), the assessed level of control risk (high, moderate, or low),
the combined risk (high, moderate, or low), and a description of the nature, extent, and
timing of the tests performed based on the combined risk. These summary working papers
must be cross-indexed to the supporting working papers that contain the detailed analysis
of the fieldwork. If control risk is evaluated at less than the maximum level (high), then the
basis for the auditor's conclusion must be documented in the working papers.
If the control risk is assessed at the maximum level for assertions related to material
account balances, transaction classes, and disclosure components of financial statements
when such assertions are significantly dependent upon computerized information systems,
the auditors must document in the audit documentation files the basis for such conclusions
by addressing (i) the ineffectiveness of the design and/or operation of controls, or (ii) the
reasons why it would be ineffective to test the controls.
4.
Evaluate the control environment, the adequacy of the accounting systems, and control
procedures. Emphasis must be placed on the policies and procedures that pertain to the
recipient’s ability to record, process, summarize, and report financial data consistent with
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the assertions embodied in each account of the fund accountability statement. This
evaluation must include, but not be limited to, the control systems for:
a.
ensuring that charges to the program are proper and supported;
b.
managing cash on hand and in bank accounts;
c.
procuring goods and services;
d.
managing inventory and receiving functions;
e.
managing personnel functions such as timekeeping, salaries, and benefits;
f.
managing and disposing of commodities (such as vehicles, equipment, and tools, as
well as other commodities) purchased either by the program or directly by USAID
Prime Partner Recipient; and
g.
ensuring compliance with agreement terms and applicable laws and regulations that
collectively have a material impact on the fund accountability statement. The results
of this evaluation must be contained in the audit documentation section described in
Section IV.E. of this statement of work dealing with the review of compliance with
agreement terms and applicable laws and regulations and presented in the
compliance report.
5.
Evaluate internal controls established to ensure compliance with cost-sharing
requirements, if applicable, including both provision and management of the contributions.
6.
Include in the study and evaluation other policies and procedures that may be relevant if
they pertain to data the auditor uses in applying auditing procedures. This may include, for
example, policies and procedures that pertain to nonfinancial data that the auditor uses in
analytical procedures.
In fulfilling the audit requirement relating to an understanding of the internal controls and
assessing the level of control risk, the auditor must follow, at a minimum, the guidance contained
in AICPA SAS Nos. 55, 60, 78 and 94 (AU110, AU319, AU324 and AU325), respectively
entitled Consideration of Internal Control in a Financial Statement Audit, Communication of
Internal Control Related Matters Noted in an Audit, and Consideration of Internal Control in a
Financial Statement Audit: An Amendment to SAS 55, The effect of Information Technology on
the Auditor’s Consideration of Internal Control in a Financial Statement Audit, SAS No. 74
(AU801) entitled Compliance Auditing Considerations in Audits of Governmental Entities and
Recipients of Governmental Financial Assistance, as well as SAS No. 99 entitled Consideration of
Fraud in a Financial Statement Audit .
D.
Compliance with Agreement Terms and Applicable Laws and Regulations
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In fulfilling the audit requirement to determine compliance with agreement terms and applicable
laws and regulations related to USAID-funded programs, the auditors must, at a minimum, follow
guidance contained in AICPA SAS No. 74 (AU801) entitled Compliance Auditing Considerations
in Audits of Governmental Entities and Recipients of Governmental Financial Assistance. The
compliance review must also determine – on audits of awards that present cost-sharing budgets on
an annual basis and on close-out audits of awards that present cost-sharing budgets on a life-ofproject basis - if cost-sharing contributions were provided and accounted for in accordance with
the terms of the agreements. The auditor's report on compliance must set forth as findings all
material instances of noncompliance, defined as instances that could have a direct and material
effect on the fund accountability statement. Nonmaterial instances of noncompliance must be
included in a separate management letter to the recipient and referred to in the report on
compliance.
The auditor's report must include all conclusions that a fraud or illegal act either has occurred or is
likely to have occurred. In reporting material fraud, illegal acts, or other noncompliance, the
auditors must place their findings in proper perspective. To give the reader a basis for judging the
prevalence and consequences of these conditions, the instances identified should be related to the
universe or the number of cases examined and be quantified in terms of U.S. dollar value, if
appropriate. In presenting material irregularities, illegal acts, or other noncompliance, auditors
must follow the reporting standards contained in Chapter 5 of U.S. Government Auditing
Standards. Auditors may provide less extensive disclosure of irregularities and illegal acts that are
not material in either a quantitative or qualitative sense. Chapter 4 of U.S. Government Auditing
Standards provides guidance on factors that may influence auditors’ materiality judgments. If the
auditor concludes that sufficient evidence of irregularities or illegal acts exists, they must
immediately contact the USAID RIG/Pretoria office and must exercise due professional care in
pursuing indications of possible irregularities and illegal acts so as not to interfere with potential
future investigations and/or legal proceedings.
In planning and conducting the tests of compliance the auditors must:
1.
Identify the agreement terms and pertinent laws and regulations and determine which of
those, if not observed, could have a direct and material effect on the fund accountability
statement. The auditors must:
a.
list all standard and program-specific provisions contained in the agreements that
cumulatively, if not observed, could have a direct and material effect on the fund
accountability statement;
b.
assess the inherent and control risk that material noncompliance could occur for each
of the compliance requirements listed in 1.a. above;
c.
determine the nature, timing and extent of audit steps and procedures to test for
errors, fraud, and illegal acts that provide reasonable assurance of detecting both
intentional and unintentional instances of noncompliance with agreement terms and
applicable laws and regulations that could have a material effect on the fund
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accountability statement. This must be based on the risk assessment in 1.b. above;
and
d.
prepare a summary working paper that adequately identifies each of the specific
compliance requirements included in the review, the results of the inherent, control,
and combined (detection) risk assessments for each compliance requirement, the
audit steps used to test for compliance with each of the requirements based on the
risk assessment, and the results of the compliance testing for each requirement. The
summary working paper must be cross-indexed to detailed working papers that
adequately support the facts and conclusions contained in the summary working
paper.
2.
Determine if payments have been made in accordance with agreement terms and
applicable laws and regulations.
3.
Determine if funds have been expended for purposes not authorized or not in accordance
with applicable agreement terms. If so, the auditor must identify these costs as questioned
in the fund accountability statement.
4.
Identify any costs not considered appropriate, classifying and explaining why these costs
are questioned.
5.
Determine whether commodities, whether directly procured by the recipient or directly
procured by USAID Prime Partner Recipient for the Sub-recipients’ use, exist or were
used for their intended purposes in accordance with the agreements. If not, the cost of
such commodities must be questioned.
6.
Determine whether any technical assistance and services, whether procured by the
recipient or directly procured by USAID Prime Partner Recipient for the Sub-recipients’
use, were used for their intended purposes in accordance with the agreements. If not, the
cost of such technical assistance and services must be questioned.
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Determine if the amount of cost sharing funds were provided according to the terms of the
agreements and quantify any shortfalls. (As applicable)
8
Determine if the cost sharing funds were provided according to the terms of the
agreements and quantify any shortfalls. (As applicable)
9.
Determine whether those who received services and benefits were eligible to receive them.
10.
Determine whether the recipient's financial reports (including those on the status of cost
sharing contributions) and claims for advances and reimbursement contain information
that is supported by the books and records.
The objective of this audit is to express an opinion on whether those statements present fairly, in
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all material respects, the Sub-recipients’ financial position within the audit period, and the results
of its operations and cash flow for the period then ended, in conformity with generally accepted
accounting principles.
E.
Follow-Up on Prior Audit Recommendations
The auditors must review the status of actions taken on findings and recommendations reported in
any prior audits of USAID-funded programs (if available) based on Chapter 4 of the U.S.
Government Auditing Standards under the section entitled Considering the Results of Previous
Audits and Attestation Engagements, which states: "Auditors should consider the results of
previous audits and attestation engagements and follow up on known significant findings and
recommendations that directly relate to the objectives of the audit being undertaken.” As well, the
Chapter states, “Auditors should use professional judgment in determining (1) prior periods to be
considered, (2) the level of work necessary to follow up on significant findings and
recommendations that affect the audit, and (3) the effect on the risk assessment and audit
procedures in planning the current audit.” They must do this to determine whether the auditee has
taken timely and appropriate corrective actions. Auditors must report the status of uncorrected
material findings and recommendations from prior audits that affect the financial statement audit."
The auditors must review and report on the status of actions taken on prior findings and
recommendations in the summary section of the audit report. The auditors must refer to the
most recent recipient or agency contracted audit report for the same award (for a follow-up
audit) or other USAID awards (for an initial audit). When corrective action has not been taken
and the deficiency remains unresolved for the current audit period and is reported again in the
current report, the auditors need to briefly describe the prior finding and status and show the page
reference to where it is included in the current report. If there were no prior findings and
recommendations, the auditors must include a note to that effect in this section of the audit report.
F.
General Purpose Financial Statements
Auditors must examine the Sub-recipients’ general purpose financial statements on an
organization-wide basis if an indirect cost rate needs to be audited,2 or if the Mission
specifically requests that the general purpose financial statements be audited. The audit must be
performed in accordance with generally accepted auditing standards of the American Institute of
Certified Public Accountants (AICPA), auditing standards that have been prescribed by the laws
of the country or adopted by an association of public accountants in the country, or auditing
standards promulgated by the International Organization of Supreme Audit Institutions or
International Auditing Practices Committee of the International Federation of Accountants.
The objective of this audit is to express an opinion on whether those statements present fairly, in
all material respects, the Sub-recipients’ financial position at year-end, and the results of its
operations and cash flow for the year then ended, in conformity with generally accepted
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accounting principles.
G.
Other Audit Responsibilities
The auditors must perform the following steps:
1.
Hold entrance and exit conferences with the Sub-recipients. The USAID Prime Partner
Recipient must be notified of these conferences in order that representatives may attend, if
deemed necessary.
2.
During the planning stages of an audit, communicate information to the auditee regarding
the nature and extent of planned testing and reporting on compliance with laws and
regulations and internal control over financial reporting. Such communication must state
that the auditors do not plan to provide opinions on compliance with laws and regulations
and internal control over financial reporting.3 Written communication is preferred.
Auditors must document the communication in the working papers.
3.
Institute quality control procedures to ensure that sufficient competent evidence is obtained
through inspection, observation, inquiries, and confirmations to afford a reasonable basis
for an opinion regarding the financial statements under audit. While auditors may use their
standard procedures for ensuring quality control, those procedures must, at a minimum,
ensure that:

audit reports and supporting working papers are reviewed by an auditor, preferably at
the partner level, who was not involved in the audit. This review must be
documented in the working papers;

all quantities and monetary amounts involving calculations are footed and crossfooted; and

all factual statements, numbers, conclusions and monetary amounts are crossindexed to supporting working papers.
4.
Ascertain whether the Sub-recipients ensured that audits of its Sub-recipients were
performed to ensure accountability for USAID funds passed through to Sub-recipients (see
paragraph 1.6 of the Guidelines). If Sub-recipient audit requirements were not met, the
auditors must disclose this in the auditor's report on the fund accountability statement and
consider qualifying their opinion.
5.
Obtain a management representation letter in accordance with AICPA SAS No. 85
(AU333), SAS No. 89, and SAS No. 99 signed by the Sub-recipients’ management. See
Example 4.1 of the Guidelines for an illustrative management representation letter.
3
The auditors only express an opinion on the fund accountability statement, and the indirect cost rate and general
purpose financial statements, if applicable, as indicated on Chapter 3 of these Guidelines.
13
V.
AUDIT REPORTS
The Sub-recipients must submit to all USAID Prime Partner Recipients two (2) copies of the
report in English. To make it easier for audit firms to comply with the Guidelines, the format and
content of the audit reports must follow the illustrative reports in Chapter 7 of the Guidelines. The
audit report must specify the correct award numbers of each award covered by the audit. The
report must contain:
A.
A title page,4 table of contents and a transmittal letter and summary which includes: (1) a
background section with a general description of the USAID-funded programs audited, the
period covered, the program objectives, a clear identification of all entities mentioned in
the report, a section on the follow-up of prior audit recommendations, and whether the
Sub-recipient has a USAID-authorized provisional indirect cost rate; (2) the objectives and
scope of the financial audit, and a clear explanation of the procedures performed and the
scope limitations, if any; (3) a brief summary of the audit results on the fund accountability
statement, questioned costs, internal controls, compliance with agreement terms and
applicable laws and regulations, indirect cost rates, status of prior audit recommendations,
and, if applicable, the Sub-recipient's general purpose financial statements on an
organization-wide basis; (4) a brief summary of the results of the review of cost-sharing
contributions; and (5) a brief summary of the recipient's management comments regarding
their views on the audit results and findings.
B.
The auditor's report on the fund accountability statement, identifying any questioned costs
not fully supported with adequate records or not eligible under the terms of the agreement.
The report must be in conformance with the standards for reporting in Chapter 5 of the
U.S. Government Auditing Standards and must include:
1.
The auditor's opinion on whether the fund accountability statement presents fairly, in
all material respects, program revenues, costs incurred, and commodities and
technical assistance directly procured by the USAID Prime Partner Recipient for the
period then ended in accordance with the terms of the agreements and in conformity
with generally accepted accounting principles or other basis of accounting. This
opinion must clearly state that the audit was performed in accordance with U.S.
Government Auditing Standards or specific alternative standards if applicable (see
paragraph 2.9.d of the Guidelines). Any deviations from these standards, such as
noncompliance with the requirements for continuing professional education and
external quality control reviews, must be disclosed (See Example 7.1.A of the
Guidelines).
2.
The fund accountability statement identifying the program revenues, costs incurred,
and commodities and technical assistance directly procured by the USAID Prime
4
“Closeout audits must specify they are closeout audits on the title page. A closeout audit is an audit for an
award that expired during the period audited.
14
Partner Recipient for the period. The statement must also identify questioned costs
not considered eligible for reimbursement and unsupported, if any, including the cost
of any commodities and technical assistance directly procured by the USAID Prime
Partner Recipient whose existence or proper use in accordance with agreements
could not be verified.
All questioned costs resulting from instances of
noncompliance with agreement terms and applicable laws and regulations must be
included as findings in the report on compliance. Also, the notes to the fund
accountability statement must briefly describe all questioned costs and must be
cross-referenced to any corresponding findings in the report on compliance (see
Example 6.1 of the Guidelines). All questioned costs in the notes to the fund
accountability statement must be stated in U.S. dollars. The U.S. dollar equivalent
must be calculated at the exchange rate applicable at the time the local currency was
disbursed to the Sub-recipient by the USAID Prime Partner Recipient.
3.
Notes to the fund accountability statement, including a summary of the significant
accounting policies, explanation of the most important items of the statements, the
exchange rates during the audit period and foreign currency restrictions, if any. In
addition, a note to the fund accountability statement must state whether any interest
on USAID funds was returned to the USAID Prime Partner Recipient.
D.
The auditor's report on internal control. The auditor's report must include as a minimum:
(1) the scope of the auditor's work in obtaining an understanding of the internal controls
and in assessing the control risk, and; (2) the reportable conditions, including the
identification of material weaknesses Sub-recipient's internal controls. Reportable
conditions must be described in a separate section (see paragraphs 5.2 through 5.4 of the
Guidelines). This report must be made in conformance with SAS No. 60 and the standards
for reporting in Chapter 5 of U.S. Government Auditing Standards. Non-reportable
conditions must be communicated to the Sub-recipients in a separate management letter
which must be referred to in the report on internal controls and sent with the audit report
(see Examples 7.2.A and 7.2.B of the Guidelines).
E.
The auditor's report on the Sub-recipients’ compliance with agreement terms and
applicable laws and regulations related to USAID-funded programs. The report must
follow the guidance in SAS No. 74. Material instances of noncompliance must be
described in a separate section (see paragraphs 5.2 through 5.4 of the Guidelines).
Nonmaterial instances of noncompliance must be communicated to the Sub-recipients in a
separate management letter, which must be sent with the audit report (see Examples 7.3.A
and 7.3.B of the Guidelines). All questioned costs resulting from instances of
noncompliance must be included as findings in the report on compliance. Also, the notes
to the fund accountability statement that describe questioned costs must be crossreferenced to any corresponding findings in the report on compliance.
The auditor's report must include all conclusions, based on evidence obtained, that a fraud
or illegal act either has occurred or is likely to have occurred. This report must include an
identification of all questioned costs, if any, as a result of fraud or illegal acts, without
15
regard to whether the conditions giving rise to the questioned costs have been corrected
and whether the Sub-recipient does or does not agree with the findings and questioned
costs.
In reporting material fraud, illegal acts, or other noncompliance, the auditors must place
their findings in proper perspective. To give the reader a basis for judging the prevalence
and consequences of these conditions, the instances identified must be related to the
universe or the number of cases examined and is quantified in terms of U.S. dollar value, if
appropriate. In presenting material fraud, illegal acts, or other noncompliance, auditors
must follow the reporting standards contained in Chapter 5 of U.S. Government Auditing
Standards. Auditors may provide less extensive disclosure of irregularities and illegal acts
that are not material in either a quantitative or qualitative sense. Chapter 4 of U.S.
Government Auditing Standards provides guidance concerning factors that may influence
auditors' materiality judgments. If the auditors conclude that sufficient evidence of
irregularities or illegal acts exist, they must contact the USAID RIG Pretoria office and
exercise due professional care in pursuing indications of possible irregularities and illegal
acts so as not to interfere with potential future investigations and/or legal proceedings.
The findings contained in the reports on internal controls and compliance related to USAIDfunded programs must include a description of the condition (what is) and the criteria (what should
be). The cause (why it happened) and effect (what harm was caused by not complying with the
criteria) must be included in the findings. In addition, the findings must contain a
recommendation that corrects the cause and the condition, as applicable. It is recognized that
material internal control weaknesses and noncompliance found by the auditors may not always
have all of these elements fully developed, given the scope and objectives of the specific audit.
The auditors must, however, at least identify the condition, criteria and possible effect to enable
management to determine the cause and take timely and proper corrective action.
Findings which involve monetary effect must:
1.
Be quantified and included as questioned costs in the fund accountability statement,
the Auditor’s Report on Compliance, and cost-sharing schedule (cross-referenced).
2.
Be reported without regard to whether the conditions giving rise to them were
corrected.
3.
Be reported whether the recipient does or does not agree with the findings or
questioned costs.
4.
Contain enough relevant information to expedite the audit resolution process (e.g.,
number of items tested, size of the universe, error rate, corresponding U.S. dollar
amounts, etc.).
The reports must also contain, after each recommendation, pertinent views of responsible Subrecipient officials concerning the auditor's findings and actions taken by the Sub-recipient to
16
implement the recommendations. If possible, the auditor should obtain written comments. When
the auditors disagree with management comments opposing the findings, conclusions, or
recommendations, they should explain their reasons following the comments. Conversely, the
auditors should modify their report if they find the comments valid.
Any evidence of fraud or illegal acts that have occurred, or are likely to have occurred, must be
included in a separate written report if deemed necessary by the USAID Prime Partner Recipient.
This report must include an identification of all questioned costs as a result of irregularities or
illegal acts, without regard to whether the conditions giving rise to the questioned costs have been
corrected or whether the Sub-recipient does or does not agree with the findings and questioned
costs.
VI.
INSPECTION AND ACCEPTANCE OF AUDIT WORK AND THE REPORT
The statement of work, audit program (including detailed audit steps), and the draft report will be
subject to approval and acceptance by the USAID Prime Partner Recipient. After approval, the
draft report will be discussed with the responsible officers of the Sub-recipient.
VII.
RELATIONSHIPS AND RESPONSIBILITIES
The client for this contract is the NHP Project, whose Acting Chief of Party is Mr. Antony
Kamigwi.
The USAID Prime Partner Recipient may meet with the public accounting firm at the beginning of
the audit to explain any financial/compliance areas of concern contained in the statement of work
that they want emphasized and provide any advice concerning the performance of the audit. All
USAID Prime Partner Recipient should provide the following information to the auditors for the
entrance conference:
1.
a list of all payments made for assets, equipment, materials, and technical assistance
purchased directly by the USAID-funded Prime Partner Recipient from third parties for the
period being audited with copies of vouchers with supporting documentation;
2.
a list of all advances and recoveries made during the audit period;
3.
a list of all disbursements made to the recipient; and
The USAID-funded Prime Partner Recipient may also provide written comments on the draft audit
report concerning the facts and conclusions contained in the report in order to obtain the best
possible end product. The USAID-funded Prime Partner Recipient may also attend the exit
conference for the same purpose.
The public accounting firm must properly maintain and store the working papers for a period of
three years from the completion of the audit. During this three-year period the audit firm must
immediately provide the working papers when requested by the USAID Prime Partner Recipient,
17
USAID Mission, or USAID RIG/Pretoria. Public accounting firms that are nonresponsive or do
not provide timely responses to questions raised by the USAID Mission or USAID RIG/Pretoria
shall be temporarily or permanently excluded from performing additional USAID audits.
VIII. SUBMISSION OF OFFERS
A. Minimum Submission Criteria
Offerers are requested to submit signed and dated offers to the office specified in this
solicitation at or before the exact time specified in this solicitation. To be eligible, Offerers
must provide full, accurate, and complete information as required by this solicitation and its
attachments, including the certifications attached.
Offers may be submitted on offerer’s letterhead stationery. As a minimum, offers must include
the following components in their response to this RFP—
1) The solicitation number;
2) The time specified in the solicitation for receipt of offers;
3) The name, addresses (street, email, other), and telephone number of the Offerer;
4) A technical description/specification of the items being offered in sufficient detail to
evaluate compliance with the requirements in the solicitation. This may include product
literature, or other documents, if necessary;
5) Fee to be charged, which should clearly display in a separate line item costs associated with
VAT;
6) “Remit to” address, if different than mailing address;
7) Acknowledgment of Solicitation Amendments, if applicable;
8) Company and past performance information to include recent and relevant contracts for the
same or similar items and other references (including contract numbers, points of contact with
telephone numbers and other relevant information);
9) A statement that the Offerer has the capacity to meet the Audit requirements and within the
required timelines;
10) Certification that the quotation remains valid for a period of 120 days;
11) Signed certifications (Attachment B); and
12) Applicable registrations (local or national) as deemed appropriate or advantageous by the
bidder including certification by USAID/OIG.
B. Date and Time of Submission
All offers must be received no later than the closing date and time set forth above. Quotations
must reference the RFP number stated above and may be submitted electronically to Antony
Kamigwi (akamigwi@fhi360.org) and Danielle Darrow de Mora (ddarrow@fhi360.org).
Hard copy deliveries should be marked clearly, delivered to the address below and dropped in
to the “USAID|NHP RFP Box.” The address to which responses can be delivered is as follows:
Request for Proposal
18
USAID|NHP
Family Health International (FHI360), Chancery Building, 3rd Floor
Valley Road,
P.O. Box 38835 - 00623
Nairobi
C. Period for Acceptance of Offers
The Offerer agrees to hold the prices/fees charges in its offer firm for 120 calendar days from
the specified closing date. Offerer may withdraw offers prior to the closing date, in writing,
either via email, fax, or in hard copy.
D. Language
All offers shall be submitted in English.
E. Questions and Answers
Any explanation desired by a prospective Offerer regarding the meaning or interpretation of
this solicitation must be requested in writing to Antony Kamigwi (akamigwi@fhi360.org), and
Danielle Darrow de Mora (ddarrow@fhi360.org) no later than 10 calendar days prior to
closing date. Answers will be sent to all bidders via the contact information they provide.
Questions may also be submitted by mail.
No inquiries by phone will be accepted or
answered.
F. Certifications and Representations
Certifications and Representations are incorporated by reference in Attachment A. Submission
of offers without specific comment or objection to the terms and conditions as specified in
Attachment A shall be construed as acceptance of such terms and conditions. Failure to accept
the terms and conditions at time of award may result in award to another offeror, cancellation
of the solicitation, or a reduction in the price.
Additional certifications provided as Attachment B must be dated and signed by an authorized
officer of the offeror’s organization and submitted with the offers.
G. Source Selection
Based on the Best Value Selection Process, award will be made to the offeror.
H. Evaluation Criteria
Evaluation and ranking of proposals will be completed by an FHI 360 review committee.
Evaluation factors are apportioned by a review committee as follows:
Criteria
Max Points (90 total)
19
Organizational Capability
-Relevance of Experience with Similar Audits
-Experience with USAID-Funded Projects
Technical Proposal
-Responsiveness to RFP Specifications
-Methodology
Proposed Staff
-Proposed Staffing Level
-Experience of Proposed Staff
Cost & Budget
-Cost Competitiveness
-Budget Detail
Implementation Timeframe
20 points
30 points
10 points
20 points
10 points
I. Terms of Performance
The effective date of this contract will be the date of the audit firm’s signature. The audit must
begin as soon as practicable after the signing of the audit contract, and from the audit start date, the
audit firm must submit to the USAID Prime Partner Recipient the following:
 a complete audit program in writing within 15 calendar days,
 a draft indexed audit report in English within 90 calendar days, and
 a final audit report that includes revisions incorporating the Sub-recipients’ comments
within 120 calendar days.
It is the responsibility of the Sub-recipients to ensure that all records are available, all accounting
entries and adjustments are made, and all other necessary steps are taken to make it possible for
the audit firm to perform the work necessary to be able to present the final audit report within 60
calendar days.
Payment will be as follows: 20 percent on receiving the audit program, 40 percent on the date of
the draft report, and 40 percent on the date the USAID Prime Partner Recipient approves the final
report.
J. Authorized Geographic Code
The Authorized Geographic Code for this procurement is:
Code 935 (any area or country including the cooperating country, but excluding foreign policyrestricted countries).
K. Value Added Tax (VAT)
FHI 360 is an exempt non-profit organization and all products are produced at the request of
USAID and the Kenyan Ministry of Health. FHI 360 will oversee the processing of VAT
reimbursement to the selected producer via the approved Kenya Revenue Authority DAI
process. All price offers should clearly delineate net costs with a separate line item displaying
VAT.
20
L. Client Prior Approval
The solicited services, once an offeror has been selected, will be subject to client approval
before an order can be placed. Therefore, offerors are reminded that there may be delays for
this process to be completed. If such approval is not given, this solicitation will be cancelled.
M. Other Special Provisions
From the Initial Environmental Evaluation (IEE), NHP and its food partners fall under the
category of “Negative Determination with Conditions” and shall comply with the following
requirements:
1) Awarded bidder will ensure adherence to applicable GoK Environmental laws and policies.
2) The implementing staff shall have sufficient capacity to complete the environmental
screening process and implement monitoring and mitigation measures.
Please review Attachment C, USAID|NHP Environmental Verification Form, for further
guidelines on compliance.
Please note that this will be a fixed-price award.
Disclaimers and FHI 360 Protection Clauses
1.
FHI 360 will not compensate offerors for preparation of their response to this solicitation.
2.
Issuing this solicitation is not a guarantee that FHI 360 will award a contract.
3.
FHI 360 reserves the right to issue a contract based on the initial evaluation of offers without
discussion.
4.
FHI 360 may choose to award a contract for part of the activities in the solicitation.
5.
FHI 360 may choose to award contract to more than one offeror for specific parts of the
activities in the solicitation.
6.
FHI 360 may request from short‐listed offerors a second or third round of either oral
presentation or written response to a more specific and detailed scope of work that is based
on a general scope of work in the original solicitation.
7.
FHI 360 has the right to rescind a solicitation, or rescind an award prior to the signing of a
contract due to any unforeseen changes in the direction of FHI 360’s client, be it funding or
programmatic.
8.
FHI 360 reserves the right to waive any deviations by offerors from the requirements of this
solicitation that in FHI 360's opinion are considered not to be material defects requiring
rejection or disqualification; or where such a waiver will promote increased competition.
9.
Data produced under this solicitation belongs to FHI 360. Any distribution of data must first
have written authorization from FHI 360 or its designated representative.
21
22
Attachment A
Contract Clauses
If a purchase order is awarded it may incorporate the following Federal Acquisition
Regulations (FAR) and AID Acquisition Regulations (AIDAR) clauses by reference with the
same force and effect as if they were given in full text. The full text of the FAR and AIDAR
clauses referenced may be found at:
FAR: http://www.arnet.gov/
AIDAR: http://www.usaid.gov/policy/ads/300/aidar.pdf
GENERAL TERMS AND CONDITIONS
If this purchase order is issued under a U.S. Government Prime Contract or Cooperative
Agreement, the applicable clauses set forth below are incorporated by reference into this
agreement with the same force and effect as if they were set forth in full. A full copy of each
clause may be obtained from the FHI 360 Contracts Department. The term FAR means Federal
Acquisition Regulation, effective as of January 1, 2010. The terms, “Contractor,”
“Government” and “Contracting Officer” as used in these clauses shall refer to the
Subcontractor/Vendor, FHI 360, and the FHI 360 Contract Administrator. This agreement is
between Subcontractor/Vendor and FHI 360 only and shall not be construed in any way to
create a contractual relationship between Subcontractor/Vendor and the U.S. Government. The
Subcontractor/Vendor shall not appeal directly to the U.S. Government without the prior
written consent/concurrence of the FHI 360 Contract Administrator.
CLAUSE TITLE
Definitions
Restriction on Subcontractor Sales to the Government
Material Requirements
Liquidated Damages (1% of Contract Value/Day)
Variation in Quantity (0% applies)
Terms and Conditions – Simplified Acquisition
(Other Than Commercial Items)
Order of Precedence
Child Labor- Cooperation With Authorities and Remedies
Privacy Act Notification
Restrictions on Certain Foreign Purchases
Patent Rights – Acquisition by the Government
Rights in Data – Special Works
FAR CITE
52.202-1
52.203-6
52.211-5
52.211-11
52.211-16
52.213-4
52.215-8
52.222-19
52.224-1
52.225-13
52.227-13
52.227-17
THESE CLAUSES APPLY TO AGREEMENTS THAT EXCEED $10,000
CLAUSE TITLE
FAR CITE
Protecting Government’s Interest When Subcontracting with
52.209-6
Contracts Debarred, Suspended or Proposed for Debarment
CLAUSE TITLE
Payments
Payments – Time & Materials and Labor-Hour Contracts
Advance Payments
Disputes, Alternate I
Stop Work Order, Alternate I
Government Delay of Work
Changes-Fixed Price
Subcontracts
Subcontracts for Commercial Items/Components
Contract Not Affected By Oral Agreement
Termination For Convenience
Excusable Delays
FAR CITE
52.232-1
52-232-7
52.232-12
52.233-1
52.242-15
52.242-17
52.243-1
52.244-2
52.244-6
52.247-27
52.249-2
52.249-14
CLAUSE TITLE
Inspection of Supplies – Fixed Price
FAR CITE
52.246-2
THESE CLAUSES APPLY TO AGREEMENT FOR SERVICES
23
CLAUSE TITLE
Payments Under Time & Materials/Labor Hours Contract
Changes – Fixed Price Services, Alternate II
Changes – Time & Materials/Labor Hours
FAR CITE
52.232-7
52.243-1
52.243-3
THESE FAR CLAUSES APPLY TO AGREEMENTS THAT EXCEED $100,000
CLAUSE TITLE
FAR CITE
Certificate of Independent Price Determination
52.203-2
Gratuities
52.203-3
Anti-Kickback Procedures
52.203-7
Cancellation, Rescission, and Recovery of Funds for Illegal
52.203-8
or Improper Activities
Price or Fee Adjustment for Illegal or Improper Activity
52.203-10
Certification and Disclosure Regarding Payment to
52.203-11
Influence Certain Federal Transactions
Limitation on Payments to Influence Certain Federal Transactions
52.203-12
Certification Regarding Debarment, Suspension, Proposed
52.209-5
Debarment, and Other Responsibility Matters
Audit and Records – Negotiation
52.215-2
Integrity of Unit Prices
52.215-14
Price Re-determination – Retroactive
52.216-6
CLAUSE TITLE
Inspection of Services – Fixed Price
Inspection – Time & Materials/Labor Hours
FAR CITE
52.246-4
52.246-6
CLAUSE TITLE
Payment for Overtime Premiums
Authorization and Consent
Notice and Assistance Regarding Patent & Copyright Infringement
Federal, State, and Local Taxes
Federal, State, and Local Taxes
Interest
Competition in Subcontracting
Contractor Inspection Requirements
Inspection of Supplies - Fixed Price
Limitation of Liability
Limitation of Liability – Services
Termination of Convenience for the Government
(Fixed Price) (Short Form)
Default (Fixed-Price Supply and Service)
FAR CITE
52.222-2
52.227-1
52.227-2
52.229-3
52.229-6
52.232-17
52.244-5
52.246-1
52.246-2
52.246-23
52.246-25
52.249-1
52.249-8
THESE CLAUSES APPLY TO SUBCONTRACTS OVER $500,000
Disclosure and Consistency of Cost Accounting Practice
52.230-3
THESE CLAUSES APPLY TO USAID AGREEMENTS
CLAUSE TITLE
Organizational Conflicts of Interest After Award
Language and Measurement
Source, Origin and Nationality
Local Procurement
Insurance – Liability to Third Persons
Salary Supplements for Host Government Employees
Payments Under Time & Materials/Labor Hours Contracts
Government Property – USAID Reporting Requirements
Title To and Care of Property
Notices
Marking
AIDAR CITE
752.209-71
752.211-70
752.225-70
752.225-71
752.228-07
752.231-71
752.232-7
752.245-70
752.245-71
752.7006
752.7009
CLAUSE TITLE
Family Planning and Population Assistance Activities
Health and Accident Insurance for AID Participant Trainees
Participant Training
Changes in Tuition and Fees
Conflicts Between Contract and Catalog
Required Visa Form for AID Participants
Withdrawal of Students
Approvals
Reports
Acknowledgement and Disclaimer
Public Notices
AIDAR CITE
752.7016
752.7018
752.7019
752.7021
752.7022
752.7023
752.7024
752.7025
752.7026
752.7034
752.7035
DRUG TRAFFICKING: FHI 360 and/or the US Government reserve the right to terminate this purchase order/subcontract to demand a refund or take other appropriate
measures if the vendor/subcontractor is found to have been convicted of a narcotics offense or to have been engaged in drug trafficking as defined in 22 CFR Part 140
TERRORISM E.O. 13224: Vendor/Subcontractor agrees to take all necessary actions to comply with Executive Order No. 13224 on Terrorist Financing; blocking and
prohibiting transactions with persons who commit, threaten to commit, or support terrorism.
(E.O. 13224 text provided and also available at:
http://www.whitehouse.gov/news/releases/2001/09/20010924-1.html Note: The attachment does not include ‘Names of Those Designated’ after 23 September 2001;
therefore, you are required to obtain the updated list at the time of procurement of goods or services.
The updated list is available at:
http://treasury.gov/offices/enforcement/ofac/sanctions/terrorism.html
24
Attachment B
Additional Certifications
CERTIFICATIONS – MUST BE COMPLETED, SIGNED AND DATED BY EACH
OFFEROR AND RETURNED AS PART OF THE OFFER SUBMISSION
CERTIFICATION REGARDING TERRORIST FINANCING
By signing and submitting this application, the prospective offeror provides the certification set
out below:
The Offeror, to the best of its current knowledge, did not provide, within the previous ten years,
and will take all reasonable steps to ensure that it does not and will not knowingly provide,
material support or resources to any individual or entity that commits, attempts to commit,
advocates, facilitates, or participates in terrorist acts, or has committed, attempted to commit,
facilitated, or participated in terrorist acts, as that term is defined in paragraph 3.
The following steps may enable the Offeror to comply with its obligations under paragraph 1:
Before providing any material support or resources to an individual or entity, the Offeror will
verify that the individual or entity does not (i) appear on the master list of Specially Designated
Nationals and Blocked Persons, which list is maintained by the U.S. Treasury’s Office of
Foreign Assets Control (OFAC) and is available online at OFAC’s website:
http://www.treas.gov/offices/eotffc/ofac/sdn/t11sdn.pdf, or (ii) is not included in any
supplementary information concerning prohibited individuals or entities that may be provided
by USAID to the Offeror.
Before providing any material support or resources to an individual or entity, the Offeror also
will verify that the individual or entity has not been designated by the United Nations Security
(UNSC) sanctions committee established under UNSC Resolution 1267 (1999) (the “1267
Committee”) [individuals and entities linked to the Taliban, Usama bin Laden, or the Al Qaida
Organization]. To determine whether there has been a published designation of an individual
or entity by the 1267 Committee, the Offeror should refer to the consolidated list available
online at the Committee’s website:
http://www.un.org/Docs/sc/committees/1267/1267ListEng.htm.
Before providing any material support or resources to an individual or entity, the Offeror will
consider all information about that individual or entity of which it is aware and all public
information that is reasonably available to it or of which it should be aware.
The Offeror also will implement reasonable monitoring and oversight procedures to safeguard
against assistance being diverted to support terrorist activity.
For purposes of this Certification25
“Material support and resources” means currency or monetary instruments or financial
securities, financial services, lodging, training, expert advice or assistance, safehouses, false
documentation or identification, communications equipment, facilities, weapons, lethal
substances, explosives, personnel, transportation, and other physical assets, except medicine or
religious materials.”
“Terrorist act” meansan act prohibited pursuant to one of the 12 United Nations Conventions and Protocols related to
terrorism
(see
UN
terrorism
conventions
Internet
site:
http://untreaty.un.org/English/Terrorism.asp); or
an act of premeditated, politically motivated violence perpetrated against noncombatant targets
by subnational groups or clandestine agents; or
any other act intended to cause death or serious bodily injury to a civilian, or to any other
person not taking an active part in hostilities in a situation of armed conflict, when the purpose
of such act, by its nature or context, is to intimidate a population, or to compel a government or
an international organization to do or to abstain from doing any act.
“Entity” means a partnership, association, corporation, or other organization, group or
subgroup.
References in this Certification to the provision of material support and resources shall not be
deemed to include the furnishing of USAID funds or USAID-financed commodities to the
ultimate beneficiaries of USAID assistance, such as offerors of food, medical care, microenterprise loans, shelter, etc., unless the Offeror has reason to believe that one or more of these
beneficiaries commits, attempts to commit, advocates, facilitates, or participates in terrorist
acts, or has committed, attempted to commit, facilitated or participated in terrorist acts.
The Offeror’s obligations under paragraph 1 are not applicable to the procurement of goods
and/or services by the Offeror that are acquired in the ordinary course of business through
contract or purchase, e.g., utilities, rents, office supplies, gasoline, etc., unless the Offeror has
reason to believe that a vendor or supplier of such goods and services commits, attempts to
commit, advocates, facilitates, or participates in terrorist acts, or has committed, attempted to
commit, facilitated or participated in terrorist acts.
This Certification is an express term and condition of any agreement issued as a result of this
application, and any violation of it shall be grounds for unilateral termination of the agreement
by FHI 360 prior to the end of its term.
26
For Vendor:
Signature:
Typed Name:
Title:
Name of Organization:
Date:
27
1. ASSURANCE OF COMPLIANCE WITH LAWS AND REGULATIONS
GOVERNING NON-DISCRIMINATION IN FEDERALLY ASSISTED PROGRAMS
(per FAR 52.2222-26 Equal Opportunity. (2/99))
The Subcontractor shall comply with subparagraphs (b)(1) through (11) below.
During performing this subcontract, the Subcontractor agrees as follows:
1. The Subcontractor shall not discriminate against any employee or applicant for
employment because of race, color, religion, sex, or national origin.
2. The Subcontractor shall take affirmative action to ensure that applicants are employed,
and that employees are treated during employment, without regard to their race, color, religion,
sex, or national origin. This shall include, but not be limited to, (i) employment, (ii) upgrading,
(iii) demotion, (iv) transfer, (v) recruitment or recruitment advertising, (vi) layoff or
termination, (vii) rates of pay or other forms of compensation, and (viii) selection for training,
including apprenticeship.
3. The Subcontractor shall post in conspicuous places available to employees and
applicants for employment the notices to be provided by the Director of Contracts that explain
this clause.
4. The Subcontractor shall, in all solicitations or advertisement for employees placed by or
on behalf of the Subcontractor, state that all qualified applicants will receive consideration for
employment without regard to race, color, religion, sex, or national origin.
5. The Subcontractor shall send, to each labor union or representative of workers with
which it has a collective bargaining agreement or other contract or understanding, the notice to
be provided by the Director of Contracts advising the labor union or workers' representative of
the Subcontractor's commitments under this clause, and post copies of the notice in
conspicuous places available to employees and applicants for employment.
6. The Subcontractor shall comply with Executive Order 11246, as amended, and the
rules, regulations, and orders of the Secretary of Labor.
7. The Subcontractor shall furnish to the Secretary of Labor or OFCCP upon request all
information required by Executive Order 11246, as amended, and by the rules, regulations, and
orders of the Secretary of Labor. Standard Form 100 (EEO-1), or any successor form, is the
prescribed form to be filed within 30 days following the award, unless filed within 12 months
preceding the date of award.
8. The Subcontractor shall permit access to its books, records, and accounts by the
Secretary of Labor or the Office of Federal Contract Compliance Programs (OFCCP) for the
purposes of investigation to ascertain the Subcontractor's compliance with the applicable rules,
28
regulations, and orders.
9. If the OFCCP determines that the Subcontractor is not in compliance with this clause or
any rule, regulation, or order of the Secretary of Labor, this subcontract may be canceled,
terminated, or suspended in whole or in part and the Subcontractor may be declared ineligible
for further Government or Family Health International 360 Inc. contracts, under the procedures
authorized in Executive Order 11246, as amended. In addition, sanctions may be imposed and
remedies invoked against the Subcontractor as provided in the Executive Order 11246, as
amended, the rules, regulations, and orders of the Secretary of Labor, or as otherwise provided
by law.
10. The Subcontractor shall include the terms and conditions of subparagraph (b)(1)
through (11) of this clause in every lower-tier subcontract or purchase order that is not
exempted by the rules, regulations, or orders of the Secretary of Labor issued under Executive
Order 11246, as amended, so that these terms and conditions will be binding upon each
lower-tier Subcontractor/vendor.
11. The Subcontractor shall take such action with respect to any lower-tier subcontract or
Purchase order as Family Health International 360 Inc. may direct as a means of enforcing
these terms and conditions, including sanctions for noncompliance; provided, that if the
Subcontractor becomes involved in, or is threatened with, litigation with a lower-tier
Subcontractor or vendor as a result of any direction, the Subcontractor may request Family
Health International 360 Inc. to enter into the litigation to protect the interests of Family Health
International 360 Inc. and of the United States.
Notwithstanding any other clause herein, disputes relative to this clause will be governed by the
procedures in 41 CFR 60-1.1.
For Vendor:
Signature:
Typed Name:
Title:
Name of Organization:
Date:
29
2. CERTIFICATION REGARDING DEBARMENT, SUSPENSION, AND OTHER
RESPONSIBILITY MATTERS -- PRIMARY COVERED TRANSACTIONS
(a)
Instructions for Certification
1.
By signing and submitting this proposal, the prospective primary participant is
providing the certification set out below.
2.
The inability of a person to provide the certification required below will not necessarily
result in denial of participation in this covered transaction. The prospective participant shall
submit an explanation of why it cannot provide the certification set out below. The
certification or explanation will be considered in connection with the department or agency’s
determination whether to enter into this transaction. However, failure of the prospective
primary participant to furnish a certification or an explanation shall disqualify such person from
participation in this transaction.
3.
The certification in this clause is a material representation of fact upon which reliance
was placed when the department or agency determined to enter into this transaction. If it is
later determined that the prospective primary participant knowingly rendered an erroneous
certification, in addition to other remedies available to the Federal Government, the department
or agency may terminate this transaction for cause or default.
4.
The prospective primary participant shall provide immediate written notice to the
department or agency to whom this proposal is submitted if at any time the prospective primary
participant learns that this certification was erroneous when submitted or has become erroneous
by reason of changed circumstances.
5.
The terms “covered transaction,” “debarred,” “suspended,” “ineligible,” “lower tier
covered transaction,” “participant,” “person,” “primary covered transaction,” “principal,”
“proposal,” and “voluntarily excluded,” as used in this clause, have the meaning set out in the
Definitions and Coverage sections of the rules implementing Executive Order 12549. You may
contact the department or agency to which this proposal is being submitted for assistance in
obtaining a copy of those regulations.
6.
The prospective primary participant agrees by submitting this proposal that, should the
proposed covered transaction be entered into, it shall not knowingly enter into any lower tier
covered transaction with a person who is debarred, suspended, declared ineligible, or
voluntarily excluded from participation in this covered transaction, unless authorized by the
department or agency entering into this transaction.
7.
The prospective primary participant further agrees by submitting this proposal that it
will include the clause titled “Certification Regarding Debarment, Suspension, Ineligibility and
Voluntary Exclusion--Lower Tier Covered Transaction,” provided by the department or agency
entering into this covered transaction, without modification, in all lower tier covered
30
transactions and in all solicitations for lower tier covered transactions.
8.
A participant in a covered transaction may rely upon a certification of a prospective
participant in a lower tier covered transaction that it is not debarred, suspended, ineligible, or
voluntarily excluded from the covered transaction, unless it knows that the certification is
erroneous. A participant may decide the methods and frequency by which it determines the
eligibility of its principals. Each participant may, but is not required to, check the
Nonprocurement List.
9.
Nothing contained in the foregoing shall be construed to require establishment of a
system of records in order to render in good faith the certification required by this clause. The
knowledge and information of a participant is not required to exceed that which is normally
possessed by a prudent person in the ordinary course of business dealing.
10.
Except for transactions authorized under paragraph 6 of these instructions, if a
participant in a covered transaction knowingly enters into a lower tier covered transaction with
a person who is suspended, debarred, ineligible, or voluntarily excluded from participation in
this transaction, in addition to other remedies available to the Federal Government, the
department or agency may terminate this transaction for cause or default.
(b)
Certification Regarding Debarment, Suspension, and Other Responsibility Matters-Primary Covered Transactions
(1)
The prospective primary participant certifies to the best of its knowledge and belief, that
it and its principals:
(A)
Are not presently debarred, suspended, proposed for debarment, declared ineligible, or
voluntarily excluded from covered transactions by any Federal department or agency;
(B)
Have not within a three-year period preceding this proposal been convicted of or had a
civil judgment rendered against them for commission of fraud or a criminal offense in
connection with obtaining, attempting to obtain, or performing a public (Federal, State or local)
transaction or contract under a public transaction; violation of Federal or State antitrust statutes
or commission of embezzlement, theft, forgery, bribery, falsification or destruction of records,
making false statements, or receiving stolen property;
(C)
Are not presently indicted for or otherwise criminally or civilly charged by a
governmental entity (Federal, State or local) with commission of any of the offenses
enumerated in paragraph (1)(B) of this certification;
(D)
Have not within a three-year period proceeding this application/proposal had one or
more public transactions (Federal, State or local) terminated for cause or default.
Where the prospective primary participant is unable to certify to any of the statements in this
certification, such prospective participant shall attach an explanation to this proposal.
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For Vendor:
Signature:
Typed Name:
Title:
Name of Organization:
Date:
32
3. CERTIFICATION REGARDING DEBARMENT, SUSPENSION, INELIGIBILITY
AN VOLUNTARY EXCLUSION – LOWER TIER COVERED TRANSACTIONS
(Code of Federal Regulations 22 CFR 208: Government-wide Debarment and Suspension
(Nonprocurement) and Government-wide Requirements for Drug-Free Workplace (Grants);
Appendix B: Certification Regarding Debarment, Suspension, Ineligibility and Voluntary
Exclusion – Lower Tier Covered Transactions
Instructions for Certification: By signing and submitting this proposal, the prospective lower
tier participant is providing the certification set out below.
2.
The certification in this clause is a material representation of fact upon which reliance
was placed when this transaction was entered into. If it is later determined that the prospective
lower tier participant knowingly rendered an erroneous certification, in addition to other
remedies available to the Federal Government, the department or agency with which this
transaction originated may pursue available remedies, including suspension and/or debarment.
3.
The prospective lower tier participant shall provide immediate written notice to the
person to which this proposal is submitted if at any time the prospective lower tier participant
learns that its certification was erroneous when submitted or has become erroneous by reason
of changed circumstances.
4.
The terms Covered transaction, Debarred, Suspended, Ineligible, Lower tier covered
transaction, Participant, Adperson, Primary covered transaction, Principal, Proposal, and
Voluntary excluded, as used in this clause, has the meanings set out in the Definitions and
Coverage sections of rules implementing Executive Order 12549. You may contact the person
to which this proposal is submitted for assistance in obtaining a copy of those regulations.
5.
The prospective lower tier participant agrees by submitting this proposal that, should
the proposed covered transaction be entered into, it shall not knowingly enter into any lower
tier covered transaction with a person who is debarred, suspended, declared ineligible, or
voluntarily excluded from participation in this covered transaction, unless authorized by the
department or agency with which this transaction originated.
6.
The prospective lower tier participant further agrees by submitting this proposal that it
will include this clause titled Certification Regarding Debarment, Suspension, Ineligibility and
Voluntary Exclusion--Lower Tier Covered Transaction,@ without modification, in all lower
tier covered transactions and in all solicitations for lower tier covered transactions.
7.
A participant in a covered transaction may rely upon a certification of a prospective
participant in a lower tier covered transaction that it is not debarred, suspended, ineligible, or
voluntarily excluded from the covered transaction, unless it knows that the certification is
erroneous. A participant may decide the method and frequency by which it determines the
eligibility of its principals. Each participant may, but is not required to, check the Non33
Procurement List.
8.
Nothing contained in the foregoing shall be construed to require establishment of a
system of records in order to render in good faith the certification required by this clause. The
knowledge and information of a participant is not required to exceed that which is normally
possessed by a prudent person in the ordinary course of business dealings.
9.
Except for transactions authorized under paragraph 5 of these instructions, if a
participant in a covered transaction knowingly enters into a lower tier covered transaction with
a person who is suspended, debarred, ineligible, or voluntarily excluded from participation in
this transaction, in addition to other remedies available to the Federal Government, the
department or agency with which this transaction originated may pursue available remedies,
including suspension and/or debarment.
Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion--Lower
Tier Covered Transactions:
(1)
The prospective lower tier participant certifies, by submission of this proposal, that
neither it nor its principals is presently debarred, suspended, proposed for debarment, declared
ineligible, or voluntarily excluded from participation in this transaction by any Federal
department or agency.
(2)
Where the prospective lower tier participant is unable to certify to any of the statements
in this certification, such prospective participant shall attach an explanation to this proposal.
For Vendor:
Signature:
Typed Name:
Title:
Name of Organization:
Date:
34
4. CERTIFICATION REGARDING A DRUG-FREE WORKPLACE
(a)
Definitions. As used in this provision,
"Controlled substance" means a controlled substance in schedules I through V of
section 202 of the Controlled Substances Act (21 U.S.C 812) and as further defined in
regulation at 21 CFR 1308.11-1308.15.
"Conviction" means a finding of guilt (including a plea of novo contender) or imposition of
sentence, or both, by any judicial body charged with the responsibility to determine violations
of the Federal or State criminal drug statutes.
"Criminal drug statute" means a Federal or non-Federal criminal statute involving the
manufacture, distribution, dispensing, possession or use of any controlled substance.
"Drug-free workplace" means the site(s) for the performance of work done by the Contractor in
connection with a specific contract at which employees of the Contractor are prohibited from
engaging in the unlawful manufacture, distribution, dispensing, possession, or use of a
controlled substance.
"Employee" means an employee of a Contractor directly engages in the performance of work
under a Government contract. Directly engaged is defined to include all direct cost employees
and any other Contractor employee who has other than a minimal impact or involvement in
contract performance.
"Individual" means and or/contractor that has no more than one employee including the
contractor.
(b)
By submission of its , the or, if other than an individual, who is making an that equals
or exceeds $25,000, certifies and agrees, that with respect to all employees of the or to be
employed under a contract resulting from this solicitation, it will - no later than 30 calendar
days after contract award (unless a longer period is agreed to in writing), for contracts of 30
calendar days of more performance duration; or as soon as possible for contracts of less than 30
calendar days performance duration, but in any case, by a date prior to when performance is
expected to be completed-(1)
Publish a statement notifying such employees that the unlawful manufacture,
distribution, dispensing, possession or use of a controlled substance is prohibited in the
Contractor's workplace and specifying the actions that will be taken against employees for
violations of such prohibition;
a.
Establish an ongoing drug-free awareness program to inform such employees about(i) The dangers of drug abuse in the workplace;
35
(ii) The Contractor's policy of maintaining a drug-free workplace;
(iii) Any available drug counseling, rehabilitation, and employee assistance programs; and
(iv) The penalties that may be imposed upon employees for drug abuse violations occurring in
the workplace;
b.
Provide all employees engaged in performance of the contract with a copy of the
statement required by subparagraph (b) (1) of this provision;
(4)
Notify such employees in writing in the statement required by subparagraph (b)
(1) of this provision that, as a condition of continued employment on the contract resulting
from this solicitation, the employee will (i)
Abide by the terms of the statement; and
(ii)
Notify the employer in writing of the employee's conviction under a criminal drug
statute for a violation occurring in the workplace no later than 5 calendar days after such
conviction;
(5)
Notify the Contracting Officer in writing within 10 calendar days after receiving
notice under subdivision (b)(4)(ii) of this provision, from an employee or otherwise receiving
actual notice of such conviction. The notice shall include the position title of the employee; and
(6)
Within 30 calendar days after receiving notice under subdivision (b)(4)(ii) of
this provision of a conviction, take one of the following actions with respect to any employee
who is convicted of a drug abuse violation occurring in the workplace:
(i)
Take appropriate personnel action against such employee, up to and including
termination; or
(ii)
Require such employee to satisfactorily participate in a drug abuse
assistance or rehabilitation program approved for such purposes by a Federal, State, or local
health, law enforcement, or other appropriate agency.
(7)
Make a good faith effort to maintain a drug-free workplace through
implementation of subparagraphs (b)(l) through (b)(6) of this provision.
(c)
By submission of its , the or, if an individual who is making an of any dollar value,
certifies and agrees that the or will not engage in the unlawful manufacture, distribution,
dispensing, possession, or use of a controlled substance in the performance of the contract
resulting from this solicitation.
(d)
Failure of the organization to provide the certification required by paragraph (b) or (c)
of this provision, renders the organization unqualified and ineligible for award. (See FAR
9.104-l(g) and 19.602-l(a)(2)(i).)
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(e)
In addition to other remedies available to the Government, the certification in
paragraphs (b) or (c) of this provision concerns a matter within the jurisdiction of an agency of
the United States and the making of a false, fictitious, or fraudulent certification may render the
maker subject to prosecution under Title 18, United States Code, Section 1001.
For Vendor:
Signature:
Typed Name:
Title:
Name of Organization:
Date:
37
5. CERTIFICATION OF INDEPENENT PRICE DETERMINATION
The offeror certifies that—
The prices in this offer have been arrived at independently, without, for the purpose of
restricting competition, any consultation, communication, or agreement with any other offeror,
including but not limited to subsidiaries or other entities in which offeror has any ownership or
other interests, or any competitor relating to (i) those prices, (ii) the intention to submit an
offer, or (iii) the methods or factors used to calculate the prices offered;
The prices in this offer have not been and will not be knowingly disclosed by the offeror,
directly or indirectly, to any other offeror, including but not limited to subsidiaries or other
entities in which offeror has any ownership or other interests, or any competitor before bid
opening (in the case of a sealed bid solicitation) or contract award (in the case of a negotiated
or competitive solicitation) unless otherwise required by law; and
No attempt has been made or will be made by the offeror to induce any other concern or
individual to submit or not to submit an offer for the purpose of restricting competition or
influencing the competitive environment.
Each signature on the offer is considered to be a certification by the signatory that the
signatory—
Is the person in the offeror's organization responsible for determining the prices being offered
in this bid or proposal, and that the signatory has not participated and will not participate in any
action contrary to subparagraphs (a)(1) through (a)(3) above; or
(i) Has been authorized, in writing, to act as agent for the principals of the offeror in certifying
that those principals have not participated, and will not participate in any action contrary to
subparagraphs (a)(1) through (a)(3) above;
(ii) As an authorized agent, does certify that the principals of the offeror have not participated,
and will not participate, in any action contrary to subparagraphs (a)(1) through
(a)(3) above; and
(iii) As an agent, has not personally participated, and will not participate, in any action
contrary to subparagraphs (a)(1) through (a)(3) above.
Offeror understands and agrees that —
(1) Violation of this certification will result in immediate disqualification from this
solicitation without recourse and may result in disqualification from future solicitations; and
(2) discovery of any violation after award to the offeror will result in the termination of the
award for default.
38
For Vendor:
Signature:
Typed Name:
Title:
Name of Organization:
Date:
39
Attachment C
NHP Initial Environmental Evaluation Criteria
USAID|NHP Activities under SO3 funding
USAID|NHP (Nutrition and HIV Program) activities that may impact on the environment:
a) Procurement, storage, management and disposal of public health commodities (Service
provision)
i) Food bags
Clients enrolled in Food By Prescription (FBP) program receive supplemental and therapeutic
foods that are packaged in plastic bags. These materials are not bio-degradable and they may
impact on the environment if not disposed of in an appropriate manner or recycled.
ii) WaterGuard® bottles
NHP provides Point of Use Water Disinfectants (PoUWD) to clients who cannot access clean
water. These disinfectants are packaged in plastic bottles.
iii) Fortified Blended Flours (expired)
Apart from the food bags, expired food may also impact the environment its disposal may
involve burning (as per Public Health Act).
b) Training activities (a ‘categorically excluded’ activity by itself)
NHP conducts training to build capacity of FPB service providers. These activities are
conducted in venues across the country (usually hotels and other appropriate training venues).
Provision of these services might impact on the environment due to wastes generated during
these events.
c) Monitoring (falls under document and information transfer- categorically excluded)
Though ‘categorically excluded’, monitoring activities might have some slight impact on the
environment. Data are recorded on forms printed on paper. Several forms (tools) are currently
in use by the project. Printing of data capture forms would impact on the environment.
d) Other activities (production of food supplements)
Insta Products EPZ Ltd is responsible for maintaining environment protection standards
including waste disposal according to the public health act.
e) Other activities (transportation of commodities)
Lorries are used to deliver food to sites. Use of fossil fuels results in fumes that directly pollute
the environment.
f) Other activities (preparation of food)
Use of fossil fuels and wood in cooking prescribed foods could impact on the
environment if the cooking time is much longer than recommended.
40