Annual Review of Strengthening Transparency, Accountability and Responsiveness (STAR) in Ghana Narrative Report Taaka Awori Richard Johnson John Rowley April 2012 Acronyms and Abbreviations CB Capacity Building CEIA Centre for Environmental Impact Analysis CIDA Canadian International Development Agency CSO Civil Society Organisation CSP Civil Society Platform CSGF Civil Society Governance Fund DPs Donor Partners EOI Expression of Interest FC Funders Committee GESI Gender and Social Inclusion GP Grant Partners G-RAP Ghana Research and Advocacy Programme IT Information Technology KITE Kumasi Institute of Technology and Environment M&E Monitoring and Evaluation POSDEV Pan-African Organization for Sustainable Development PMT Programme Management Team QA Quality Assurers RAVI Rights and Voice Initiative RI Results Initiative SC Steering Committee SP Service Providers STAR Strengthening Transparency Accountability and Responsiveness TA Technical Advisors TOR Terms of Reference USAID United States Agency for International Development VFM Value for Money Table of Contents 1 Background 1 2 Review Objectives 2 3 Review Process 2 4 Progress Against Expected Results 3 5 Monitoring and Evaluation 9 6 Value for Money 10 7 Implementation Strategies 13 8 Governance and Management 16 9 Conclusion 19 STAR-Ghana Annual Review Narrative Report ________________________________________________________ 1. Background STAR-Ghana is a five-year multi-donor pooled funding mechanism aimed at increasing the influence of civil society and Parliament in the governance of public goods and service delivery. The ultimate goal is to improve the accountability and responsiveness of Ghana’s government, traditional authorities and the private sector. STAR-Ghana builds on previous programmes such as: Rights and Voice Initiative (RAVI) (2004-2010) Ghana Research and Advocacy Programme (G-rap) (2005-2011) KASA (2008-2010); and the Civil Society Governance Fund (CSGF) (2004-2010). Ghana has achieved significant reduction in income poverty and progress in consolidating democracy. However, deficits in accountability institutions persist and the responsiveness of these institutions to the provision of basic services is low. There is also evidence of high public demand for accountability but this is insufficiently aggregated. STAR-Ghana has therefore commenced at a very critical time in the country’s progress towards middle income status. Oil revenues are likely to influence foreign aid flows, particularly allocations to budget support. Windfall oil revenues typically strain political institutions and reduce accountability incentives. Effective momentum to bring about real pro-poor policy change requires the mobilisation of sustained constituencies external to government. Following on from the achievements of the four earlier funding mechanisms, there is need to institutionalise, strengthen and improve further the role that CSOs and Parliament play in influencing the way government does business. There is therefore the need to support Ghana’s objectives to address accountability and responsiveness deficits even more broadly and in more depth. The programme impact of STAR is therefore to increase the accountability and responsiveness of government, traditional authorities, and private enterprise to Ghanaian citizens. The outcome is to increase the influence of CSOs and Parliament in the governance of public goods and service delivery. The Programme is focused on delivering the following Outputs: Increase capability of CSOs to enable citizens- particularly women and excluded groups to claim rights. Enhanced civil society engagement in policy formulation, implementation and monitoring Increased use of civil society evidence in policy and practice Improved representative oversight and lawmaking functions of selected parliamentary committees 2. Review Objectives The overall purpose of this first annual review of STAR was to assess and score the progress that the programme has made towards achieving its purpose. More specifically, the review was expected to: assess progress against expected results as stated in the programme log-frame, considering each indicator and respective Year 1 milestones and including evidence and implications for the programme. assess the effectiveness of the programme in capturing and monitoring results and providing and using evidence of progress. assess the programme’s performance on value for money, considering measures put in place at - and between - programme and grant partners. assess the overall effectiveness of programme implementation, drawing lessons and making recommendations for future programming and implementation; assess the efficacy of the programme’s governance and management arrangements (including financial management). 3. Review Process The review was conducted by a team of three consultants1 and a DFID Zambia Accountability Adviser2 from January 16th to February 2nd 2012. The process included consultations with the STAR Programme Management Team, Grant Partners, CSOs who had applied for but did not receive STAR funding, Members of the Steering Committee, all Development Partners, staff of Coffey (the lead Partner in the implementing Consortium ), members of the other Consortium partners, and various Service Providers. Meetings were held in Accra and in Tamale where many of the Grant Partners are based. For a list of people and organizations met, please see Annex 5 to this report. The process also consisted of a review of a significant amount of documentation from STAR including PMT inception and monitoring reports, Grant partner reports, financial data, reports from the service providers, media reports on GP activities, applications and proposals of select GPs and evaluations and project completion reports of STAR’s predecessors. 1 2 Taaka Awori, Richard Johnson and John Rowley. Mulima Akapelwa. The process of conducting the annual review has not been without its challenges. STAR is a large and complex programme. The documentation is immense and the stakeholders are many. There is only so much that can be covered in a mission period of a little over two weeks. For this reason, this review and this narrative report in particular only seek, under each of TOR areas, to capture significant achievements and issues where corrective action is urgently needed. A deliberate effort was made to keep this report short and simple. Further details of many of the issues raised herein can be found in the Annexes on Monitoring and Evaluation, Value for Money and Governance contained in Volume II to this report. It is strongly recommended that these Annexes are carefully read by the Programme Management Team who will be responsible for taking forward the recommendations. Other stakeholders such as the Development Partners and Steering Committee who want to better understand specific issues raised in this report, should read the relevant sections of the annexes. 4. Progress against Expected Results Overall the Review team was impressed by the significant amount of work that has gone into setting up STAR in a very short period of time. Significant achievements include: » Awarding grants to 40 organisations in the Results Initiative (RI) and Oil and Gas Calls (during inception) and launching three additional calls on elections, education and sustainability within education. » Supporting organisations to conduct capacity self-assessments and following this up with support from Quality Assurers, M&E Service Providers and Change Facilitators to work with grant partners. » Conducting comprehensive Political Economy Analyses (PEA) of Ghana in general and the education sector in particular. » Developing programme strategies for capacity building, sustainability, gender and social inclusion (GESI) and work with Parliament and the media. » Establishing governance structures which include a Steering Committee of eminent Ghanaians with significant and diverse expertise. » Developing an M&E framework and baseline for the log frame. These achievements notwithstanding, DFID requires that the log frame is the framework against which STAR’s progress is measured. While using the log frame to measure progress is a commonly-used and objective benchmark for assessment, it is limited in that the process can appear to be rather mechanistic, i.e. you are primarily asking whether the milestone was met or not? In addition, the assessment is dependent on the quality of the log frame and the milestones set. To address these limitations, the recommendations provided in this section go beyond the narrow review of milestones to look more broadly at the progress made towards the outputs. a. Output 1: Capability of CSOs Output 1: Capability of grant partners to enable citizens, particularly women, children, and excluded groups, to claim rights increased. The Review Team found that the Output “moderately did not meet expectation”3. The milestones for the first and second indicators in terms of grant partners capability and number of public actions to demand citizens’ rights were achieved. However, the milestone was not achieved for the third indicator which is: “the number of grant partners reporting increased number of constituents particularly women, children and vulnerable groups claiming specific rights at local and national levels.” This third milestone is at the heart of the output which in practice means citizens increasingly claiming their own rights rather than civil society organizations (CSOs) claiming rights on their behalf. A good example of this approach is reflected in the work of the Center for Environmental Impact Analysis (CEIA) which empowered the residents of Tarkwa Nsuaem Municipality and Prestea Huni Valley District to address the detrimental effects of mining on their health. STAR and Grant Partner reports indicate only 9 organisations made significant efforts to empower men and women across the sector which was well below the rather ambitious target of 41. Included within the 9 organisations were the Kumasi Institute of Technology and Environment (KITE) who trained and facilitated citizens of Jomoro District to contribute to the development of the District Medium Term Development Plan and the Pan-African Organization for Sustainable Development (POSDEV) which worked with queen mothers and other women’s groups to become more involved in leadership within local government. To ensure achievement of the output in the future, the Review Team recommends that STAR should: 1. Include approaches and tools that nurture the direct agency of citizens, particularly women and excluded groups, within GP capacity building. This would include conscientization of constituents so that they see themselves as agents of change and rights holders rather than victims or beneficiaries; training and equipping constituents with sufficient information so that they can engage directly with duty bearers and creating safe and empowering spaces and process for the engagement between constituents and duty bearers.4 Best practices in this respect could be shared amongst organizations during the thematic learning festivals. 2. Ensure that CSO capability to nurture the direct agency of constituents is included in the results framework of GPs. 3 This is the terminology used in the DFID annual review template which this narrative report has adopted to ensure consistency. 4 For further information and examples of this see: Samuel, J (2002): What is People-Centered Advocacy, PLA Notes, 43: 9-12 at www.planotes.org/documents/plan_04302.pdf. b. Output 2: Grant Partner Engagement Output 2: Grant partner engagement in policy formulation, implementation, and monitoring enhanced. The Review Team found that the Output moderately exceeded expectations as follows: Indicator 2.1 - No. of partners demonstrating support to public access (including private sector) to budget, policy, and performance information. Year 1 Milestone - 25 Grant partners. Most of the 41 GPs have included public awareness of government policies and/or budget as part of their activities. Indicator 2.2 - No. of representations and submissions made by grant partners to Parliament for changes to policy, implementation, and legislation particularly in ensuring gender equality and social inclusion. Year 1 Milestone - 7 representations and submissions to Parliament. 15 presentations were made to Parliament by GPs. Indicator 2.3 - Effective monitoring initiatives undertaken by grant partners that improve accountability and responsiveness of government, private sector and traditional authorities. Year 1 Milestone - 11 initiatives undertaken by GPs. STAR and GP reports indicate 12 monitoring initiatives have been undertaken. Undoubtedly, progress achieved against this output built on significant work undertaken by CSOs before STAR. This is because the Results Initiative Call was designed to support work that had begun under STAR’s predecessors but needed additional funding for results to be achieved. Grant Partners who are beginning new initiatives may not be able to achieve the same results in the grant period. Experience in Ghana and elsewhere has shown that CSO influencing of Government is more effective when engagement is consistent (rather than one-offs) and when trust is present in the relationships. Ensuring consistent engagement and developing relationships is much easier when CSOs have formal spaces for encounters. This also ensures that CSO access to government is not dependent on the goodwill of one public servant. Some of these spaces exist, like the education sector working group but are not effectively utilized by CSOs. In the next year, STAR should encourage the education grant partners to work with the other education CSOs to effectively use this space. At the District level, STAR could explore with grant partners within a particular theme what mechanism would be appropriate to ensure regular and consistent follow up on their engagement with the District Assembly and how they could best lobby for the creation of such a mechanism. Furthermore, to ensure that CSO engagement with Government has an aggregate impact, linkages have to be made between work at the national and the local level. In all its calls, STAR has encouraged GPs to form coalitions and alliances to maximize the impact of their work. However, GPs expressed concerns about these networks, which some claim are primarily formed to access funding rather than formed around genuine commitment to a shared vision. Either through the upcoming learning festivals or GP conventions, STAR should encourage a frank dialogue amongst GPs about the challenges in national-local networking. The dialogue should include lesson learning from national local platforms which are commonly cited as having been successful, such as the Civil Society Platform on Oil and Gas and the Ghana Federation of the Disabled advocacy on the 2% of the District Assembly Common Fund (DACF) for Persons with Disabilities. Individualized support to GPs should also be provided on this issue through PMT technical support and the Quality Assurers. In this respect, the Review Team recommends that STAR should: 1. Support GPs to effectively use or lobby for formal spaces for engagement with Government at both national and local level where there can be consistent follow up on issues raised and relationships of trust can be developed. 2. Encourage a frank dialogue and lesson learning amongst GPs on how to conduct effective national - local networking. 3. Provide technical support to GPs to strengthen work in coalitions particularly those involving national and local CSOs. c. Output 3: Use of Civil Society Evidence Output 3: Increased use of civil society evidence in policy and practice The Review team found that the output met expectations as follows: Indicator 3.1 - Number of GPs generating critical evidence on policy issues and practices. Year 1Milestone - 10 grant partners. STAR and GP reports indicate 15 GP generating critical evidence. Indicator 3.2 - Number of different actions undertaken by GPs to make available evidence from their work to policy makers and implementers. Year 1 Milestone - 35 actions undertaken. The STAR reports that 35 actions were undertaken and a review of documentation during this annual review indicates that this is about right. Indicator 3.3 - Number of GPs whose evidence has been taken up in policy making and implementation around STAR-Ghana’s thematic priorities. Year 1 Milestone - 11 GPs. The STAR report indicates that 11 GPs have had their evidence taken up and review of documentation during this annual review indicates that this is about right. Again, success in meeting the output milestones can be probably attributed to previous work undertaken by the GPs.5 In order to sustain these achievements, STAR will have to support the new grant partners to use more innovative and politically astute strategies. STAR’s project memorandum recognizes that the following four factors are important in determining CSO influence on policy outcomes: (i) the existence and strength of alliances between organisations representing those affected, their support groups, reformers within government and elected representatives; (ii) the quality of research and documentation on problems and proposed solutions; (iii) a skilled combination of popular mobilisation and public pressure (with lobbying and the use of political access where it exists); and (iv) the employment of the media to influence public opinion, increase awareness of rights and responsibilities and change the terms of debate. The evidence reflects that to date GPs have not effectively used the right combination of popular mobilisation, media engagement and alliance building to achieve their advocacy objectives. Particularly in the run up to elections where the attention of both Parliament and Government are on campaigning, it will be critical for GPs to very strategic and tactical in their choice of strategies. STAR can provide support to grant partners in this respect through the learning festivals, peer learning and coaching from the Quality Assurers. In this respect, the Review Team recommends that STAR should: Support GPs to use more politically astute strategies for influencing government particularly in the run up to elections. This would include strategic engagement with the political machinery and leadership of the 3-4 major political parties, careful use of the media and reframing constituents as voters rather than beneficiaries and encouraging constituents to engage with political aspirants as voters on the critical issues. d. Output 4: Strengthened Parliamentary functions Output 4: Strengthened legislative, oversight and representative functions of Parliament in relation to priority issues identified by STAR-Ghana. The Review team found that Output substantially did not meet expectations as follows: 5 It should also be noted that the milestones set in this output were more realistic than in other outputs. Output indicator 4.1 - Committees’ improved access to information for legislation. Year 1 Milestone - Committee work plans in place. Committees have draft work plans but these will require significant work to be completed. Output indicator 4.2 - Committees have conducted increased oversight activities. Year 1 Milestone - Committees have plans that contain efficient oversight actions. Some oversight activities are included in the Committees’ work plans. However, as noted previously, these plans still require significant work to be completed. Output indicator 4.3 - Number and outcomes of Parliamentary interactions with citizens at all levels. Year 1 Milestone is 3 out of six committees are proactively engaging with citizens. Since action plans are yet to be finalized, Committees have not begun to engage citizens based on these plans. The difficulty in achieving the targeted results for this output reflects how time consuming it is to work with Parliament in a manner that is owned and driven by the institution. Currently the main instrument STAR is using is Technical Assistance. The review team was not convinced whether the current level and mix of local TA will enable STAR to achieve its targets with respect to Parliament and there are similar concerns within the PMT. There was insufficient time for the team to study the issue in detail and propose an alternative set-up but we would encourage STAR, with support from the international TA on Parliament to review current arrangements and develop a revised plan for discussion at the next STAR global retreat. The Addendum to STAR’s Parliamentary Strategy reflects a very wise re-consideration of planned activities for this year given impending elections. Given the experience to date, the list of planned activities still seems too ambitious. What may be more realistic is to prioritise on the Committees work stream: (i) finalization of the work plans; and (ii) reflections on the 5th Parliament. On the work stream with the Parliamentary Service, STAR should concentrate on: (i) Preparation of the Induction Programme for new MPs; (ii) Development of Committee Specific Resource Manuals which would be critical for the new MPs; and (iii) the Speaker Breakfast Forum which could address pressing legislative issues of current GPs such as the Right to Information Bill, the Mental Health Bill and the Property Rights of Spouses Bill. Finally, despite the efforts of STAR to ensure a connection between the Committees and the Education GPs, the draft work plans don’t currently reflect a very strong linkage. One option to address this gap is for STAR to facilitate an interface between GPs and the committees on education and women and children in particular to present some of the issues they are working on and explore how Parliament can be of support. In this respect, the Annual Review Team recommends that STAR should: 1. Review the nature and level of TA required to achieve the Parliamentary work stream objectives and present a revised plan during the next global retreat in this respect. 2. Scale-down the level of planned activities for Parliament given impending national elections. 3. Strengthen the link between Committees and the work of Education GPs. 5. Monitoring & Evaluation The TORs for the Annual Review asked the Review Team to: “assess the effectiveness of the programme in capturing and monitoring results and providing and using evidence of progress.” The following section provides the key findings and recommendations in this respect. A more detailed discussion of M&E can be found at Annex 2 to this report. The Review Team found: »Good focus on results: Overall, the methods developed and applied oblige grant partners to pay attention to results. The tools are effective and the focus on results that appears in project proposals results frameworks and quarterly reports is appropriate. »Significant support to M&E. The focus on M&E as the first area for capacity strengthening was justified. The Review team were able to talk to all four of the Service Providers in M&E and a number of grant partners who had taken part in the training provided. All the grant partners met during the review said that the support in M&E from the Service Providers was excellent and much appreciated. The same very positive appreciation was heard about the results days that were carried out in Accra during the Review. »Variable quality in quarterly reports - The quarterly reports from GPs are a key element of M&E and a major source of information for reporting on the log frame. The management of the quarterly reports is therefore essential to the success of the M&E. The reports seen during this review are variable in quality. The best are very good whilst the poor reports contain all the common difficulties that are routinely encountered in project reports. These include the confusion between impact indicators and the completion of activities; assertions of impact with no corroborating evidence; and high expectations that do not relate to the level of activity. It was also observed that a significant number of quarterly reports contain sections that have not been completed. Nevertheless some of the quarterly reports conform to the requirements of the form and demonstrate a complete grasp of results based approaches and contain excellent recording of milestones and accounts of changes. They are among the best results based project reports seen and could be used directly at any level of reporting. »Rejections, budget slashing, reporting needs put pressure on relationships. . The question of management of relationships comes out of interviews with GPs which raised a number of concerns over the quality of communications and understanding between STAR-Ghana and GPs. The very demanding applications procedures; the capacity self-assessments; the rejections of proposals; the budget slashing and the demands of the reporting formats all caused GPs difficulties. These difficulties were not mitigated by good relationships which might have helped communication and understanding. The biggest concern comes from comments which suggest that GPs may choose not to raise questions with STAR-Ghana for fear of negative repercussions. »Log frame seems incomplete and hard to use. There is a need for a further reworking of the log frame which contains a number of difficulties. Overall there is a need to follow the convention that the programme should be able to take responsibility for success at output levels and that it should be easy to make the connection between success at output and outcome levels. The question should be asked: Is a GP able to do this? If yes, then it may be an output. If success requires others to act as well as the GP then in may be an outcome. Currently there is a mix of indicators with some apparently too close to the completion of activities and some too far removed (and too close to being outcomes) which may create problems for the programme in later reviews. »Theory of Change requires strengthening: The Inception Report describes Theory of Change (TOC) which is centred on a description of a Government Business Cycle (GBC) and shows where pressure can be applied to the theoretical and actual processes involved in that cycle. The main point that comes out of the presentation of the GBC is a concern to improve as many elements in the cycle as possible. This is to avoid the perceived problem that too much CSO activity is focused on advocacy for policy change which is not followed up by sufficient work on implementation and monitoring of government performance. This description is not a complete theory of change for STAR because it does not show how the various actions of the programme lead to changes that lead to the impacts that the project is intended to contribute to. Based on these findings, the Review Team recommends that STAR should: 1. Dedicate time in the next year, with professional help if needed, to reflect on how to strengthen relationships between the various stakeholders of STAR, particularly between the PMT, applicants and grant partners. 2. Review and develop for approval a revised Log frame and attendant Theory of Change at the next Global Retreat. 6. Value for Money The TORs for the Annual Review asked the Review Team to: “assess the programme’s performance on value for money, considering measures put in place at - and between programme and grant partners.” As with the section on M&E, this section provides the key findings and recommendations with respect to Value for Money. A more detailed discussion of STAR’s performance on value for money is provided in Annex 3. The Review Team found: »STAR has a deeply integrated approach to VfM and effectiveness. STAR has put Value for Money at the core of its project design. This is reflected in its engagement with projects, its assessment of management costs, and its assessment of effectiveness within the log frame. The 3Es are used by STAR-Ghana in its approach of “mainstreaming” VfM. These include: Economy – getting the best value inputs Efficiency – maximising the outputs for a given level of inputs Effectiveness – ensuring that the outputs deliver the desired outcome. »STAR’s drive for economy & efficiency puts effectiveness at risk. STAR has achieved strong advances in understanding and applying principles of economy and effectiveness. STAR has worked hard at economy and efficiency to get best value. However, its application of these principles risks undermining project effectiveness and value for money. For example, STAR reduced successful applicants’ proposed project budgets from approximately $24 m to $10m, a cut of 60%, in the first 4 calls. All CSOs encountered, however, reported that their budgets had been “slashed” without adequate explanation or agreement. While the attempt to achieve economies is valuable, where budgets are imposed without the agreement of the grant partner, the imposition is likely to result in reduced output, causing loss of effectiveness and impact. STAR has also looked hard at its own management costs. Similarly, one of the strategies STAR used to improve the efficiency of grantees’ operations was to encourage shared working between grant partners. In some instances, this has been perceived as STAR requiring grantees to commit to enter an alliance as a condition of accepting a grant. In this respect, while alliances between willing partners are innovative, and offer both efficiency savings and improvements in effectiveness, alliances between unwilling partners cannot be enforced, and may damage project effectiveness and sustainability as well as efficiency. At the heart of this is that the contribution of these efforts to VfM depends on the process used and the underlying relationships between STAR and GPs. Recognizing the power that the project wields with respect to potential and successful grant partners, it is critical that STAR’s relationships with Grant Partners fosters a spirit of partnership and ownership by Grant Partners. »Cost of management does not reflect its value for Programme Outputs. STAR has conducted a useful benchmark study of programme management costs6. It is, however, concerned that its management cost of £5.0m over five years appears high at 26.9% of grant spend, relative to a comparable range of 20-27%. However, the PMT also contributes to the development of capacity within civil society, and this goes beyond management. Budgets and accounting systems can record expenditure based on inputs, activities or outputs. STAR currently presents its management expenditure as inputs: fees for staff, consultants and associated expenses. An activity-based budget would enable STAR to distinguish expenditure on administering grants and capacity building. An Output-based budget would show the contribution by PMT and TA to STAR’s Outputs. STAR has already made progress in this direction, by funding QA under the Grants budget. of a political economic analysis of civil society to determine STAR’s strategy and legacy. STAR’s initial P.E.A. does not assess civil society in the same depth as government. The absence of such an assessment increases the likelihood that STAR could have an adverse as well as positive impact on civil society. STAR is widely reported to be the dominant funder of civil society. Its creation, evolution and closure can be expected to have major impact on civil society. Co-funding DPs and CSOs expressed concerns about its dominance, and the fact that its replacement of bilateral funders reduces opportunities for funding. »Absence To make an effective and sustainable contribution to civil society, STAR needs a clear understanding of the sector, its strengths and weaknesses, its resource base, and its prospects for the future. The initial PEA of Ghana tells us about some of the achievements of civil society7, but less about the sector as a whole. Without a clearer strategy based on a fuller analysis, there is a high risk of unintended consequences. Furthermore, the strategy needs to be clearly reflected within the log frame. This will ensure that STAR provides appropriate resources to maximise sustainable impact, thereby maximising effectiveness and cost effectiveness. »Without progress towards exit strategy, long-term impact, sustainability and VfM are at risk. There was uncertainty about what will happen after 2015. There was just as much uncertainty about whether STAR itself will live on after 2015. Alternatives were offered for the future of STAR itself, both in discussion and in the Operations Manual. While everyone “hopes” for a sustained benefit, there is no clear strategy within the log frame to achieve it, at either the programme or project level. An exit strategy, whether a follow-on programme or otherwise, is important for STAR. Without it, there is a risk that gains are dissipated, resulting in a serious loss of value for money. This is a fundamental major risk to STAR’s sustained impact and therefore to its VfM. 6 Benchmarking of Fund Management Costs, STAR January 2012 Political Economic Analysis of Ghana and Thematic Strategy Development for STAR-Ghana, Inception Report, Appendix 3.1, Section 6.3 7 Based on these findings, the Review Team recommends the following: 1. Focus on process and relationships with GPs to win real effectiveness and VfM. See M&E recommendation no. 2. 2. Build a widely owned Civil Society PEA and strategy for sustainable impact. This should be used as a basis for its exit or other strategy beyond 2015. This process should be led by the steering committee, with the intention of achieving broad ownership within civil society and other stakeholders. 3. Revise log frame to include a strategy for civil society and for long term sustainability of its impact. 4. Consider extracting CB/TA from management cost, and make provision for it in project grant budget. Where PMT and TA contribute to outputs beyond such core functions as strategic management, secretariat and grant administration, STAR should consider showing these as expenses against the programme outputs. 7. Programme Implementation The TOR for the Annual Review asked the Review team to: “assess the overall effectiveness of programme implementation, drawing lessons and making recommendations for future programming and implementation.” Programme implementation has largely comprised of grant making, technical support from the PMT and capacity building. The Review Team found: informed by in-depth understanding of sector – STAR has conducted political economy analyses of Ghana generally and the education sector in particular. Both analyses are very useful in that they enable STAR to understand the drivers of change and disincentives and or incentives for government officials to behave in a more transparent and accountable manner. In education, in particular, sharing the findings and recommendations with the Grant Partners also contributed to a better understanding within the CSOs of the key issues that needed to be addressed. »Calls »Well managed and robust application process. From the inception period to date, STAR has made five calls for proposals: Oil and Gas, Results Initiative, Education, Elections and the Education Sustainability Grant. On the whole, these calls have been well managed and robust. Furthermore, each time calls were made, the application process was strengthened to respond to challenges identified in previous calls. Grant Partners who have applied more than once for STAR funding gave examples of changes that they really appreciated. For instance, the timing of the regional information sessions were changed to make them early enough for CSOs to include their learning in their applications. Grant Partners also noted that at first when the deadlines were extended if you had already put in your application, you couldn’t retrieve it to work on it during the extended period. In the last call, however, this changed and now applicants can make the most of the extended deadline by retrieving their applications. These changes reflect a learning culture within the PMT and flexibility in designing processes to be more effective. As the PMT continues in this spirit, Grant Partners have asked STAR to consider other areas in further strengthening the application process. These include: Improving the IT platform that supports the application process – often it is difficult for applicants to attach documents Ensuring regional consultations are held in all regional capitals; avoid combining any of the northern regions; it puts the cost of travel on CSOs rather than on STAR. Avoid extension of deadlines because it creates uncertainty and confusion. Rather right from the beginning give a longer period for organisations to submit EOIs and proposals. »Gender Equality and Social Inclusion (GESI) comprehensively integrated in key STAR processes. STAR has gone a long way to integrate GESI into its systems and procedures. The log frame includes specific indicators for GESI, the application form asks for specific information on GESI, the website provides detailed guidance on GESI, the information sessions also provide further information on GESI and the organizational assessment tool includes a dimension on GESI. STAR reports that as a result of these efforts, the GESI content of the education grantees was much higher than that of the results initiative grantees. Capacity development of GPs in GESI has been planned for early this year. »STAR’s approach to social change is very state-centred. STAR’s theory of change is centred on the Government Business Cycle. The GBC provides a useful framework against which to analyze Grant Partner action and ensures that CSO’s work is effectively placed in the context of government’s work. However, as STAR itself admits: “PEA shows that incentives often mean the de jure model of the government business cycle is distorted. Change can happen by understanding the de facto situation and working with it.”8 STAR aims ultimately to influence the behaviour of government. As the PEA indicates many of the factors affecting the behaviour of government occur well outside the GBC. Thus while STAR should continue to support grant partners to situate their work within the de jure model of the GBC, they increasingly need to support grant partners to work within the de facto model of government business in Ghana which is largely driven by political patronage. »Capacity building as currently implemented unlikely to achieve desired results. By the time of this review, STAR had not fully embarked on its capacity building activities. Up to this point, capacity building had primarily been provided by the Quality Assurers and the Monitoring and Evaluation Service Providers and to a lesser degree by the PMT through the information sessions and feedback on grant partner reports. While the activities undertaken reflect a commitment to build the capacity of Grant 8 STAR Inception Report at pg. 7. Partners, the manner in which they have been undertaken is not in alignment with STAR’s own capacity building strategy and is unlikely to result in sustainable capacity strengthening within grant partners. First, as STAR’s capacity building strategy quotes: “Capacity-building efforts to be sustainable, interventions need to adopt a participatory approach and develop into empowering partnerships for which those involved feel a high degree of ownership.” The Strategy goes to explain that capacity building in STAR should be principally demand-driven, with STAR-Ghana playing a connecting and shaping role when needed in order to ‘join dots’, avoid duplication and put people in touch. Grant Partners report that while they valued the sessions on M&E by the service providers they were not consulted on the choice of the service provider nor on the nature of support to be provided.The same could be said of the Quality Assurers. Thus the use of external resource people was done in a manner that was neither participatory nor owned by grant partners. The second challenge with the STAR’s capacity building activities so far is that they have been characterized by short training by the Service Providers or short inputs by the Quality Assurers. A key lesson from other programmes is that achieving the goals envisioned in STAR’s capacity building strategy (i.e. to be, to do and relate) is a labourintensive process often characterized by accompaniment. Given the increasing number of grant partners it is not clear to what extent the PMT can play that role. It is not also clear whether the Quality Assurers are expected to play that role as “critical friends” or whether they are more “monitoring policemen.”9 This is an issue that STAR must study closely and decide on. Ultimately, with support from the Technical Adviser on Capacity Building, STAR needs to revise its current approach to capacity building to become one that is more demand-driven, participatory and includes sufficient accompaniment to achieve the desired results. »STAR still largely inaccessible to small remotely-located CSOs. While STAR has gone some way in going beyond the usual Accra-based CSOs, the programme is still largely inaccessible to small CSOs, particularly those outside of the regional capitals. This point was emphasized by the grant partners outside of Accra. International organisations such as Ibis talked about the extensive support they had to provide to some of their partners in the application process because even though the organizations were clear about what they wanted to do, they found it difficult to articulate it in a manner required by STAR. Many of these small organizations are those whose presence on the ground gives them the credibility and knowledge to mobilize constituents. They, therefore, play an important role in enabling STAR to achieve its ultimate objectives. STAR’s current application process is a one-size fits all. There is a need to look at different processes for different types of organisations. One option may be to create a window specifically for smaller emerging CSOs. Another option may be to use intermediaries to support small organisations to access the funding and implement the initiatives. Ultimately within the next year, STAR should 9 More details on the Review Team’s concerns with the capacity building activities are provided in Annex 2 to this report on M&E. examine various options and design something that is appropriate. Whatever option is selected should be based on lessons from other CSOs funds in Ghana and elsewhere and on consultations with civil society. »Understanding and ownership of the sustainability grant by shortlisted GPs. One of the concerns that CSOs constantly raise about STAR is the absence of the type of core funding that was available under G-RAP. The sustainability grant is STARGhana’s approach to develop greater sustainability among CSOs. The sustainability grant has been offered on a competitive basis within a particular theme and to date 31 organisations have been shortlisted within the Education theme. Discussions with a number of the shortlisted organisations revealed a lack of understanding about what activities would ultimately be eligible for funding and how this grant is different from core funding. The success of the sustainability grant and the extent to which civil society buys into this idea will be largely influenced by the first group of grant partners. It will be critical, therefore, that STAR ensures that those who are eventually awarded the grants fully understand and own the process envisioned. The PEA of the civil society sector should also inform further roll out of these types of grants. Based on these findings, the Review Team recommends that STAR should: 1. Review implementation of capacity building strategy to ensure that it is more demand driven, participatory and encompasses more long term accompaniment support to grant partners. 2. Develop a strategy to enable smaller, remotely-based CSOs to access funding. 3. Hold information session with shortlisted CSOs to better explain the sustainability grant and include lessons from the PEA of the civil society sector in subsequent sustainability grant awards. 8. Governance and Management The TORs for the Annual Review asked the Review Team to: “assess the efficacy of the programme’s governance and management arrangements (including financial management).” As with the section on M&E and Value for Money, this section presents primarily the key findings and recommendations. A more detailed discussion of STAR’s performance on Governance and Management is provided in Annex 4. The Review found: »Broadly effective working between contractor, management agent, consortium, funders and PMT. The administrative working relationships for STAR between these parties are broadly effective. The administrative axis between the PMT, Coffey and DFID is a powerful driving force, but may be difficult to challenge. Funders engage strongly in the programme, particularly DFID as lead contractor. Currently it is also chair of both the Funders Committee and represents the funders on the Steering Committee, roles which it will hand over this year. Other funders had varied views on their own engagement, and maintain a constructively critical communication with DFID. Broadly their views on this relationship are positive: they support STAR’s contribution to donor harmonisation and lowering of transaction costs; they support STAR’s breadth of coverage; they feel able to influence the programme or leave DFID to take a leadership role, as is appropriate for them. However, donors have concerns about the quality of STAR’s engagement with civil society. There is concern whether STAR has sufficient insight into some specific themes, such as the elections. Funders are interested in the future of STAR beyond 2015, but are generally open-minded, without a fixed vision of what this may be. Consortium members have varying relationships with STAR. As Lead agent, Coffey has a strong managerial relationship. Other consortium members were positive about their relationship with each other and with Coffey. There are clear roles for the Programme Director (Coffey) and Technical Director (ITAD). The other consortium members have less defined roles. However, consortium relationships with the PMT have not been easy for all partners, and this has reduced the contribution of members of the consortium. The use of TA from consortium members is planned within the annual TA work plan. There was concern within the Consortium, echoed by service providers and others, about the adequacy of technical assistance for the broad organisational development needs of CSOs, partly as a result of budgetary constraint. »Rights and accountability re applicants, CSOs, wider Ghanaian society, staff and consultants less clear. Accountability is about more than formal mechanisms. Trust had been affected by the transition from former funding mechanisms, including IBIS, GRAP and RAVI, to STAR. Although donors and the emerging new organisation worked hard to consult on proposed changes, there were many difficulties to overcome, and some felt that the engagement of civil society was inadequate. Some remain concerned that STAR’s relationship with civil society is as a “conduit” for funds, rather than as a cooperative strategic agency, and that it is dominated by pressure to “get money out the door”. »The Steering Committee does not yet steer strategy or hold management to account. STAR has provided a structure for its committees, and appointed respected members to its Steering Committee, but they have not yet been given authority to exercise the full range of duties with which they are charged. Historically, many of the key decisions in relation to STAR were made before the appointment of the Steering Committee, notably the formulation of the project memorandum, the award of the management contract and the establishment of the PMT. The SC was only appointed 4 months into the Inception Period. The Steering Committee has therefore made a useful start in grant scrutiny, but has yet to take on a wider oversight. There is no record of it commenting on or approving the Year 1 Implementation Plan, Inception Report, Log frame updates, Operations Manual, Quarterly Report or 6 Month Report, nor of receiving any report from the Funders Committee. It has not yet made any major contribution to the strategic direction of STAR. It was reported that at its meeting in December it was agreed that it would have a regular role in policy development, but this has not been confirmed. The Steering Committee might be expected to make a strong contribution to the capacity of STAR to develop its strategic role in relation to civil society, but has not clearly had the opportunity to do so. In addition, the SC’s capacity to hold management to account is limited. The Programme Director does not report to the Steering Committee but to DFID. Neither the Programme Director nor the Technical Director regularly report to the SC, nor work closely with members between meetings. In assessing the performance of the governing structures, it is impossible to ignore the strong administrative axis of power between PMT, Coffey and DFID and the Co-funding DPs. These three have defined the main administrative components that drive STAR: the Inception plan, Log frame, Implementation plan and Operations Manual. Major reports are prepared by the PMT and Coffey, and presented to DFID. This administrative axis remains the driving force for planning and implementation, and is likely to be difficult to challenge. There is still some way to go before a governing body can maintain an overview and intervene within this axis. systems need development – document retrieval, flow of funds, and audit. Completing office systems is important to reduce delays and to reduce fiduciary risk. The review found it difficult and slow to obtain documents both on projects and for the programme as a whole. We were not given complete project documents either in physical, chronological files, or in complete electronic folders. Old emails were archived and difficult to retrieve. This makes it difficult for either PMT staff or an external auditor to construct the history of any project, and thereby monitor, control or correct it. It could also affect the broader quality of relationship with each project. It was similarly difficult to get the agenda, papers and approved minutes of each Steering Committee meeting. On this basis, we were not able to reconcile practical document management with the requirements of Coffey’s ISO Quality System as set out in the Operations Manual and its appendix 5.3. »Some Audit responsibility remains to be fully established. Although responsibility for the overview and execution of internal and external financial audit is specified in the Operations Manual, no one appeared to be taking responsibility for internal audit. DFID has proposed ToR for external audit, having agreed with STAR that the first audit should be for 18 months which includes the inception phase and the full year implementation. Early in a project’s life it is important to establish and confirm financial controls at project and programme level, in order to mitigate fiduciary risk. After 15 months of operation, it could be expected that internal audit procedures would have been put into operation. It is sometimes seen as good practice for the external and internal auditor to cooperate in establishing and maintaining both internal controls, reporting to management; and independent external audit, reporting to stakeholders10. Based on these findings, the Review Team recommends that STAR should: 1. Steering Committee to evolve to lead direction of STAR and hold management to account. STAR’s funders, management agent and PMT need to ensure that the SC is empowered to exercise its duties of governance, including the leadership of key strategic processes. 2. Deepen accountability to local stakeholders, including GPs. STAR should develop formal and informal ways to engage applicants, GPs and wider civil society. “Be the Change you wish to see in this world.” Gandhi 3. Develop PMT systems to provide easy access to all information about projects, management and governance. STAR’s systems should meet the management agent’s quality standards. Quality does not mean complexity: STAR’s information requirements and their management should be as simple as possible. 9. Conclusion As noted before, the Review Team was highly impressed by how much STAR achieved in such a short period of time. While the pressure will be on to get more grants out the door in the coming year, it will be critical to balance this frantic pace with reflection about some of the strategic issues emerging. The review team hopes that we have provided a mirror by which STAR can look at itself and collectively with its stakeholders determine how best to strengthen the programme to achieve more accountable and transparent governance in Ghana. ***** 10 Cooperation between Internal and External Auditors, A Good Practice Guide, National Audit Office, UK