GLOBAL FUND OBSERVER (GFO), Issue 109: 6 November 2009.

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GLOBAL FUND OBSERVER (GFO), an independent

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Issue 109: 6 November 2009. (For formatted

web, Word and PDF versions of this and other issues, see www.aidspan.org/gfo)

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CONTENTS

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1. NEWS: Global Fund

Report Reveals Lenient Interpretation by Secretariat of CCM Requirements

The Global Fund Secretariat determined in

Round 8 that all proposals received from CCMs were eligible for consideration

by the TRP, even though some of the CCMs had not complied with at least one of

the six minimum requirements that have been established by the Global Fund

Board.

2. COMMENTARY: CCM

Requirements: How Much Flexibility Is Appropriate?

" Some of the decisions of the Global

Fund’s Screening Review Panel are scandalous – or at least, they would

be if it wasn't so obvious that its members are trying to do what is

‘best’ in a complex world. Does the Secretariat believe that the

Fund’s minimum requirements regarding CCMs are too stringent? If so, why

doesn’t the Secretariat ask the Board to soften the requirements? "

3. COMMENTARY: Pointless PowerPoints

" If I am ever granted the job of World

Dictator, my first act will be to ban the use of PowerPoint. "

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1. NEWS: Global Fund Report

Reveals Lenient Interpretation by Secretariat of CCM Requirements

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In Round 8, a year ago, the Global Fund Secretariat determined that all

proposals received from CCMs were eligible for consideration by the Technical

Review Panel (TRP), even though some of the CCMs had not complied with at least

one of the six minimum requirements that have been established by the Global

Fund Board.

Also, the Secretariat recommended that consideration be given to

changing the proposal guidelines to make " Non-CCM proposals " eligible

if they address the needs of vulnerable populations that have been left out of

the national response.

These points are revealed in a Global Fund report entitled " Report of the Round 8 Screening Panel. "

Copies of the undated report are available at www.theglobalfund.org/documents/ccm/Screening_Review_Panel_Report_Round_8.pdf.

(A report regarding the screening process for Round 9 proposals is

expected within the next few months.)

As explained in the report, all applications submitted in Round 8 were

screened by the Global Fund Secretariat for eligibility. Only proposals deemed

to be eligible were passed on to the TRP for review. The Global Fund imposes a

number of eligibility criteria; they vary depending on the type of applicant.

The screening had nothing to do with evaluating the quality of the proposal

– that was left to the TRP; it just evaluated whether the applicants had

followed certain requirements. If they had not, the TRP never saw the proposal.

The screening was a two-part process. First, the applications were

reviewed by a Screening Team, made up of 16 people who receive special

training. The Screening Team rated each application as fully compliant (FC),

indeterminate compliant (IC) or non-compliant (NC). An " IC " rating

meant that the members of the Screening Team had some doubts concerning whether

the application met the eligibility criteria.

Second, a more senior Screening Review Panel (SRP), made up of staff

from various parts of the Secretariat, reviewed the applications and the

recommendations of the Screening Team. For those applications rated FC by the

Screening Team, the SRP reviewed a small sample of the applications. If the SRP

was satisfied that the Screening Team had rigorously and appropriately reviewed

the sample, it then voted to accept all FC recommendations as a block. For all

applications rated IC or NC by the Screening Team, the SRP examined each one

individually.

In its deliberations, the SRP did not rely entirely on the information

contained in the applications. It also sought clarifications from the

applicants, from other Global Fund staff, and from the Fund’s partner

organisations.

Of the 123 applications, 96 were ultimately determined by the SRP to be

eligible. The numbers break down as follows:

Ninety-three of the 95 applications

from coordinating mechanisms were deemed eligible (all 88 applications

from CCMs, three of the four applications from Sub-CCMs, and two of the

three applications from RCMs).

Three of the eight applications from

Regional Organisations (ROs) were deemed eligible.

None of the 20 applications from

Non-CCMs were deemed eligible. (Non-CCMs are national organisations other

than the CCM – usually NGOs or faith-based organisations [FBOs].)

These results are similar to the results of the screening process for

Round 7, except that in Round 7 all applications from ROs were deemed eligible.

(See GFO 92 for details on the Round 7 screening.)

Below, we provide more information from the " Report of the Round 8 Screening Panel " on the

screening process for (a) applications from coordinating mechanisms; (

applications from ROs; and © applications from Non-CCMs.

A. Applications from coordinating

mechanisms

In its " Report of the Round 8

Screening Review Panel, " the Global Fund provided details of

the screening that was done on the 95 applications submitted by coordinating

mechanisms. The Screening Team and the Screening Review Panel assessed whether

applicants met a number of criteria related to (a) the composition and

operations of the coordinating mechanisms and ( the proposal development

process. (These criteria are known as " the six CCM minimum

requirements. " )

In its initial review of applications from CCMs, the Screening Team

rated 73 applications as fully compliant (FC) and 15 as either indeterminate

compliant (IC) or non-compliant (NC). The Screening Review Panel (SRP) confirmed

all 73 FC ratings and, after reviewing the 15 IC- and NC-rated applications,

the SRP decided that all of them were also fully compliant.

With respect to the other coordinating mechanisms, the SRP found only

one sub-CCM (Congo Kasai) and one RCM (Andino) to be non-compliant.

In the report, the Global Fund Secretariat concluded that applicants

had less difficulty demonstrating compliance compared to previous rounds. The

Secretariat said that

" Contrary to Round 7, more CCMs

submitted comprehensive documentation to prove an inclusive and transparent PR

selection process. Also, most CCMs easily demonstrated that new non-government

representatives had been selected in a transparent manner. There was also

clearer linkage between proposal solicitation and the review of submissions

received. "

The following is a summary of what the report said about the screening

conducted for each of the six minimum CCM requirements.

Requirement No. 1 –

All CCMs are required to show evidence of membership of people living with

and/or affected by the diseases.

Most applicants were able to demonstrate

compliance fairly easily. Only three – CCM Democratic People’s

Republic of Korea (DPRK), Sub-CCM Russian Federation and Sub-CCM Congo Kasai

– were rated IC or NC initially by the Screening Team in regard to this

requirement. Sub-CCM Congo Kasai was then determined to be non-compliant by the

SRP because it failed to provide any supporting documentation. CCM DPRK and Sub-CCM Russian

Federation were determined to be fully

compliant by the SRP. In the case of CCM DPRK, although the proposals from that

country were signed by one person previously treated for malaria, and one

person previously treated for TB, there were no representatives of people

living with HIV/AIDS on the CCM. However, the SRP noted that DPRK had no

official data on HIV/AIDS and concluded that the CCM had shown " sufficient

effort at meeting the spirit and intent of the requirement. "

In the case of the Sub-CCM Russian Federation, which submitted a TB

proposal, it had submitted no evidence of membership of persons living with the

diseases. However, after clarification, it was revealed that a person living

with TB had been added to the CCM.

Requirement No. 2 – CCM members

representing the non-government sectors must be selected by their own sector(s)

based on a documented, transparent process, developed within each sector.

Seven applicants were initially rated IC or NC by the Screening Team

with respect to this requirement – two first-time applicants to the Global

Fund (Sub-CCMs from Kyrgyzstan

and Russian

Federation), plus Sub-CCM Congo Kasai and CCMs from Algeria, DPRK, Bangladesh

and South Africa.

The SRP determined all but Sub-CCM Congo Kasai to be fully compliant.

Even though each of the other six applicants failed to provide the necessary

documentation to demonstrate compliance, the SRP judged them to be compliant

based on additional information obtained from the applicant, information

provided by the regional teams in the Secretariat or special circumstances in

the country in question, or a combination of the above. In several cases, the

decision might have been a close call, but the SRP gave the applicant the

benefit of the doubt. The SRP said that the Secretariat should work with the

applicants involved to improve their selection processes.

Requirement No. 3 – CCMs are

required to put in place and maintain a transparent, documented process to

solicit and review submissions for possible integration into the proposal.

The SRP said:

" On the whole, CCMs demonstrated

better understanding of this requirement [compared to previous rounds], in

particular the need to link both parts of the requirement in order to be

determined eligible. CCMs mostly used local newspapers and/or the internet to

solicit ideas from interested stakeholders for possible incorporation into the

final proposal. Furthermore, CCMs clearly documented their processes to review

submissions received with many of them providing justifications for including

or excluding submissions received. "

Nevertheless, seven applicants were initially rated IC or NC by the

Screening Team with respect to this requirement. Three CCM applicants (Gabon, Iran

and Sri Lanka)

had a clear proposal solicitation process but could not show evidence of a

transparent and documented review process. The Sub-CCM Russian Federation had a

documented review process but could not show evidence of an inclusive

solicitation process. CCM Kazakhstan and Sub-CCMs from Kyrgyzstan and Congo Kasai had

neither.

The SRP determined all but Sub-CCM Congo Kasai to be fully compliant.

Once again, the SRP relied on clarifications from the applicant and input from

the regional teams in the Global Fund Secretariat. And once again, the SRP gave

several applicants the benefit of the doubt. For example, Sub-CCM Russian Federation

did not publicly call for submissions. It stated that all organisations that

had meaningful input to the proposal development process were already on the

sub-CCM. The regional team confirmed this. But while the SRP determined Sub-CCM Russian

Federation compliant with this requirement,

it said that the SRP was

" concerned about legitimizing this

trend of substituting documented open processes, with a claim that all relevant

organizations had been involved in the process. The panel noted that this

could, in the long run, result in proposal development processes being limited

to selected organizations and institutions and thus not meeting the

board’s requirements on openness and accountability. "

The SRP said that the Global Fund " needs to communicate to all

applicant types, and especially those in [Eastern Europe and Central

Asia] region, the need to reach beyond known or familiar networks

to ensure a broad and inclusive process in meeting the requirement. " The

SRP added that applicants should be reminded that open transparent processes

must be documented for two aspects of proposal development – i.e., for

both the solicitation and the review of stakeholder inputs.

Requirement No. 4 – CCMs are

required to put in place and maintain a transparent, documented process to

nominate the Principal Recipient(s) (PR) and oversee program implementation.

With respect to the PR nomination process, the SRP said:

" In general, applicants understood the

need to reach beyond current PRs and consider other potential candidates. Most

applicants placed a public call soliciting ‘Expressions of

Interest’ from interested organizations. Others linked discussions for

potential PR and/or sub recipients (SRs) to the proposal solicitation and

review processes, designating authors of proposal submissions as PRs or SRs.

Still, others reverted to current PRs after having considered alternative

options. The common denominator in all of these cases was the applicants’

recognition of the need to designate PRs based on some evaluation criterion, at

least an implicit one, and to ensure that the process employed was transparent

and documented. "

The SRP also said that, in general, applicants recognised the need to

describe their oversight processes fully.

Nevertheless, 11 applicants were initially rated IC or NC by the

Screening Team with respect to this requirement: CCMs from Algeria, Benin,

DPRK, Gabon, Kenya, South

Africa, Sri

Lanka and

Yemen; and Sub-CCMs from Congo

Kasai, Kyrgyzstan

and Russian Federation.

Once again, only Sub-CCM Congo Kasai was determined to be non-compliant

by the SRP. The other ten applicants were determined to be fully compliant,

mainly after clarifications from the applicants and input from the regional

teams in the Secretariat.

In at least one case (CCM Gabon), the decision was a close call. The

CCM nominated the Ministry of Health as PR for its HIV proposal, but provided

no documentation concerning a selection process. As well, the SRP said that the

CCM’s description of its oversight plan was " lacking " and that

" t was clear that the CCM misunderstands its oversight role and

responsibility. " The SRP was tempted to declare the CCM ineligible with

respect to its HIV proposal, but the regional team argued that there were

restructuring efforts underway in the CCM and that the Round 8 HIV proposal was

very important to ongoing projects in Gabon. In the end, the SRP was

unable to arrive at a consensus. The decision to find CCM Gabon eligible was

based on a majority vote.

In its report, the SRP commented that " preselecting government PRs

without due process definitely contradicts the spirit of openness and

transparency " in the CCM requirements.

The SRP noted that most CCMs were quite willing to implement dual-track

financing (DTF), and that " DTF discouraged many applicants from simply

reverting to current PRs, as has been normal practice in the past, since they

were being requested to solicit for expressions of interest from potential

civil society PR candidates. "

Requirement no. 5 – CCMs are

required to put in place and maintain a transparent, documented process to

ensure the input of a broad range of stakeholders, including CCM members and

non-members, in the proposal development and grant oversight process.

Initially, eight applicants – CCMs in Algeria,

Gabon, Iran, South Africa

and Sri Lanka; sub-CCMs in

Congo Kasai and Kyrgyzstan;

and the SADS RCM – were rated NC or IC by the Screening Team.

Once again, the SRP determined Sub-CCM Congo Kasai to be non-compliant

and the others to be fully compliant. As was the case with Requirement No. 4,

the SRP was split concerning CCM Gabon, and finally determined the CCM to be

eligible based upon a majority vote.

The SRP pointed out that applicants often revert to documentation

submitted for Requirements No. 3 and No. 4 to prove compliance with Requirement

No. 5 since all three requirements are seemingly linked.

Requirement No. 6 – When the

PRs and Chair or Vice-Chair of the CCM are the same entity, the CCM must have a

written plan in place to mitigate the inherent conflict of interest.

Most applicants had no problems demonstrating compliance with this

requirement. All were determined to be fully compliant by the SRP. However, in

one case – CCM China – the decision was not automatic.

CCM China nominated the State Council AIDS Working Committee Office

within the Ministry of Health as PR. The chair of the CCM comes from the

Ministry of Health. The CCM said it did not recognise the need for a COI

policy, insisting that the two entities (the Committee and the Ministry) were

different. The regional team explained the close links between all entities and

the government in China.

The SRP considered having someone go back to the CCM to clarify the

relationship between the two institutions. According to the report, " After

much deliberation, the SRP agreed to screen CCM China in as compliant on

condition that the regional team works with the CCM to write a COI plan. "

Further note concerning Sub-CCMs

Current guidelines allow a Sub-CCM to be deemed eligible to apply as

long as it can provide any of the following documentation in support of its

independent operations: (a) statutes or other legal

documents confirming the independent authority of the sub-CCM; (

international agreements or conventions that recognise the independent nature

of the Sub-CCM's territory; and © proof of the CCM's acceptance of the

sub-CCM's independence. The SRP recommended that the guidelines be revised to

ensure that Sub-CCMs and their respective CCMs justify the programmatic need

for the sub-CCM as a complement to the national CCM. The SRP said this would

prevent " the creation of multiple coordinating mechanisms in any single

country and promote the coordination of

proposals at a national level. "

RCM Andino

RCM Andino, which covers certain countries in South America, was deemed

ineligible, not because it failed to meet any of the requirements outlined

above, but rather because it failed to obtain endorsements of its proposal from

all of the national CCMs in its region.

B. Applications from regional

organisations

Eight Regional Organisations (ROs) applied in Round 8, all for HIV/AIDS

proposals. The SRP determined that only three ROs were eligible because the

others had failed to submit endorsements from national CCMs in all of the

countries included in their proposals.

The SRP commented as follows:

" Regional

Organizations are a potential force in the effort to mobilize demand to fight

HIV/AIDS, TB and malaria. Being cross border and multi-country in nature, these

proposals could complement national programs and help prioritize activities

otherwise excluded or ignored due to in-country politics, negative attitudes

and/or ongoing stigma and discrimination. Unfortunately, very few of these

proposals [reach the TRP] due to ROs inability to secure CCM

endorsements. "

C. Applications from Non-CCMs

In its " Report of the Round 8

Screening Review Panel, " the Global Fund provided details of

the screening that was done on the 20 applications submitted by Non-CCMs. The

Global Fund actively discourages applications from Non-CCMs. It only accepts

Non-CCMs proposals if they are from countries:

that are without legitimate

governments;

that are in conflict, facing natural

disasters, or in complex emergency situations; or

that suppress or have not established

partnerships with civil society and non-governmental organisations.

If a Non-CCM submits an application on the basis that its country

suppresses or has not established partnerships, it has to demonstrate that it

contacted the CCM in an attempt to get its suggestions included in a national

proposal.

At 20, the number of applications from Non-CCMs in Round 8 was up from

the 16 applications in Round 7, but was still considerably lower than in

earlier rounds. Non-CCM proposals were received from applicants in 13

countries, almost twice the number of countries for Round 7.

The SRP deemed all 20 applicants ineligible. It said that none of them

met the criteria; that all 13 countries has functioning CCMs with civil society

representation; and that none of the applicants proved that they had contacted

their respective CCMs. The SRP said that 19 of the 20 applicants did not even

explain why they had applied outside their CCM.

Despite the fact that no Non-CCM proposals were deemed eligible, the

SRP said that " the non-CCM window remains an opportunity for groups

marginalized as a result of stigma and discrimination in government

policies. " The SRP recommended that proposals from Non-CCMs be examined

more closely and that consideration be given to changing the proposal

guidelines to make Non-CCM proposals eligible if they are addressing the needs of

vulnerable populations that have been left out of the national response. The

SRP also recommended that the Secretariat develop a fact sheet providing more

guidance for Non-CCMs and to " increase their chances at meeting

compliance. "

Editor’s note: Most of the

information for this article came from the " Report

of the Round 8 Screening Panel. "

Supplementary information was obtained from the Global Fund Secretariat. The

following article is a Commentary on this whole process.

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2. COMMENTARY: CCM

Requirements: How Much Flexibility Is Appropriate?

by Garmaise

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Some of the decisions of the Global Fund’s Screening Review Panel

(see previous article) are scandalous – or at least, they would be if it

wasn't so obvious that its members are trying to do what is " best " in

a complex world.

In July 2008, I wrote a commentary in GFO in which I said that in Round

7, three years after the " CCM minimum requirements " were adopted by

the Board, the Global Fund Secretariat continued to exercise a considerable

amount of discretion in applying these requirements to the screening process

for proposals.

Since then, nothing much has changed. In Round 8, virtually all of the

applications from CCMs, Sub-CCMs and RCMs were " screened in " (i.e.,

were deemed eligible for consideration by the TRP). Yet, as happened with Round

7, it is also clear that this was done even though many CCMs were still not

meeting the minimum requirements. Further, in Round 8, for the first time, the

Screening Review Panel (SRP) was unable to reach a consensus in a small number

of cases.

Consider two examples of decisions made by the SRP with respect to the

requirement that the representatives of non-government sectors on the CCM must

be selected through a documented and transparent process run by the sectors

themselves.

First, for CCM Algeria,

the report tells us that:

The CCM did not provide required

documentation regarding the selection processes.

The CCM had been reconstituted by the

Minister of Health in 2006 as a result of corruption allegations regarding

the previous CCM.

The Minister appointed all 48 CCM

members directly, including civil society representatives, and

" ensured that all interested NGO stakeholders were represented. "

According to the report, the SRP nevertheless decided that CCM Algeria

was " fully compliant. " It did so based on the following: (a) regional

teams in the Global Fund Secretariat said that while Algeria had previously

received funding (in Round 3) from the Global Fund, the CCM was still

" new " to the Global Fund’s requirements; and ( the list of

CCM members attached to the proposal included a number of the NGOs that are

most active in the fight against the diseases.

How can it be said that CCM Algeria was compliant? There was no

" open and transparent " sector-led selection process of CCM members,

as is required. It’s not enough for someone to determine that people

appointed by the Minister to the CCM include " all interested NGO stakeholders. "

Second, for CCM Bangladesh,

the report tells us that four of the six new civil society representatives who

had joined the CCM since it was last determined eligible in Round 7 were

personally picked by the CCM. There was no selection process run by the sector.

According to the report, the SRP determined that CCM Bangladesh was fully

compliant because (a) the majority of its non-governmental representatives were

on the CCM at time of the Round 7 screening when the CCM was determined to be

fully compliant with this requirement; and ( to be compliant with this

requirement, it is sufficient if 50 percent or more of the sector’s

representatives were transparently selected by the sector.

This is exercising discretion to the point of bending over backwards.

In Round 7, the SRP came up with the 50 percent rule, even though there is

nothing in the requirement itself that states that the CCM needs to be only 50

percent compliant. For Round 8, the Global Fund said that CCMs that had met

certain requirements in Round 7 would not have to meet them again in Round 8,

which is fair. But the Global Fund also said that any new non-governmental

representatives added since the Round 7 submission had to be selected in an

open and transparent process run by the sectors themselves. That did not happen

here.

Consider also one example of decisions made by the SRP with respect to

the requirement that CCMs put in place and maintain a transparent, documented

process to nominate the PR(s) and oversee program implementation.

For CCM Gabon, the report

says that the CCM simply nominated the Ministry of Health as PR for its

HIV/AIDS proposal because of its track record as PR on other grants. There was

no process. There was no evidence that the CCM had evaluated the MOH’s performance

" in comparison with other options or likely PR candidates. " The

report also says that CCM Gabon’s description of its program oversight

plan was lacking.

The rest of what the report has to say about this case reads like a

debate:

" The SRP was faced with the

dilemma of whether to declare the CCM as ineligible and thereby reject

both proposals (it also applied for malaria) or only accept one based on

the adequacy of documentation submitted. "

" This sparked an appeal from the

regional team which noted all the ongoing restructuring efforts within the

CCM as well as the importance of the Round 8 HIV/AIDS proposal to ongoing

projects in Gabon. "

" The SRP reminded the regional

team of the equal weight for each of the six minimum requirements. "

In the final analysis, the SRP could not reach consensus, so CCM Gabon

was declared compliant on the basis of a majority vote.

Clearly, however, the requirement was not met.

Finally, the SRP screens proposals against each of the CCM minimum

requirements, one by one, but it does not appear to take into account any

" cumulative effect. " Sub-CCM

Russian Federation

was given the benefit of the doubt for no less than four of the six

requirements. If a CCM or Sub-CCM squeaks through on four of six requirements,

doesn’t that raise questions about whether that applicant is fully

compliant overall? The following applicants were also given the benefit of the

doubt for multiple requirements: Sub-CCM Kyrgyzstan (also four requirements); and CCMs

from Gabon, Algeria, Sri Lanka

and South Africa

(three requirements each).

Does the Secretariat believe that the minimum requirements are too

stringent, even though CCMs have by now had several years to become compliant?

If the answer is Yes, why doesn’t the Secretariat ask the Board to

consider softening the requirements, and why doesn’t it inform all CCMs

that until the Board makes a decision, it will not enforce the requirements

strictly? Whereas, if the answer is No, why does the Secretariat treat

some non-compliant CCMs as if they were compliant, and why doesn’t the

Board complain about this? If the requirements are considered to be too

stringent, they should be changed, not ignored.

Garmaise (garmaise@...) is a Senior

Analyst with Aidspan.

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3. COMMENTARY: Pointless PowerPoints

by Bernard Rivers

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As you read this article, thousands of people around the world –

possibly millions – are sitting in meetings where speakers are projecting

PowerPoint slides onto a screen. The speakers assume that these PowerPoint

slides are helping the audience. But, with rare exceptions, they are wrong.

If I am ever granted the job of World Dictator, my first act will be to

ban the use of PowerPoint.

Why? Because PowerPoint slides usually have far too many words on them,

as a result of which, they distract the audience from what the speaker is

actually saying.

I recently went to a conference where there were presentations by,

among others, a senior official from the World Bank and another from the

European Commission. Each of these two people spoke to a series of excessively

verbose slides. I spent one third of my time trying to read what the slides

said (but being distracted by the speaker), one third of my time trying to

listen to what the speaker said (but being distracted by the slides), and one

third of my time feeling really grumpy. Furthermore, if a slide dealt, at

length, with points A, B, C and D, the speaker often spoke to only one of

these, or to some point E that didn’t even feature. What, please, was the

point of these slides? I felt lost and – did I mention? – grumpy.

Here are some tips, from a frequent PowerPoint victim. If you are

giving a talk and you want to provide your audience with a detailed record of

your talk – OK, go ahead, create detailed slides. But then print

them, and make the printout available at the end of your talk. During

the talk itself, either use no slides at all – leading to the wonderful

result that your audience will actually look at you and listen to you –

or create some extremely simple slides with four or five bullets on each slide,

with each bullet consisting of only four or five words. If possible, arrange

your slides so that each new bullet only appears on the screen when

you’re ready for it, so your audience sees a brief summary of what you have

said and of what you are talking about right now, but not of what you will

say during the next few minutes.

PowerPoint has destroyed the art of public speaking. Down with

pointless PowerPoints!

PS: Slides produced by the Global Fund are actually pretty good, in

contrast to those mentioned above.

Bernard Rivers (rivers@...) is Executive Director

of Aidspan and Editor of its GFO.

" Reproduced from the Global Fund Observer Newsletter

(www.aidspan.org/gfo), a service of Aidspan. "

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