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Implementation Completion Report (ICR) Review - Institutional Strengthening - ANSES II TA

1. Project Data:   
ICR Review Date Posted:
Project Name:
Institutional Strengthening - ANSES II TA
Project Costs(US $M)
 37.5  26.89
L/C Number:
Loan/Credit (US $M)
 25.0  18.054
Sector Board:
Public Sector Governance
Cofinancing (US $M)
Government of Argentina
Board Approval Date
Closing Date
09/30/2010 09/30/2012
Central government administration (100%)
Other public sector governance (40% - P) Administrative and civil service reform (40% - P) Other accountability/anti-corruption (20% - S)
Prepared by: Reviewed by: ICR Review Coordinator: Group:
Brian Ames
Iradj A. Alikhani Lourdes N. Pagaran IEGPS2

2. Project Objectives and Components:

a. Objectives:

    The Project Development Objective (PDO) of the Institutional Strengthening of the National Social Security Administration II (ANSES II) technical assistance project, reported in the Loan Agreement, was to
    (a) enhance ANSES’ service-delivery capacity, through the improvement of its: (i) efficiency, effectiveness, transparency and accountability functions; and (ii) change management initiative; and
    (b) support the institutional strengthening of the Social Security Secretariat (Loan Agreement, page 15).

    The PDO reported in the Project Appraisal Document (PAD) was to enhance service-delivery by ANSES by improving its efficiency, effectiveness, transparency and accountability through institutional re-engineering, fraud and error detection, change management and greater internal and external oversight, as well as institutional strengthening of the Social Security Secretariat. (PAD, page 7).

    Hence, there is a minor difference in language regarding the PDO as presented in the Loan Agreement and the PAD. The PDO in the Loan Agreement is used as the benchmark for this evaluation.

b. Were the project objectives/key associated outcome targets revised during implementation?

c. Components:

ANSES II consists of four components:

Component 1. Institutional Effectiveness of ANSES (cost estimated at appraisal: US$20.1 million; actual cost: US$23.89 million): This component aimed at increasing efficiency and effectiveness of ANSES through the design of a new strategy, re-engineering and automation of core business processes, a redesign of the organizational structure and the necessary enabling mechanisms to support these changes in the corporate culture. It supported the following sub components: (a) strategic management; (b) re-engineering of core business processes; (c) Automation of core business processes and integration of systems; and (d) improvement of the organizational structure and decentralized service delivery. ANSES was responsible for executing this component.

Component 2. Institutional Effectiveness of the Social Security Secretariat (cost estimated at appraisal: US$3.0 million; actual cost: US$0.20 million): This component aimed to promote the institutional strengthening of the Social Security Secretariat (SSS) of the Ministry of Labor to enhance its managerial and technical capacity for greater oversight of social security institutions, supporting particularly the following sub components: (a) strengthening the management capacity of the Secretariat; (b) strengthening the technical capacity of the Secretariat; and (c) promoting outreach in other public institutions, the private sector and civil society. The SSS was responsible for carrying out this component, with the assistance of ANSES regarding disbursement and procurement.

sub-components:Component 3. Transparency and Participation (cost estimated at appraisal: US$7.9 million; actual cost: US$0.96 million): This component aimed at enhancing the transparency of ANSES by improving access to and exchange of information, particularly through improved fraud and error detection, litigation control, cross-checking of beneficiary data with other institutions and social accountability mechanisms for beneficiaries and other stakeholders. It supported the following sub-components: (a) fraud and error detection; (b) strengthening litigation control; and (c) greater access to information. ANSES was responsible for executing this component.

Component 4: Change Management (cost estimated at appraisal: US$3.8 million; actual cost: US$1.77 million): This component was designed to ensure sustainability of organizational reforms and included overall project management and specific change management instruments, such as a communications strategy and dissemination of best practices. It supported the following sub components: (a) project management; (b) monitoring and evaluation; and (c) change management. ANSES was responsible for executing this component.

d. Comments on Project Cost, Financing, Borrower Contribution, and Dates

ANSES II is a Technical Assistance project financed by an IBRD loan in the amount of US$25 million and borrower counterpart financing in the amount of $12.5 million. It was appraised on May 17, 2005; approved by the Bank Board on July 5, 2005; became effective on November 16, 2006; was restructured on January 17, 2011 and on September 27, 2012, and was closed on September 30, 2012 (24 months after the original closing date at appraisal). Total project costs at closing amounted to US$26.89 million, with US$6.95 million being cancelled shortly after closing. It is unclear, however, as to whether the total project costs reported in the ICR included the SSS’s own funding of the second component.

3. Relevance of Objectives & Design:

a. Relevance of Objectives:

The PDO of the ANSES II is appropriately ambitious and framed in a manner consistent with the country’s priorities and the Bank’s Country Partnership Strategy (CPS) for 2010-12. Following the country’s deepest political economic crisis in generations, Argentina’s economy started to rebound strongly in 2003, but the social impact of the crisis was enormous. The challenges of securing sustainable long-term growth while supporting greater social expenditure required effective governance, strong institutions, and efficient and transparent management of public policy. As ANSES was the administrative pillar of the social security system, the government considered its strengthening as critical to enhancing public sector management and to providing demonstration and multiplication effects for similar institutional strengthening elsewhere. The three pillars of the CPS (sustained growth with equity, social inclusion, and improved governance) are aligned with the Government’s development agenda, with a special focus on institution building and the prioritization of social safety nets and job creation. The PDO is fully aligned with the third pillar, which aims to promote better governance by improving accountability and transparency. Moreover, the ANSES II project was included within the US$2 billion CAS lending program at the request of the authorities. The framing of the objectives was appropriate as they were aimed at addressing critical problems undermining the effectiveness and efficiency of the social security system. Importantly, the PDO remains relevant today as the country continues to face challenges in ensuring effective and efficient service delivery by ANSES and the SSS. The relevance of objectives rating is Substantial

b. Relevance of Design:

The design of ANSES II is consistent with, and highly relevant to its PDO since it contributes to the institutional strengthening of one of the country’s largest public institutions both in terms of the volume of social expenditure it manages and the population it serves. The components (institutional effectiveness of ANSES/SSS, transparency, and change management) covered the critical areas where specific activities were required to strengthen capacity in order to achieve the PDO. ANSES II included a Results Framework that linked the PDO with intermediate results along with both PDO and intermediate outcome indicators for each of the four project components. Although there was no separate presentation in the ICR of specific objectives linked to each component, the causal chain between the components and the outcomes was nevertheless clear and convincing. The TA instrument appears appropriate given the capacity building objectives sought, even if complementary policy-based lending would have provided an instrument for tackling policy issues, notably related to investment policy and governance. The relevance of design is rated Substantial.

4. Achievement of Objectives (Efficacy) :

ANSES II included an overarching PDO, four specific objectives, five PDO-specific indicators, and 14 Intermediate Outcome (IO) indicators. The indicators were relevant and sufficiently ambitious. Although the Results Framework (RF) used in the Implementation Status Reports (ISRs) differed from that of the PAD and although the Bank made changes to certain indicators and end-targets that were not formalized during the two project restructurings, both the ICR and this Review assess project implementation against the RF presented in the PAD.
    PDO: Enhance service delivery by ANSES

    As indicated in the ICR, the project broadly achieved its PDO of contributing to enhanced service delivery by ANSES through the re-engineering and automation of core business processes, integration of systems, improved organization structure and centralized service delivery. Together, these measures significantly reduced the time in benefit-award and client-service, improved beneficiary satisfaction, and generated savings as a result of more efficient internal management processes. The average time for service provision decreased substantially for new social security benefits (from 140 days in 2006 to 74 days in 2012), new retirement benefits (from 66 days in 2005 to 19 days in 2012), and processing death benefits (from 170 days in to 66 days). Moreover, beneficiaries’ satisfaction rates with service delivery improved from 45% in 2005 to 86% in 2012. As elaborated below, two of the five PDO indicators were fully achieved, two had significant progress achieved, and one was not achieved.

    Specific Objective 1: Consolidate and expand selected organization reforms of ANSES

    This objective was broadly achieved. The PDO indicators related to this objective regarding improved service delivery (PDO Indicator 1) and reduction of the average time in the provision of new benefits (PDO Indicator 2) exceeded their targets. Moreover, two of the six IO indicators related to this objective were achieved, three were partially achieved, and one was not achieved. The targets regarding an increase in the number of employees in the Career Plan (IO indicator 6) and the percentage of modules completed for improvements in the beneficiaries data base, the Single System for Family Allocations, and individual work history (IO indicator 5) were met or exceeded. Regarding the partial achievement of the indicators on reduction in time in the provision of death benefits by phone/service center (IO Indicator 1) and an increase in the number of offices per year (IO Indicator 3), this was due principally to the shift in ANSES’ strategy in 2006 to emphasize the use of "web services" over "phone services" and "kiosks" over "offices". Similarly, the partial achievement (90%) of the indicator on the percentage of pension systems fully integrated and automated (IO indicator 4) was due mainly to the setting of an unrealistic target (i.e., 100% compliance). Finally, the target for the average initiation of retirement benefits by employee per month (IO Indicator 2) was not achieved primarily on account of the shift towards reliance on the telephone/internet and an increase in personnel to meet the overall demand for services. Hence, as regards efficacy in achieving this specific objective, the lack of performance on these latter four intermediate outcome indicators for the reasons previously cited should not offset the achievement of the two PDO indicators and other two intermediate outcome indicators.

    Efficacy in achieving the first specific objective is rated Substantial.

    Specific Objective 2: Support the institutional strengthening of the SSS

    This objective was not achieved and should have been dropped during the project’s restructuring owing to the institutional tensions between the SSS and ANSES that impeded this part of the project' implementation, as well as changes in leadership and a weakened level of ownership by the Secretariat. There was no progress recorded regarding improved disclosure and dissemination of studies (PDO Indicator 1). Moreover, performance regarding the intermediate outcome (IO) indicators for this objective was mixed with the indicator on redefined long-term strategy and functions, streamlined processes, new organizational structure and M/E (IO Indicator 7) being achieved, while those regarding the number of monitoring reports and studies on social policy (IO Indicator 8) and the supervision of all autonomous agencies (IO Indicator 9) were not measured during implementation. The SSS undertook some of the activities envisaged in the project with its own financing.
    Efficacy in achieving the second specific objective is rated Negligible.

    Specific Objective 3: Enhance access to information and exchange of information, help fraud and error detection, and promote citizen engagement and oversight

    This objective was broadly achieved and complemented the first specific objective regarding the institutional modernization of ANSES by focusing on specific activities targeted at improving transparency. The targets regarding a reduction in the error rates in the determination of death benefits (PDO Indicator 3), the implementation of the Claims Management System (IO Indicator 11), and the number of external evaluations completed (IO Indicator 12) were all met, while the indicator on the implementation of citizens control evaluation mechanisms (IO Indicator 10) fell slightly short of its target (75% versus 100%).

    Efficacy in achieving the third specific objective is rated Substantial.

    Specific Objective 4: Promote change management, innovation and dissemination of good management practices

    This objective was broadly achieved. The project’s activities were designed to ensure effective project implementation across components, help mitigate risks, and support sustainability of the organizational reforms. The PDO indicator regarding the survey to employees and other stakeholders that reflects support of the project and openness to change improved significantly even though it did not reach its target (78.5% versus 90%). The targets for the intermediate indicators regarding the installation and operation of management and M&E systems at ANSES (IO Indicator 13) and the completion of a communications strategy (IO Indicator 14) were both fully achieved
    Efficacy in achieving the fourth specific objective is rated Substantial.

5. Efficiency:

Both the PAD and the ICR argued that it is not possible to quantify the economic and social benefits of this institutional strengthening technical assistance project and instead pointed to various qualitative efficiency gains (i.e., improved process redesign/re-engineering, targeting, fraud and error detection, and internal/external control). These qualitative gains, however, are largely with regard to sector efficiency and not whether project resources were used efficiently in achieving the PDO. However, the ICR did note that one of the outcomes of the project was a reduction in training costs, although it did not elaborate upon nor quantify these efficiency gains. At the same time, the 18 month delay in effectiveness, the need to extend project closing by 2 years, the limited progress in implementing two of the project’s four components, and the need to cancel the loan served to offset some of these efficiency gains.
    Efficiency in achieving project’s objectives is rated Modest.

    a. If available, enter the Economic Rate of Return (ERR)/Financial Rate of Return at appraisal and the re-estimated value at evaluation:

Rate Available?
Point Value
ICR estimate:

* Refers to percent of total project cost for which ERR/FRR was calculated

6. Outcome:

The project’s development outcome rating is “moderately satisfactory” taking into account the “substantial” relevance of the program’s objectives (which were aligned with the CPS and the government’s development agenda) and design (whose Results Framework linked plausible results with each of the project's components), its “modest” efficiency (due to implementation delays and lack of evidence on efficient use of project funds), and “weaknesses“ regarding the achievement of the specific objectives related to the SSS.

a. Outcome Rating: Moderately Satisfactory

7. Rationale for Risk to Development Outcome Rating:

The PAD considered the project as “high risk” before mitigation measures, with critical risks including: opposition to change; potential limited sustainability and accountability; limited inter-institutional coordination; and use of project funds for purposes incompatible with the project’s objectives. These risks were to be mitigated by Bank staff working closely with counterparts who had strong ownership of the reforms; systematizing practices and external accreditation and thereby making the reforms difficult to reverse; establishing clear roles and expected results; facilitating data-crossing; and a strong focus on procurement, fraud, error detection and auditing. There remain, however, three main risks to development outcomes. First, if left unchecked, the institutional tensions between ANSES and the SSS that complicated project implementation could impede further progress in this area. Second, it remains unclear as to whether a culture of greater public participation and access to information has been imbedded and will continue after project completion. Last, there is a risk that the pension fund could come under stress and the gains from the project lost altogether if the government resorts to the pension fund to finance budgetary expenditures as, according to the Wall Street Journal and the Economist, occurred in the period immediately following Argentina’s 2001/02 economic crash and again in the aftermath of the global financial crisis in 2008.

a. Risk to Development Outcome Rating: Significant

8. Assessment of Bank Performance:

a. Quality at entry:

Overall, the quality at entry of ANSES II was moderately satisfactory. The project design benefited from the lessons drawn from ANSES I and from other world Bank experiences with institutional reforms in the region and elsewhere, including the importance of underpinning reform measures with in-depth analytical work and of pursuing reforms in a gradual, sequenced, and dynamic manner with a greater focus on incentives and results and the inclusion of a sound monitoring and evaluation (M&E) system. Project design also benefited from the Bank’s engagement in a close dialogue with other public institutions, the private sector, multilateral and bilateral institutions, and a variety of civil society organizations. It also called for the establishment of a steering Committee to ensure inter-agency coordination and for a mid-term review that would provide an opportunity to enhance the project’s impact. Shortcomings at entry included unrealistic expectations regarding the speed of effectiveness, reliance on too many performance indicators, and the lack of consideration of the impact of possible government decisions to use pension funds to finance budgetary expenditures.

Quality-at-Entry Rating: Moderately Satisfactory

b. Quality of supervision:

Both the ICR and the QALP-2 report assessed the overall quality of implementation as “moderately satisfactory”. The ICR (para. 58) notes that the Bank team conducted supervisory missions one to three times per year and responded flexibly to client demands as the changing circumstance (i.e. change in ANSES' strategy, evolution in technologies, etc.) required a re-evaluation of the project’s activities during implementation. But changes in the top managers within ANSES and the SSS, in the project coordination unit, and in the World Bank's country team posed significant challenges during project implementation. Although the Bank team was pro-active in supervising the project, it did not monitor and report on project implementation in line with the RF specified in the PAD, failed to “formally” change the project indicators and targets that it “informally” adjusted during implementation, and should have taken all necessary measures to cancel Component 2 as recommended by the Quality Assessment of Lending Portfolio (QALP-2) given the problems encountered. A critical lapse in supervision was not insisting that the Steering Committee be operational for project effectiveness. The Bank’s decision to extend a partial waiver removing this condition proved to be a serious shortcoming as the Committee never became operational and tensions and lack of cooperation between the two institutions most critical to project implementation persisted. As noted in the ICR (para. 57), had the Steering Committee been operational, the institutional challenges could have been addressed. The project also experienced a slow disbursement rate (only 35% as of June 30, 2011-—three months after the original closing date and one year before the revised closing date where it finally reached 72%). It is unfortunate that the mid-term review did not take place (for reasons not discussed in the ICR) and that the Implementation Status Reports (ISRs) consistently rated project implementation as “satisfactory” up unto the final report where it was downgraded to “moderately satisfactory”, raising questions about the basis of the ratings during project implementation.

Quality of Supervision Rating: Unsatisfactory

Overall Bank Performance Rating: Moderately Satisfactory

9. Assessment of Borrower Performance:

a. Government Performance:

The ICR underscored the government’ strong commitment to achieving the PDO as demonstrated by its moving forward on project preparation despite the lags in signing the loan agreement and in effectiveness on account of the request for a waiver regarding the operationalization of the Steering Committee. It also cites the government’s willingness to adjust the project to the changing domestic context (i.e., nationalization of private pension funds, changes in ANSES’ strategy, technological advances) as further evidence of its commitment. However, the resolution of the tensions between ANSES and the SSS required a “political solution” that was not forthcoming on the part of the government. This resulted not only in a six-month lag in effectiveness due to a difference of view on the terms of the national decree, but in the failure to create the Steering Committee that was critical to ensuring project coordination and execution, particularly with regard to activities that did not take off.

Government Performance Rating: Moderately Satisfactory

b. Implementing Agency Performance:

ANSES and the SSS were the key implementing agencies. As noted earlier, the failed creation of the Steering Committee undermined both the inter-agency coordination and cooperation that was critical to successful project implementation and the added layer of accountability by ANSES. As indicated in the ICR (para. 62), ANSES demonstrated strong commitment to the achievement of the projects’ PDO regarding the activities under its direct control, although changes in its staffing made it difficult to reach internal consensus on project procurements and resulted in delays in implementation. The SSS also demonstrated its commitment to the PDO by using its own resources rather than relying on project finance to implement some of the project’s activities. However, changes in SSS leadership and a decline in ownership by the agency undermined project implementation and monitoring, including the lack of reporting to the Project Coordination Unit (PCU) on the status of implementation regarding the associated intermediate outcome indicators. All in all, however, the positive performance by ANSES offset man of the challenges posed by the lack of an inter-agency Project Steering Committee and the weakened level of ownership by the SSS.

Implementing Agency Performance Rating: Moderately Satisfactory

Overall Borrower Performance Rating: Moderately Satisfactory

10. M&E Design, Implementation, & Utilization:

a. M&E Design:

Drawing on the lessons learned from ANSES I regarding the need to have in place a solid M&E system, the PAD put forward a comprehensive RF that specified the PDO and specific objectives, the PDO and intermediate outcome indicators, and the links between inputs and outputs to these desired outcomes. Importantly, ANSES II benefited from the carry-over of experience and continuity of the Project Coordination Unit from ANSES I. Monitoring was to take place through the PCU, ANSES, the SSS, and external stakeholders and to be complemented by Bank supervision through missions, annual work plans and a mid-term review and by participatory M&E on the part of stakeholders and civil society organizations.

b. M&E Implementation:

As previously noted, the application of the M&E envisaged at design differed somewhat from that carried out during implementation. The project aimed at strengthening the M&E of the SSS regarding the oversight of the social security institutions (including ANSES), but this never occurred due to tensions between the two agencies. Moreover, the Bank staff did not use the PAD RF in its reporting through the ISRs and made adjustments to indicators and targets without formalizing them during the project restructurings, which complicated the assessment of project implementation.

a. M&E Utilization:

The ICR noted that the project was designed to allow for the effective integration of M&E results into decision making by top management, building on the use of country systems and sustainability. However, the ICR does not provide any detailed assessment as to whether this actually occurred and, if so, to what extent and to what end. As there are no immediate plans for further World Bank support for ANSES, it is not clear whether the lessons from the implementation of the current M&E system would be integrated into subsequent M&E systems. However, the ICR notes that several initiatives are expected to be maintained and further institutionalized following the project’s closing, and it is possible that the good practice of using M&E results to inform senior-level decision making would be maintained.

The overall Modest rating for M&E quality takes into account its relatively sound design as well as shortcomings in M&E implementation and utilization.

M&E Quality Rating: Modest

11. Other Issues:

a. Safeguards:

As indicated in the PAD, the project did not trigger any of the Bank’s environmental or social safeguard policies.

b. Fiduciary Compliance:

As noted in the PAD and ICR, fiduciary arrangements were in line with Bank policies. A Country Financial Accountability Assessment (CFAA) prepared by the Bank in 2003-04 indicated that the Government had a fully integrated budget, accounting, treasury, and public debt financial management system. Moreover, a Financial Management Assessment (FMA) was carried out and determined that the project had acceptable financial management arrangements in place. ANSES was deemed to have the requisite institutional capacity and the human resources required for project administration, as evidenced by the gradual transfer of procurement responsibilities from the United Nations Office for Project Services (UNOPS) to ANSES. The project’s Interim Financial Reports (IFRs) were submitted in a timely manner, although there were some delays in the submission of annual audited financial statements, as well as some internal control weaknesses that led to qualified opinions. But these did not involve any substantial accountability issues.

c. Unintended Impacts (positive or negative):

The ICR identified the following unintended impacts: improved communication between different units within ANSES, changes in ANSES’ organizational structure as a result of project implementation, reduced training costs, and changes in ANSES’ organizational and management culture. Although these were all “positive” impacts, it is not clear these should not be classified as unintended. Although strengthened collaboration with national universities and the demand from universities to sign cooperation agreements with ANSES appears to be an unexpected outcome, the precise impact is unclear. A negative unintended impact was the fact that the project’s inability to operationalize the Steering Committee and to address the tensions between ANSES and the SSS underscored the vulnerability of the reform effort to the important political and bureaucratic pressures.

d. Other:

12. Ratings:

IEG Review
Reason for Disagreement/Comments
Moderately Satisfactory
Moderately Satisfactory
Risk to Development Outcome:
Risk of continued inter-agency tensions, uncertainty over sustainability of public participation and access to information, and concerns over possible government use of the pension fund resources warrants a significant risk rating. 
Bank Performance:
Moderately Satisfactory
Moderately Satisfactory
Borrower Performance:
Moderately Satisfactory
Moderately Satisfactory
Quality of ICR:
- When insufficient information is provided by the Bank for IEG to arrive at a clear rating, IEG will downgrade the relevant ratings as warranted beginning July 1, 2006.
- The "Reason for Disagreement/Comments" column could cross-reference other sections of the ICR Review, as appropriate.

13. Lessons:

The four main lessons learned from the implementation of the Argentina ANSES II are:
    1. The desire for flexibility should not come at the cost of ensuring key conditions for project success. Given the difficult and ever changing circumstances facing member countries, there is a need for the Bank to be flexible regarding project design and implementation. In the case of ANSES II, Bank management granted a partial waiver on the condition for effectiveness regarding the creation of the Steering Committee. While the waiver may have been viewed as necessary to expedite loan effectiveness, its impact on overall project implementation (particularly regarding Component 2) could have been confronted and addressed prior to effectiveness.

    2. Analysis of political and bureaucratic factors can ensure better project outcomes. Ex ante political economic analyses are critical to effective project design and successful project implementation. The tensions and differences of view between the two implementing bodies (ANSES and the SSS) were well known and ultimately proved problematic for project implementation. The project would have therefore benefited from a deeper analysis of the political factors complicating inter-agency coordination.

    3. Adjustments to project indicators and targets should be formalized in the context of mid-term reviews and/or restructurings. It is inevitable that performance indicators may need to respond to changes in program activities and circumstances. The Bank revised several indicators and targets in response to changes in project activities arising from strategy and technological changes at ANSES. The lack of formalizing these changes undermined project monitoring and assessment relative to the RF specified in the PAD.

    4. Effective coordination mechanisms are needed to facilitate cooperation when institutional responsibilities overlap and service delivery is segmented. Political buy-in and ownership is critical to any reform effort. Such buy-in becomes even more important when there are multiple agencies involved in and critical to project implementation. The lack of coordination and collaboration by the key agencies involved in project implementation therefore impeded satisfactory project implementation. Efforts need to be redoubled at the design stage and prior to project effectiveness to ensure that broad-based support is in place, including through the inclusion of an inter-agency steering committee as originally proposed.

14. Assessment Recommended?


15. Comments on Quality of ICR:

The ICR was well written and its tone relatively candid. It included a useful and detailed assessment of the key factors affecting project design, implementation, and outcome. Although it underscored key project deficiencies (i.e., the lack of creation of a Steering Committee, the continued tensions and lack of coordination between ANSES and the SSS, etc.), the ICR could have taken a stronger stand regarding the Bank’s overly optimistic assessment of project implementation in the ISRs and its failure to carry out a mid-term review and to seek Board approval of the informal changes made to the M&E indicators and targets. The ICR could also have questioned whether project outcomes could be undermined by government decisions regarding the use of the pension funds, made a judgment as to the quality of the beneficiary surveys, included an explicit discussion of the cancelled loan amounts and their impact on efficiency, and not characterized certain impacts as being unintended.

a. Quality of ICR Rating: Satisfactory

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