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Implementation Completion Report (ICR) Review - Federal District Multisector Management


  
1. Project Data:   
ICR Review Date Posted:
08/27/2013   
Country:
Brazil
PROJ ID:
P107843
Appraisal
Actual
Project Name:
Federal District Multisector Management
Project Costs(US $M)
 400.0  966.0
L/C Number:
L7675
Loan/Credit (US $M)
 130.0  26.1
Sector Board:
Health, Nutrition and Population
Cofinancing (US $M)
   
Cofinanciers:
Board Approval Date
  04/09/2009
 
 
Closing Date
12/31/2012 12/31/2012
Sector(s):
Public administration- Transportation (33%), Public administration- Health (18%), Public administration- Education (18%), General education sector (16%), Health (15%)
Theme(s):
Education for all (34% - P) Other urban development (32%) Health system performance (13%) Population and reproductive health (11%) Child health (10%)
         
Prepared by: Reviewed by: ICR Review Coordinator: Group:
Pia Schneider
Judyth L. Twigg Christopher D. Gerrard IEGPS2

2. Project Objectives and Components:

a. Objectives:

According to the Legal Agreement, the objectives of the project were: "to (a) improve public sector management and accountability by expanding results-based management practices and improving fiduciary oversight; and (b) increase access, quality and efficiency of the education, health and public transport services, through the modernization of the education system, the modernization, decentralization and integration of various levels of health care, and the strengthening of the institutional and operational capacity of the public transport sector."

The objectives in the Project Appraisal Document (PAD) were identical (p. 14).

Progress towards the objectives was to be measured through 28 indicators, of which 11 were linked to disbursement (Legal Agreement Schedule 5, pp.18-19).

b. Were the project objectives/key associated outcome targets revised during implementation?
No

c. Components:

The project contained two components:

Component 1. Strengthening Results-based Management in the Public Sector (appraisal: US$ 130 million; actual: US$ 24.5 million). This component would use a Sector Wide Approach (SWAp) to support the adoption of results-based management tools, including the signing of annual results agreements between the Governor and each of the line secretariats and agencies of the Federal District, and the submission of annual reports on performance with respect to agreed targets. The component was to co-finance selected eligible expenditure programs (EEPs) in health (modernization of health secretariats and primary health care, health information systems, communicable diseases, hospital management), education (education always, school for all, modernization of school management), and transport (management support, safe transportation). Subject to legislative approval, the Government intended to introduce rewards (e.g., additional budget, bonus payments) for those entities that met or exceeded their performance targets in their expenditure programs.

Component 2. Building Capacity in the Public Sector (appraisal : US$ 10 million; actual: US$ 1.25 million). This component was to finance: (i) technical assistance and training to support the implementation of results-based management and the fulfillment of agreed performance targets under the first component; (ii) preparatory studies for a possible future operation; and (iii) technical assistance to strengthen fiduciary oversight of the project. Technical assistance was planned for cost-accounting systems, assessment of management programs, outsourcing of services, reforming public transport, impact evaluations, strategy training, capacity building in financial management and procurement, and a Public Expenditure and Financial Accountability (PEFA) exercise.

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

Project Costs at appraisal were US$ 400 million, including US$ 270 million from the Borrower and US$ 130 million from IBRD. Actual project costs increased to US$ 966 million, including US$26 million from IBRD and a considerably higher Borrower contribution of US$ 940 million (see below).

Financing: The project was to be financed by an IBRD loan of US$ 130 million to the Federal District in Brazil. The loan disbursed $26.1 million, reflecting 20% of the appraised amount. The remaining loan amount of US$ 109.9 million was cancelled (Cancellation letter, July 17, 2013). The loan was to disburse against 11 indicator targets when they were met as outlined in the Legal Agreement Schedule 5. Non-compliance resulted in proportionally lower disbursements based on an agreed algorithm.

Borrower Contribution was estimated at US$ 270 million at appraisal. Based on information provided by the Government, the ICR reports a substantially higher actual borrower contribution of US$ 940 million (ICR, p. 19). The TTL clarified that the Borrower fully financed the EEPs in health, education and transport, and that the initial Borrower contribution amount had been underestimated at appraisal.

Dates: Project closure was on time on December 31, 2012, as originally planned.


3. Relevance of Objectives & Design:

a. Relevance of Objectives:

Relevance of objectives: High. The objectives were highly relevant in the socio-economic and fiscal context. In 2008, during project preparation, the global economic crisis started to negatively affect economic growth in Brazil. Social sector spending had increased substantially over time. Some States introduced efficiency reforms and measures to improve quality of service delivery. The new government in 2007 launched reforms to improve the efficiency and effectiveness of public expenditures and signed results agreements with government agencies. Project objectives were in line with the Bank's Country Program Strategy (CPS, 2008-2011), which was to support growth, good governance, and public sector management as a foundation to address equity, competitiveness and sustainability. The CPS also supported State-level operations. The project's objectives are also supported by the current CPS (2012-2015) objectives of improved quality in public services for low-income households. The region further clarified that although, the definition of the project's objectives is complex involving three sectors, the objective is in line with the strong implementation capacity at the District government, it supports existing expenditure programs at the government, and indicators reflected ongoing government policies.

b. Relevance of Design:

Relevance of design: Modest. Project design had some innovative elements and used Government procedures and staff to foster ownership, reduce transaction costs, and strengthen local systems. It provided necessary funds to the Federal District to implement a Federal Government program, and it disbursed against results instead of financing inputs. A focus on results was expected to improve resource allocation and reduce service inequality across States. The design used a SWAp, meaning that it financed the government's eligible expenditure programs in health, education, and transport, and would disburse against the execution of budgeted programs when agreed indicator targets were met. The design was to use Government systems, procurement, and staff.

However, the design was overly complex, spanning over three sectors and involving several agencies and secretariats. The algorithm linking disbursement to results was not clearly defined. The design was not clear about the Bank's procurement rules in this SWAp, which used Government systems. Although the design was to introduce results-based disbursements, it did not require independent technical audits of disbursement indicator data submitted by the Government. The results framework was inappropriate for such a complex design. It included overly ambitious project objectives defined for three sectors. Activities and indicators were either not linked to the objectives, or missing. The second component was to fund technical assistance, which was against the Law authorizing the Bank loan; this design was not restructured, and the Law authorizing technical assistance was only changed on July 14, 2011, two years after the project had been approved. The design was also much too complex for the political context considering that any change in leadership in the Government would lead to changes in technical staff and loss in critical capacity to implement such a complex project design.


4. Achievement of Objectives (Efficacy) :

Few project activities were implemented. Under Component 1, incentive rewards for health and education were not introduced. and education programs were discontinued under the new administration from 2009 - 2011. The transport sector was most affected by a corruption scandal, and therefore several activities were not implemented. The project's lack of procurement capacity led to no procurement under Component 1 until its final year. Under Component 2, none of the planned technical assistance was contracted. Instead, training was provided to auditors working at the State Secretariat of Transparency and Control to improve its auditing function. Study tours were financed to Uruguay and studies carried out on the quality of asphalt, information technology systems, and social participation among subpopulations. These studies were not linked to project objectives and results indicators, and most of them were only finalized by the end of 2012. Delays in the approval of the procurement plan severely delayed the implementation of these activities.

The results framework did not distinguish between process and outcome indicators.

(i) Improve public sector management and accountability - Negligible

Outputs:

  • The number of annual results agreements signed increased from 1 in 2008 to 26 in 2011, meeting the target of 26. However, an annual report by the Institutional Planning Coordination unit identified only 20 active results agreements in 2012. It is thus not clear whether results agreements had an impact on public sector management and accountability.
  • The number of annual performance reports issued by secretariats and published by the State Secretariat of Planning and Management (SEPLAG) increased from 0 in 2008 to 20 in 2012, almost meeting the target of 21.
  • There was increased budget execution of EEPs from 0% in 2008 to 56% in education, 53% in health, and 55% in transport in 2011, not meeting the target of 70%. Health and transport met the target in 2010.

Outcomes:
  • Compliance with Fiscal Restructuring and Adjustment Program (PAF) as measured by a ratio of less than 1 for financial debt / real net income and less than 60% for personnel expenditures: Target was achieved every semester. The latest ratio was 0.24, and expenditures were 52%.
  • A Public Expenditure and Financial Accountability (PEFA) action plan was agreed but not fully implemented, not meeting the target.
  • A procurement plan based on OECD indicators diagnostic was agreed but not fully implemented, not meeting the target.
  • A decree was approved to introduce performance incentives in the education sector, but the decree was cancelled in June 2010. Target not met.
  • A decree was approved to introduce performance incentives for health, but it was never implemented. Target not met.
  • Bus companies did not supply the necessary data to assess whether the Federal District Transport Authority (DFTRANS) is processing primary operational and fare revenue data on a daily basis.

(ii) Increase access to public services - Negligible

Health:
Outputs
  • The percentage of the population with Cartao de saude (electronic health cards) increased from 10% in 2008 to 75% in 2012, surpassing the 50% target; however, no information is provided on whether a health card leads to improved access to health services.
  • The percentage of the population covered by the Family Health Program increased from 7% in 2008 to 20% in 2012, not meeting the target of 40%.
Outcomes
  • Pregnant women with at least 4 prenatal visits increased from 72% in 2008 to 88% in 2012, surpassing the target of 80%. These are average numbers and do not distinguish between program beneficiaries and others.

Education:
Outputs
  • Full-time basic education activities were not implemented in the 100 targeted schools in low-income areas. The full-time schools that were supposed to develop the program were not located in the priority areas.
Outcomes
  • Enrollment in Early Childhood Development (ECD) programs in low-income areas for children aged 4-5 years decreased from 77% in 2007 to 68% in 20011, not meeting the target of 90%. There were not enough public schools to serve the target groups with ECD programs.
  • Completion rates in primary education increased from 63% in 2007 to 85% in 2011, surpassing the target of 80%. However, it is not clear how the project has contributed to this result.
  • Completion rates in secondary education dropped from 75% in 2007 to 66% to 2011, not meeting the target of 85%.

Public Transport:
Outputs
  • The State Secretariat of Transport submitted a master plan for urban transport to the legislature, which was approved in May 2011.
Outcomes
  • No information is provided on how this master plan has affected access to public transport.

(iii) Increase quality of public services - Negligible

Health:
Outcomes
  • The percentage of infant deaths investigated increased from 40% in 2008 to 64% in 2012, not meeting the target of 90%.
  • The pap smear rate among women declined from 13.4% in 2008 to 12% in 2012, not meeting the target of 20%.

Education:
Outcomes
  • The Basic Education Development Index in primary schools located in poor urban areas increased by 2% in 66 schools, not meeting the target of 125 schools. From 2009 - 2011, no school had developed the 7-hours-per-day program in low-income areas.
  • The number of students with over-age distortion in basic education declined from 92,104 in 2007 to 69,693 in 2011, not meeting the target of 17,000. The Government discontinued the program by private entities.
  • The number of students with over-age distortion in secondary education declined from 34,805 in 2007 to 23,733 in 2012, not meeting the target of 3,000. The new Government discontinued the EEP education program.

Public Transport:
Output
  • A planned Control Center for Operations was not established,
Outcomes
  • DFTRANS could not monitor the targeted 10% of the basic bus service fleet.
  • Data are not available to assess whether the number of complaints on non-compliance with timetables and itineraries declined from 9,000 in 2008 to a target of 7,000 in 2012. The methodology was changed to assess this indicator.

(iv) Increase efficiency of public services - Negligible

Health:
Output
  • A civil society organization was selected to manage the Hospital St. Maria in 2008, but the contract was cancelled by 2012.
Outcomes
  • The target of 70% cost reporting and more than 70% patient satisfaction in the St. Maria Hospital was not achieved.

Education:
  • Data are not available to assess whether there was an increase in the efficiency of implementation of the school management strategy from 0% to the targeted value of 90%.

Public Transport:
  • Data are not available to assess whether the regularity index for bus trip compliance increased from 77% in 2008 to the targeted value of 90%.

5. Efficiency:


The PAD (p. 107) estimated a Net Present Value (NPV) of benefits of US$1,500 million over 10 years and an internal rate of return (IRR) of 56 percent. This IRR is very high raising concerns about the methodology used. This IRR was estimated based on expected improvements in education (avoided dropouts), health (avoided hospitalization) and transport (hours saved). However, most project activities were not implemented or discontinued (ICR, p. 11); thus, in reality the project did not contribute to benefits anticipated in the economic analysis. The ICR does not include an efficiency analysis.

Efficiency in project implementation was negatively affected by frequent turnovers in Government administration and related staffing, and there were long periods of inactivity.

Efficiency is rated Negligible.

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
Coverage/Scope*
Appraisal:
Yes
56%
100%
ICR estimate:
No
%
%

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

6. Outcome:

Relevance of objectives is rated as Substantial and relevance of design as Modest because of an overly complex project design and weak results framework. Progress toward improved public sector management and accountability is rated Negligible in the absence of evidence. All three sub-objectives on access, quality and efficiency are rated Negligible, as most targets have not been met, and planned activities were not implemented or data not collected to measure progress. Efficiency was Negligible, as project activities did not contribute to benefits anticipated in the economic analysis. Overall outcome is rated highly unsatisfactory due to severe shortcomings in the operation's achievement of its objectives and and its efficiency.

a. Outcome Rating: Highly Unsatisfactory

7. Rationale for Risk to Development Outcome Rating:

The Government has not allocated the necessary funding to develop and continue reforms anticipated under the project. Most education and transport activities were modified or discontinued. Federal funding is expected to continue financing the family health program and the implementation of health cards in the States. Uncertainty about funding and political changes that limit the continuity of institutional capacity in the Government administration pose a significant risk to the development outcomes. The region clarified that these risks mainly pertain to education and public sector management, and to a lesser extend to reaching the development outcomes in the health and transport sectors which constituted more than 60 percent of project financing.

a. Risk to Development Outcome Rating: Significant

8. Assessment of Bank Performance:

a. Quality at entry:

Project preparation was informed by a social assessment, financial management and procurement capacity assessment, and a Public Expenditure and Financial Accountability Assessment (PEFA) with an action plan to address weaknesses. Procurement training was organized using OECD indicators. A Quality Enhancement Review (QER) was conducted in April 2008 and recommended a more realistic approach to the results framework and disbursement modality. The Bank saw a results-based SWAp design, as implemented in other States (Minas Gerais), as a cutting-edge approach.

The (PAD, p. 27) anticipated elections in 2010 that could lead to political changes, including a less reform-oriented Government, that could slow down progress. However, the PAD assumed that by then the project would have yielded positive results that would convince any new administration to continue the reform agenda supported under the project. The PAD also considered that delays in program implementation and insufficient capacity among staff could affect progress toward targets, which would slow down disbursement. All these risks were considered as low or moderate because of strong Government support for the reform program. In addition, the Project operated in a high fiduciary risk environment. Financial management risk was assessed to be moderate and procurement risk as average at the time of appraisal. However, all these risks materialized and severely affected the development outcome of the project.

Quality at entry had severe shortcomings. The Bank team did not adequately draw from other project experience. As a result, the project's results framework was too complex, and the required M&E framework for a results-based operation was not developed (see Section 10). The PAD does not clarify how results agreements would be monitored and evaluated, and M&E capacity was not assessed. The Bank did not adequately address procedural constraints in a SWAp, such as the need for the Federal District Attorney General's office to approve procurement, and the Loan Approval Law that declared project funds for technical assistance as unfeasible. The Bank did not prepare a results framework that linked objectives to activities and indicators, and project design with three sectors was much too complex. The Bank could have developed a simpler project based on the experience of other results-based programs in Brazil and Argentina. The Bank did not provide for independent technical audits of data used for disbursement indicators. The Bank's risk assessment was too optimistic and did not provide for adequate alternatives in the event that risks materialized. All these shortcomings ultimately had a detrimental impact on project performance.

Quality-at-Entry Rating: Unsatisfactory

b. Quality of supervision:

Supervision was inadequate for a results-based operation. There was a corruption scandal in the Government in 2010, shortly after the project became effective. The Bank conducted a fiduciary review and did not find any corruption in Bank-funded projects. The Bank considered triggering project suspension; however, insufficient project files and incomplete data collection impeded any legal action. The Bank's financial management and procurement teams did not reassess financial management and procurement capacity after the corruption scandal, which involved substantial turn-over of fiduciary staff at the Government. The Bank did not follow up on developing the missing M&E framework needed for a results-based operation.

Although disbursement was linked to results, supervision visits after June 2010 did not report on relevant indicators. Aides Memoire were irregular, incomplete, or missing, and there was no reporting on the results agreements. Project files provide evidence of only three missions during more than three years of project implementation, and these missions were incomplete, missing relevant sector specialists. After the project's first year, only 7 of 25 indicators were met, and from 2010 to 2012 several indicators deteriorated with none of the activities under Component 2 implemented. There were delays in preparing acceptable procurement plans, which delayed disbursement. Disbursement only started in April 2011, more than one year after the project became effective. Bank supervision did not become more active when project implementation and related disbursement was seriously delayed. The mid-term review in February 2011 found the project to be relevant and provided fiduciary training to new staff at the Government. In June 2011, the Bank discussed with the Government a project restructuring proposal, and the request was sent to the Bank in October 2011. The planned PEFA was not conducted.

The region clarified that supervision became extremely difficult due to the political circumstances after Project effectiveness and the lack of capacity at the Government's Project management team after a new administration took office. In 2011, after the political crisis had settled, the supervision team spent considerable efforts towards a restructuring, but the Government was slow to respond. When the Bank finally received the Government proposal for restructuring, the Bank, decided against an extension, given the track record of implementation. The team maintained a high level dialog with the Governor to define an action plan for the remaining period of the Project. The team also explored options for suspension with the regional Chief Council. However, the Governor took several months to respond to the correspondence from the Bank. In 2012 suspension was not deemed feasible due to (a) the length of a formal suspension of disbursements process and the short time until the Closing Date (December 2012), and (b) the weak legal grounds for triggering the suspension. It was concluded that the Bank should not take any unilateral action and let the Project close at the respective Closing Date.

Quality of Supervision Rating: Unsatisfactory

Overall Bank Performance Rating: Unsatisfactory

9. Assessment of Borrower Performance:

a. Government Performance:

The Government includes the Governor's office, the State Secretariat of Finance, and the Federal District Court of Accounts. The Government during project preparation showed strong commitment to the project, as evidenced by a high planned Borrower contribution and a detailed project proposal that served as the basis to develop the project. The Government proposal identified the three sectors (health, education, and transport) most in need of support. The Government appointed focal points from education, health, transport and the Secretariat of Planning (SEPLAG) to design the project with the Bank team. However, immediately after project effectiveness, Government performance deteriorated. A corruption scandal in 2010 led to the arrest of the Governor, and his Deputy resigned. The corruption did not affect any Bank projects financially, but it seriously affected Government commitment and support to the project. Consequently, the Governor changed five times within the first project year, and each Governor brought new staff and altered administrative structures. These staffing changes contributed to a loss of ownership for the project. The Government did not facilitate the capacity needed in the project coordination unit for project implementation as required by the project's operational manual. The Government did not take any action to address obvious weaknesses in project performance and in project management. A request for restructuring was prepared only eight months after it had been discussed with the Bank.

Government Performance Rating: Unsatisfactory

b. Implementing Agency Performance:

The project was implemented by five agencies: the State Secretariat of Planning and Management (SEPLAG), State Secretariat of Education (SEE), State Secretariat of Health (SES), State Secretariat of Transport (SET), and Federal District Transport Authority (DFTRANS). Project ownership in these agencies was low and was negatively affected by political interference. Coordination meetings did not take place as planned, and progress reports were not prepared. Staff working in the project coordination unit (PCU) changed several times in line with Government changes. The PCU had limited access to decision makers and other partners. The team had insufficient capacity in fiduciary and M&E skills to implement the project. Supervision and validation of data received from the sectors were incomplete. No training was provided to build M&E capacity. Poor planning caused delays in access to funding. The procurement specialist and independent technical audit consultancy were never hired. This resulted in serious procurement and disbursement delays. Financial audits were delayed. The 2012 audit report found that recommendations issued in 2010 had not been addressed. Only two audits were carried out, even though the fiduciary environment was considered high risk.

Implementing Agency Performance Rating: Highly Unsatisfactory

Overall Borrower Performance Rating: Highly Unsatisfactory

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

a. M&E Design:

This was a results-based operation, and M&E should have provided a strong framework to collect reliable data for disbursement indicators. However, the PAD did not describe how results agreements between the different partners would be monitored and evaluated. No outcome indicators were included to measure changes in public sector management derived from the results agreements. Indicators were not clearly defined and were incorrectly calculated in progress reports. A results framework, linking objectives with activities and indicators, was not prepared.

b. M&E Implementation:

The PCU was responsible for M&E, including ensuring data quality and building M&E capacity. The secretariats' statistical units provided the data for the various indicators. Data quality was not reviewed. Staff changed frequently and did not have the necessary capacity to implement the required data collection and analysis. No training was provided to build capacity. No independent technical audit was conducted of indicators used to define disbursement.

a. M&E Utilization:

This results-based project was a missed opportunity to set up and institutionalize a simple M&E framework with clearly defined indicators for disbursement. Indicators were used to define the disbursement amount; although the validity of data is questionable. Data for several indicators in transport and education were not collected or were invalid and could thus not be used (see Section 4). The project did not contribute to strengthening M&E utilization.

M&E Quality Rating: Negligible

11. Other Issues:

a. Safeguards:

Safeguards were not triggered. Construction consisted only of minor repairs in existing health clinics and schools.

b. Fiduciary Compliance:

Financial Management (FM): Weaknesses identified during project preparation and the PEFA assessment were to be addressed through an agreed FM Action Plan. However, key actions to improve internal controls were overly optimistic, considering the weak financial management capabilities of the Government, resulting in delays. By March 2011, the first audit report (2008-2009) had yet to be carried out. The Bank agreed to waive this audit report and the report for the first six months of 2010, as there were no Bank-financed expenditures during the period. The Bank agreed to have external audits. The audit for the second semester of 2010 was delayed, mainly because the Bank feedback was delayed by more than four months. The 2011 audit was submitted in November 2012, and the report noted that several weaknesses detected in 2010 on the PCU's ability to manage project funds had not been addressed. The PEFA to be carried out under the Project was never executed.

Procurement: A draft Procurement Action Plan, which was to be finalized during the first semester of implementation and financed through Component 2, was prepared based on the Procurement Assessment. The assessment included only SEPLAG’s Central Bidding Committee (CBC), as it was to carry out all project procurement under the Project. The CBC suffered significant staff rotation due to the corruption scandal, as well as loss of staff (and later a restructuring). This lack of procurement capacity led to no procurement under Component 1 until its final year. Delays in the approval of the procurement plan delayed access to Component 2 funds. In addition, the Federal District Attorney General’s office had to approve all procurements; however, they were unaware of the agreed procedures.

c. Unintended Impacts (positive or negative):
None reported.

d. Other:



12. Ratings:

ICR
IEG Review
Reason for Disagreement/Comments
Outcome:
Unsatisfactory
Highly Unsatisfactory
Relevance of objectives is rated as High and relevance of design as Modest because of an overly complex project design and weak results framework. Progress toward improved public sector management and accountability is rated Negligible in the absence of evidence. All three sub-objectives on access, quality and efficiency are rated Negligible, as most targets have not been met, and planned activities were not implemented or data not collected to measure progress. Efficiency was Negligible, as project activities did not contribute to benefits anticipated in the economic analysis.  
Risk to Development Outcome:
Moderate
Significant
Uncertainty about funding combined with political changes that limit the continuity of institutional capacity in the Government administration pose a significant risk to the development outcomes.  
Bank Performance:
Unsatisfactory
Unsatisfactory
Quality at Entry and Supervision were inadequate to manage a complex results-based financing operation in a high risk fiduciary setting and in a context of constant political and administrative changes.

 

Borrower Performance:
Highly Unsatisfactory
Highly Unsatisfactory
 
Quality of ICR:
 
Satisfactory
 
NOTES:
- 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 ICR (p. 17) offers valuable lessons:

Results-based operations with SWAp agreements require strong Government commitment, including high-quality staff. Safeguards could help to quickly adjust to changes in Government and commitment.

M&E is a cornerstone in results-based operations. In this case, the missing M&E framework severely affected validity of data and of indicators used for disbursement.

Bank procurement rules in a SWAP can remain challenging and require special attention, even though country fiduciary systems are used. In this case, the Bank's procurement rules requested contracts to comply with anti-fraud and anti-corruption clauses, which was not a requirement in the country procurement system.


14. Assessment Recommended?

No

15. Comments on Quality of ICR:

The ICR is well written, clear, candid, and concise. It provides an unusually candid assessment of weaknesses in Bank and Borrower performance and how these have factors negatively affected project outcomes. The quality of evidence and of analysis is strong. The ICR is internally consistent and in adherence to the guidelines.

a. Quality of ICR Rating: Satisfactory

(ICRR-Rev6INV-Jun-2011)
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