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Implementation Completion Report (ICR) Review - Transparency And Accountability Capacity Building Project

1. Project Data:   
ICR Review Date Posted:
Project Name:
Transparency And Accountability Capacity Building Project
Project Costs(US $M)
 15.0  5.6
L/C Number:
Loan/Credit (US $M)
 15.0  5.6
Sector Board:
Public Sector Governance
Cofinancing (US $M)
Board Approval Date
Closing Date
12/31/2012 12/31/2012
Central government administration (85%), General public administration sector (15%)
Public expenditure financial management and procurement (50% - P) Other public sector governance (25% - S) Administrative and civil service reform (25% - S)
Prepared by: Reviewed by: ICR Review Coordinator: Group:
Nestor Ntungwanayo
Fareed M. A. Hassan Lourdes N. Pagaran IEGPS2

2. Project Objectives and Components:

a. Objectives:

        The Project Development Objective (PDO) was to (i) enhance transparency and efficiency in public finance management (PFM), and (ii) strengthen accountability in the use of public resources [Project Appraisal Document -(PAD)] p. 5. The Financing Agreement (FA) on p. 5 had a similar PDO, but also emphasized the four project components.

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

c. Components:

The project had four components as detailed below:

Component 1: Improving budget management including procurement: $4.1 million at appraisal against actual amount of $2.4 million. This component focused on giving support to revision of processes, methods and regulations for budget programming, budget execution including procurement, budget monitoring and controls, and treasury accounting, in order to primarily address deficiencies in capital budget management and limitation in the execution of investment projects.

Component 2: Integration and development of the financial management information system (FMIS) including the human resources (HR) and payroll management: ($5.9 million at appraisal against actual amount of $1.2 million). The component aimed primarily to (i) enhance efficiency, transparency, controls, and checks and balances in the management of personnel and payroll through improvement of the current information system, and (ii) contribute into accelerating the implementation of the ongoing human resources management (HRM) reform, in particular the decentralization of personnel and payroll management database.

Component 3 : Strengthening external oversight and monitoring and evaluation (M&E): ($1.9 million at appraisal against actual amount of $0.8 million). The objective of this component was to enhance external oversight, communication and M&E, to allow national stakeholders to carry out effective management and use of public resources, and fight corruption, while enabling the legislature and citizens to exercise scrutiny and increase their demand for more accountability.

Component 4: Support to the project focal point for PFM Reforms coordination: ($1.5 million at appraisal against actual amount of $0.9 million). This component was to support capacity building activities for the Ministry of Finance and the PFM reforms structures to properly carry out their coordination, monitoring, and leadership roles in line with the Paris Declaration objectives.

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

This operation was a technical assistance credit approved on 06/24/2008 in the amount of $15 million and made effective on 06/05/2009. The project was restructured (level 2) once on 12/04/2012, and closed on schedule on 12/31/2012. Actual disbursed amount (current and expected at closure) was $5.6 million (37% of total loan), incccccluding $0.3 million disbursed as PPF advance and contingency fund. The un-disbursed balance was cancelled.

3. Relevance of Objectives & Design:

a. Relevance of Objectives:


Improving governance and fighting corruption has been Cameroon’s greatest development challenge during the two last decades or so. Transparency International's corruption rating for Cameroon rose from last place in the late 1990s to 138th of 163 countries surveyed in 2006. For six years in a row (2005-10), Cameroon's Country Policy and Institutional Assessment (CPIA) rating for transparency, accountability, and corruption in the public sector as well as on property rights and rule-based government stagnated at 2.5, underscoring how vested interests outweighed all country's efforts to improve governance indicators.

      To address the above challenge, the 2009 Growth and Employment Strategy Paper (GESP) for Cameroon intended to continue the modernization of the public administration, especially by improving the institutional framework, administrative management and governance. The GESP's emphasis was to be laid on: (i) capacity-building in strategic planning, regulation of the economy and public finance management, (ii) human resource management, and (iii) protection of the domestic economic sphere. (GESP, p.98). Moreover, the 2006-10 National Governance Program aimed at strengthening the state’s role as facilitator and regulator of economic and social activity, improving the business climate, and increasing citizen participation in public affairs.
      Starting in the mid-1990s, the Bank diagnosed the State’s governance deficit, and governance has been an overarching theme of IDA strategy objectives in Cameroon. During the implementation period of the ISN FY07-08, the Bank focused on four areas: (i) strengthening public financial management, including procurement, (ii) supporting harmonization and strengthening personnel and payroll management, (iii) helping the Government and national stakeholders deliver results on corruption, and (iv) supporting the continued implementation of the extractive industries transparency initiative (EITI), focusing on the independent audit of oil revenues and the development of oversight capacity by civil society organizations. The development objective continued to be relevant in the context of the CAS for the period 2011-2013 that incorporated governance as a cross-cutting theme to improve service delivery and promote inclusive growth.
      However, as noted in the ICR (para 35-40), the project design was too ambitious with respect to the scope of planned activities, the number of beneficiary institutions intended to be covered, and the weak government technical capacity. In all, the project objective was consistent with the Bank's strategy in Cameroon at the project launch and at closure, and was addressing key challenges to the country's development, but it was overly ambitious.

b. Relevance of Design:


The result chain of the project was well-thought through (see Tables 3&4 and graph on page 36 of the PAD). It is worth noting that the design of the results matrix and the choice of indicators was built on the basis of the results of the 2007 Public Expenditure and Financial Assessment (PEFA) and the 2006 Public Expenditure Management and Financial Accountability Reports (PEMFAR).
Project indicators were appropriately selected but the targets were too ambitious. It was unrealistic to address concomitantly budget, HRM and payroll reforms, as well as FMIS and external oversight and M&E in the context that was prevailing in Cameroon. The project design did not sufficiently take into account the implications of the country's political economy situation in project design. In particular, limited consideration was given to reform sequencing and change management aspects.

4. Achievement of Objectives (Efficacy) :

      The Project Development Objective (PDO) was to (i) enhance transparency and efficiency in public finance management (PFM), and (ii) strengthen accountability in the use of public resources. Efficacy of project implementation is summarized below.

      To enhance transparency and efficiency in public finance management (PFM): Modest

      The performance was to be measured by the availability of information on resources received by service delivery unit (PEFA indicator, PI-23). While this indicator for Cameroon should have increased from the D level in the 2008 PEFA report to a score of B in 2012 through the support of the project, data was not available to measure progress. Two intermediate performance indicators for this sub-objective were missed as the decree on new budget nomenclature was never drafted, and the financial statement on budget execution was not completed as planned. There was no data to gauge performance as regards to: (i) the percentage of investment projects which were domestically financed in annual budget compliant with the new project legal and procedures framework, (ii) the number of control steps and duration of critical controls in expenditure chain, and (iii) the percentage of contracts above threshold procured through open competition in selected ministries.

      Most of the activities undertaken toward this sub-objective were comprised of diagnostic work. The only tangible improvement was the timely preparation of the 2013 Budget. There were no significant changes with regard to streamlining the expenditures chain and strengthening treasury inspection services. The impact of the project on public procurement reform was insignificant when the project closed. The creation of the Ministry of Public Procurement in December 2011, with shared responsibility between the Regulatory Agency for Public Procurement has added an additional layer of bureaucracy that could be detrimental to the effectiveness of public procurement operations.

      The project helped to consolidate and sustain the Government's commitment to the reforms envisaged. The establishment of the Public Financial Management Technical Secretariat (PFMTS) contributed to enhancing overall reform coordination by the State. Support provided by the project to the PFMTS team in the form of equipment and training contributed to the implementation of the national PFM reform agenda. However, this contribution could not do much against a low level of government commitment to reforms, especially in strategic areas of public finance and human resources management.

      To strengthen accountability in the use of public resources: Modest
      The project’s sub-objective was also to be evaluated by the PEFA indicator (Indicator PI-10) measuring public access to key fiscal information. The country’s score for this indicator was expected to progress from B in 2008 to A by the end of the project in 2012, but this indicator target was not met. Other intermediate performance indicators for this sub-objective were all missed, as the timely issuance of semi-annual budget reports was not improved, and the degree of integration and reconciliation between personnel records and payroll data was below the target. The only achievement under this sub-objective was the production and adoption of a comprehensive ICT strategy by the Ministry of Finance, but the strategy was not implemented, and the project impact on enhancing financial reporting or increasing access to information was insignificant. The diagnostics of the HRM and payroll information management systems was completed and adopted by the Government. Neither the pilot study on civil servant remuneration, nor the technical assistance to revise the HR procedures manual was completed and the project was closed before the completion of the HRM and payroll reform.

      Progress was limited toward enhancing external oversight, communication and M&E, which are necessary to enable national stakeholders to support effective management and use of public resources, fight corruption, and enable the legislature and citizens to exercise scrutiny and increase demand for more accountability. The two indicators set for this sub-objective were all missed as the rating of the scope of the legislature scrutiny of the annual budget law was unchanged, and the target for timeliness of the release of semi-annual budget reports on available media was not met. While a Public Expenditure Tracking Survey (PETS) was published, there was no dissemination and planned capacity building activities were not implemented. A diagnostics of the local committee's monitoring of investment budget execution was completed and recommendations were used to draft a decree, but the latter had not been approved yet when this report was completed.

5. Efficiency:

        There was no quantitative analysis of economic return prepared for this project, and the ICR didn't provide any information under this section. Operational and administrative efficiencies and shortcomings that were linked to the design choices and project implementation approaches were not substantiated in the ICR either. Considering that the project realized few of the originally intended activities and results, and that the project was disbursed at the level of 37% of the approved amount, the overall efficiency of the project is deemed to have been 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
ICR estimate:

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

6. Outcome:

      The relevance of objective was substantial as the project was in support to the Bank's strategy for Cameroon at the project launch and at its closure, and intended to address key challenges to the country's development (poor governance and weak transparency). However, the project objective was ambitious. Relevance of design was modest, because while the result chain of the project was sound, the magnitude of the program was not realistic and limited consideration was given to reform sequencing and change management aspects.

      Efficacy on each of the two sub-objectives is rated modest. Regarding budget preparation, execution and control, the only tangible improvement was the timely preparation of the 2013 Budget. As regards to the development of an FMIS, there was only the production and adoption of a comprehensive ICT strategy by the Ministry of Finance. Toward strengthening external oversight and M&E, three expected achievements were inconclusive. Finally, the establishment of the PFMTS contributed to enhancing overall reform coordination by the State, but this contribution could not do much against a low level of government commitment to reforms.

      Efficiency is rated negligible. The ICR provided little information on the project efficiency, which is considered very low by this review, because of limited progress towards the achievement of the PDOs, and the low level of disbursed amount (37% of the approved amount).

      a. Outcome Rating: Unsatisfactory

7. Rationale for Risk to Development Outcome Rating:

        The reform program supported by the project performed poorly, mainly because of insufficient political will to confront vested interests, specifically in the areas of procurement and human resources management. Limited achievements were mostly in the area of diagnostic work which has not contributed significantly to tangible outcomes. Introduction of program budgeting was achieved in 2013, but this new practice has not yet translated into measurable improvements in transparency and accountability in the use of public resources and in service delivery. While accounting, treasury, financial control and procurement, and HR-payroll integration were expected to progress in 2013, FMIS, and external oversight may take longer to materialize.
        Short of a strong signal and more engagement from the Government toward increased transparency and accountability, even the few results achieved might backtrack. Governance and corruption remain the major challenges for the country, as Cameroon ranked below the 20th percentile for all key governance indicators throughout the period 2000-2011(see World Governance Indicators series). Lowest levels were recorded for the rule of law and the control of corruption indicators.

        a. Risk to Development Outcome Rating: Significant

8. Assessment of Bank Performance:

a. Quality at entry:
The focus and scope of the project built on close consultations with the Government of Cameroon and other donors active in PFM reforms. While the project was relevant to the needs of the country, the Bank under-estimated the contextual aspects of public administration, and down-played the obstacles that were to be overcome to implement a delicate governance reform agenda. The project experienced significant delays, due mainly to underlying political economy factors in the public administration.

While the political economy risks were broadly acknowledged in the PAD, and raised during concept and quality enhancement review meetings, the project design did not sufficiently take into account the implications of limited Government commitment to reforms and the power of vested interests in project design and implementation. In particular, limited consideration was given to reform sequencing and change management aspects.

Quality-at-Entry Rating: Unsatisfactory

b. Quality of supervision:

The operation needed intense Bank supervision, because of a difficult institutional context, high number of beneficiary institutions and the limited experience of Cameroonian public administration in managing Bank projects. Such close supervision would have been more effectively conducted by a field-based TTL who could have facilitated a strong and regular policy dialogue; he would also have identified the bottlenecks and addressed issues swiftly; and enhanced the absorption of Bank procedures by the project team.

Supervision was appropriate when the Bank's team helped meeting the effectiveness conditions, and in the recruitment of the project procurement specialist. However, the frequency of Bank supervision missions declined over time. In particular, while the project was experiencing delays in implementation and after it was rated Moderately Unsatisfactory twice in a row, no formal supervision missions were held. The Government and the Bank explored options for project restructuring, but disagreement among the two parties on the pace and the direction of the reform agenda led to a decision not to go ahead with a project restructuring. The dialogue on project restructuring was also temporarily affected by the change of TTL in early 2012.

In all, while the Bank team provided some support to project implementation in the beginning, there was a mismatch between the field supervision challenges and the ways and means deployed by the Bank to supervise the project.

Quality of Supervision Rating: Unsatisfactory

Overall Bank Performance Rating: Unsatisfactory

9. Assessment of Borrower Performance:

a. Government Performance:

The PFM reform program supported by the project was led by the Ministry of Finance, with apparently limited support from other government actors. It experienced challenges in ensuring inter-ministerial coordination and was not ready for project implementation.

The effective implementation of the project experienced some delays, as the project became effective one year later in June 2009. The Government support for the PFM reform implementation was only clearly manifested in December 2010. The numerous beneficiary institutions charged with monitoring the day-to-day project implementation represented a coordination challenge, and the project team and the Ministry of Finance had no previous experience in applying Bank procurement and fiduciary procedures.

Given the context of the reform, the Government was not in a position to take decisive measures to accelerate reforms that were lagging behind. As a result, no early adjustments to the plan and calendar were sought, and the opportunity to improve project implementation prospects was therefore missed. Finally, coordination and dialogue between the Government and the donor community on the PFM reform agenda was not smooth.

In conclusion, the Government attitude towards the reforms agenda supported by the project was ambiguous. While it cooperated in the appraisal and approval of the project reform agenda, it showed little engagement in facilitating its implementation and its coordination.

Government Performance Rating: Unsatisfactory

b. Implementing Agency Performance:

At appraisal, a Public Financial Management Steering Committee (PFMSC) was identified to oversee strategic coordination of implementation and monitoring of progress of the project and was to be chaired by the Minister of Finance representative. The focal point for the daily management of project activities was to rest upon the Public Financial Management Technical Secretariat (PFMTS), set up in the Ministry of Finance to coordinate and monitor the preparation and implementation of all the PFM platform activities.

The ICR indicated that the PFMTS had new offices in 2010, and by mid-2011, three years after approval, the PFM reform department was effectively staffed. The ICR did not provide additional detail on the effectiveness of the PFMTS and the PFMSC in leading the project execution, but judging from the results, performance of the implementing agencies was limited.

Implementing Agency Performance Rating: Unsatisfactory

Overall Borrower Performance Rating: Unsatisfactory

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

a. M&E Design:

      The ICR provided a matrix framework describing the configuration of the results chain linking the PDO, the sub-objectives and the outcomes, with specific indicators for each outcome. It delineated the arrangements for results monitoring, with key expected outputs and respective indicators, baseline and target values, and the mechanisms for data collection and reporting.

      Project M&E was built on the premise that the European Commission were to fund PEFA exercises every two years over the lifetime of the project (2009, 2011 and 2013). Joint donor supervision and M&E missions were planned to be regularly undertaken to streamline the supervision process. The project was to finance a short-term consultancy to develop the M&E system and plan. An M&E Committee was to be established to include representatives of the Public Finance Management Steering Committee, donors, and other participants selected from PFM users. This committee was to review and validate progress reports on performance indicators and recommend corrective measures if needed.

      A mid-term review was planned to assess progress and make recommendations for any changes in PDO, content of components, allocation of project resources, and performance indicators, should it be necessary.

b. M&E Implementation:

No comprehensive M&E tool was put in place. The high number of beneficiary institutions and limited capacity for monitoring in a complex environment ultimately had an impact upon the swift implementation of the project. Most of the M&E arrangements specified in 10.a above were not acted upon during project implementation. The planned mid-term review didn't take place, however, a 2012 mid-term review of the broader PFM Reform Action Plan took place with the support of the Bank, but with resources other than those of the project.

a. M&E Utilization:

Given the context of the reform, the Government was not in a position to take decisive measures to
accelerate reforms that were lagging behind. As a result, no early adjustments to the plan and calendar were sought, and the opportunity to improve project implementation prospects was therefore missed.

M&E Quality Rating: Modest

11. Other Issues:

a. Safeguards:

This was a category C project.

b. Fiduciary Compliance:

The ICR reported that procurement delays occurred at every step of the process from the definition of terms of reference, to the issuance of Requests for Expressions of Interest, to the assessment of Expressions of Interest and proposals, to the signing of contracts. For the major contracts, there was an average delay of 19 months between the originally planned date of submission of proposals in the Procurement plan and the actual date of contract signature. The ICR did not report on the project compliance with other Bank fiduciary practices.

c. Unintended Impacts (positive or negative):

There were no unintended impacts identified in the ICR

d. Other:

Not applicable

12. Ratings:

IEG Review
Reason for Disagreement/Comments
Risk to Development Outcome:
Negligible to Low
There is little likelihood that limited achieved outcome will be maintained, due to limited commitment to reforms by the Borrower. 
Bank Performance:
Borrower Performance:
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 following lessons distilled from the ICR could guide and inspire the design and implementation of similar projects:
(i) As governance and accountability reforms are in essence challenging to design and implement, prior political economy studies need to be undertaken in order to shed light on the reform feasibility and the required support to this kind of reforms. Identification of vested interests and incentives for the Government to reform deserve more attention in this preparatory work.

(ii) The political commitment and ownership of the borrower matter: Absence of support and champions in the Government and lack of readiness of teams operating in the PIU are two important factors explaining the lack of traction of the governance and accountability reforms agenda.

(iii) When reforms have to be conducted in many line ministries with the support of many donors, coordination from a higher institutional level (Prime Ministry's office) is necessary to ensure coherence and consistency of the reform agenda.

(iv) A field based TTL is a critical factor for complex projects dealing with governance and accountability reforms. TTL's daily interaction with country stakeholders allows to adjust implementation with the field constrains.

14. Assessment Recommended?


15. Comments on Quality of ICR:

The ICR was comprehensive and provided a story-line of the project design and implementation. Overall assessment of project performance was sound., with the exception of assessment made about the risk to development outcome. Appropriate lessons were distilled from this project's implementation experience. The presentation of project costs and disbursement could have been clearer.

a. Quality of ICR Rating: Satisfactory

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