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Memorandum submitted by the International Rescue Committee
Summary
The Department for International Development (DfID) is playing a leading role in promoting pooled funding mechanisms for delivering humanitarian aid in emergencies and early-recovery contexts. However, given the centrality of NGOs to the humanitarian system - delivering up to 80 per cent of humanitarian relief - the impact of pooled funds on NGO activities needs to be carefully assessed before rolling out these approaches more broadly. Drawing particularly on NGO experience of the pilot common funds in Sudan and DR Congo, this submission outlines a number of concerns from an NGO perspective.
Common Funds - 'Doing more with less?'
1. As stated in its 2007 Annual Report, the Department for International Development (DfID) is increasingly championing the use of pooled funding mechanisms in humanitarian and early recovery contexts.[1] These include:
- The Central Emergency Response Fund (CERF), a global fund that has distributed emergency financing to UN agencies operating in 46 countries, to which the UK government is the largest donor; [2]
- Various stand-alone country-specific Emergency Response Funds, managed in-country by the UN Humanitarian Coordinator (e.g. in Angola, Indonesia, Liberia and Somalia);
- Two pilot common funds in Sudan and DR Congo, to which both UN agencies and NGOs have direct access.[3]
2. Pooled funding mechanisms are multilateral arrangements managed or overseen by UN agencies on behalf of donors such as DfID. They are designed to improve humanitarian responses by addressing funding gaps and promoting more strategic, coordinated and accountable allocations. In supporting pooled funds, DfID reduces its bilateral support for NGOs and effectively 'out-sources' decision-making to a UN-managed system, which has responsibility for financing both UN agencies and NGOs. Pooled funding mechanisms are being promoted as part of the Good Humanitarian Donorship initiative and the UN and humanitarian reform agendas, in which DfID is playing a leading role. Given that pooled funding mechanisms are intended to reduce transaction costs - at least at the donor level - they also tie in closely with DfID's commitment 'to do more with less'.
3. This submission particularly addresses NGO experience of the pilot common funds in Sudan and DR Congo. As stated in DfID's Annual Report, independent assessments have concluded that these common funds have improved planning and programming and created stronger incentives for coordination. The report also notes that an independent evaluation has commended the approach, despite some teething difficulties, and recommended that the pilots be maintained and the potential for replication explored.
4. As a large operational NGO working extensively in humanitarian contexts, including both Sudan and DR Congo, the International Rescue Committee understands and sympathises with many of the underlying arguments in favour of pooled funding approaches. However, we believe that some of the challenges that they pose for NGOs have yet to be fully addressed. In our view, these need to be tackled before seeking to expand the use of pooled funds to other countries.
Specifically, we have the following concerns:
a) Programme funding vs. project funding Both UN agencies and NGOs can seek support from the common funds, with the allocation determined by joint in-country sector-specific working groups making decisions under the ultimate authority of the UN Humanitarian Coordinator. However, UN agencies and NGOs tend to be funded differently, with UN agencies usually seeking funding to help cover broadly defined 'programme' budgets while NGOs usually seek funding for specific projects. Project funding generally allows less flexibility than programme funding; in particular, projects usually need guarantees of 100% financing in order to be viable. This relative inflexibility can weaken NGOs' position when negotiating funding allocations and make it less likely that their projects - which may well be critical to meeting urgent humanitarian needs - will be funded. When NGOs do accept less than 100% funding they take on the risk of finding the remainder from other sources or from subsequent tranches; if no more funds are allocated to a running project after the first tranche, they risk doing more harm than good by mobilising communities and then pulling out, scaling down or suspending a project. This contrasts with the generally reliable project funding that bilateral donors such as DfID are able to offer.
DfID should ensure that common funds are able to provide dependable project funding for NGOs and that the allocation process is not biased against this sort of financing.
b) Pre-financing requirements A combination of slow disbursals from donors and delays in processing funding through the UN system has sometimes meant that NGO recipients have been asked to pre-finance projects supported through common funds. In the worst cases, NGOs have been asked to pre-finance projects even before contracts have been signed and with no guarantee that funds will eventually be forthcoming. Unlike UN agencies, pre-financing is not a viable option for most NGOs, leaving a choice of either delaying project implementation for months until the funding is delivered or cancelling planned projects. In the context of a humanitarian aid operation, either option can lead to loss of life or additional distress for communities needing immediate humanitarian aid. Pre-financing requirements particularly limit the participation of smaller and local NGOs.
DfID should ensure that pre-financing is never a requirement for accessing common funds.
c) Needs-based allocations One perceived strength of pooled funding mechanisms is that, in contrast to bilateral donor funding, they allow a more field-driven and better coordinated approach to funding allocations, with the UN country team usually overseeing in-country sectoral working groups that determine how resources should best be spent. However, experience of these mechanisms suggests that the goal of fully strategic, needs-based funding allocations is still sometimes compromised by other factors. There is a perception that some agencies have tended to seek support for programmes at least in part to fit their own internal priorities, for example because they are already active in a particular location or sector or because they feel a need to be seen to be so. If true, these factors would tend to disadvantage smaller agencies, especially local NGOs, who are likely to have weaker advocacy capacity and lower profile. The relative lack of robust needs assessments has been frequently noted, as have the lack of clarity in the criteria for selecting projects, the inconsistency with which these criteria have been implemented and the limited independent oversight of the allocation process. These factors make it harder to analysis the actual basis for allocations or the extent to which they match real humanitarian needs on the ground.
DfID should:
- support greater investment in needs assessments;
- promote clearer guidance on selection criteria and measures to ensure greater transparency about the basis on which allocations and recommendations to UN Humanitarian Coordinators are determined.
d) Monitoring and Evaluation In addition to ensuring that common fund allocations are more rigorously based on needs, greater investment is also required in monitoring and evaluating the projects and programmes that they support in order to assess whether they are meeting their objectives. These are an important component of the 'Learning and Accountability' principles established under the Good Humanitarian Donorship initiative. So far, there has been very little analysis of the impact of the common funds on beneficiaries themselves. Moreover, the monitoring requirements are not generally as robust as those established for projects funded by bilateral donors such as DfID. More comprehensive data showing the volumes allocated to NGOs vis à vis UN agencies, the amount of funding that UN agencies then subcontract to NGOs and the amounts retained as indirect support costs would also be useful in assessing whether common funds lead to a net reduction or a net increase in transaction costs.
DfID should push for robust ongoing monitoring and evaluation of projects and programmes funded by common funds.
e) Relationship building and information dissemination UN agencies rely heavily on NGOs as implementing partners. Building trust and solid working relationships between UN agencies and NGOs is therefore crucial to timely and effective humanitarian response. However, pooled funds can compromise the relationship between NGOs and UN agencies, with the channelling of NGO funds through the UN system effectively placing NGOs in a more subordinate position. In our experience, relationships in the field can vary considerably, depending on the quality of communication, the level of transparency and other factors. Moreover, there is evidence that many actors remain ignorant both of the detail of common fund mechanisms (including implementation timelines, eligibility criteria, etc.) and of the wider policy agenda of which they are part. Greater clarity on how common funds work will be required if they are to have their maximum impact.
DfID should:
- encourage greater efforts to publicise the reforms of the humanitarian system to all actors, including to international and local NGOs;
- promote a continued commitment to consultation, coordination and genuine partnership.
5. Neither humanitarian reform nor DfID's objective of 'doing more with less' are problematic in themselves; indeed both have much to recommend them. However, given the centrality of NGOs to the humanitarian system, the impact of pooled funds on NGO activities needs to be carefully assessed, and the delivery mechanisms streamlined and improved, before rolling out similar approaches more broadly. This should be an explicit requirement of any evaluations of these reforms.
6. Given that the primary object of all these activities is to ensure better, more strategic, effective, and accountable outcomes for people in need, it is also essential to assess the ultimate impact of these approaches on beneficiary populations before replicating the model elsewhere.
Recommendations
DfID should:
- ensure that common funds are able to provide dependable project funding for NGOs and that the allocation process is not biased against this sort of financing;
- ensure that pre-financing is never a requirement for accessing common funds;
- support greater investment in needs assessments;
- promote clearer guidance on selection criteria and measures to ensure greater transparency about the basis on which allocations and recommendations to UN Humanitarian Coordinators are determined;
- push for robust ongoing monitoring and evaluation of projects and programmes funded by common funds;
- encourage greater efforts to publicise the reforms of the humanitarian system to all actors, including to international and local NGOs;
- promote a continued commitment to consultation, coordination and genuine partnership;
- require that evaluations of pooled funding mechanisms specifically assess their impact on NGO-led interventions;
- support evaluations of the ultimate impact of these mechanisms on people in need before replicating the model elsewhere.
Annex A: Gender - How is DfID addressing Violence Against Women and Girls?
1. The International Rescue Committee welcomes this year's Gender Equality at the Heart of Development publication, which is valuable in restating the inter-relationship between poverty and gender-based discrimination, and in setting out DfID's commitments in these areas. The recently published Gender Equality Action Plan 2007-2009 also represents an important step forward in ensuring effective mainstreaming of gender issues across DFID's policies and programmes.
2. However, IRC believes that the Gender Equality Action Plan does not yet go far enough. While we fully endorse the need to ensure that gender equality is mainstreamed throughout DfID's policies and programmes, we believe that the challenges facing women and girls in the developing world will not be adequately addressed without a commitment to much higher levels of targeted funding, more work on developing effective programming strategies and a commitment to using the UK's influence to push gender issues at a global level.
3. In particular, much greater levels of support are required for programmes that address violence against women and girls, especially in contexts that are not usually prioritised for gender-focused programming, such as humanitarian crises and countries affected by, or recovering from, conflict. These situations often suffer much higher levels of gender-based violence, with higher levels of impunity for perpetrators and potentially catastrophic effects on socio-economic recovery and development.
4. Violence against women and girls is a critical factor in ensuring continuing under-development, poor health and insecurity for millions of the world's people, especially in the most vulnerable areas.
a. Violence against women and girls profoundly impedes post-crisis recovery. Women's health and socioeconomic wellbeing is critical for sustainable development. Gender-based violence entails costs to the country's healthcare and legal systems, loss in production, emotional stress and other social costs which constrain economic and social development. It perpetuates poverty by reducing women's capacity to work outside the home, their mobility and access to information, and children's attendance at school. Countries that do not capitalise on the full potential of women, one half of their societies, risk misallocating their human resources and undermining their full potential.
b. In a crisis or post-crisis situation, violence against women often becomes self-perpetuating. The economic status of poor women may necessitate that they engage in survival activities such as trading sex for food, money or other items. In turn, without access to land ownership, natural resource management and the job market these women then remain destitute and vulnerable. In a country recovering from conflict or other crisis it is especially important to intervene early to help break this cycle.
c. Countries affected by conflict are often at particular risk of continuing endemic violence against women and girls. As DfID's Annual Report 2007 notes, after many conflicts men who have been demobilised continue to perceive their identity and status as based on aggression, resulting in high levels of gender violence, crime and insecurity that can threaten a fragile peace.[4] While congratulating DfID on the support it provides to demobilised youth in countries such as Sierra Leone, the IRC's experience in conflict-affected and post-conflict contexts suggests that much more can still be done to target this problem directly.
d. Violence against women negatively affects maternal and child mortality and morbidity. It has also been shown that abusive partners or cultural stigma can prevent victims of violence from accessing healthcare, including prenatal care and HIV/AIDS treatment. In contexts where violence against women is particularly prevalent, the implications in terms of overall health outcomes are potentially enormous.
e. Violence against women negatively affects children's health and development. Children suffer the consequences of violence against women either during the mother's pregnancy or during their own childhood due to neglect and/or the effects of abuse.
f. Violence against women is both a cause and consequence of the growing rate of HIV infection. Failure to address violence against women can therefore significantly impede efforts to stem the spread of HIV.
g. Violence against women and girls is a grotesque violation of human rights in itself.
5. The IRC welcomes DfID's commitment to addressing gender equality and, as part of this, to tackling violence against women and girls. We also welcome the support that DfID already provides to programmes working to combat gender-based violence, both directly and indirectly. However, we believe that much more can be done. The critical impact of violence against women on developmental, health and human rights outcomes needs to be much more broadly recognised. In order to do justice to the analysis contained in Gender Equality at the Heart of Development and in its 2007 Annual Report, DfID should ensure that all aid programmes in humanitarian, recovery and other fragile contexts are based on a comprehensive assessment of the extent and impact of violence against women, and that targeted programmes are designed and funded to mitigate it.
6. We also call on DfID to continue speaking out about violence against women and to take the lead internationally on developing programmes and policies to end it.
Sarah Hughes Director International Rescue Committee UK
4 July 2007 [1] 2007 Annual Report, the Department for International Development, para 7.28-9 [2] UN CERF Secretariat homepage: http://ochaonline2.un.org/Default.aspx?alias=ochaonline2.un.org/cerf [3] In addition, examples of non-humanitarian pooled funds include Multi-Donor Trust Funds, which tend to be administered by the World Bank and UN and are designed to fund reconstruction in post-crisis situations, and thematic pooled funds (such as multi-donor funds for HIV/AIDS, orphans, avian flu). [4] 2007 Annual Report, the Department for International Development, box 7.3 |