oversight

Foreign Assistance: Circumstances Surrounding a Family Planning Project

Published by the Government Accountability Office on 1990-04-26.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                     I lni t tvi Sta1.w Gent~ral Accounting         Offiw
                                     Report to the Honorable
                                     William I&man, House of’
                                     Iteprttsentat,ives

d     --
!I
      April   1990
11
3
1                                    FOREIGN
,1                                   ASSISTANCE
                                     Circumstances
                                     Surrounding a Family
                                     Planning Project


                                                                                            141288




     -e-w             _-.--~--“--.       .--   .-..   . . --___..   --”   .-   --
     (;AO/NSIAI)-!)O-H!)
                   United States
GAO                General Accounting Office
                   Washington, D.C. 20548

                   National Security and
                   International Affairf3 Division

                   B-238296

                   April 26,199O
                   The Honorable William Lehman
                   House of Representatives
                   Dear Mr. Lehman:
                   This report respondsto your February 27,1989, request that we exam-
                   ine the fiscal year 1984 Agency for International Development (AID)
                   cooperative agreement’ award to the Family of the Americas Founda-
                   tion, Inc. (FM!). The objectives of our review were to (1) determine if AID
                   followed applicable policies and procedures in awarding the agreement
                   to FM; (2) report on the end-of-project evaluation, including the selection
                   of the evaluation team members and FAF’S cooperation with the evalua-
                   tion; and (3) describe FAF’S efforts to obtain additional AID funding since
                   fiscal year 1986.
                   As pointed out in your letter, the HouseCommittee on Appropriations,
                   Subcommittee on Foreign Operations, withheld approval of funds for
                   F4F’S initial award and a 1986 extension until it had received certain
                   assurancesfrom AID about the agreement.AID provided the Subcommit-
                   tee with such assurances.You recently expressedconcern,however,
                   that the award to FAF may not have been made in accordancewith AID
                   procurement policies.
                   FM  is a non-profit organization that AID used to produce and distribute a
                   film on the Billings Ovulation Method-a natural family planning
                   method-and other educational materials, and also to develop and con-
                   duct a U.S.-basedtraining course for Latin Americans who wished to
                   becomeovulation method teacher trainers.


                       decided to fund, on a noncompetitive basis, a FAF project despite rec-
Results in Brief   AID
                   ommendations to the contrary by AID reviewers. Federal statutes and
                   regulations do not prescribe procedures for negotiating and awarding
                   cooperative agreements,but the funding decision did not conflict with
                   AID guidelines for processingsuch agreements.AID guidelines allow for
                   the award of noncompetitive agreementsunder certain conditions. AID
                   met those conditions in making the award to FAF.

                   ‘A cooperative agreement is an assistance instrument used by AID to support or stimulate the recipi-
                   ent’s own program or project. Unlike a grant or contract, however, a cooperative agreement entails
                   substantial involvement by AID.



                   Page 1                                                         GAO/NSIAD-90-S@ Family Plaming
             An end-of-project assessmentby an external evaluation team was done
             as required. However, it was delayed several times and was not initiated
             until mid-1989-about 1 year after the project was completed. AID ini-
             tially postponed the external evaluation becausethe agreement had
             been extended so that FM could complete certain aspectsof the project
             and conduct additional training. The evaluation processwas further
             delayed by (1) negotiations with FAF in selecting the evaluation team
             members and (2) FAF’s delay in providing certain information necessary
             for the evaluation.
             While the evaluation team found that FAF generally conducted the train-
             ing and produced and distributed the required materials, the team
             reported several deficiencies. For example, it questioned the cultural
             appropriateness and practicality of FAF’S materials and how the materi-
             als were distributed. In addition, the team concluded that FAF had been
             uncooperative with AID in all substantive aspectsof the project. The
             team recommendedthat, in the future, AID fund only those organizations
             that demonstrate the ability and willingness to cooperatewith AID and
             subscribeto AID’S population policy. FAF has strongly objected to the
             results of the evaluation team’s report, asserting that the evaluation
             was unfair and biased. The evaluation team is currently reviewing FAF’S
             comments.

             Since December1986, FAF has proposed ten projects relating to the Bill-
             ings Ovulation Method, totaling about $7.3 million. However, FAF has not
             received any additional AID funding. Sevenof these proposals were not
             officially evaluated becauseFAF did not submit them to Georgetown Uni-
             versity, as required.2Of the three other FAFproject proposals submitted
             to Georgetown,two were rejected and one was not consideredbecause
             the respective AID mission expressedno interest in the project. In
             responseto an AID survey of five countries where FAF wanted to do
             work, Georgetown suggestedthat FIW submit a proposal tailored to the
             needsof India. However, FAF had not done so by the time we completed
             our review.

             In fiscal year 1984, AID obligated or allocated about $6.8 million for nat-
Background   ural family planning related activities, including AID bilateral family

             ‘Under a September 1986 cooperative agreement with AID, Georgetown University has been acting
             as an umbrella organization for identifying, supporting, and monitoring all AID natural family plan-
             ning activities. Georgetown’s role is to help improve the knowledge, availability, acceptability, and
             effectiveness of natural family planning in less developed countries. In accordance with this agree
             ment, all natural family planning proposals are required to be reviewed by Georgetown.



             Page 2                                                           GAO/NSLWMO-SS Family Planning



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                     5233295




                     planning programs. Organizations conducting only natural family plan-
                     ning projects were awarded $3.2 million- FAF received about one-third
                     of these funds.
                     AID’S use of sole-sourcecooperative agreementsfor managing its popula-
                     tion assistanceactivities was not unusual. In fiscal year 1984, AID’S
                     Office of Population provided funds to 17 population assistance
                     projects. Eight were sole-sourcecooperative agreement awards basedon
                     unsolicited proposals from nine universities and private organizations,
                     One award was a sole-sourcecontract made under the Small Business
                     Act, and the remaining eight awards were competitive contract awards.

                     FM’S  cooperative agreement award was for an estimated cost of $1.1
                     million. The agreementwas amendedfour times which extended it to
                     May 1,1988, and resulted in FAF receiving a total of about $2 million.
                     Overall, the agreement directed FAF to
                     produce and distribute a film on the Billings Ovulation Method for fam-
                     ily planning service providers worldwide;
                     produce and distribute educational materials to be used in teaching and
                     practicing the ovulation method worldwide; and
                     develop and conduct a U.S.-basedtraining course for Latin Americans,
                     Africans, Asians, and people of the Near East who wish to becomeovu-
                     lation method teacher trainers,


                     Between 1981 and 1983, FAF (or its parent organization, World Organiza-
Award Made to FAF    tion Ovulation Method-Billings) submitted sevenunsolicited proposals to
Despite Reviewers’   AID for funding Billings Ovulation Method projects. AID reviewers
Recommendations      rejected all sevenproposals on technical or programmatic grounds. Gen-
                     erally, representatives from AID’S Bureau for Scienceand Technology/
                     Office of Population and its Population Sector Council reviewed and
                     evaluated unsolicited proposals from organizations requesting a cooper-
                     ative relationship with AID.3 AID officials either met with or sent letters
                     to FAF explaining why the proposals did not meet the agency’sneedsand
                     in somecases,made recommendationson how FAF could modify the pro-
                     posals to make them more acceptable.FAF submitted modified versions
                     3According to an AID official, unsolicited proposals were generally reviewed by (1) an assigned Cog-
                     nizant Technical Officer in a relevant division of the Population Office, (2) a Research Review Com-
                     mittee with representatives from each of the Office’s divisions, and (3) the Population Sector Council
                     (consisting of staff persons from each of AID’s regionsl bureaus, the Director of the office, and the
                     director of the now defunct Directorate of Health and Population). One FAP proposal was not
                     reviewed by the Population Sector Council; instead, it was reviewed by consultants from the National
                     Institutes of Health and the World Health Organization.



                     Page 3                                                          GAO/NSIAD-SO-89 Family Phning
                                                                                              tr


                      B-238296




                      of someproposals, which were again reviewed by AID but judged unsat-
                      isfactory on technical or programmatic grounds.
                      Despite the reviewers’ recommendationsnot to fund FAF's proposals
                      regarding the production of a film on the Billings Ovulation Method and
                      ovulation charts, in a letter dated July 1,1983, the Director of AID'S
                      Office of Population informed FAFthat AIDneededsuch a film. While AID
                      had not decided whether it neededthe Billings Ovulation charts, AID had
                      concluded that somewritten material on the charting procedures would
                      be desirable. AID further indicated that it envisioned substantial change
                      in the proposal regarding the charts and offered to work with FAF. After
                      AID'S decision to fund FAF, AID staff combined three of FXF'Soriginal pro-
                      posals and wrote a scopeof work that was acceptableto both FAF and
                      AID.


                      OnceAID and FAF agreedon the scope of work, AID followed its proce-
Award Met AID Sole-   dures for awarding a sole-sourcecooperative agreement.According to
Source Criteria       AID'S Handbook 13, competition is not required when, among other rea-
                      sons,the potential awardee is consideredto have exclusive or predomi-
                      nant capability for the required service. A sole-sourceaward can also be
                      made when the Assistant to the AID Administrator or Office Director
                      determines that certain circumstancesare critical to the objectives of
                      the foreign assistanceprogram, AID’Swritten justification cited FAF'S
                      special capabilities and experience in the Billings Ovulation Method. It
                      also cited reviews made by two Assistant Administrators and the AID
                      Administrator that determined the proposal was critical to foreign assis-
                      tance program objectives. This met AID'S criteria for awarding a sole-
                      source cooperative agreement.

                      The cooperative agreementrequired that AID evaluate the project. This
AID’s Evaluation of   was supposedto begin during the final month of its implementation,
the FAF Award Was     However, AID'S evaluation was delayed for various reasonsand did not
Delayed               begin until about 1 year after the FAFproject expired in May 1988.
                      The purpose of AID'S evaluation was to document FAF'Sperformance in
                      delivering the products and achieving the objectives stated in the agree-
                      ment, as well as determining lessonslearned. Basically, the products
                      included a motion picture; 10,000 leaflets about the film; 80,000 kits
                      with a plastic chart and stamps (in English, French, Spanish, Portu-
                      guese,and Arabic) for plotting fertile and non-fertile periods; and the
                      design and implementation of nine training courses.


                      Page4
                          B-228296




                          Basedon the original agreement,the external evaluation team’s assess-
                          ment of FiW'S project and performance should have begun in May 1986,
                          but it did not begin until May 1989. AID documentsindicate that the
                          agreement’sextensions and amendmentsprovided for FAF'S completion
                          of the film and educational materials, further refinement of the training
                          curriculum, and the conduct of additional training. In July 1986, when
                          most of these project componentswere consideredeither completed or
                          well underway, AID scheduledthe evaluation for November 1986. How-
                          ever, the evaluation processwas further delayed becauseof problems in
                          selecting the evaluation team members and FAF'S delay in providing nec-
                          essary information to AID.
                          In commenting on a draft of this report AID stated that another reason
                          for the delay was that FAF had notified AID of a cost overrun. We were
                          unable to confirm this additional reason.


Delays in Selecting the   AID documents show that FAF started recommending individuals for the

Evaluation Team           evaluation as early as 1986, but AID decided that these individuals did
                          not meet the agency’sskill and experience criteriae4While the subject of
                          team composition was part of continuing overall discussionsbetween
                          FAF and AID, formal negotiations between AID and FAF for selecting team
                          members did not begin until September 1988.

                          At that time, AID informed FM of two individuals who would potentially
                          comprise the team. FAF objected to these persons becausethey had been
                          employed by organizations which FAF consideredbiased against it. Dur-
                          ing negotiations for selecting team members,FAF told AID that it would
                          not accept an AID-proposedevaluator unless AID accepteda FM-proposed
                          evaluator.
                          Although AID had planned to have a two-member evaluation team, AID
                          and FAF agreed in December1988 on a three-member team. One of these
                          individuals was recommendedby FAF. AID officials acceptedthe FAF
                          request to name one of the evaluators, which according to AID was
                          highly unusual, but did so to help assureFAF'S cooperation and to pro-
                          ceedwith the evaluation. The three individuals had backgrounds in nat-
                          ural family planning and met AID'S experience and expertise criteria.

                          41nitially, AID had determined that two consultants would be needed--one with a strong background
                          in family planning information and communication and the other with knowledge and experience
                          specific to natural family planning, with an emphasis on training. AID also desired that one of the
                          consultants be fluent in Spanish or French.



                          Page 5                                                         GAO/NS~99~9        Family plannine
                           B&39295




Delays in Obtaining Data   As part of the evaluation, a questionnaire was to be sent to all FAFtrain-
                           eeson the extent and effectiveness of their follow-on activities and use
                           of the materials produced by FAF. Becausethis evaluation component did
                           not require an evaluation team, AID had planned to implement this com-
                           ponent by August 1988.

                           In early August 1988, AID requestedthat FAF provide the trainees’ names
                           and current addressesby August 19, 1988. AID made two additional
                           requests in January 1989. FAF did not respond until the end of February
                           1989. However, it did not provide the names and addressesof its train-
                           ees;instead, it sent AID the names and addressesof organizations and
                           teachers who participated in the teacher training program (coordina-
                           tors) who FAP thought would be able to send the questionnaires to indi-
                           vidual trainees5 Although the questionnaires were sent to the
                           individuals identified on &W’S list, AID reported a one-third response
                           rate, which the evaluation team consideredlow. According to AID, the
                           responseswere used, in part, to answer someof the evaluation
                           questions.

                                 evaluation team completed its report in December1989. It was pro-
Results of the             AID’S
                           vided to FAF for comment and AID is currently considering FAF'Scom-
Evaluation                 ments in finalizing the report. The evaluation team,8while noting certain
                           strengths in FAF’S implementation of the agreement,reported several
                           “deficiencies and possible violations” in carrying out the letter and the
                           spirit of the agreement.These were in the areas of materials develop-
                           ment, training, distribution of materials, and the cooperating agency
                           relationship.
                           Regarding the Billings Ovulation Method film, the evaluation team con-
                           cluded that FAF failed to comply with several aspectsof the cooperative
                           agreement.Specifically, the team noted that (1) the film was not
                           directed toward the intended audience-family planning service provid-
                           ers, (2) FAP had not delivered either the pre-printed materials or the
                           original footage as required by the agreement,and (3) there is a dispute

                           ‘In commenting on our draft report, FAP asserted that it did not respond to the August 1988 request
                           because the team members had not been selected. It also considered AID’s request unnecessary
                           because FAP had provided AID similar information on every participant prior to his or her training.

                           OAID’s end-of-project, external evaluations for population assistance activities are conducted by
                           teams of consultants hired by Dual and Associates/Population Technical Assistance Project Division
                           (POPTIXH). This organization (under contract with AID) provides consultants from a broad spec-
                           trum of dlsclplines involving areas such as evaluation, population policy, education, communication,
                           and maternal and child health care.



                           Page 0                                                          GAO/NSIADOO-S9 Family Planning
                       5298295




                       between FAF and AID as to whether the master print of the film was
                       delivered.
                       The other materials produced, according to the evaluation team, were
                       generally but not uniformly, technically accurate, visually attractive,
                       and durable. However, somefundamental questions were raised about
                       the cultural appropriateness and practicality of the materials. Because
                       of the various concernsin the field use of FAF’Smaterials, the evaluation
                       team concluded that the FM? project “...in a sensecan be seenas an
                       expensive, large-scale,but unsystematic field test for materials FAF
                       wanted to produce.”
                       The evaluation team found that FM’S training workshops appeared to
                       have been well organized-the faculty was appropriate and the course
                       documentation remains useful. However, the team noted several con-
                       cerns about how FAF conducted the training. These concernsincluded (1)
                       FAF’Srigidity and lack of cooperation in respecting AID’Spriorities and
                       guidance in the selection of countries and participants and (2) the
                       amount of AIDstaff time required to monitor and assist in FAFactivities
                       was more than anticipated.

                       The evaluation team also concludedthat teacher and user materials pro-
                       duced were not evenly distributed. According to the evaluation report,
                       FAFsent more material to natural family planning programs of which it
                       approved than to those it did not approve. Other organizations that had
                       cooperative agreementswith AID missions or AID/Washingtonhad the
                       greatest trouble obtaining materials.


                       FAF’S efforts to obtain AID funding for additional projects have been
FAF Has Not Received   unsuccessful.Since December1086, FAF submitted sevenunsolicited pro-
Any Additional         posals7directly to AIDand three to Georgetown University, totaling
Funding                about $7.3 million, related to the Billings Ovulation Method.
                       AIDdid not review the proposals submitted to it becauseall natural fam-
                       ily planning proposals must be reviewed and funded through the cooper-
                       ative agreementwith Georgetown.In a May 1086 letter to the Secretary
                       of State, FAF stated that it did not wish to submit its funding applica-
                       tions directly to Georgetown because(1) Georgetown’scooperative
                       agreementwith AID contained unacceptable conditions and (2)

                       7FAF submitted an eighth proposal to AID; subsequently FAF resubmitted it to Georgetown. The
                       other seven propaals were not resubnWecl.



                       Page 7                                                       GAO/-9             Family pknnine
                                                                                               .
                                                                                                    “r



B-238296




Georgetown had rejected an application submitted by one of FAF’S lead-
ing subsidiaries. BecauseFAF believed that other funding was available,
it requested that the Secretary intercede with the AID Administrator to
make an exception to AID’Snormal review procedures. In response,AID
informed FAF that it would have to submit its proposals to Georgetown
and abide by AID’S “referral and informed choice” family planning
policy.8
FAF did not resubmit these proposals. Instead, in April 1087, FAF submit-
ted a new proposal (valued at $3.1 million) to AID for conducting a train-
ing project. AID told FAF that the proposal must be submitted to
Georgetown; FAF resubmitted the proposal as instructed. Citing various
technical reasons,Georgetown, in consultation with AID, rejected this
proposal and a secondproposal (valued at $1.6 million) that was submit-
ted in May 1988 for developing and distributing educational materials.
Georgetown, however, made suggestionson two occasionsregarding
areas in which AID and FAF might be able to reach agreement.In its
responseto the secondproposal, Georgetown recommendeda project
smaller in scopeinvolving further testing of the educational materials,
at a cost not to exceed$100,000. In an October 1088 letter to the AID
Administrator, FAF protested Georgetown’srecommendation, but no
funds were awarded to FAF.
In March 1089, FAF submitted a proposal for about $200,000 to develop
and distribute its materials in Swahili, a language used in Kenya. How-
ever, FAF’S executive director and Georgetown and AID officials met and
agreed that AID would contact the missions in five countries initially pro-
posed by FAF (including Kenya) to determine whether these countries
were interested in receiving information on the Billings Ovulation
Method. For various reasons,the only AIDmission that reported any
interest, or thought the proposal feasible, was India. Thus, the Swahili
proposal was not consideredbecauseAID’S Kenya mission expressedno
interest.


sBssed on sec. 109 of the Foreign Assistance Act of 1967 and sec. 302 of the International Security
and Development Cooperation Act of 1980, AID policy for natural family planning activities is one of
voluntary participation and informed choice. ‘I... [FJamily planning projects sre required to offer,
either directly or through referral to, or information about accessto, a broad range of family plsnning
methods and services.” Because some organizations, such ss FM, did not want to provide or refer to
other methods, AID would waive the referral requirement on a caseby-case basis. However, the 1986
continuing resolution appropriating funds to AID for population and development assistance (Public
Law 99-190, Dec. 19,1986) and appropriations acts each year since have contained a provision essen-
tially blocking AID from making such waivers.



Page 8                                                          GAO/NSIAD-99-99 Family Planning
                 According to AID and Georgetown officials, FM?was advised in March
                 and June 1989, basedon the survey results, to tailor a proposal for
                 India. FAF, however, noted in its February 1000 responseto AID’S evalua-
                 tion report that negotiations have been suspended.FAFwould not agree
                 to sign a subagreementwith Georgetown becauseof a provision that
                 would require FAFto (1) provide information on a broad range of family
                 planning methods and servicesavailable in the country in which the
                 activity is conducted or (2) indicate where such information may be
                 obtained. FAF, in commenting on our report, stated that it “prefers not to
                 receive funding if [it] has to agreeto such unfair conditions...”


Agency and FAF   We obtained comments on a draft of this report from AID and FAF. AID
                 provided certain technical changesand updated information. FAFpro-
Cements          vided information that it used in responding to AID’S evaluation report
                 and updated the status of its negotiations with Georgetown University.
                 We have incorporated this information where appropriate.
                 Overall, FAF strongly disputed the results and conclusionsof the evalua-
                 tion team’s report. FAF further stated that certain membersof the evalu-
                 ation team were biased against FAF, and did not fairly assessits
                 accomplishmentsunder the cooperative agreement.We did not evaluate
                 the team’s methodology or report to assesstheir objectivity. However,
                 the evaluation team and POPTECHare currently considering FAF’S
                 responsein finalizing the report on FAF'Sproject,


Scopeand         We reviewed relevant legislation, the Federal Acquisition Regulation,
                 and AID guidelines (contained in its Handbook 13) for making coopera-
Methodology      tive agreementsand sole-sourceawards. We interviewed officials and
                 reviewed records at AID’SBureau for Scienceand Technology/Office of
                 Population, Dual and Associates/PomXcHDivision, and Georgetown Uni-
                 versity Institute for International Studies in Natural Family Planning.
                 We conducted our review between March 1080 and January 1000 in
                 accordancewith generally acceptedgovernment auditing standards.
                 Unless you publicly announceits contents earlier, no further distribu-
                 tion of this report will be made until 7 days from its issue date. At that
                 time, we will provide copiesto the Chairmen, Senateand HouseCommit-
                 tees on Appropriations, House Committee on Foreign Affairs, and Sen-
                 ate Committee on Foreign Relations; and the Administrator of AID. We
                 will make copies available to others upon request.


                 Page9                                         GAO/NSLADgosg
                                                                           FamtlyPlaming
B-288296




If you should need additional information or if we can be of further
assistance,pleasecall me on (202) 27645790.Major contributors to this
report are listed in appendix I.
Sincerely yours,




Harold J, Johnson
Director, Foreign Economic
  Assistance Issues




Page10                                      GAO/NSIADBO439
                                                        Family Planning
    l


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        Page11   GAO/NSW99-99   Family Plannhj
Appendix I

Major Contributors to This Report


National Security and   MaeWandaMichael-Jackson,Evaluator-in-Charge
International Affairs   Carolyn Minick, Evaluator
Division, Washington,
D.C.




(4721tl7)               Page12                                 GAO/NSIAD-90-99
                                                                            Family Plaming
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                 ‘I’t~ltq~lww   202-275-63241

                 ‘l’lw first, five copies of each rtqmrt. are free. Additional   twpit~s art’
                 s2.00 twch.
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