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 II’ , 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 . 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 --~ ---- .II.__-- ‘I’t~ltq~lww 202-275-63241 ‘l’lw first, five copies of each rtqmrt. are free. Additional twpit~s art’ s2.00 twch. . *’ .
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)