Transparency and accountability policy

If GAVI is to deliver on its mission, it must take some risk, and do everything possible to mitigate that risk. Donors realise this, but also rightly expect risks to be mitigated and action to be taken when misuse is uncovered.

On January 1, 2009, GAVI enacted a new Transparency & Accountability policy (TAP) that governs the management of all cash-based support to GAVI eligible countries.

How the Transparency and Accountability Policy (TAP) works:

Principles

The policy is founded upon a core set of principles:

1. rely and build on existing country capacity to the greatest extent possible, ensuring alignment with country systems;
2. be consistent with the commitments of the Paris Declaration on Aid Effectiveness;
3. promote mutual accountability by encouraging assessments of progress in implementing GAVI support;
4. apply a country-by-country approach to reduce fiduciary risks in a manner which is equitable and transparent;
5. adopt a set of minimum standards for the management of GAVI cash funding: funding should be used for agreed programme objectives; funds must be managed in a transparent manner, and provide accurate and verifiable financial reports on a regular basis, as specified by individual funding arrangements; funds must be managed within accounts that meet national legal requirements for auditing, accounting and procurement.

Guardian of donor funding

The GAVI Alliance takes very seriously its responsibility as a guardian of donor funding and it holds all recipient governments accountable for the support it provides and expects that proper financial management and accountability systems are in place.

GAVI maintains a transparency and accountability process, managed independently by the office of the internal auditor. 

When GAVI suspects misuse of its funds, it halts cash disbursements and in-country funds are frozen. When misuse is confirmed, GAVI's fund agreement with a partner government requires it to repay any missing funds. GAVI actively communicates pending cases to the GAVI Board and to our donors and publicly provides information on its website.

GAVI support

GAVI supports countries largely through funding for vaccines and other related supplies, which are centrally procured and delivered to Ministries of Health in eligible countries. Approximately 85% of GAVI support is provided in this way.

Vaccines represent a low risk of misuse compared to cash payments or other medicines, for which there is a secondary market.

GAVI's cash support to eligible countries is used to help countries increase their capacity to introduce and sustain new vaccine programmes. This support allows countries to address their specific priorities and system bottlenecks. GAVI's cash-based support represents about 15% of its annual disbursements.

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The following three safeguards provide a deterrent to potential funding misuse and have improved the effectiveness of GAVI's response in cases when controls have been identified as weak or the appropriation of GAVI funding has been questioned:

Initial assessment

Prior to providing a grant, GAVI's Transparency and Accountability Unit undertakes a Financial Management Assessment (FMA) on a programme's financial controls to ensure that any weaknesses are addressed. Then, as programmes are carried out, these assessments are repeated periodically to verify whether financial management systems continue to operate effectively.

Early warning system

GAVI's Transparency and Accountability Unit oversees an "early warning system" that makes use of external sources of information, including using the experience of GAVI partners and other organisations such as UN agencies, bi-lateral donors and other aid agencies with presence in GAVI-funded countries.

Independent audit annually

Additionally, to manage the risk of misuse, all countries benefiting from GAVI's cash-based programmes undergo independent external audits on an annual basis.

A Financial Management Assessment (FMA) is required before an eligible country can introduce new Health Systems Strengthening (HSS) or Immunisation Service Support (ISS) programmes.

Conducting an FMA is the single most effective way to gather relevant intelligence in a country: from the implementing government agency, in-country partners and bilateral and multilateral organisations.

An FMA provides a basis upon which to determine whether further probes into possible misuse are necessary. Carrying out FMAs from GAVI's Internal Audit function, rather than from inside the country, helps to safeguard the independence and objectivity of the exercise.

Strengths and weaknesses

The FMA is geared to help GAVI better understand the strengths and weaknesses of each countries' public financial management system in the health sector. More importantly, the FMA helps countries to identify the best financing mechanism(s) for the management of GAVI cash-based support.

GAVI is implementing FMAs on a phased basis, starting with:

1. countries applying for new cash-based programmes;
2. countries deemed "higher risk" for financial management.

GAVI conducts FMAs in all eligible countries within a two to three-year period. As of January 2011, GAVI's Transparency and Accountability unit has carried out over 30 FMAs.