CD implementation Step 6

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Accountability and Supervision

Objectives

  • Develop an accountability plan that includes all aspects involved in preventing, identifying, and mitigating the impact of fraud, theft, or diversion of ITNs. This does not need to be a separate document as the accountability plan can be incorporated into the implementation guidelines.
  • Develop a supervision plan.

Outputs

  • Fraud prevention, identification and mitigation plan
  • Supervision plan

Activities

  • Convene a coordination committee meeting.
  • Combine the findings of the risk assessment conducted in Step 4 and the finalized logistics and supply management plan, to develop an accountability plan that reflects all aspects of planning, management, and implementation to support the prevention, identification, and impact mitigation of fraud, theft, and diversion.
  • Develop a supervision plan as a tool for sub-national managers.
  • Conduct monitoring visits in line with monitoring plan.
  • Receive monitoring reports.
  • Review monitoring reports for findings and recommendations.
  • Discuss monitoring findings and recommendations at regular review meetings and coordination committee meetings.
  • Adapt distribution approach, as appropriate.
Guidance

VectorWorks developed a document with considerable detail on current practices and recommendations for a range of aspects around accountability. We built these recommendations into all the steps of the CD implementation guide, as appropriate. You can download the document here. Following is a summary of the main points to remember during planning:

  • Accountability in high-value commodity distributions is important because of the numerous opportunities for fraud, theft, and diversion.
  • Building options to prevent, identify, and mitigate the impact of fraud, theft, and diversion into the CD planning and implementation is important.
  • Supervision has an important role to play in accountability and the two are closely linked.
  • This table gives an overview of the risks throughout the ITN supply chain.
  • This table gives an overview of recommendations to be included in an accountability plan.
  • Include a wide range of stakeholders at the planning stages—including community representatives and, where appropriate, law enforcement representatives—to ensure their perspectives are considered when developing the logistics plan (see below).
  • Seek out ministerial, regional, and district political and administrative support for accountability and transparency. Expectations of accountability and transparency should be clear, including the repercussions for failing to meet these expectations.
  • The logistics and storage plan developed in the previous step will include accountability aspects, and it should be shared widely and referenced in detail during training sessions.
  • An accountability and supervision plan will be a useful supplementary tool to ensure all efforts to achieve good accountability are described in one place. This plan should include a description of:
    • Efforts to prevent fraud, theft, and diversion, which will include—
      • Personnel
        • Clear presentation of which personnel have important roles to play in the efforts to improve accountability and include clear descriptions of these roles.
        • Provide clear information on how to select personnel for distribution.
        • Provide clear guidance on measures to take against poorly performing personnel.
      • How a strong logistics and storage plan is important for accountability and what steps will or has been taken to achieve this:
        • Risk assessment of the supply chain
        • Warehouse assessments
        • Focus on accountability in training and supervision
        • Ensure supplies for tracking and data reporting are available in a reasonable time
        • Robust and timely contracting of third party logistics suppliers
        • Formal agreements of responsibility for public sector personnel
        • Documentation requirements.
    • Efforts to detect fraud, theft, and diversion, which will include—
      • Making tools or checklists available to guide supervision visits.
      • Engaging political, law enforcement and community leaders, and influence groups should, at all levels, increase the likelihood that instances of theft or diversion are reported.
      • Making all store points and distribution points aware of the quantity of ITNs they should expect to receive, in advance of delivery.
      • Visually spot check all stocks.
      • Reviewing the document trail to identify any loss.
    • Efforts to mitigate the impact of fraud, theft, and diversion, which will include—
    • Ensuring contracts with third party logistics suppliers:
      • Are legally binding
      • Commit third party logistics suppliers to an appropriate level of insurance access.
      • Clearly state that payment will be withheld if the exact required number of commodities cannot be accounted for, at any time.
      • Review documents with third party logistics suppliers on signing.
      • Cover both transport and storage providers.
    • Partnerships, perhaps even formal task forces at key levels, including with:
      • Security agencies, such as the army and the police, where appropriate, to support a rapid investigation of instances of fraud or theft to increase the likelihood that any stolen goods will be retrieved.
      • With the community—including civil society—to promote early reporting of thefts and facilitate identification of culprits and return of any stolen ITNs.
    • Experiences are reviewed at least annually, or as appropriate, in line with the planning and implementation cycle; use them to refine the logistics plan and other policies, systems, and practices involved in the ITN supply chain.
    • Supervision includes monitoring the skills and practices of the various people involved in running the delivery channel. Supervision visits should include a review of adherence to procedures, communications activities, and quality of training. Supervision reports should be collated and findings used to inform planning of subsequent rounds.
    • Include a detailed supervision plan which should—
      • Describe roles and responsibilities.
      • Describe timelines for supervision.
      • Include job aides for supervisors appropriate to the different channels used.
      • Describe the expected outputs of supervision and the mechanism to ensure that findings are acted on.

Channel specific guidance

Health facility-based distribution
  • CD through health facilities primarily rely on the existing systems. Therefore, they also provide the opportunity to impact the wider health system accountability improvements, if steps are taken to improve performance in accountability for the ITNs. While the distribution will be largely integrated into the existing mechanism, it does not mean that system reviews, improvements, and supervision should be less than for other channels. In fact, many aspects of the supply chain in the health facilities may be performing below the ideal level, and this can be an opportunity to improve.
  • The VectorWorks document, Guide to Health Facility-based Distribution of Insecticide-treated Nets, provides more detail on these issues.
Community-based distribution
  • Accountability issues may be particularly challenging for this channel, which sees a diverse, large and scattered network of communities and personnel involved. Supervision will be important and regular review of accountability performance important to inform the need for adjustments or increases to supervision.
  • Involving the communities in the design, planning and management of the distribution may be a useful way to improve accountability—with community members acting to support the efforts to prevent and detect fraud, theft, or diversion.
  • The VectorWorks document, Guide to Community-based Distribution of Insecticide-treated Nets, provides more detail on these issues.
School-based distribution
  • Needs around accountability for this channel are very similar to those under campaign distribution. Opportunities for fraud are fairly high given the possibilities for ghosting of recipients. Having sub-national education team personnel involved in reviewing micro-quantifications and distribution plans will be important to help estimate the numbers and investigate areas of suspected fraud.
  • Supervision by health facility personnel during distribution can effectively improve accountability, and because the distribution, normally, is only once per year, a high level of supervision is more feasible than for on-going community-based distributions.
  • The VectorWorks document, Guide to School-based Distribution of Insecticide-treated Nets, provides more detail on these issues.

Resources

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