To: American Embassy Abidjan Priority; American Embassy Accra Priority; American Embassy Asmara Priority; American Embassy Antananarivo Priority; American Embassy Bamako Priority; American Embassy Dakar Priority; American Embassy Conakry Priority; American Embassy Cotonou Priority; American Embassy Dhaka Priority; American Embassy Guatemala Priority; American Embassy Jakarta Priority; American Embassy Kampala Priority; American Embassy Kigali Priority; American Embassy La Paz Priority; American Embassy Lilongwe Priority; American Embassy Lima Priority; American Embassy Luanda Priority; American Embassy Managua Priority; American Embassy Maputo Priority; American Embassy Lusaka Priority; American Embassy Nairobi Priority; American Embassy New Delhi Priority; American Embassy Niamey Priority; American Embassy Tegucigalpa Priority; American Embassy Port au Prince Priority

Source: AIDUNC.009442

Drafted by: AID/DCHA/FFP: A. Crumbly

SG: Cable -- 12/4/2002 202-71

Approved by: AID/DCHA/FFP: L. Landis

Subject: FFP guidance on the review of Title II FY 2004 Cycle DAPS, DAP Amendments and CSR4s

(a) 98 State 044913 (Title II M&E Reporting Requirements);
(b) 98 State 086386 (Bellmon Certification Requirements for PL 480 Title II Activities);
(c) 99 State 095910 (Enhanced Mission Responsibilities)

Summary

1. This cable provides development program review and management pointers for USAID Personnel providing oversight to Title II Food Aid Programs in the field.

2. Mission staff with Title II responsibilities should review the guidance documents to be familiar with their contents, as well as the above referenced cables, mission management criteria, and the DCHA/FFP Policy Letter issued previously by DCHA/FFP. These instructions for mission review of FY 2004 cycle documents should address most mission questions and concerns; further clarification may be obtained from Country Backstop Officers (CBOS) at DCHA/FFP.

3. Final draft guidance to Cooperating Sponsors (CS) and Missions for FY 2004 Development Assistance Programs (DAP) and DAP amendments was sent 08/30/02. The most significant change between the draft and final guidance was the extension of DAP completion dates from a standard of 5 years to a standard 6 years as appropriate. However, DAPS can be of shorter duration, ranging anywhere from 1 to 6 years.

Proposal Submission and Review

4. DAP proposals and DAP amendments should be submitted by the CS to DCHA/FFP and to the USAID Mission or Representative by November 1, 2002. Extensions of these deadlines may be made on an exceptional basis, by DCHA/FFP, in consultation with the USAID/Mission. CS should address their requests to DCHA/FFP, in advance of the respective deadlines.

5. Pursuant to the DAP Guidelines, missions should not request the CS to revise DAPS/DAP amendments for initial submission to DCHA/FFP. USAID Missions will review DAPS/DAP amendments and submit comments to USAID/Washington within 45 days of receipt of the complete DAP. Timely submission of mission comments will be critical. Mission cables should include an approval/disapproval recommendation and comments which include brief descriptions of any deficiencies and steps to correct them, making a distinction between threshold and non-threshold issues. Mission review should be further elaborated upon in the DAP/DAP amendment worksheet prepared by CBOS with input from missions and regional FFP Officers. Templates for these worksheets are available from FFP.

6. A formal review of DAPS/DAP amendments during the new statutory mandated 120-day review period will be held either in Washington or the field, starting in the month of January. USAID/Washington will review the DAP/DAP Amendment and USAID/Mission comments and send an "issues letter" to the CS thirty days in advance of the formal review meeting with the CS. Following the formal review meeting, USAID/Washington will reach a final decision (approve and negotiate a signed transfer authorization, or deny approval) on DAPS/DAP amendments within 120 days of submission of a complete document to USAID/Washington. In the case of denial, FFP will specify the reasons and inform the CS of the conditions that must be met for approval of the proposal. In the case of denial the proposal should be deferred to the subsequent DAP cycle. In all cases, prior to approval, a complete, revised DAP/DAP amendment will be required, responding to USAID/Mission and USAID/Washington comments.

7. Based on the New Farm Security and Rural Investment Act of 2002 (Farm Bill), DCHA/FFP would like to emphasize that a single DAP document will be submitted to USAID/Mission and DCHA/FFP for a single USAID review during the 120-day review period.

8. CSR4 documents are to be submitted to USAID/Washington and to the USAID Mission or Representative (with copies to the East or West Africa Regional Food for Peace Officer, if appropriate) by November 1, 2002. Mission comments are to be included in a cable to DCHA/FFP with a funding recommendation by February 1, 2003. In those cases where a mission recommends changes in annual funding levels of an activity, mission comments should include brief reasons for the recommended changes. These may be further elaborated upon in the CSR4 worksheet prepared by the missions and regional FFP Officers with input from the CBOS. Templates for these worksheets are available from FFP. DCHA/FFP plans to review submitted CSR4s in February and early March.

9. Resource requests for the second year of a DAP will be granted with minimal review. Document submission should follow the format of the CSR4 sections as applicable.

Coordination with Mission Strategy

10. Where Title II activities are proposed in countries with resident USAID Missions and fall within the USAID country strategy, FFP encourages consistency of the food-assisted activity with the mission's relevant strategic objective(s), to the extent possible. In this regard, missions should continue to invite CSs to participate in planning processes of USAID Missions as members of expanded strategic objective, strategic support objective and/or special objective (SO) teams. They should also participate in the identification of country development problems and in the development of information systems or indicators showing the impact of the use of Title II Food Aid on improved food security.

11. The activities outlined in new DAPS will ideally be consistent with mission priorities for the associated countries. However, this is not a requirement for approval of a DAP, which cannot be denied solely because it does not fit within mission strategic or special objectives. If a USAID Mission determines that a given Title II Activity, or CS Program as a whole will not fit into its strategic objectives, the mission should nevertheless provide comments following the instructions contained in this cable. At a minimum, the mission is requested to discuss how the program complement USAID's Food Security Policy Objectives as stated in the February, 1995 Food Security Policy Paper, host country food security objectives, as well as how the program will result in benefits that can be sustained by the host government and/or other donors.

12. If no USAID Mission is present in the country, the proposal should be reviewed by the U. S. Diplomatic Post's Country Team, who should provide comments to DCHA/FFP. The USAID Regional Economic Development Services Office (REDSO), Regional Food for Peace Officers, and/or Bilateral Missions with oversight responsibilities for the non-presence country should also review and comment on the proposal.

13. If a CS is proposing a Regional Program, the DAP should be submitted to all affected USAID Missions (and/or other structures, as applicable) for review and submission of comments to DCHA/FFP.

Mission Cable Recommendations and Review Comments

14. A mission cable is required to convey the following: formal recommended levels (commodity tonnages, ITSH, and Section 202(e) dollar and monetization local currency budget totals) for CSR4s, DAPS, and DAP amendments, concurrence with environmental compliance documentation, financial certification of a CS's ability to manage monetization funds, a review of the Bellmon Analysis, a Bellmon determination by the Mission Director, and a statement regarding the CS' host country Food for Peace Program Agreement. (missions to whom responsibility for annual resource request review and approval has been redelegated should refer to 99 State 095910 from DCHA/FFP on Enhanced Mission Responsibilities). Mission comments and analysis as a result of the mission review should be elaborated on in the review worksheet format (available from FFP CBOS), with threshold issues identified as such. This should be conveyed to the CBO via email.

AER Submission

15. The Annual Estimate of Requirements (AER) is a required component of all submissions, and follows the same submission and review process. Although the AER is prepared and signed by the CS, execution of the remaining signatures will be contingent on whether the mission recommends the activity for approval. Only when approval is recommended, the USAID Mission (and/or other structures, as applicable) should sign the AER and return it to the CS to be endorsed by the CS headquarters; and finally submitted to DCHA/FFP in Washington. When disapproval is recommended, the same steps should be followed with the caveat that there should be no mission signature on the AER. However, in the case of any supplemental or revised AERs, headquarters may sign for their field offices (subject to CS procedures) and DCHA/FFP may sign for the mission (subject to email concurrence with tonnage levels). Missions to whom responsibility for CSR4 review and approval has been redelegated should refer to 99 State 095910 from DCHA/FFP on Enhanced Mission Responsibilities).

Bellmon Determination and UMR Requirements

16. The mission director is required by DCHA/FFP to determine that the USAID Food Aid Program does not create a disincentive to local production and a statement acknowledging the adequacy of storage. Missions must also make a Bellmon determination when the analysis is provided by the CS, where a mission does not undertake the analysis itself. Missions are reminded to ensure that Bellmon Analyses are to take into account the aggregate impact of multiple CS programs, as well as Title I, Title III, and USDA Section 416(b) and Food for Progress Programs, if applicable. This must be submitted as part of the Mission Review Cable (see Para. 13) and certified in each Call Forward Concurrence Cable.

17. USDA will complete an analysis of usual marketing requirements (UMR) for each country and commodity planned for monetization in FY 2004. That analysis will be used by DCHA/FFP to make final decisions on tonnage available for us programming. DCHA/FFP CBOS will coordinate with missions to confirm FY 2004 UMR levels when they are known, usually in the month of August for the following fiscal year.

Host Country Food for Peace Agreements


18. In all cases missions are requested to closely review all CS Host Country Food for Peace Agreements (HCFFPAS), as called for in USAID Reg 211 sections 211.2 and 211.3. General counsel interpretation of the requirement is that the HCFFPA must incorporate and/or make reference to all of Reg. 11 in its text or as an annex to the agreement. HCFFPAs that fall short of this standard must be amended and renegotiated with the host government. In the interim, or if there is no HCFFPA, the mission cable (see Para. 13) should convey a justification and certify to FFP that the program can be effectively implemented in the absence of such an agreement. This cable should also state what steps the CS will take in the future to obtain a HCFFPA, and the projected timeframe.

Proposal Review and Approval Criteria


19. All Title II country programs are required by DCHA/FFP to include direct distribution using us food commodities. The reasons are several: (1) each year FFP falls well short of a congressional mandate to use 75 percent processed, bagged, and blended commodities; (2) each year the intent of congress to allow at least 15 percent of the program commodities to be monetized is greatly exceeded; (3) food assistance is intended to complement and not replace the 150 account development assistance (DA) resources of the agency, (4) growing concerns based on the results of demographic health surveys that show persistent high rates of child malnutrition lead FFP to recommend an increase in food-assisted child survival activities, and (5) an important role for development programs is to maintain a food pipeline in place to mitigate against and respond to periodic emergencies.

20. In addition to the policy criteria described in Para 17, approval of DAP proposals will be based on the criteria described in the DAP proposal guidance, Section VI, Proposal Review & Approval criteria. These cover the areas of technical quality, geographic & sectoral focus, legislative mandates, integration & partnership, and cooperating sponsor capacity. DAP amendments will also be reviewed against some or all of these criteria, as appropriate.

21. In the case of a follow-on DAP, additional emphasis will be placed on the fifth (5th) year CSR4 of the previous DAP. Final evaluations are expected to be completed by the first quarter of the final year of the DAP. They will influence the review of the follow-on proposal. Annual funding is subject to the availability of funds and commodities.

    DCHA/FFP Operating Year Budget and Approval Levels

22. DCHA/FFP will prepare a draft operating year budget (OYB) for FY 2004. The congressional budget justification (CBJ) is expected to be submitted to congress in December 2003. DCHA/FFP CBOS are responsible for obtaining regional bureau and mission input into the OYB and CBJ. The resulting OYB budget will be used in monitoring program-wide and specific approval levels through the FY 2004 approval cycle.

Approval Documentation

23. For completed submissions without threshold issues, program approval documents will be drafted immediately upon completion of the review. Where incremental funding with FY 2003 monies is appropriate, obligation (and issuance of transfer authorization TA or TA modifications) may take place within 3-4 weeks of completion of the reviews (or if necessary, after receipt of revised submissions, following review feedback). However, obligation normally takes place once FY 2004 funding becomes available on October 1, 2003.

Environmental Compliance

24. Compliance with regulation 216 is required of all Title II development activities. All Title II DAPS should include an initial environmental examination (IEE). IEEs or IEE amendments must be cleared by the mission director or his/her designee, then be sent to FFP for clearance, and from FFP to the DCHA or Geographic Bureau Environmental Officer for final concurrence. All CSR4s should include an environmental status report detailing the actions they have undertaken with regards to their previously approved IEE. DAP amendments must include an IEE amendment.

Procurement

25. It is DCHA/FFP policy to adhere to the requirements of the Foreign Assistance Act and USAID source origin and nationality rules regarding procurement. When CSs are requesting Title II funding for vehicle procurement, provide concurrence of the CS's procurement plan (including vehicles & high value equipment) for the full DAP period. For approval of non-U. S. Vehicles, missions are expected to provide: 1) specific concurrence for non-U. S. Vehicles or equipment, based on the CS's justification why U. S. Vehicles or equipment are not adequate to carry out Title II activities; and 2) a description of the USAID Mission's vehicle or equipment procurement policy or plan, as endorsed by the USAID/mission's Executive Officer (EXO) or Contracting Officer. Non-U. S. Vehicles, if required, should be requested in DAPS or DAP Amendments, although such requests will also be considered as part of a CSR4 for on-going programs.

General Mission Management

26. DCHA/FFP uses a list of ten mission management criteria to assist in: 1) assessing the strengths and weaknesses of mission Title II program management; 2) identifying capacity needs and developing appropriate training responses, where possible; and 3) evaluating mission capacity for redelegation of certain management and annual resource request approval responsibilities.

27. An annual review of mission management of Title II programs, against the ten criteria below will serve in lieu of the requirement (as stated in USAID handbook nine pending issuance of the FFP ADS) for missions to submit food aid management plans, except as otherwise requested by DCHA/FFP. Conducting this self-assessment should become a routine part of annual Title II reviews.

28. The summary criteria are listed below. Detailed examples are provided on DCHA/FFP's website or are available from CBOS.
    

    1. Integration with mission strategy: Title II Food Aid Development Programs are well integrated into the overall strategic plan of the mission.

    2. Capacity for technical review and oversight: the mission has the capability and established record for providing technical review and oversight of Title II Food Aid Development Programs.

    3. Management structure and staff: the mission has a clearly defined management structure and sufficient knowledgeable staff to manage Title II Food Aid Development Programs.

    4. Competent commodity management: the mission has an established record of competent performance in commodity management in accordance with USAID Regulation 211 requirements.

    5. Institutional relationships: the mission has on-going constructive relationships with Host Country Government Agencies, Cooperating Sponsors, World Food Program and other donors.

    6. Monetization: the mission has performed properly those responsibilities related to monetization of food aid.

    7. Bellmon Determination: the mission can be relied on to confirm that cooperating sponsors have provided sufficient and accurate information for the mission director's Bellmon Determination.

    8. Reports and records: the mission receives and reviews the reports required of the CSs and recipient agencies and maintains records of agreements pertaining to the conduct of Title II Food Aid Development Programs in-country.

    9. Financial management: the mission performs the necessary reviews and follow-up actions to ensure proper financial management of Title II Food Aid Programs.

    10. Monitoring and evaluation: the mission has developed clear performance indicators for measuring results of its strategies, both food security related and others, and works with the CSs to establish monitoring and evaluation procedures that meet both mission and global needs.

    Country Backstop Officer Assignments

29. The development programs division is divided into two teams, a team responsible for East and Southern Africa and Asia, and another team responsible for W. Africa and Latin America. CBO responsibilities are allocated as follows:
    
    Planning and Implementation Team (Leader: Angelique Crumbly)

    Cathy Brown: Malawi, Ethiopia, India
    Michelle Cachaper: Madagascar, Kenya, Tanzania, Zambia
    Carolyn Hughes: Bangladesh, Indonesia, Mozambique, Eritrea, Pakistan, Tajikistan
    Bridget Ralyea: Angola, Rwanda, Uganda
    Sandra Tedeschi: MCH/N/HIV AIDS Activities
    
    Technical Advisory and Results Reporting Team (Leader: Curt Nissly)
    
    Curt Nissly: Chad, Ghana, Guinea, Liberia, Mali, Niger, Haiti
    Kathy Hunt: Benin, Burkina Faso, Cape Verde, Mauritania, Senegal, Sene-Gambia, WFP
    Rudy Vigil: Guatemala, Honduras, Nicaragua, Bolivia, Peru, and Agriculture and Environmental Compliance
    Julie March: Agriculture Activities
    

30. Mission directors and deputy directors are required to ensure compliance with this guidance. Mission staff is encouraged to contact CBOS in case of questions or clarifications.
    

31. Minimize considered for Abidjan.
    Powell