How To Write A Case Study On A Certification System For Nongovernmental Organisations

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1 Certification Review Project Reviewing the Draft Certification Model: A Case Study in DRC (Goma) 1 September 2014 Report prepared by Jock Baker and Philip Tamminga

2 Table of contents Acknowledgements... 1 Introduction Structure of the report Background to the field research The humanitarian context in DRC CARE in the DRC Views of Affected Communities Views of Government Health and Education Staff Views of Other Stakeholders on the Model Alignment with Other Relevant Processes Alternative Criteria for the Model? Conclusions Recommendations...16 Annex 1 - List of Interviewees...17 Kinshasa...17 North Kivu...17

3 Acknowledgements We would like to thank the CARE International (CARE) and Oxfam International (Oxfam) DRC Country Offices for hosting this pilot case study. Oxfam provided transportation and logistics support for the Kinshasa portion of the field research, participating in interviews, and facilitating meetings with NGOs, UN agencies and donor representatives in Kinshasa. Special thanks are due to Vincent Koch, Joanna Trevor and Sandra Kiyanga for their support. The bulk of the research was conducted in eastern DRC, where CARE provided transportation and logistics support and, along with OCHA, helped set up meetings with other stakeholders working in the region. CARE staff gave the study team full access to their policies and procedures and staff were generous in sharing their time and opinions around how certification could improve their work. In particular, we would like to thank CARE s Country Director Yawo Douvon, Assistant Country Director, Abdoulaye Toure, and the other members of their team for their active engagement and constructive feedback on the project with special thanks to Cathy Katimbabo who helped with preparations and logistics. Particular thanks are also due to Anne-France White at OCHA in Goma both for providing OCHA s perspectives and for facilitating discussions with the broader humanitarian community. Jock Baker and Philip Tamminga 1

4 Introduction How can certification of humanitarian organisations contribute to greater effectiveness and accountability in humanitarian action? Over the past 18 months, the Certification Review Project, sponsored by the Steering Committee for Humanitarian Response (SCHR), has been researching what a successful, sustainable certification model might look like and how to achieve it. The project aims to a) explore the relevance and feasibility of a widely-endorsed certification system for nongovernmental organisations (NGOs) aimed at improving quality, effectiveness and accountability of humanitarian actions; b) identify the conditions that would make certification sustainable and successful; and, c) seek recognition by donors, governments and UN agencies, and alignment of their different requirements to any proposed model. This report on the case study in the Democratic Republic of Congo (DRC) documents is the third in a series of country case studies aimed at generating more detailed analysis of the usefulness, relevance and practical implications of a draft certification model developed by the project (version 2.0). The main focus of the case study was to examine the potential applicability of the draft model based on current policies and practices of CARE International s (CARE) country office. This case study also collected relevant information and perspectives from other stakeholder groups, including national and international NGOs, UN agencies, local government and donors. The research team was comprised of Philip Tamminga, Certification Review Project Coordinator, who was in Kinshasa from May 19-23, and Jock Baker, Independent Consultant, who visited eastern DRC during June Structure of the report This report sets out the findings from the field research, and offers some initial recommendations on how the proposed model could be improved in order to meet the needs and expectations of other stakeholders working in the DRC context, with a particular focus on eastern DRC. It also describes an alternative structure that was suggested during the course of discussions, along with its perceived pros and cons. The background to the study and an overview of the objectives, methodology and limitations and is followed by brief overview of the humanitarian situation and coordination mechanisms in place in DRC. Following this, there is an analysis of the alignment of the proposed core requirements and indicators of the draft certification model: In comparison with CARE DRC s (and, where relevant, CARE International s) current policies and practices as an example of how the model could work for an international NGO. It also includes CARE views on the relevance and usefulness of the model. With other NGO assessment and certification-like processes, notably the Pooled Fund managed by UN OCHA in DRC and the Harmonized Approach to Cash Transfers (HACT) systems being used by some UN agencies for their implementing partners. The final section discusses the feasibility of the model based on the research findings, along with an initial analysis of the potential costs for organisations to participate in an assessment process along with conclusions and recommendations based on findings from field research. 2

5 2. Background to the field research The project has developed a draft model with a proposed assessment framework that attempts to establish the core requirements to describe a principled, accountable and effective organisation. The proposed core requirements are grounded in existing commitments, standards and good practices adopted by the humanitarian community, including version 2 of the draft Core Humanitarian Standard (CHS). 1 The proposed model involves organisations making a commitment to reflect the core requirements in their policies and practices, report with supporting evidence on how these requirements are being applied, and, if relevant and appropriate to the organisation, undergo a third party external verification process to certify that the core requirements are being applied in practice. This DRC pilot case study is the third of four case studies designed to review the main elements of the proposed certification model from the perspective of actors in different crisis contexts. Other countries include Ethiopia and Pakistan (the reports are available at along with the Philippines, which also took take place during June. These countries were selected to assess the relevance, usefulness and feasibility of the model in a mix of different crisis types and responses. Countries were also selected in order to assess the model for alignment against national level legislation or other certification-like systems for NGOs. Participating organisations were selected to ensure a balance between international and national NGOs, currently certified (under HAP or a national level certification system, for example) and non- certified, members of wider networks, and SCHR members. The CARE DRC country office volunteered to participate as the principal focus of this case study, with additional support offered from the Oxfam DRC country office in Kinshasa. CARE has a multi-sectoral programme that encompasses emergency response, health, sexual and gender-based violence (SGBV), rehabilitation, governance and peace building. 2 Oxfam s programmes include emergency responses, health, and education programmes. 3 Objectives of the DRC Field Visit The purpose of the field research was to review the relevance, usefulness and feasibility of the draft model against CARE DRC s current programming policies, systems and practices. The research also collected the views and perspectives of UN agencies, NGOs, government representatives and other key stakeholders on the model and its potential contribution to aid quality, effectiveness and accountability of humanitarian aid in DRC. These case studies aim to increase understanding of how organisations apply, measure and promote humanitarian principles, quality and effectiveness, and accountability in their humanitarian work, and the potential role and contribution of external verification and certification in support of those efforts. Each case study will inform subsequent case studies in terms of improving the methodology and addressing gaps and opportunities that are identified through the research process. The overall results from the case studies will be used to substantiate recommendations on whether external verification and certification can contribute to quality, accountability and effectiveness, and if so, what a relevant and appropriate model might look like. Methodology The case study approach included interviews and document reviews with key stakeholders based in Kinshasa and in North Kivu in eastern DRC. In Kinshasa, senior representatives from Oxfam, UN agencies, other NGOs and donor agencies were interviewed. The bulk of the research was conducted in

6 eastern DRC, where most humanitarian programming takes place. In North Kivu, the research included key informant interviews, focus group discussions and direct observations during a field visit to three CARE project sites in the Massisi area. The main focus of the research was to gather CARE DRC s views on the relevance and practical implications of the three main pillars of the proposed model: humanitarian principles, accountability and quality and effectiveness. Staff were interviewed to draw upon their experiences and perspectives around the use and application of quality and technical standards, accountability mechanisms and the role of external evaluation and verification processes. This was then crosschecked against CARE s policies and procedures, including a desk review of project documentation, and interviews with external stakeholders familiar with CARE s work. The one-day visit to Massisi allowed the researcher to directly observe some of CARE s project activities and speak to community members, local authorities, government health staff and community-based health committees. The field research collected inputs and perspectives on the usefulness and relevance of the proposed model from various stakeholders, including government, UN agencies, and national and international NGOs, and NGO umbrella, coordination or certification bodies including: CARE DRC: 22 staff members from CARE DRC senior management, programme and programme support staff. CARE DRC Local Partners: 4 staff members from two national NGOs who are two of CARE s main partners in eastern DRC. Oxfam International DRC 8 staff from Oxfam s senior management team, including programme, advocacy and finance staff. Others: senior representatives from the main UN agencies working in DRC, staff members from other international NGOs, donor representatives, 10 community members and leaders, and government staff. A detailed list of interviews and meetings is attached as an annex. Constraints and Limitations Main constraints and limitations during the visit to the DRC included: Scheduling difficulties meant that the DRC field research was conducted in two phases Kinshasa in late May and Goma in early June. This meant a slight disconnect between staff and programmes in both locations, although in practice, given the scale and logistic challenges in DRC, this reflects the operational reality for many organisations operating there. The lack of familiarity of humanitarian staff with the SCHR Certification Model (and certification in general) and absence of practical tools meant that a substantial amount of time in country was devoted to describing the model and helping interviewees to understand its potential applications. The exception was those staff from CARE who participated in a series of two to three discussions during the field visit who were thus in a better position to appreciate potential practical applications. Upon the advice of OCHA, national and regional government authorities were not interviewed to avoid undermining current discussions around the IDP situation. The lack of direct consultations was addressed through discussions with local authorities and government health staff. During interviews, NGO and UN staff were also asked to describe their relationships with government authorities and how certification processes my impact these. The research team originally intended to use the Core Humanitarian Standard (CHS) as a framework to discuss assessment criteria with participating organisations; however, a revised draft was not ready at the time of the research. The research team was able to review in depth the model s proposed indicators, and suggestions on improvements, etc., will be shared with the team leading the CHS consultations. 4

7 3. The humanitarian context in DRC The Democratic Republic of Congo (DRC) has often been described as the world s worst humanitarian crisis by the United Nations, a factor that led to its selection as one of the pilot countries for the Good Humanitarian Donorship initiative 4 in DRC has consistently ranked at the top of the World Bank s list of fragile states 5 where communities have long experience of dealing with recurrent violence and a lack of basic services. Eastern DRC in particular has experienced several decades of conflict that caused large and repeated population displacements, both internally and across borders. The most recent resurgence of violence in the east of the country can be traced to 2008, when hostilities flared and militant forces briefly occupied Goma in late Out of a population of around 77 million, more than 2.9 million people are currently displaced within the country, with over 1 million IDPs in the eastern part of the country and over Congolese finding refuge in neighbouring countries. 6 The humanitarian situation remains precarious due to serious problems relating to risks of indiscriminate violence, access to basic services, and a significant reduction in harvests connected to access difficulties and insecurity. Given the size of the country and the complex nature of the crisis, priority needs vary from one region to another. In the conflict-affected areas, the over-arching need is protection from violence. All armed groups, including the DRC Armed Forces (FARDC), frequently commit violations of human rights against civilians; this includes acts of sexual and gender-based violence against women and young girls, but also against men and boys. 7 Other frequent incidents related to the need for protection include arbitrary arrests, pillaging and forced labour. Conflict and fear have driven several million people out of their homes and their fields: this generates needs in terms of livelihoods, nutrition and access to services notably health. 4. CARE in the DRC CARE DRC has been operating in DRC since the Rwanda refugee crisis in The organisation has a programme covering both humanitarian and development projects and its project activities are increasingly being implemented through local government and NGO partners. In their current Strategic Plan for , CARE s target groups include poor and vulnerable women, adolescent girls and boys as well as displaced and returning populations. Access to health care is one of CARE s primarily programme areas, with a focus on women s health issues, including reproductive health, family planning, and treatment for survivors of sexual violence. CARE also tries to ensure that populations affected by conflict, including displaced persons, can access adequate health care services of sufficient quality. The organisation works with the Ministry of Health and civil society organisations, providing essential drugs and equipment, rehabilitating health centres, and supporting training and community mobilisation for health care education and advocacy. CARE mainstreams gender equity into all its projects, while emphasizing female empowerment in their SGBV programming. General observations CARE International has well-developed global policies and procedures around its quality and accountability commitments 8 and has a clear set of organisational standards that are communicated to staff and external stakeholders. The organisation has been actively engaged and committed to initiatives to improve quality, accountability and effectiveness in the sector

8 CARE's Humanitarian Mandate Statement commits CARE to meeting international standards of quality and accountability when responding to emergencies. CARE's Humanitarian Accountability Framework (HAF) consists of 8 humanitarian benchmarks, 5 performance metrics indicators and compliance measures. HAF benchmarks: 1. Provide leadership on accountability. 2. Ensure CARE's response adequately considers needs and rights. 3. Ensure good enough' planning, design and internal monitoring systems are in place. 4. Guarantee the participation of stakeholders in decision-making processes. 5. Solicit stakeholder feedback and put a complaints mechanism in place. 6. Be transparent and share information publicly, especially with beneficiaries. 7. Use independent reviews, monitoring, evaluation and learning to improve policy and practice. 8. Build staff competence and human resource management capacity for emergencies. HAF Performance Metrics Indicators: Timeliness of the response Quality and accountability of the response CARE's competence in core sectors Emergency revenues Financing of emergency capacity To help ensure compliance with their Humanitarian Accountability Framework, CARE promotes the use of a combination of internal and external reviews following large-scale emergency responses including reviewing application of the Humanitarian Accountability Framework during evaluations, Rapid Accountability Reviews 9 and during After Action Reviews. 10 CARE DRC s most recent After Action Review took place in February Alignment to the draft model s proposed core requirements The research team reviewed documentation of CARE DRC s commitments, policies and procedures, both at a global and country level, and evidence of how they put these into practice, and compared these to the proposed certification model. Pillar One: Principled Humanitarian Actions CARE s policies and procedures recognised humanitarian principles and were reflected in humanitarian programming. Senior staff, many with extensive experience of working in conflictaffected contexts, demonstrated a good understanding of neutrality, impartiality and independence in practice. Staff were able to articulate how they address the challenges in maintaining operational independence and the perception of being a neutral, impartial actor in a context like DRC. In this regard, the proposed criteria in the model were seen as useful and relevant. Pillar Two: Accountability towards affected people As indicated above, CARE DRC has a well-developed accountability framework in place, supported by global accountability and learning processes. Accountability is a core value CARE International, and 9 A Rapid Accountability Review is a rapid performance assessment of emergency response against CARE's HAF that takes place within the first few months after an emergency response. 10 The purpose of an After Action Review is to capture and learn from lessons, so that improvements can be made in CARE's operational procedures, structures and policy. The After Action Review will usually take a workshop format that involves key staff in the emergency response from the CARE Country Office, the relevant CARE Lead Member and other parts of CARE. 6

9 this commitment can be observed in their participatory approaches with communities and with partners along with an emphasis on seeking community inputs when assessing, monitoring and evaluating their activities. CARE DRC staff noted the validity of the proposed indicators and noted the need to improve participation and feedback systems for their own activities. Nevertheless, the difficulties of access, security and conflict at time limited the organisation s ability to fully integrate participatory methods at all times. Pillar Three: Quality, Effectiveness and Continuous Learning Among the three pillars, this one was felt to be the most practical for the DRC context by CARE staff since it makes reference to day-to-day work (financial management, monitoring & evaluation) along with a specific learning focus. The proposed criteria matched many of the requirements already in place internally and externally Views on the Certification Model CARE DRC Overall, the certification model was viewed positively. The exception was the first part of the draft model s vision statement, which speaks of affected communities having informed choices about the assistance they receive and the organisations that provide it. Many CARE staff felt was unrealistic given the nature of the current system, driven more by supply than demand. There was a consensus that this portion of the statement should focus instead on promoting more meaningful participation of affected people in the aid system. Nevertheless, in so far as the certification system is focused on meeting the priorities of disasteraffected communities, this was viewed as something that could increase trust of external stakeholders (particularly donors and host government) and allow agencies to focus on key issues to effective and accountable aid. The precondition for this to work is that there was sufficient buy-in (particularly from donors) according to staff interviewed. Other key feedback from CARE staff included: With the exception of Sphere and, to a limited extent HAP Standard, most CARE staff were unfamiliar with the most of the other approaches listed as Compatible with the model, which limited their ability to provide feedback. Even for Sphere and HAP, there was very limited awareness amongst program support staff. The few that were familiar with other references (e.g. AAP, GHD) felt that these were relatively broad and needed to be contextualized before the accountability commitments would be clear for staff working in the field. A related recommendation was to try and link accountability more directly to CARE DRC s own codes and standards, since this is what staff (including program support staff) were most familiar with. It was pointed out that CARE s own codes and standards were based on common standards and codes. 11 The proposed indicators were not specific enough for application at country level. It would be better if these could be contextualized. There seemed to be a fair amount of duplication or overlap between indicators, notably equity indicators under Pillar 1. On the other hand, apart from a reference to finance in the third pillar, there was a lack of indicators that were relevant to program support staff (one example given was to revise 3.2 to link more to agency processes such as staff performance reviews). Other indicators that seemed to be missing included partnership (in the context of CARE s partnership 11 The preference of field staff for internal codes and standards is consistent with research findings from previous studies see Gostelow, L. et al. (2010) SCHR Peer Review on Accountability to Disaster-Affected Populations: An overview of lessons learned and Bhattacharjee, A. (2007) A Common Humanitarian Accountability Framework for IWG Agencies - Inter Agency Working Group: Emergency Capacity Building Project (ECB2) 7

10 with local NGOs and the government). The alternative structure of the certification model (see below) was felt to be better organized, although for CARE interviewees it would be important that the headings be worded similar to the indicators so as to bring out the perspective of the affected community. While donor buy-in would be critical to the success of a certification scheme, it will be important to protect the system from being dominated by donor interests. Even though the concept of the model is good, it was recommended that the model and related tools - be made more concrete so that implications of different options can be more clearly understood. For example, it would be important to understand what is the proposed frequency for reviews and what would be the process actually entail. It was also recommended that certification shouldn t be like a visit from the police, but give a suitable emphasis to learning. Views on certification CARE DRC Local Partners Overall views of CARE s two local partners were largely consistent with those of CARE DRC, i.e. overall quite positive, but difficult to understand the implications without more details on how the model would work. Specific points by local partners included: The DRC government should be closely involved and needs to feel ownership of the certification process. Capacity building is very important, particularly for national NGOs. National NGOs should be included in the system, but for reasons of comparability and costeffectiveness there should be minimum requirements. The suggested minimum was a budget $100,000 along with a minimum number of humanitarian staff and a track record in humanitarian operations. Key findings: CARE DRC s current system appears to be compatible with certification and staff view certification positively if it helps their systems function more effectively. However, it is important that it not become an additional parallel process. 2. Contextualization of the certification model will be needed before it can be usefully applied. 3. Referencing the agency s own policies and codes (as long as they meet minimum humanitarian standards) and providing a tool kit to help with implementation would also increase relevance. 4. Capacity building is very important, particularly for national NGOs. 5. National NGOs should be included in the system, but for reasons of comparability and cost-effectiveness there should be minimum requirements. 5. Views of Affected Communities Discussions with members of health committees and beneficiary communities in the Massisi area focused more on understanding what their criteria of a good NGO was rather than a review of the Certification Model as such. The community members met had witnessed operations of 5-7 NGOs (including CARE DRC) during the past decade and most were thus able to draw comparisons. In each of the 4 separate discussions it proved difficult to move past a discussion on material assistance (i.e. what non-food items, medical assistance, etc. they had received and how timely it had been) to discussions about agency performance as described in the indicators in the Model. This could be an indicator of relatively low level of participatory approaches by agencies - something that CARE DRC 8

11 acknowledged they were trying to improve Views of Government Health and Education Staff In contrast with community members and some staff, government health and education staff were quick to grasp the concept and felt that certification was a very logical step for NGOs and pointed out potential benefits of certification, notably: Bring donors closer to the affected population and help reduce the delays in allocating funding by providing them assurances that organisations are capable and competent. Increase trust and confidence in the agency amongst external stakeholders. Similar to community members, the main criteria mentioned for a good NGO was the ability to understand what the real needs are, and to fulfil commitments once activities start. 7. Views of Other Stakeholders on the Model Virtually everyone who was shown the model was generally supportive of the concept and approach, including UN agencies, donors and other NGOs. There were, however, a significant number of respondents who wondered if certification would make much of a difference in a failed state situation, with very limited government and civil society capacity to engage with and hold humanitarian actors accountable. On the other hand, others felt that the model, with a clearer set of indicators, could be a useful tool to drive better and more consistent performance across the board. Specifically regarding Oxfam, similar to CARE, certification was seen by staff as complementary to their own internal quality assurance processes. These processes were seen as compatible with the proposed pillars and indicators of the model. The research team reviewed Oxfam DRC s policy and procedures and interviewed key staff, and found that Oxfam s approach is aligned to the model, though field level verification of this was not possible. Staff also recognised areas for improvement, and several suggested that an external review process based on the model s proposed criteria could help them pinpoint where action was required, and provide a framework for monitoring changes. One specific area mentioned by several staff was the need to include the accountability of government and other actors to respect humanitarian principles and ensure safe access and security. In terms of improving the model, there were suggestions to emphasise the need for NGOs to accompany, listen to and engage with communities and local partners as part of their commitments. In practice, however, the demands of the crisis context in DRC, with frequent situations of localised conflicts and rapid population movements often meant larger INGOs and UN agencies were the only ones with a standing capacity to respond quickly. This is a challenge in terms of building and sustaining local capacity. The majority of UN agency representatives interviewed also saw an added value in the proposed model. This was particularly the case for staff responsible for partner and funding decisions, who consistently mentioned the benefit of having a better idea of technical competencies and performance of NGO partners. Many recognised that their main focus on partner selection tended to be on risk management from a financial perspective, with not enough emphasis on results and performance. Several mentioned that in an era of decreasing funding for the DRC, a more systematic and objective approach to selecting partners would be needed, and the proposed model could also be used to orient local NGOs on how to build capacity. 12 it should be noted that CARE was viewed more positively in this respect by community members than some of the other agencies 9

12 Nevertheless, others questioned that the model would add value and suggested the particular dynamics of the DRC, along with the unique tools and approaches 13 developed by the humanitarian community working there might be a more cost-effective way of ensuring good performance and results. In this sense, most respondents saw building on and recognising existing initiatives as very important, as well as simplifying and streamlining processes. Donor government representatives also were supportive in principle of the model, though somewhat more sceptical of it being adopted and supported by all, including their own governments. Some were able to see the benefits, but expressed concerns about potential duplication of efforts, while others suggested that the limited number of potential partners to work with in the DRC meant that most partner relationships were built on trust established over time sometimes at the expense of building and supporting local capacity, as one admitted. Still, the model was also seen as a potential tool to help donors to focus their support on NGOs most likely to deliver results, or that might evolve over time to have greater capacity to scale up and improve their programming to be able to respond quickly to future crises. From the perspective of national NGOs, broad support for certification was tempered with a word of caution that it should not become a tool to exclude them from the system. A focus group session with Caritas Congo national staff (including 40+ staff from the diocese level) engaged in humanitarian programmes level around the country was quite illustrative of the general attitude and concerns expressed by other national NGO partners of international actors. Caritas Congo staff were very well informed about Sphere and HAP standards, clusters protocols and other quality and accountability initiatives, and demonstrated capacity to deliver complex humanitarian programmes. Yet despite this, many felt that this capacity and experience was overlooked or ignored by partners and funders, and that they were too often viewed simply as providing access to communities and for carrying out activities. Many felt that more could be done to transfer funding and management of projects directly to national partners, instead of relying on international expatriate staff for management and oversight of projects. Several felt this was unfair, and worried that the model would require them to learn yet another set of requirements without fundamentally changing the dynamics of partner and funder relationships. Others saw the model as a potential tool to demonstrate to donors and the government that they are credible, competent and have capacities that are in line with INGOs, and therefore could be treated equitably. The majority of all stakeholders consulted made two specific suggestions to improve the model. First, there was a strong message to keep any model as simple as possible and to build on, consolidate and streamline existing processes rather than creating another level of requirements. The second, more specific to the context of the DRC, was to ensure any model or assessment process include measures against corruption and misuse of resources. Another suggestion made by many was to ensure the government participated in the model, but to make clear that the assessment process and any decisions around granting certification needs to be completely independent from government to preserve the integrity of the process. A similar suggestion was to make the emphasis on learning and improvement, and not as a tool to punish or reward NGOs. Potential benefits of certification: One NGO key informant noted that NGOs in Sierra Leone had recently been asked to come before 13 A good example of such a contextualized approach is the Rapid Response to Population Movement (RRMP) 10

13 a Parliamentary Commission tasked with preparing NGO legislation and a certification model would have been helpful for NGOs to develop a coherent position. Assist with the current challenges faced by agencies who are supposed to be prioritizing inputs from beneficiaries when designing and implementing projects, while at the same time coming under pressure to include global priorities. Other relevant comments and questions included: While it could be useful, the humanitarian system already seems process-heavy. Is it really the time to make the system even heavier? With certification will agencies need to recruit staff with profiles that are comparable to internal auditors? While it is necessary to involve the government in a certification process, their involvement may not always be positive. It is important that any certification system be country-specific and appropriate to the context. It shouldn t be a one-size fits all approach and, given its humanitarian focus, it needs to accommodate different levels of tolerance for risk. Current model seems to be relatively soft, with more emphasis on learning than compliance, whereas in some situations, more rigorous compliance is needed. It will be important to include national NGOs, but will there be different qualification criteria from other organisations? It takes a long time to build sufficient trust in a system, mainly because of the implications about shifting of resources and the risks that the system will not deliver what it promises. Certification needs to show that it is adding value by building trust, supporting more consistent action, and improving quality. With support from OCHA in Goma, a presentation of the Certification Project followed by a discussion was included in the agenda of the weekly Heads of Agencies meeting. The consensus from this meeting was that: The criteria and approach are relevant and valid, but before embarking on the process, the model needs to be better defined in terms of expectations of organisations. For a certification process to become widely accepted and respected it needs to be widely accepted by the donor community. If it is the other way around it will only be a set of agreed upon good standards that everybody may agree with and aspire to if all the stars are aligned, but with no one really holding the INGOs responsible to respect. What is the value added of a certification process? Even though potential benefits were discussed, it was still not clear. All agreed that in theory this all sounds really good, but there are still outstanding questions about where and how will this make a difference practically and what will be different from any previous efforts (e.g. HAP certification) in this direction. 8. Alignment with Other Relevant Processes As part of the research, the team also reviewed NGO selection criteria, review and certification processes used by other organisations to assess the extent of compatibility and alignment with the draft model and its proposed requirements, based on interviews and document reviews. These included: Harmonized Approach to Cash Transfers to Implementing Partners (HACT) 14 that was launched in 14 _undaf/harmonised_approach_to_cash_transfers 11

14 2005. DRC Pooled Fund 15 In general terms, the draft model is compatible with each of these different approaches although the emphasis of these approaches is on financial and management practices, and relatively less on programme quality and accountability of specific technical competencies and expertise. The proposed requirements of the draft model therefore do not significantly overlap these process, which, on one hand means that certification would complement them but, on the other, implies that this could be an add on and might not necessarily lighten or replace existing processes. A short analysis of the alignment with each process is provided below. Harmonized Approach to Cash Transfer (HACT) During interviews with UNICEF, the proposed Certification Model was compared to the Harmonized Approach to Cash Transfer (HACT) system, which is currently being applied to government and NGO implementing partners for UNICEF, UNFPA and UNDP. The main aim of the HACT is to shift the management of cash transfers from a system of rigid controls to a risk management approach by: Reducing transaction costs pertaining to the country programmes of the ExCom agencies by simplifying and harmonizing rules and procedures; Strengthening the capacity of implementing partners to effectively manage resources; Helping to manage risks related to the management of funds and increase overall effectiveness. While there is a global framework, each agency Country Representative has primary responsibility and accountability for implementation of the HACT framework at country level. What this means in practice is that the same implementing partner may be given different risk ratings in different countries. The HACT framework consists of four processes: (1) macro assessments, (2) micro assessments, (3) cash transfers and disbursements, and (4) assurance activities. Assurance activities include planning, periodic on-site reviews (spot checks) and audits. Assurance should also include programmatic monitoring, although the examples seen focused mainly on financial management aspects. Macro assessments look at the overall cash transfer environment in the country. Micro assessments look at individual implementing partner s financial management capacity (i.e. accounting, procurement, reporting, internal controls, etc.) to determine the overall risk rating and assurance activities. The risk rating, along with other available information, is also taken into consideration when selecting the appropriate cash transfer modality for an implementing partner based on each agency s business model. Assessments are by an external body that should normally be undertaken once per programme cycle (every 5 years), although it may be done sooner if circumstances change significantly. The risk rating allocated to the agency determines the frequency of reviews by the partner by the relevant UN agency. In DRC, KPMG has been contracted for external assessments, covering implementing partners each year at a cost of US$5,000 per agency. For efficiency reasons, assessments are not usually done for partners with a project value of less than $100,000 or a budget of less than $500,000 over the program cycle. While the HACT looks closely at financial management capacity and systems of partners, a global assessment carried out in on the HACT contains some findings that appear to be relevant to the UNOG Advisory Group (2011) Global HACT Assessment %20Gobal%20HACT%20Assessment%207%20Dec%202011%20pdf.pdf 12

15 Certification Model: Difficulties to mobilize Task Force members, particularly since there was not a designated permanent coordinator. The UN Development Assistance Framework s Planning Monitory & Evaluation Group did not fulfil its expected role in HACT. Resistance to change and continuation with agency specific procedures and business as usual (e.g. parallel financial audit processes); and Difficulties in agreeing on how quality assurance should be carried out. Another challenge was that processes were being done on an individual basis and in uncoordinated way, which was attributed to a lack of flexibility the HACT system to adapt to specific contexts. In the revised version, there are more possibilities to contextualize processes. DRC Pooled Fund The Common Humanitarian Fund (CHF) - better known as the Pooled Fund in DRC - has become the largest source of funding for humanitarian projects in-country, representing approximately 17 percent of funding received through the DRC Humanitarian Action Plan (HAP) in The Pooled Fund humanitarian financing mechanism was established in 2006 at the initiative of humanitarian donors to support the Humanitarian Reform and to empower the Humanitarian Coordinator (HC). 17 The Pooled Fund s consultative allocation process is designed to respond to the humanitarian needs identified in the annual Humanitarian Action Plan (HAP) through NGOs and UN Agencies. The main objective of the Pooled Fund in general is to enable the HC and the humanitarian community to ensure timely and predictable funding for humanitarian needs, providing grants to priority projects. Allocations are based on a participative consultative allocation process that engages clusters and other relevant stakeholders at country level in a comprehensive prioritization exercise and has two allocation modalities: the Standard Allocations and the Reserve. Two standard allocation rounds are undertaken per year, which use the bulk of funding. The HC is responsible for the overall management and day-to-day management is performed by OCHA. The UNDP Multi-Partner Trust Fund Office (MPTF) undertakes the financial administration. MPTF receives and manages donor contributions and channels funds to implementing partners. The HC makes final decisions on PF grants following the recommendations from the Technical Review Board, comprised of cluster leads, and in consultation with an Advisory Board. The Advisory Board that includes donor, UN and NGO representatives, also advises the HC on policy issues and strategic direction for the fund. While the OCHA staff interviewed acknowledged the potential value of the proposed certification model, a cautionary note was sounded about linking certification directly to funding. This view was based on the past experience with using pre-selection processes for Pooled Fund allocations, something that was halted in 2010 since the process was found to be generating mistrust and competition between agencies. 18 Key findings: 1. Generally positive feedback on the model, but there is remaining questions about the practical implications of implementation. What is the business model for different disaster scenarios? 17 welcome 18 Spaak, M. and Mattsson, A. (2011) Evaluation of the Common Humanitarian Fund DRC Country Report 13

16 2. Certification-type processes, such as HACT and the Pooled Fund can provide useful examples on partner selection processes, both in terms of how the model should be structured, how it could complement these processes and general lessons learned in terms of implementing a certification system. Donor buy-in is critical to avoid this becoming a process that adds on, rather than eases, transaction costs. Trust-building will take time, however, and is likely to result in increased transaction costs during the start-up phase. 9. Alternative Criteria for the Model? One the questions asked during the consultations in DRC was how the model could be improved. One of the first key informants from a UN agency interviewed had spent a number of years in DRC and is frequently involved in selecting and reviewing implementing partners. He suggested the following alternative structure model using criteria based on lessons-learned: 1. Human Resources frequent staff turnover is a significant issue in eastern DRC and often has a direct impact on quality and accountability. When reviewing partners, it would was not only be important to look at what management in place but also at the capacity of agencies to fill staffing gaps. 2. Financial Management corruption is another serious undermining factor in the DRC context and, in order for a Certification Model to be trusted, financial management would need to be specifically addressed. 3. Quality Assurance/M&E what is the agency s capacity and track record in assessment, quality assurance, monitoring and evaluation? 4. Risk Management is there evidence that the agency has a track record of managing different types of risk? 5. Preparedness does the agency have surge capacity, standby stocks, preparedness training, reserve funding that would allow them to initiate a response? 6. Partnership and links with the government for international NGOs, are their relationships with the government and their local NGO partners building capacity while ensuring that minimum quality and accountability standards are maintained? This alternative model was subsequently tested along with the existing model during interviews. Most interviewees expressed a preference for the alternative structure since it: Was easier to see the division of responsibilities, notably in the case of program support staff who saw the current certification model as being designed for program staff and largely irrelevant to their own functions; More directly addressed issues that they faced in their own work. The current model was felt to be too abstract and difficult to apply to their day-to-day work; Had more chance of being eventually accepted by donor - something that was widely seen to be critical to the success of any certification model. The fear was that, with the current model, it wouldn t replace current processes but rather be an add-on. At the same time, it was felt that a number of the indicators could be retained along with the overall community-based accountability focus. Otherwise, it was feared that certification could end up being donor-driven. These observations will be shared with the team developing the Common Humanitarian Standard (CHS), as it may be relevant input to shape the structure of the next version of the standard. 10. Conclusions The field research findings are encouraging in the sense that NGOs (both international and national), government representatives, UN agencies and donor governments were all interested in the project 14

17 and saw the relevance of the model. This may be largely due to the model s attempt to show that the proposed requirements are closely aligned to what internal and external stakeholders already look for from NGOs. The general sense was that these were things that NGOs should be doing already and that, as long as it gained enough acceptance and didn t become an overly bureaucratic process, certification could help them focus on what is important. Feasibility of the model The field research findings largely validate the basic assumptions and main elements of the proposed draft model in a context like the DRC. As in other countries, the majority of stakeholders consulted saw advantages in certification and generally supported the model, but wondered about the practical difficulties of putting humanitarian certification into practice, and the tangible benefits that could eventually emerge for participating organisations. At the same time there were two main reservations expressed with the existing model which were felt to be serious flaws or potential gaps in the model: The second part of the draft Vision statement was largely accepted and validated. However, the first vision statement consistently elicited responses from field level staff (whether NGO, UN or donor) along the lines of utopian, nice concept but completely unrealistic, especially in fastmoving some suggested that communities would tend to go with the agencies they know, rather than make an informed comparison between agencies based on competencies and experience. Others felt that such an approach might drive agencies as a perverse incentive to focus on public relations, publicity and campaign promises without necessarily improving quality. This seemed to be also validated during discussions with community members, where the focus was much more on material assistance and what a community would receive potentially at the expense of genuine participation, dialogue and an understanding of what agencies are supposed to do. While the pillars were accepted in principal, most key informants felt they would need to be contextualized (sector, country) before they were of practical use. Although government health and education staff were quick to view the relevance of the model, community leaders and community members had difficulty in responding to questions about the certification model. It took a lot of explanation and descriptions of examples of NGO assistance before the conversation moved to a place that was more directly related to the certification model and its implications. Applying humanitarian principles in complex emergencies As in other complex emergencies, humanitarian actors are subject to constant challenges in providing principled humanitarian action in conflict-affected environments. In the DRC context, however, humanitarian actors tend to be much less of a target than the people themselves. While access continues to be a major issue, both for logistics (and cost) and insecurity, agencies also face challenges in adhering to principles of humanitarian action due to widespread corruption and difficulties in dealing with a fragmented and under-resourced government. Validation of internal quality assurance systems The assessment of CARE DRC s (and CARE International s) own internal systems indicates that they should be capable of providing evidence that they meet many of the proposed requirements of an external certification process. (A similar conclusion can be inferred from Oxfam and Caritas Congo, although the review process was less extensive and did not include field level verification.). However, management and leadership support are required, and introducing any new system, particularly an external system, may not have the same level of acceptance or success as one developed internally. This suggests that the draft model should consider validating internal quality assurance mechanisms like that of CARE International at different levels, rather than individually certifying each country operation, as this is likely to give more value added, both in terms of feasibility and in helping to 15

18 strengthen the agency s own systems. Comparing NGOs on an equitable basis Similar to the findings in the Pakistan case study, most NGOs do not have the same level of resources as CARE DRC has to develop and sustain quality assurance and accountability processes, particularly the national NGOs, which are highly dependent on project funding. This makes it somewhat unfair to compare compliance with a set of requirements, as many organisations would be at a disadvantage compared to larger or more experienced actors, although there appears to be recognition amongst national NGOs of the need for a minimum threshold. Similar to findings in the Pakistan case study, a possible solution is to revisit an earlier version of the model which proposed a different scale or requirements depending on the type of organisation a minimum set of requirements for all, but additional requirements for organisations that, for example, work internationally or that work mainly through partners. Such requirements could incorporate most of the agency s own selection criteria (to strengthen and complement the agency s selection processes, rather than be a parallel process), and include responsibilities in terms of building national capacities including supporting partners in achieving the minimum requirements. 11. Recommendations Suggestions and recommendations emerging from the DRC field research to contribute to improving the model and include: 1. Consider using similar objectives and indicators, but with an alternative structure for the model that is more familiar to humanitarian agencies and donors (see above suggested structure). Given the focus on disaster-affected communities, there also seems to be a need for a version of the model that can be more easily understood by this important stakeholder group. 2. Reduce duplication within the indicators and balance with more focus on program support indicators that directly affect the quality and accountability of the response. 3. To be realistic in humanitarian contexts, it will be important that the model accommodate a Good Enough approach, i.e. an approach that emphasizes simple and practical solutions. 4. Revise the first vision statement in the model to give a more realistic vision of participation of communities affected by disasters. 5. Additional field-testing is needed, but the model first needs to be adapted to be more relevant to field staff by, for example, contextualization by country and by sector. Referencing the agency s own policies and codes (as long as they meet minimum humanitarian standards) and providing a tool kit to help with implementation would also increase relevance. This could include: a) Develop protocols and tools based on the model(s) to better understand what certification would look like in practice. b) For future field tests, a user-friendly version of the model and separate interview guide should be developed for communities that are more relevant to this important stakeholder group. 19 c) Develop business cases for different disaster scenarios to help better understand potential costs and benefits. 19 Examples might be What is the best experience you ve had with an NGO and why? Would you prefer an agency that first asks you what you need and takes a bit more time, or agencies that give quickly without asking? 16

19 Annex 1 - List of Interviewees Kinshasa Oxfam Staff - Kinshasa 1 Joanne Trevor 19-May-14 Oxfam Programme Director 2 Jeanne Ndamaga 19-May-14 Oxfam Country Finance Director 3 Joseph Nindorera 19-May-14 Oxfam Head of Finance 4 Julva Lisandela Ngongo 19-May-14 Oxfam Funding Officer 5 Jean Bonheur Kongolo 20-May-14 Oxfam Policy Advocacy Advisor Other NGO Staff 1 Yawo Douvon 20-May-14 CARE Country Director 2 Dr Bruno MITEYO Nyenge 21-May-14 Caritas Congo Executive Secretary 3 Blaise Mbo 21-May-14 Caritas Congo Program Manager 4 Arésene Nlinga 21-May-14 Caritas Congo Program Manager 5 Christian Nsangamink 21-May-14 Caritas Congo Program Manager 6 Irene Mado Kubaki 21-May-14 Caritas Congo Program Manager 7 Emmanuel Mbuna 21-May-14 Caritas Congo Program Manager 8 Jean-Pierre Pokavu 21-May-14 Caritas Congo Project Officer A Focus Group Discussion was also held with Caritas Congo national programme managers and staff (40+ participants), 21-May International Government Donors 1 Alastair Burnett 20-May-14 DFID Humanitarian Advisor 2 Magali Carpy-Botoulou 21-May-14 ECHO Technical Officer 3 Jay Nash 22-May-14 USAID/OFDA Humanitarian Advisor UN Agencies 1 Moustapha Soumaré 20-May-14 OCHA Humanitarian Coordinator 2 Niels Stassyns 20-May-14 OCHA Humanitarian Advisor 3 Alain Decoux 20-May-14 OCHA Manager, CHF 4 Stefano Severe 21-May-14 UNHCR Regional Representative 5 Nona Zicherman 22-May-14 UNICEF Chief, Emergency & Transition Section North Kivu CARE Staff - Goma 1 Adolphe MUWAWA 10-Jun-14 CARE Monitoring & Evaluation Adviser 2 Marius Lipandasi 10-Jun-14 CARE Human Resources Manager 3 Joseph Nindorera 10-Jun-14 CARE Rubaya Project Manager 4 Abdoulaye Toure 10-Jun-14 CARE Program Quality Director 5 Marius Lipandasil 10-Jun-14 CARE Human Resources Manager 6 Monica Tucker 17-Jun-14 CARE Assistant Country Director (Program Support) 7 Papa Diop 18-Jun-14 CARE 8 Drocella Mundere 18-Jun-14 CARE Project Manager 9 Floerence Masika 18-Jun-14 CARE Gender & Equity Adviser 10 Teshite Jeldo 18-Jun-14 CARE Responsible Composante Engagement des Hommes / GEWEP 11 Ezechiel Cigoha 18-Jun-14 CARE Monitoring & Evaluation Officer 12 Francis Kasimu 18-Jun-14 CARE Chargé du Volet Psychosocial PASC/Ujio Wetu 17

20 13 Roseline Shombo 18-Jun-14 CARE M & E Officer PASC/Ujio Wetu 14 Fanny Mukendi 18-Jun-14 CARE Chef de Programme GEWEP 15 Hawa Kazi 16-Jun-14 CARE Responsible GEWEP 16 Julienne Efongo 16-Jun-14 CARE Procurement Officer 17 Crispin Kasongo 16-Jun-14 CARE Warehouse Manager 18 Alexander Lianye 16-Jun-14 CARE Procurement Office Kindu 19 Daniel Bilembo 16-Jun-14 CARE Fleet Manager 20 Faustin Uzinga 16-Jun-14 CARE Field Officer, Goma 21 Cynthia Katimbabo 16-Jun-14 CARE Administrative Officer 22 Fatouma Mahenga 16-Jun-14 CARE IT Officer Other NGO Staff 1 Emile Mputu MPANYA 12-Jun-14 LWF DRC Country Director 2 Nicola Pin 13-Jun-14 Oxfam Humanitarian Program Manager Belgique 3 Clovis Mwambatsu 13-Jun-14 Oxfam GB Provincial Coordinator, N. Kivu 4 Heather Kerr 17-Jun-14 Save the Country Director Children 5 Nicolas Coutin 17-Jun-14 World Vision Co-lead Protection Cluster 6 Petra Hoskovec 16-Jun-14 irc Provincial Director, North Kivu SCHR Certification Project Presentation/discussion at Heads of Agency Meeting in Goma on June 16 th with WFP, IOM, IRC, NRC, WVI, UNICEF, DRC, MSF (observers) and OCHA (chair) International Government Donors 1 Frédéric BONAMY 12-June-14 ECHO Goma Assistant Technique UN Agencies 1 Anne-France White 10-Jun-14 OCHA Goma Humanitarian Affairs Officer 2 Jean Metenier 12-June-14 UNICEF Head of Goma Office 3 Steven Michel 12-June-14 UNIC Emergency Specialist 4 Fafa Olivier Attidzah 17-June-14 EF UNHCR Head of Sub-Office 5 Philippe Martou 17-June-14 WFP Head of Area Office Community 1 Chef du Village 11-June-14 Kibabi, Chef du Village 2 Shiramber Unyaneza 11-June-14 Massisi Kibabi, Vice Secretaire CODESA 3 Harenimana Walengu 11-June-14 Massisi Kibabi, Health Committee (RECO) 4 Augustin Kapayana 11-June-14 Massisi Kibabi, Health Committee (RECO) Massisi 5 Hittmanea Rugarura 11-June-14 Bibihambo President Health Committee 6 Hittmanea Rugarura 11-June-14 Bibihambo President of Health Committee 7 Focus group of four women 11-June-14 Matanda Trainees in Centre Formation Professionelle Government Representatives/Local Authorities 1 Dr. Bonshi 11-June-14 Centre Sante Responsable Médicale 2 Jean Marie Vianner 11-June-14 Reference, Infirmier Titulaire Kibabi, 3 Thierry Kitambal 11-June-14 Administrateur Massisi 4 Bindu Nyota Anuaute 11-June-14 Bibihambo Infirmier Titulaire, Centre Sante 5 Blaise Mutumbi 11-June-14 Matanda Chef de Centre Formation Prof. 18