Standard 15: Engaging donors appropriately throughout implementation.
Engage with donors throughout project implementation to ensure accountability and compliance and to strengthen donor relationships.
Ensure that regular program, finance and other operations compliance checks are conducted throughout the project lifespan.
Regular monitoring of a project’s compliance with program, finance, and other operations requirements is a fundamental part of effective project management. It is also crucial to project stewardship and donor accountability. Regular compliance monitoring throughout project implementation:
- Provides key information for project team decision-making.
- Reinforces accountability for project progress and adherence to donor regulations.
- Builds CRS credibility and relationship with the donor.
- Facilitates project close-out by ensuring that the project team complies with requirements and identifies and addresses compliance issues throughout project implementation.
- Primary responsible: Project manager or chief of party (PM/CoP)
- The PM/CoP leads the planning and implementation of program, financial, supply chain, and other operations monitoring, in close coordination with any project/country program risk and compliance staff.
- Others involved: Project/country program risk and compliance staff (if part of project/country program staffing); finance manager (FM); head of operations (HoOps); head of programming (HoP); MEAL staff; supply chain management staff; other programming and operations staff (e.g. project officers); IDEA staff for centrally-funded projects; global and regional risk and compliance staff; partner leadership and project staff
- Country program risk and compliance staff (in country programs/projects where this position exists), the FM, HoOps, MEAL and supply chain management staff conduct or lead the monitoring activities with support from the HoOps, HoP and other programming and operations staff as necessary.
- For centrally-funded projects, IDEA staff help clarify donor compliance requirementsFor USG centrally-signed awards, project support staff typically prepare an “Award Brief” during project start-up which highlights key compliance requirements. and support communication with the donor around compliance issues, as needed.
- Global and regional risk and compliance staff provide guidance and technical assistance as needed.
- Partner project staff and leadership assist with monitoring.
Continually, as per the project detailed implementation planAs highlighted in Standard 7, key action 4, project MEAL plans are integrated into the project DIP. and supply chain management plans as well as the sub-recipient financial management policy (SRFMP), CRS MEAL policies and procedures,Projects of at least US$1 million in value and at least one year in duration must complete an annual self-assessment against CRS MEAL procedures (typically in quarter 4 of CRS’ fiscal year); an annual MEAL procedures self-assessment is good practice for other projects and emergency responses. project reporting cycles, and donor regulations as stipulated in the project agreement.Update the compliance monitoring plan as needed after any award modification.
This key action builds on the start-up key action of reviewing donor requirements and orienting project staff to the same.
Follow these steps to ensure that the appropriate staff conduct regular checks to ensure project compliance with CRS and donor programmatic, financial, and other operations requirements:
Tailor compliance monitoring to donor requirements and project and partner realities: While many compliance monitoring activities will look quite similar across different projects, different donors have different requirements and each project is unique. With support from risk and compliance colleagues (and IDEA staff for centrally-managed donor relationships) and building on efforts earlier in the project management cycle,For example, the agreement review process (see Standard 8, key action 1 and Standard 10, key action 1); partner capacity assessments (Standard 6, key action 4); the updated operating context review that takes place during project validation (Standard 7, key action 1); start-up workshop discussions on aspects of the project that may be particularly challenging from a programming, financial management, and/or operations perspective (Standard 10, key action 2), as well as regular project risk and issue monitoring/management (Standard 11, key action 2). the PM/CoP leads the CRS and partner project team in continuously reviewing and reflecting on donor compliance requirements, the project-specific risks associated with meeting those requirements, and the project team’s progress with respect to compliance. In some cases, CRS may decide to conduct project compliance checks more frequently than required by the donor due to the identification of specific institutional or operating context risks that require closer monitoring.
- The PM/CoP follows up with programming and operations staff throughout project implementation to ensure that the proper compliance checks are occurring per CRS policy and donor requirements and according to the schedule in the project detailed implementation plan (DIP), with additional checks conducted at other times as needed.
Finance compliance checks
- Based on information from the sub-recipient financial management assessment (see Standard 8, key action 2) and any other information about areas of risk in partner financial management capacity, the PM/CoP, risk and compliance staff (if part of project/country program staffing), FM, and HoOps coordinate appropriate monitoring of partner compliance with the financial terms and conditions of the award (see also Standard 13, key action 3).
- During CRS’ review of required audits or program and finance team review of partner liquidations, the PM/CoP and finance staff may identify additional areas for financial compliance monitoring. In such cases, the PM/CoP, finance staff, HoOps, and risk and compliance staff discuss these concerns and adjust monitoring plans accordingly.
Program compliance checks
- The PM/CoP ensures proper planning and execution of the following implementation-phase checks which are critical to program quality and adherence to CRS’ MEAL policies and procedures (MPP) and any donor MEAL requirements (see the Donor MEAL Checklist Template and MPP 7.1Procedure 7.1: Integrate donor MEAL requirements into the MEAL system and check on compliance during implementation.
- Visits by members of the CRS project team to field sites at least quarterly, to verify that implementation of project activities is in line with the approved project design, agreed adaptations to the design, and project implementation plans (MPP 2.1)Procedure 2.1: Conduct quarterly field visits to observe anticipated and unanticipated changes, communicate with community members, and conduct routine data quality assurance checks.
- Quarterly meetings of the CRS and partner project team to jointly analyze and reflect on monitoring data, per MPP 2.4Procedure 2.4: Reflect on a quarterly basis with partners on monitoring data and community feedback, to inform ongoing and adaptive decision-making and action planning. and CRS project management standard 11.
- MEAL advisor review of evaluation TORs and (as applicable) research protocols (MPPs 3.3, 3.4, and 3.7)Procedure 3.3: Regional MEAL advisors review baseline and evaluation ToRs to improve evaluation quality and ensure appropriateness to information needs.
Procedure 3.4: Conduct a midterm review or evaluation as appropriate to the project scope and information needs.
Procedure 3.7: Reflect on evaluation findings with partners and other stakeholders to generate appropriate recommendations and inform agency learning.
- In addition to the MEAL-focused compliance activities above, the PM/CoP works with the CRS and partner project team to conduct an annual project self-assessmentProjects of at least US$1 million in value and at least one year in duration must complete an annual self-assessment against CRS MEAL procedures (typically in quarter 4 of CRS’ fiscal year); an annual MEAL procedures self-assessment is good practice for other projects and emergency responses. against CRS’ MEAL procedures. The PM/CoP ensures that the project team develops a MEAL improvement action plan based on self-assessment results, to further strengthen quality in CRS’ adherence to the MPPs.
- The PM/CoP and CRS and partner project team use regular project meetings (e.g. quarterly and annual project review and planning meetings) (Standard 11, key action 4) to review the status of the actions in the MEAL improvement action plan.
- The CRS project team follows up on other programming compliance issues relevant to the project and operating context. These may include targeting/beneficiary selection; disaggregation of project data; anti-trafficking and other protection issues; and other donor-specific requirementsFor example, the “Protecting Life in Global Health Assistance Policy” which applies to USG-funded health programs.
Other operations compliance checks (including supply chain management)
- The PM/CoP and operations staff carry out operations compliance monitoring activities per agreed plans (for additional details on supply chain monitoring, see Standard 12, key action 2).
- Pay special attention to monitoring potentially challenging operations compliance issues identified during the project start-up workshop review of compliance requirements.
- Ensure regular checks of systems to ensure compliance with requirements for procuring project goods and services --for example, some donor sourcing requirements restrict potential suppliers to a set list.
- For projects which include the procurement, transport, storage, and distribution of project goods, ensure proper supply chain management checks through appropriate Distribution Verification Monitoring (DVM) and Post-Distribution Monitoring (PDM) systems (see the Supply Chain Management Handbook, Chapter 12 for guidance).
- The PM/CoP and project staff adjust project plans for compliance checks based on information from internal or external project reviews, evaluations, or audits; technical assistance and other monitoring visits; and ongoing monitoring of the internal and external project operating context as part of regular project risk and issue management (see Standard 11, key actions 2 and 4).
Compliance and staff turnover: Turnover among project staff, whether at CRS or partner level, can present a compliance risk. In such situations, ensure that new staff involved in conducting compliance checks are properly oriented to key compliance issues and requirements specific to the project. Consider increasing the frequency of compliance checks until the staffing situation has stabilized.
- If any donor regulations change and/or if the donor modifies the award, the PM/CoP, IDEA staff (as applicable), compliance and risk staff (country program, regional, and HQ) and others (including senior management as needed) discuss:
- The implications, if any, of these changes on project compliance processes and systems, including plans for compliance checks.
- Any orientation and training needed for CRS and partner staff to ensure their understanding of and ability to comply with the changes.
- If CRS staff identify critical risks or issues requiring higher-level discussion and follow-up while conducting project compliance checks, the PM/CoP escalates these issues and risks to senior management, country program, regional, and headquarters risk and compliance staff, IDEA staff (as applicable), and members of the project governance structureA project governance structure is a group of individuals that provides support for a project and is accountable for enabling project success. A project governance structure may consist of a small group of senior leaders for a smaller, less complex project, or a larger project board for a complex, multi-partner project. as appropriate.
- See Standard 11, key action 2 for guidance on internal escalation of critical risks and issues.
- See Standard 15, key action 2 for guidance on engaging donors around project risks and issues.
When CRS is a sub-recipient
- Given partners’ key role in project implementation and project resource management, much of project compliance monitoring will involve partners. There can be many sensitivities and misunderstandings around compliance monitoring. Good practice is to discuss the reason for the monitoring with partners well in advanceThis should begin during project design, as part of CRS and (prospective) partner discussions around an external funding opportunity and the anticipated donor requirements (see Standard 1, key action 2); when deciding on partner sub-award types (see Standard 3, key action 3); and when designing project management structures to support compliance with donor requirements (see Standard 2, key action 2). During the start-up phase, CRS and partners should also review partner-specific compliance monitoring during finalization of partner sub-agreements as part of early project start-up; during partner capacity assessment (see Standard 6, key action 4); and when reviewing project requirements and strategies for compliance monitoring as part of the start-up workshop (see Standard 10, key action 2 for guidance for the project start-up workshop). of the actual compliance monitoring visits. Reiterate the reasons for compliance monitoring throughout implementation, particularly when there are transitions in the partner project team or organizational leadership. If CRS or donor compliance monitoring requirements change during the project period, take the time to review the change and the reasons for it with partner staff and leadership. Engage CRS senior leadership in these discussions as needed and seek support from partnership and capacity strengthening specialists as appropriate (see also Standard 11, key action 5, for additional guidance and resources on proactive partner relationship management).
- While CRS should reserve the right to conduct spot checks at partner level if needed, it is good practice to jointly develop and update a compliance monitoring schedule with partner as part of detailed implementation planning and MEAL system development and regular review of DIP and MEAL plans. This includes requesting partner inputs on the timing of regular visits by CRS finance staff (if applicable) as part of SRFMP compliance.
- Use CRS and partner quarterly and annual project review and planning meetings as an opportunity to discuss overarching compliance issues and challenges and to identify ways to improve project compliance. These meetings should include a review of improvements in project MEAL compliance, per the MEAL improvements action plan developed following the annual project self-assessment against CRS' MEAL procedures.Projects of at least US$1 million in value and at least one year in duration must complete an annual self-assessment against CRS MEAL procedures; an annual MEAL procedures self-assessment is good practice for other projects and emergency responses. Discuss partner-specific compliance issues and challenges in individual meetings.
- Follow the same procedure when CRS is a sub-recipient, though note that some CRS MEAL procedures are not required when CRS is a sub-recipient.
- Telescope the guidance above as appropriate per CRS and donor policy.
- The fluid, fast-paced environment of emergency projects and in some cases practical constraints like limited physical access to partners and project sites can present challenges for frequent compliance checks. CRS and partners must find appropriate ways to ensure adequate compliance checks precisely because of the challenges and additional vulnerabilities and risks inherent in emergency response. Seek advice from the HoOps and risk and compliance staff.
- In the case of emergency responses funded by multiple donors with different compliance requirements, seek advice from the HoOps and regional or global risk and compliance staff on the most effective approaches to compliance monitoring, and options for streamlining the same (engage IDEA staff as applicable).
- Refer to the Emergency Field Operations Manual procurement section for minimum standards and requirements for working in emergency situations.
- If you are working on a large-scale emergency where several Caritas Internationalis (CI) Members are responding and/or supporting a response of the national Caritas, please refer to the Protocol for CI Coordination in Emergency Response, Emergency Framework and Toolkit for Emergency Response documents on the CI Baobab website. These documents provide guidance on coordination and the process of developing, implementing, monitoring and reporting on an Emergency Appeal for funding via the CI Network. If you are not registered on the CI Baobab site, please register here.When registering for the CI Baobab site, CRS staff should select "Caritas United States - CRS" as their organization and list the Humanitarian Response Department and email@example.com as the reference contact. If you have any questions, please contact CRS’ Humanitarian Response Department (firstname.lastname@example.org).
Tools and templates
Donor MEAL Checklist Template (from CRS' MEAL Policies and Procedures site)
Policies and procedures
GKIM-Records Management-001: CRS Records Management Policy
Patriot Act Eligibility Verification (PAEV) Procedure (as distributed, confidential)
POL-FIN-SRFM-023: Subrecipient Financial Management Policy
POL-OOD-PRG-008: MEAL Policies & Procedures
PRO-OOD-PIQA-001 Protection Policy Rollout to Partners Procedure
PRO-OOD-RSK-001: Fraud Allegation Management Procedure
PRO-OOD-SUB-001: Non-U.S. USAID Subrecipient Audits Procedure
PRO-OOD-SUB-001: US government sub-recipient audits procedure
PRO-OSD-GEN-015: FFATA Reporting Procedure
Emergency Field Operations Manual (procurement section)
MEAL Policies and Procedures site, resources for policy 2 on project monitoring, procedures 2.1, 2.2, 2.4, and 7.1 Procedure 2.1: Conduct quarterly field visits to observe anticipated and unanticipated changes, communicate with community members, and conduct routine data quality assurance checks.
Procedure 2.2: Conduct annual data quality assessments to identify and address data quality issues.
Procedure 2.4: Reflect on a quarterly basis with partners on monitoring data and community feedback, to inform ongoing and adaptive decision-making and action planning.
Procedure 7.1: Integrate donor MEAL requirements into the MEAL system and check on compliance during implementation.
Supply Chain Management Handbook, Chapter 12, Supply Chain Monitoring
- Primary responsible: Project manager or chief of party (PM/CoP)