Tuesday, March 22, 2011

A submission to the UK Independent Commission for Aid Impact (ICAI)

"ICAI is holding a public consultation to understand which areas of UK overseas aid stakeholder groups and the public believe the Commission should report on in its first three years. The consultation will run for 12 weeks from the 14th January until the 7th April 2011.
Click here to respond to the consultation
If you would like to read further information on ICAI, the consultation and the aid budget, please click on Consultation document.
If you would like to consider the questions in detail before responding, please click on Downloadable questions. You will need to access the online response form to respond".
Two initial comments:

1. An online survey is a fairly narrow approach to a public consultation. There are many other options, even if the ICAI is limited to those that can take place online, rather than face to face

2. The focus of the consultation is also narrow, i.e. "which areas of UK overseas aid stakeholder groups and the public believe the Commission should report on in its first three years". Equally important is how those areas of aid should be reported on.

On widening the process of consultation

1. All pages on the ICAI website should have associated Comment facilities, which visitors can make use of. More and more websites are being constructed with blog-type features such as these, because website managers these days expect to be interacting with their audience, not simply broadcasting. Built into such a facilitwould be an assumption that there will be an ongoing process of consultation, not a once off event.

2. The raw data results of the current online survey should be made publicly available, not just summaries. This is already possible, with minimal extra work required, because the survey provider (SurveyMonkey.com) is able to provide a public link to the survey results, with multiple options regarding reading, filtering and downloading the data. The more people who can access the data, the more value that might be obtained from it.  However, the most important reason for doing so is that the ICAI should be seen to be maximally transparent in its operations. Transparency will help build trust and confidence in the work and judgements of the commission.

3. Although late in the day, the ICAI should edit the Consultation page to include an invitation to people to submit their own submissions using their own words and structures.

4. The ICAI website should include an option for visitors to sign up for email notification of any changes to the website, including the main content pages and any comments made on those pages by visitors.

5. The ICAI should be open about what it will be open about. It should develop a policy on transparency and place that policy on its website. Disclosure policies are now commonplace for many large international organisations like the World Bank and IMF, and transparency in regard to international aid is high on the agenda of many governments, including the UK. Having such a policy does mean everything about the workings of the ICAI must be made public, but it would typically require a default assumption of openness along with specified procedures and conditions relating to when and where information will not be disclosed.

On widening the content of consultation

 1. The ICAI should be aware, if not already, that there continues to be intense debate about the best ways of assessing the value of international aid. This debate exists because of the  multiplicity of purposes behind aid programs, many and varied types of aid, the enormous diversity of contexts where it is provided, the wide range of people and organisations involved in its delivery, as well as some genuinely difficult issues of measurement and analysis. There are no simple and universally applicable solutions. Value for Money provides only a partial view of aid impact, and is only partially measurable. Randomise Control Trials (RCTs) can be useful for simple replicable interventions in comparable conditions, but many aid interventions are complex. The best immediate response in these circumstances is for the ICAI to be maximally transparent about the methods being used to assess aid interventions, and to be open to the wider debate.

A good starting point would be for the ICAI to make public: (a) the Terms of Reference for the "Contracted Out Service Provider" who will do the assessment work for the ICAI, and (b) the tendered proposal put forward by the winning bidder. Both of these documents refer to ways and means of doing the required work. It is also expected that there will be periodic reviews of the work of the winning bidder. The ToRs and reports of those reviews should also be publicly disclosed on the ICAI website. Finally, all the  "evaluations, reviews and investigations" to be carried out by the winning bidder on behalf of the ICAI should be publicly disclosed, as hopefully has already been agreed.

2. It would be useful, if only to help ensure that the ICAI itself delivers Value for Money", if the ICAI could clarify not only how its role will differ from that of the DFID Evaluation Department and multi-agency initiatives like 3IE, but also how it will cooperate with them to exploit any complementarities and possible synergies in their work.Complete and utter independence could lead to wasteful duplication. In the worst case various wheels could be reinvented. 

For example, the OECD's Development Assistance Committee (DAC) has over the years developed a widely agree set of evaluation criteria, however these are nowhere to be seen in the ICAI's ToR for the "Contracted Out Service Provider". Instead, Value For Money receives repeated attention, and its definition is sourced to the National Audit Office (NAO). However, the NAO is a member of the Improvement Network, which has provided a wider perspective on Value for Money. Their website notes that effectiveness is part of Value for Money, as well as efficiency and economy. Commenting on effectiveness they note:
"Effectiveness is a measure of the impact that has been achieved, which can be either quantitative or qualitative....Outcomes should be equitable across communities, so effectiveness measures should include aspects of equity, as well as quality. Sustainability is also an increasingly important aspect of effectiveness."
Sustainability is a DAC evaluation criteria which has been around for a decade or more.
A link to this blog posting has been emailed to c-robathan@icai.independent.gov.uk.
Other readers of this blog might like to do the same, with their own views.

PS: See Alex Jacob's March 22nd submission to the ICAI: Advice for the new aid watchdog