2013年-世界发展银行全球_Kenya_National_Safety_Net_Program_for_Results___Integrated_Fiduciary_Assessment_41页_1mb

Kenya National Safety Net Program for Results: Integrated Fiduciary Assessment Summary

Core Content

The Kenya National Safety Net Program for Results (NSNP) is a government initiative aimed at improving the welfare and resiliency of vulnerable and poor households through the coordination and harmonization of five main cash transfer programs:

• Older Persons Cash Transfer (OPCT)
• Cash Transfer for Orphans and Vulnerable Children (CT-OVC)
• Hunger Safety Net Programme (HSNP)
• Urban Food Subsidy Cash Transfer (UFS-CT)
• Persons with Severe Disability Cash Transfer (PWSD-CT)

The World Bank is supporting the NSNP with a US$250 million Program for Results (PforR) operation, designed to strengthen operational systems, expand coverage, and improve the effectiveness of cash transfers. The assessment focuses on the fiduciary performance and significant fiduciary risks of the program, particularly ensuring that the "right people are being paid the right amount at the right time."

Main Program Objectives

The NSNP aims to achieve the following objectives:

• Enroll the most vulnerable and poorest households.
• Ensure beneficiaries receive appropriate, reliable, and accessible payments.
• Enable citizens to appeal and complain to improve program performance.
• Ensure programs are responsive to shocks.
• Ensure a functioning monitoring and learning system.
• Harmonize the cash transfer sector and make it government-managed.

Key Fiduciary Risks

The assessment identifies three primary fiduciary risks:

1. Inaccurate or incomplete personal/household data at the point of targeting or application.
2. Delays or leakage in the payment of beneficiaries.
3. Failure to notify or act on changes in beneficiaries' circumstances.

These risks are linked to potential fraud and corruption, and the program's performance is assessed through Disbursement-Linked Indicators (DLIs). Each DLI has an allocated financing amount and an indicative timing of disbursement, as detailed in Table 5.1.

Financial Management (FM) Arrangements

Strengths

• Sector-wide planning and budgeting via Sector Working Groups (SWGs), the Medium-term Plan (MTP), and the Medium-term Expenditure Framework (MTEF).
• Computerization through the Integrated Financial Management Information System (IFMIS).
• Single registry development to share beneficiary information across all five programs, linked to the National Population Registration System (NPRS).
• Independent external audit by the Kenya National Audit Office (KENAO).
• FM capacity in the National Drought Management Authority (NDMA) is assessed as adequate.

Challenges

• Lack of ring-fenced resources for the administration, supervision, and monitoring of cash transfer activities.
• Inadequate internal audit coverage and limited use of risk-based auditing.
• Funds and cash flow management inefficiencies at the ministry and program levels.
• Insufficient procurement capacity in the Ministry of Gender, Children, and Social Development (MGCSD).

Procurement Management

The procurement process for the NSNP is governed by the Public Procurement & Disposal Act (PPDA) 2005 and its associated regulations. The Public Procurement Oversight Authority (PPOA) oversees procurement activities. Key considerations include:

• Procurement of payment service providers (PSPs).
• Procurement activities for operational purposes.
• Use of standard bidding and request for proposal (RFP) documents.
• Controls and integrity measures.
• Procurement capacity.
• Filing and recordkeeping.
• Contract management.
• Complaints handling mechanisms.

The MGCSD has limited capacity to manage procurement processes independently, and the current payment service provider (PSP) has shown inefficiencies. A full-time expert will be engaged to assist the MGCSD in selecting and supervising PSPs, with funding from a development partner.

Fraud and Corruption

Analysis

• The NSNP has strengths in fraud and corruption (F&C) prevention, including:
  • Local committees involved in vetting applications.
  • Public visibility of targeting mechanisms and transparency of beneficiary lists.
• The new MIS systems and single registry are expected to further strengthen F&C controls.
• The National Drought and Disaster Contingency Fund (NDDCF) will be managed by a Board of Trustees, including independent members, to ensure oversight and accountability.

Mitigation Measures

• Sharing of F&C complaints with the World Bank through the Social Protection Secretariat.
• Exclusion of debarred or suspended firms from NSNP procurement.
• Investigation of F&C allegations by the World Bank's Integrity Vice Presidency (INT).
• Annual audit of the NSNP financial statements by KENAO, with public reporting.

Institutional Arrangements

• The NSNP is managed by the MGCSD and the MSDNKAL.
• The NDMA, a state corporation under the MSDNKAL, manages the Hunger Safety Net Programme (HSNP), which is implemented by NGOs.
• The NDDCF is a Trust Fund under the Ministry of Finance, with a Board of Trustees overseeing its operations.
• The IFMIS and program-specific MIS systems are being developed to improve transparency and accountability.
• The PFM reform strategy (2012-2017) includes strengthening the Integrated Financial Management Information System (IFMIS) and enhancing legal and institutional frameworks.

Mitigation Measures

The Program Action Plan includes the following mitigation measures:

• Capacity building in financial management and procurement.
• Improvement of MIS systems and single registry.
• Two-factor authentication for electronic payments.
• Performance standards for timely delivery of transfers.
• Complaints and grievance mechanisms to be strengthened and integrated into MIS systems.

These measures are reinforced by disbursement-linked indicators (DLIs), which are monitored throughout the program's implementation.

Conclusion

The overall fiduciary risk for the NSNP is assessed as substantial, but the PFM system and program-specific mitigation measures are considered adequate to support the operation. The Bank and the GoK are working closely to ensure transparency, accountability, and participation in the NSNP, with the goal of long-term sustainability and effective delivery of safety net support to vulnerable populations.