Ukraine: State and USAID Should Improve Processes for Ensuring Partners Can Perform Required Work
Fast Facts
Congress appropriated more than $174 billion to support Ukraine since the start of the war. State and the U.S. Agency for International Development awarded a portion of this for humanitarian and development projects supporting Ukraine's needs. These funds went to 111 partners in 197 awards.
We looked at how the agencies (1) screened potential partners' past performance before awarding funds and (2) monitored their partners' screening of sub-partners—e.g., contractors—in 28 of the awards. We found weaknesses in some processes State and USAID used, but USAID's processes were more robust.
Our recommendations address issues we found.
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Highlights
What GAO Found
From the start of Russia's invasion of Ukraine through September 30, 2023, the Department of State and the U.S. Agency for International Development (USAID) had 111 implementing partners carrying out 197 awards that GAO defined as for Ukraine non-security assistance. About 80 percent of these partners were nongovernmental organizations (NGO), with U.S. NGOs implementing the largest number of these awards. Almost 70 percent of their 2,400 sub-partners were Ukrainian organizations with 36 sub-partners having also been primary implementing partners for Ukraine non-security assistance since the invasion.
State and USAID Implementing Partners by Category of Organization
For 26 of the 28 awards GAO reviewed in-depth, State and USAID reviewed potential partners' past performance. For the two awards GAO reviewed that were a certain type of agreement with international organizations, State did not screen for past performance. State policy does not require this screening. As a result, State has a higher risk of selecting partners for this type of agreement that may be excluded by the U.S. government from receiving an award or may not perform well in carrying out the needed assistance. For USAID's awards in the sample, USAID officials documented detailed information about applicants' past performance. In contrast, State did not record this level of detail because State does not require such detail to be documented. Detailed documentation could help other State officials understand the risks of using these partners to implement non-security assistance now and in the future.
While USAID routinely monitors its NGO implementing partners' screening of their sub-partners for past performance, it does not perform this monitoring for its international organization partners and State does not perform this monitoring for either type of partner. Without periodic monitoring of implementation, the agencies risk that partners may not have effectively screened sub-partners to help ensure they can implement assistance effectively.
Two USAID bureaus and many implementing partners reported challenges obtaining qualified partners to implement non-security assistance. According to the 106 respondents to GAO's survey of implementing partner representatives, challenges included obtaining sub-partners with human resource capacity and expertise in humanitarian assistance. Implementing partners experienced issues resulting from these challenges, such as a reduced ability to provide assistance in certain geographic areas. Survey respondents identified actions they have taken to address the challenges, such as building the capacity of sub-partners through training or guidance.
Why GAO Did This Study
Russia's invasion of Ukraine in February 2022 led to a significant humanitarian crisis. State and USAID have obligated at least $5.2 billion to support selected non-security humanitarian, stabilization, and development assistance in Ukraine and neighboring countries. Implementing partners play a key role in executing this assistance. State and USAID aim to select high performing partners to help ensure they perform the work required.
GAO was asked to review the agencies' use of partners since the invasion. This report examines (1) key characteristics of these partners, (2) agency reviews of past performance when selecting implementing partners, (3) agency monitoring of implementing partners' screening of sub-partners' past performance, and (4) any challenges agencies and implementing partners had obtaining partners.
GAO analyzed data for all 197 State and USAID awards, and reviewed award and past performance documents for a nongeneralizable sample of 28 of these awards against agency policy and internal control standards. GAO also surveyed partner representatives, conducted field work in Poland; and interviewed officials.
Recommendations
GAO is making five recommendations, including for State to screen all international organization partners for past performance, for State to improve its documentation of past performance reviews, and for State and USAID to monitor partners' screening of sub-partners for past performance. State and USAID concurred.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of State | The Secretary of State should ensure that the Bureau of Administration, Office of the Procurement Executive establish a requirement in the Federal Assistance Directive for State award officials to conduct a verification search in the System for Award Management and screen international organizations for past performance and exclusions when selecting them for Circular-175 letters of agreement. (Recommendation 1) |
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
|
| Department of State | The Secretary of State should ensure that the Bureau of Administration, Office of the Procurement Executive require award officials to include in the award file detailed documentation of the sources and assessments of past performance information that inform officials' decisions prior to approving implementing partners for awards. (Recommendation 2) |
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
|
| Department of State | The Secretary of State should ensure that the Bureau of Administration, Office of the Procurement Executive establish a requirement in the Federal Assistance Directive for State award officials to periodically monitor the implementation of non-governmental organization implementing partners' procedures for screening sub-partners for past performance when selecting them for sub-awards. (Recommendation 3) |
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
|
| Department of State | The Secretary of State should ensure that the Bureau of Administration, Office of the Procurement Executive establish a requirement in the Federal Assistance Directive for State award officials to periodically monitor the implementation of international organization implementing partners' procedures for screening sub-partners for past performance when selecting them for sub-awards. (Recommendation 4) |
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
|
| U.S. Agency for International Development | The Administrator of USAID should ensure that the Office of the General Counsel and the Bureau for Planning, Learning, and Resource Management establish a requirement in USAID's operational policy for USAID award officials to periodically monitor the implementation of public international organization implementing partners' procedures for screening sub-partners for past performance when selecting them for sub-awards. (Recommendation 5) |
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
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