Response to the ICAI consultation

ICAI launched a consultation on its work programme at the end of July, with a deadline of 21. September. I thought it might be useful to share my own contribution, partly in the hope that it might stimulate others to respond. ICAI’s brief for the consultation is pasted in at the end.

I have commented extensively on ICAI’s mandate, work programme and findings, most recently here, with six questions for the future of ICAI, viz:

1. Does ICAI accept the recommendation of the Cabinet Office Review of 2013, that it should focus less on routine scrutiny of spending and more on exploring high-level development issues?
2. If so, what are those issues?
3. How exactly does ICAI differentiate itself from the NAO and DFID’s own evaluation programme? Are the boundaries right?
4. What exactly is ICAI’s ‘method’?
5. How should ICAI approach lesson-learning and synthesis?
6. How can ICAI best support the IDC?

With reference to the first question, a key issue for ICAI is not to fall into the aid trap and limit the mandate to ODAOverseas Development Assistance spending. The consultation document shows signs of doing exactly that, in the opening paragraph, the description of the themes (including one described hopefully as ‘Beyond Aid’ but actually focused on ODA), and in the description of core issues. Perhaps this is a clever and subtle framing, to allow policy issues in by the back door, but at first sight it looks like a real missed opportunity. In my view, the new ICAI needs to be robust right from the beginning about how its remit is to be interpreted. Otherwise, there will be push-back whenever non-spending issues are raised.

The list of themes is odd, and at odds with DFID’s own description of its likely future priorities (see Justine Greening’s keynote speech on 3 July 2015). The main problem is that the Beyond Aid category (a) refers to ODA, and (b) contains a mixture of issues. Why not call this category ‘Economic development’, which would have the advantage of relating to DFIDDepartment for International Development priorities, but would also cover some of the other topics, like trade and taxation? It would then become obvious that there are some issues missing, including public spending, infrastructure, industrial policy, innovation, employment, cities, food security, and so on. I recommend a systematic cross-checking between the DFIDDepartment for International Development Results Framework and the Greening speech, on the one hand, and the ICAI themes on the other, to make sure all likely HMGHer Majesty's Goverment priorities feature.

This would then leave a problem with what to do with Beyond Aid. One suggestion is to make non-aid implications one of the core issues that will be covered in every report. A paragraph in the Introduction would provide a hook for this.

Some other changes would also be useful in the list of ‘core issues’ to reflect the strategic choices and dilemmas facing DFID, and which will become apparent in the BAR and MAR, as well as the strategic review. I would like to suggest that core issues include explicit attention to:

• Comparators, so that a core issue could be ‘whether HMGHer Majesty's Goverment is performing well compared to other international actors’;
• The appropriate choice between bilateral and multilateral channels with respect to particular initiatives, programme and projects;
• Policy content, including the contribution of DFID’s policy teams;
• The contribution and quality of DFID’s own evaluation work;
• The implications for DFID’s results framework; and
• Policy implications of the analysis.

In terms of a specific work programme, this will need to be negotiated with the IDC. There will need to be a judicious balance of country, sector and thematic studies. However, some good topics would be:

• HMG’s contribution to the design of the Sustainable Development Goals;
• The effectiveness of the UK’s climate diplomacy;
• The mainstreaming of climate change in country programmes;
• Follow-up to G8Group of Eight commitments on tax;
• DFID’s evaluation effort;
• Political conditionality in the context of human rights violations (with specific reference to countries like Ethiopia and Rwanda);
• DFID capacity and spending on infrastructure;
• Graduation strategies for non-LLDCs;
• Returnable capital, including commitments to CDC;
• The postponed enquiry on CDC;
• More generally, a review of DFIDDepartment for International Development engagement with different DFIs (including CDC, EIB, IFC etc . . .);
• The effectiveness in terms of the UK of global anti-corruption legislation and measures;
• Debt sustainability;
• Resilience to global shocks (finance, food, fuel, disease) and DFIDDepartment for International Development support to policy and fiscal space;
• DFID policy influence in Europe;
• Migration and development;
• Of course, the BAR and MAR themselves, and more generally, DFID’s country choices.

This could obviously be a long list! A key lesson learned from work with the IDCInternational Development Committee is that a matrix approach is useful, in which country studies (which can be thought of as rows) cover a number of topics (which can be thought of as columns. This may have implications for the sequencing and size of reports. For example, a series of short country reports could all contribute to one or more longer thematic reports. It is important to treat the work programme as a single whole.

Finally, ICAI can greatly improve its reporting and lesson-learning. A strong Annual Report is a sine qua non, but more lesson-learning briefs that abstract from reports would certainly be useful.

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ICAI’s brief for the consultation:

Consultation on ICAI Work Plan

Published: 23rd July 2015

The Independent Commission for Aid Impact (ICAI) has opened a consultation on its future work plan.

ICAI scrutinises UK aid spending. We work to ensure UK aid is spent effectively for those who need it most and delivers value for UK tax payers. We report to the International Development Committee of the UK parliament. Our mandate covers all UK Official Development Assistance (ODA), including the work of the Department for International Development (DFID) and ODAOverseas Development Assistance spent by other UK government departments.

We plan to put in place a rolling work plan of between six and eight reviews each year. Reviews will cover a broad cross-section of UK development programmes, with particular emphasis on subjects that will tell us most about development impact and value for money, and are of interest to parliament and the public.

Our work plan will draw on four broad themes. These themes reflect the challenges and priorities facing the UK development effort and provide us with a framework for selecting and prioritising our work and, over time, sharing lessons across individual reviews. Alongside these themes, we will retain some capacity to undertake ad hoc reports on specific issues of interest or concern to key stakeholders.

Our themes

Transparency, Accountability, and Empowerment: covering areas such as governance, political participation, tackling corruption, women’s empowerment and promoting human rights.

Humanitarian Crises, Building Resilience, and Stability: covering areas such as emergencies, protracted crises, post-conflict stabilisation, adaptation and resilience.

Leaving No One Behind: covering areas such as tackling extreme poverty, vulnerability, promoting equity, youth and inclusion.

Beyond Aid: covering non-traditional forms of ODAOverseas Development Assistance such as trade, migration, economic development, taxation, private sector, and climate change.

All reviews will need to consider some core issues irrespective of theme, and we will investigate these as appropriate:

Our core issues

• Approaches to financial and risk management;
• Approaches to programme delivery, monitoring and evaluation;
• Cross-government working;
• Working with and through partners;
• Gender and equality; and
• The quality of evidence and its use in enhancing development impact.

Source: http://icai.independent.gov.uk/2015/07/23/consultation-on-icai-work-plan/

Image: http://www.shapard.com/wp-content/uploads/2012/08/megaphone.jpg.