of funding to partner country governments as prime partners has remained relatively stable over time.

As described in this part of the chapter, which focused on PEPFAR funding levels and distribution, the committee aimed to come to a full understanding of the amount and distribution of the annual direct investment of PEPFAR in partner countries, which is a critical input to assess in order to understand the performance of the program. However, limitations in the available financial data made this very difficult. In particular, there are limitations to understanding the amount and distribution of funds outlaid on an annual basis, with data only readily available for annual congressional appropriations and cumulative obligations and outlays. Furthermore, these data are not available disaggregated by type of activity or by type of partner. Thus, the committee used data on what was planned/approved in annual budgets to look at how PEPFAR funding is distributed at the country, program, and partner levels. Even within this planned/approved funding, there are limitations to matching the data in the reported budget codes to the program’s activities, and data are limited on the types of partners that ultimately receive the funding.

Until recently, OGAC has been unable to track and assess how PEPFAR funds have moved from congressional appropriations to OGAC to the implementing agencies to prime partners to subcontractors, because USG implementing agencies were not required to report on expenditures at all levels of the program (Donnelly, 2012b). In May 2012 OGAC requested approval from the U.S. Office of Management and Budget (OMB) to require all partners receiving PEPFAR funding to report annual program expenditures using an electronic template (60-Day Notice, 2012). It is important to note, however, that while this will improve the availability of useful financial data, requiring more financial reporting may also create additional reporting burden for partners and country teams (NCV-4-USACA). OGAC initially estimated that recipients of PEPFAR funding would need an average of 12 hours each year to comply with the new reporting requirements, but based on public comments received during the Paperwork Reduction Act approval process, the average burden estimate was increased to 24 hours (30-Day Notice, 2012; 60-Day Notice, 2012). The estimate was calculated by surveying diverse partners that participated in pilot expenditure analyses from 2009 to 2011 and taking an average of the responses; OGAC has noted that the time will vary considerably depending on the size of partners and the portfolio of programs they implement (OGAC, 2013b). OGAC anticipates the burden to be reduced over time as partners familiarize themselves with the data collection process. The current estimate of 24 hours will be reassessed in 2014, 2 years after OMB’s approval of the reporting form in November 2012. The reassessment will account for improvements

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