OGAC should also look to other organizations with wide geographic reach and organizational complexity, such as multi-country PEPFAR implementing partners, other large global health initiatives, and global corporations, for models of successful knowledge transfer systems.

•    OGAC should develop a policy for data sharing and transparency that facilitates timely access to PEPFAR-created knowledge for analysis and evaluation. The purpose of this policy would be to ensure that, within a purposefully and reasonably defined scope, specified program monitoring data and financial data, evaluation outcomes, and research data and results generated with PEPFAR support by contractors, grantees, mission teams, and U.S. Government (USG) agencies be made available to the public, research community, and other external stakeholders. OGAC and the PEPFAR implementing agencies should consult with both internal and external parties who would be affected by this policy to help identify the data that are most critical for external access and that can be reasonably subject to data-sharing requirements, as well as to help develop feasible mechanisms to implement a data- sharing policy.

o   For routinely collected financial and program monitoring data, a limited set of essential data should be identified and made available for external use in a timely way.

o   Evaluation and research reports and publications using data collected through PEPFAR-supported programs should be tracked and made available in a publicly accessible central repository. USG agencies with similar repositories can be considered as models.

o   For research data and other information that is expressly generated for new knowledge, the policy should respect time-bound exclusivity for the right to engage in the publication process, yet also ensure the timely availability of data, regardless of publication, for access and use by external evaluators and researchers. OGAC should look to USG agencies with similar research data policies as models.

o   In developing the policy and specifying the scope of data to be included, several key factors and potential constraints that can affect the implementation of the policy will need to be addressed. These include patient and client information confidentiality; the financial resources, personnel, and time needed to make data available; and issues of data ownership, especially in the context of increasing responsibility in partner countries and the provision of PEPFAR support through country systems or through activities and programs supported by multiple funding streams.

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