FOR OFFICIAL USE ONLY Report No: RES40932 INTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT AND/OR INTERNATIONAL DEVELOPMENT ASSOCIATION RESTRUCTURING PAPER ON A PROPOSED PROGRAM RESTRUCTURING OF {KENYA DEVOLUTION SUPPORT PROJECT} {APPROVED ON MARCH 15, 2016} TO {THE} {REPUBLIC OF KENYA} {Urban, Resilience And Land Global Practice} {Africa Region} Regional Vice President: Hafez M. H. Ghanem Country Director: Carlos Felipe Jaramillo Regional Director: Simeon Kacou Ehui The World Bank Kenya Devolution Support Project (P149129) Practice Manager: Meskerem Brhane Task Team Leader(s): Abdu Muwonge, John Muratha Kinuthia The World Bank Kenya Devolution Support Project (P149129) ABBREVIATIONS AND ACRONYMS ACPA Annual Capacity & Performance Assessment DLI Disbursement Linked Indicator DLR Disbursement Linked Result DPSM Department of Public Service and Management KDSP Kenya Devolution Support Program KSG Kenya School of Government MAC Minimum Access Condition MPC Minimum Performance Condition MODA Ministry of Devolution and ASAL Areas MoPSYGA Ministry of Public Service, Youth and Gender Affairs NT National Treasury OAG Office of the Auditor General PCU Performance Contracting Unit POM Program Operations Manual VfM Value for Money The World Bank Kenya Devolution Support Project (P149129) DATA SHEET (Kenya Devolution Support Project - P149129) BASIC DATA Project ID Financing Instrument IPF Component P149129 Program-for-Results Financing No Approval Date Current Closing Date 15-Mar-2016 31-Dec-2020 Organizations Borrower Responsible Agency National Treasury Ministry of Devolution and ASAL Program Development Objective(s) To strengthen capacity of core national and county institutions to improve delivery of devolved services at the county level. OPS_TABLE_PDO_CURRENTPDO Summary Status of Financing Net Approval Effectiveness Closing Ln/Cr/TF Signing Date Commitment Disbursed Undisbursed Date Date Date 15-Mar- IDA-57650 15-Apr-2016 15-Sep-2016 31-Dec-2020 200.00 106.67 94.00 2016 Policy Waiver(s) Does the Program require any waivers of Bank policies applicable to Program-for-Results operations? No Page 1 of 19 The World Bank Kenya Devolution Support Project (P149129) I. PROGRAM STATUS AND RATIONALE FOR RESTRUCTURING 1 KDSP was prepared, designed and started up at the same time as Kenya began implementation of its far-reaching devolution reforms. The program became effective in September 2016 and is now coming towards the end of its third year of implementation. As of November 2019, total disbursements have been US$ 106.67 million. Overall implementation progress has been consistently rated as moderately satisfactory. 2 Through its DLIs, KDSP seeks to incentivize capacity building actions and enhanced performance at both the national and county government levels. Through participating MDAs, the national government is provided with incentives to: (a) undertake annual capacity and performance assessments (ACPAs) of all counties; and (b) provide capacity support (in a variety of ways) to county governments. County governments are provided with incentives to undertake capacity building activities and to improve their overall performance. At the national level, incentives take the form of funding for MDAs; at the county level, incentives take the form of: (a) modest Level 1 grants for county government capacity building; and (b) larger Level 2 grants for improvements in county government performance. 3 Over the course of KDSP implementation, a number of issues and challenges have been identified. These are as follows: a. Initial delays in carrying out ACPAs, resulting in delays in grant allocations and delays in grant disbursements to county governments. In addition, bottlenecks in the inter-governmental fiscal transfer system have further delayed grant disbursements. Bottlenecks have included difficulties in ensuring that KDSP grants to counties are properly included in the annual County Allocation of Revenues Act (CARA). b. Social risk management, grievance redress management and program financial reporting by counties have been sub-optimal or inadequate. To improve county performance across these areas, more focused capacity building is required. c. Overly ambitious or unrealistic DLI targets: in the case of DLI1, deadlines set for county audits by the OAG have proven impossible to achieve and are unlikely to be achieved. In the case of DLI2, the requirement that ACPAs include annual Value-for-Money audits is unrealistic and will not be met. d. Changes in the organizational structure of the national government, resulting in functions being re-assigned from one MDA to another MDA. These changes mean that DLIs 2 and 5 need to be amended in order to remain consistent with GoK’s organizational structure. e. Other DLI targets, on the other hand, have been over-achieved, resulting in a rapid drawdown on the DLI allocation. This is the case for DLI7, which all counties have been able to achieve. Based on current DLI7 achievement rates, the funds allocated to DLI7 will be exhausted before the end of the program. f. Funding pool calculation and the allocation formula for Level 2 grants do not appear to provide sufficient incentives to county governments to meet certain performance benchmarks. This has been modified at restructuring. g. The verification protocol for DLI7 needs to be revised in order to ensure timeliness. 4 The proposed re-structuring of the program is intended to address these issues and challenges. Proposed changes will ensure that KDSP: (a) is fully aligned with GoK’s organizational structure; (b) sets realistic targets and provides adequate incentives for achieving DLIs; and (c) provides adequate funding for meeting DLI targets over the entire life of the program. 5 In addition to this restructuring paper, the financing agreement has been updated (see attached) and disbursement letter will be updated. In addition, the Program Operations Manual will to be revised in order to take into account all changes resulting from re-structuring. Additional notes with details of proposed changes of this restructuring are captured in the attachment to this paper and amendment to the legal agreement. The World Bank Kenya Devolution Support Project (P149129) II. DESCRIPTION OF PROPOSED CHANGES 6 Changes in DLIs and/or DLI funding allocations: Under restructuring it is proposed to add one new DLI (DL12a). Otherwise, broad descriptions of all DLIs remain as before. However, there are several amendments to the detailed descriptions of most DLIs, as well as changes to annual DLRs. In addition, changes to the total amounts allocated to some DLIs have been made. All of these modifications will need to be reflected in amendments to the POM and the FA. 7 Changes in DLIs and/or DLI funding allocations: One new DLI (DLI2a) is being added; otherwise, broad descriptions of all DLIs remain as before. However, there are several amendments to the detailed descriptions of most DLIs, as well as changes to annual DLRs. In addition, total amounts allocated to some DLIs have been changed. All of these modifications will be reflected in amendments to the POM and the FA. 8 DLI1 Office of the Auditor General submits audit reports on time and in compliance with ISSAI for all counties that have submitted financial statements in compliance with the PFMA and prevailing accounting standards: the annual targets originally set for this DLI have proven overly ambitious. and DLI1 does not provide realistic incentives for incremental improvements in the performance of the OAG. DLI1 is thus being modified to be scale-able with more realistic deadlines. The total amount allocated to DLI1 will be reduced, and the balance re-allocated to other DLIs. 9 DLI2 Introduction and timely implementation of Annual Capacity & Performance Assessments by MODA: this DLI is intended to incentivize the timeliness of the ACPA and will continue to do so, but with an amendment to the deadlines so as to make them more realistic (on the basis of past experience). In addition, the original detailed description of this DLI included Value-for-Money (VfM) audits as an integral part of the ACPA from year 3 onwards; the inclusion of VfM audits (as part of the regular ACPA) now appears to be unrealistic – it is therefore proposed not to include VfM audits in the ACPA. Instead, an end -of -program VfM will be added to DLI5 and will be the responsibility of the National Treasury. Funds allocated for the ACPA plus VfM audits will be re-allocated to other DLIs. 10 DLI2a MoDA coordinates KDSP implementation (new DLI): during program implementation, it has become clear that MoDA needs to more actively coordinate MDAs in KDSP implementation. It is therefore proposed that DLI2a provide an incentive for MoDA to do so and to demonstrate that it is taking on the challenge of KDSP coordination. To this end, MoDA will provide annual progress reports which include a description of KDSP coordination activities. Funding for this new DLI will be financed through the re-allocation of funds from other DLIs. 11 DLI3 MODA implements annual planned activities to strengthen countrywide frameworks and systems and to address county capacity gaps: the amendment to the detailed description of DLI3 is intended to shift the responsibility for capacity building for county planning from MoDA to the National Treasury, in line with recent changes in the mandates of the respective Ministries. In addition, MODA’s capacity building will explicitly include environmental & social safeguards issues, as well as GRM and program financial reporting; this will address the challenges in these areas encountered during KDSP implementation to date. A year 6 DLR has been added to ensure that MODA has incentives to implement capacity building plans in FY 2019-20. The total DLI allocation has been increased accordingly 12 DLI4 MoPSYGA implements annual planned activities to strengthen countrywide frameworks and systems and to address county capacity gaps: A year 6 DLR has been added to ensure that MoPSYGA has incentives to implement capacity building plans in FY 2019-20. The total DLI allocation remains unchanged. The amount originally allocated to year 5 has been reduced and the amount allocated to year 6; the total DLI allocation remains unchanged. The World Bank Kenya Devolution Support Project (P149129) 13 DLI5 National Treasury and Planning implements annual planned activities to strengthen countrywide frameworks and systems and to address county capacity gaps: the amended detailed description has been changed to reflect the shift in the responsibility for capacity building for county planning from MoDA to the National Treasury and to make the National Treasury responsible for undertaking an end-of-program Value-for-Money audit (as noted above). In addition, a year 6 DLR has been added to ensure that NT has incentives to implement capacity building plans in FY 2019-20. Annual DLR allocations for this DLI have been changed to accommodate the year 6 DLR but the total DLI allocation remains unchanged. 14 DLI6 Kenya School of Government implements annual planned activities to address county capacity gaps: a year 6 DLR has been added to ensure that KSG has incentives to implement capacity building plans in FY 2019-20. Annual DLR allocations for this DLI have been changed to accommodate the year 6 DLR but the total DLI allocation remains unchanged. 15 DLI7 Counties have undergone annual capacity and performance assessments and met access conditions: it is proposed that more funds be allocated to this DLI, in recognition of the higher than expected rate of county participation in the program. Funds will be re-allocated from DLI8 as well as from other modified DLIs. 16 DLI8 Counties have undergone annual capacity and performance assessment and have met Minimum Access Conditions and Minimum Performance Conditions for grant funding and implemented projects according to Program requirements: the detailed description of this DLI is being amended to ensure that Level 2 grant allocations to counties provide adequate incentives for counties to comply with MPCs and to improve their performance (as measured by ACPAs); qualifying counties will receive an equal share allocation of US$0.4 million, with the remaining funding pool being allocated to qualifying counties on the basis of the current formula. Funds for this DLI will be reduced (to take into account a lower level of uptake) and will be re-allocated to DLI7 and other DLIs. The matrix on the following page summarizes KDSP’s restructured DLI architecture. 17 Changes to DLI verification protocol: during implementation it became clear that it was impractical to link the verification or DLI 7 and DLI 8 as part of the ACPA. The two processes had a temporal misalignment as DLI 7 needed to be verified early in the FY to allow qualifying counties ample time to start implementing the year’s capacity building - DLI 8 could only be verified in the second half of the FY once the previous year’s audits were ready. MoDA will now recruit individual consultants to verify DLI 7 and the firm provided for in the PAD to conduct the ACPA would focus on DLI 8. 18 Change in Key Parameters (Disbursement Arrangements, Institutional Arrangements, Technical, Fiduciary, Environmental and Social): In order to take into account changes in the organizational structure of national government, it is proposed that responsibility for capacity building for county-level planning is assumed by the National Treasury (rather than MODA). 19 Technical, Fiduciary, Environmental and Social: The POM will be updated to reflect all agreed changes as summarized in this restructuring paper. The World Bank Kenya Devolution Support Project (P149129) Note to Task Teams: The following sections are system generated and can only be edited online in the Portal. Please delete this note when finalizing the document. III. SUMMARY OF CHANGES Changed Not Changed Change in Results Framework ✔ Reallocation between and/or Change in DLI ✔ Change in Disbursements Arrangements ✔ Change in Institutional Arrangements ✔ Other Change(s) ✔ Change in Implementing Agency ✔ Change in Program's Development Objectives ✔ Change in Program Scope ✔ Change in Loan Closing Date(s) ✔ Change in Cancellations Proposed ✔ Change in Disbursement Estimates ✔ Change in Systematic Operations Risk-Rating Tool ✔ (SORT) Change in Safeguard Policies Triggered ✔ Change in Legal Covenants ✔ Change in Technical Method ✔ Change in Fiduciary ✔ Change in Environmental and Social Aspects ✔ Change in Implementation Schedule ✔ IV. DETAILED CHANGE(S) The World Bank Kenya Devolution Support Project (P149129) OPS_DETAILEDCHANGES_EA_TABLE . The World Bank Kenya Devolution Support Project (P149129) ANNEX 1: RESULTS FRAMEWORK Note to Task Teams: The following sections are system generated and can only be edited online in the Portal. Please delete this note when finalizing the document. . . Results framework Program Development Objectives(s) To strengthen capacity of core national and county institutions to improve delivery of devolved services at the county level. Program Development Objective Indicators by Objectives/ Outcomes RESULT_FRAME_TBL_PDO Indicator Name DLI Baseline End Target PDO Indicator 1: Counties have strengthened institutional performance as demonstrated in the ACPA Counties have strengthened institutional performance as 0.00 55.00 demonstrated in the ACPA (Percentage) PDO Indicator 2: MC-Number of counties which comply with the minimum performance conditions (DLI 8) MC-Number of counties which comply with the minimum 0.00 35.00 performance conditions (DLI 8) (Number) PDO Indicator 1: Counties have strengthened institutional performance as demonstrated in the ACPA - Score in the ACPA 0.00 55.00 for institutional performance of participating counties (average across all counti (Percentage) Page 7 of 19 The World Bank Kenya Devolution Support Project (P149129) RESULT_FRAME_TBL_PDO Indicator Name DLI Baseline End Target PDO Indicator 2: MC-Number of counties which comply with the 0.00 25.00 minimum performance conditions (DLI 8) (Number) Action: This indicator has been Revised PDO Table SPACE Intermediate Results Indicators by Result Areas RESULT_FRAME_TBL_IO Indicator Name DLI Baseline End Target Building county-wide institutional capacity for devolution IR Indicator 1.1: Number of months taken to produce a full set of 12.00 9.00 audits of financial statements of counties (Months) Action: This indicator has been Revised IR Indicator 1.2: ACPA and value for money audits completed on No Yes time (DLI 2) (Yes/No) IR Indicator 1.3: Annual capacity building plans for county No Yes governments are completed (DLI 3) (Yes/No) IR Indicator 1.3: Planned MoDA Capacity Building activities are implemented according to the annual implementation plan (DLI No Yes 3) (Yes/No) Action: This indicator has been Revised IR Indicator 1.4: Annual HRM capacity building activities for No Yes county governments are completed (DLI 4) (Yes/No) Page 8 of 19 The World Bank Kenya Devolution Support Project (P149129) RESULT_FRAME_TBL_IO Indicator Name DLI Baseline End Target IR Indicator 1.4: Planned DPSM capacity building activities are implemented according to annual implementation plan (DLI 4) No Yes (Yes/No) IR Indicator 1.5: Annual PFM capacity building activities for No Yes county governments are completed (DLI 5) (Yes/No) IR Indicator 1.5: Planned NT PFM capacity building activities are implemented according to annual implementation plan (DLI 5) No Yes (Yes/No) IR Indicator 1.6: Kenya School of Government implements annual planned activities to address county capacity gaps (DLI 6) No Yes (Yes/No) IR Indicator 1.6: Planned KSG capacity building activities are implemented according to the annual implementation plan (DLI No Yes 6) (Yes/No) IR Indicator 1.7: Inter-Governmental Relations Strengthened 0.00 47.00 (Number) Action: This indicator has been Revised IR Indicator 2.1: Strengthened County PFM capacity. Average (for all counties) aggregate deviation between budget and outturn 0.00 5.00 (average across all sectors) reduced by: (Percentage) IR Indicator 2.1: Strengthened county PFM capacity. Value of Audit queries as % of total expenditures reduced by: 0.00 5.00 (Percentage) IR Indicator 2.1: Strengthened county PFM capacity. Number of counties with 25 steps in the IFMIS procurement process 0.00 5.00 adhered to by: (Percentage) Page 9 of 19 The World Bank Kenya Devolution Support Project (P149129) RESULT_FRAME_TBL_IO Indicator Name DLI Baseline End Target IR Indicator 2.2: Improved Planning and M&E capacities. Number 0.00 10.00 of CIDPs that adhere to guidelines increased by: (Percentage) IR Indicator 2.2: Improved Planning and M&E capacities. Number of Counties producing County Annual Progress Reports on time 0.00 7.00 (September 30) by: (Percentage) IR Indicator 2.2: Improved Planning and M&E Capacities. Number of counties where the county M&E Committee (COMEC) meets 0.00 5.00 regularly increased by: (Percentage) IR Indicator 2.3: Improved HR and performance management capacity. Number of counties with staff performance appraisal 0.00 5.00 process operationalized increased by: (Amount(USD)) IR Indicator 2.3: Improved HR and performance management capacity. Number of counties with performance contracts for 0.00 5.00 level 1 (and or 2) increased by: (Amount(USD)) IR Indicator 2.4: Strengthened citizen education and public participation at the county level. Number of counties with 20.00 5.00 established and functional civic education units increased by: (Percentage) IR Indicator 2.4: Strenghthened citizen education and public participation at the county level. Number of counties with 0.00 5.00 established and functional civic education units increased by (Percentage) IR Indicator 2.4: Strenghthened citizen education and public participaton at the county level. Number of counties with 0.00 5.00 evidence of citizen input in plans and budgets increased by (Percentage) Page 10 of 19 The World Bank Kenya Devolution Support Project (P149129) RESULT_FRAME_TBL_IO Indicator Name DLI Baseline End Target IR Indicator 2.4: Strengthened citizen education and public participation at the county level. Number of counties with the 0.00 4.00 following documents published online: CIDP, ADP, Annual Budget, Fiscal Strat (Percentage) IR Indicator 2.5: Improved investement implementation and value-for money. Number of counties that prepare Annual 0.00 6.00 Environmental and Social Audits/reports increased by: (Percentage) IR Indicator 2.5: Improved investment implementation and value-for-money. Number of counties projects with a satisfactory 0.00 7.00 value-for-money levle increased by (Percentage) Capacity and Performance Based Grants - County institutional performance Capacity and Performance Based Grants - County institutional 0.00 60.00 performance (Percentage) IO Table SPACE Disbursement Linked Indicators Matrix DLI IN00817094 ACTION DLI 5: National Treasury implements annual planned activities to strengthen countrywide frameworks and systems and to DLI 1 address county capacity gaps Type of DLI Scalability Unit of Measure Total Allocated Amount (USD) As % of Total Financing Amount Output No Text 10.00 20.00 Period Value Allocated Amount (USD) Formula Page 11 of 19 The World Bank Kenya Devolution Support Project (P149129) Baseline 0.00 fiscal year 2018-19 10.00 DLI IN00817095 ACTION DLI 4: MoPSYGA implements annual planned activities to strengthen countrywide frameworks and systems and to address DLI 2 county capacity gaps Type of DLI Scalability Unit of Measure Total Allocated Amount (USD) As % of Total Financing Amount Output No Text 2.50 0.00 Period Value Allocated Amount (USD) Formula Baseline 0.00 fiscal year 2018-19 2.50 DLI IN00817096 ACTION DLI 1: Office of the Auditor General submits audit reports on time and in compliance with ISSAI for all counties that have DLI 3 submitted financial statements in compliance with the PFMA and prevailing acc Type of DLI Scalability Unit of Measure Total Allocated Amount (USD) As % of Total Financing Amount Output No Text 5.00 0.00 Period Value Allocated Amount (USD) Formula Baseline 0.00 fiscal year 2018-19 5.00 Action: This DLI has been Revised. See below. Page 12 of 19 The World Bank Kenya Devolution Support Project (P149129) DLI IN00817419 ACTION DLI 1: Office of the Auditor General submits audit reports on time and in compliance with ISSAI for all counties that have DLI 3 submitted financial statements in compliance with the PFMA and prevailing acc Type of DLI Scalability Unit of Measure Total Allocated Amount (USD) As % of Total Financing Amount Output No Text 5.00 0.00 Period Value Allocated Amount (USD) Formula Baseline 0.00 fiscal year 2018-19 5.00 DLI IN00817097 ACTION DLI 4 DLI 2: Introduction and timely implementation of Annual Capacity & Performance Assessments by MoDP Type of DLI Scalability Unit of Measure Total Allocated Amount (USD) As % of Total Financing Amount Output No Text 8.10 0.00 Period Value Allocated Amount (USD) Formula Baseline 0.00 fiscal year 2018-19 8.10 DLI IN00817098 ACTION DLI 3: MoDP implements annual planned activities to strengthen countrywide frameworks and systems and to address DLI 5 county capacity gaps Type of DLI Scalability Unit of Measure Total Allocated Amount (USD) As % of Total Financing Amount Output No Text 7.50 0.00 Period Value Allocated Amount (USD) Formula Page 13 of 19 The World Bank Kenya Devolution Support Project (P149129) Baseline 0.00 fiscal year 2018-19 7.50 DLI IN00817099 ACTION DLI 6 DLI 6: Kenya School of Government implements annual planned activities to address county capacity gaps Type of DLI Scalability Unit of Measure Total Allocated Amount (USD) As % of Total Financing Amount Output No Text 5.00 0.00 Period Value Allocated Amount (USD) Formula Baseline 0.00 fiscal year 2018-19 5.00 DLI IN00817100 ACTION DLI 7 DLI 7: Counties have undergone annual capacity & performance assessment and met access conditions. Type of DLI Scalability Unit of Measure Total Allocated Amount (USD) As % of Total Financing Amount Output No Text 33.00 0.00 Period Value Allocated Amount (USD) Formula Baseline 0.00 fiscal year 2018-19 33.00 Page 14 of 19 The World Bank Kenya Devolution Support Project (P149129) DLI IN00817101 ACTION DLI 8: Counties have undergone annual capacity and performance assessment and have met minimum access conditions DLI 8 and minimum performance conditions for grant funding and implemented projects according Type of DLI Scalability Unit of Measure Total Allocated Amount (USD) As % of Total Financing Amount Output No Text 127.00 0.00 Period Value Allocated Amount (USD) Formula Baseline 0.00 fiscal year 2018-19 127.00 DLI IN00817412 ACTION DLI 9 DLI2a: MODA coordinates KDSP implementation Type of DLI Scalability Unit of Measure Total Allocated Amount (USD) As % of Total Financing Amount Outcome No Yes/No 1.40 0.00 Period Value Allocated Amount (USD) Formula Baseline No fiscal year Yes 1.40 Action: This DLI is New Note to Task Teams: End of system generated content, document is editable from here. Please delete this note when finalizing the document. Page 15 of 19 The World Bank Kenya Devolution Support Project (P149129) ANNEX 2: PROGRAM ACTION PLAN Note to Task Teams: The following sections are system generated and can only be edited online in the Portal. Please delete this note when finalizing the document. . . PAP_NOT_CHANGE_TBL Action Description Source DLI# Responsibility Timing Completion Measurement Conduct a review of the implementation of the first year of full grant disbursements, and discuss options for financing of the C&P Grant beyond FY 2019/20 at the KDSP Steering Annual performance assessment Committee Technical Client Recurrent Continuous (APA) Eligibility criteria including resettlement and dealing with vulnerable and marginalized groups will be included in the Program Operational Manual (capacity and performance grants Manual) and in training for Environmental and Social KDSP. Systems Client Recurrent Continuous APA Interested county governments are sensitized to ACPA and grants and able to meet the program minimum access conditions Technical Both Recurrent Continuous APA Ministry of Public Service/DPSM appoints a focal point/team to coordinate HR action plans, Completed reflected in MODA reports, budget Technical Client Recurrent Continuous progress report Page 16 of 19 The World Bank Kenya Devolution Support Project (P149129) submissions Independent Annual exercise captured in ACPA conducted Technical Client Recurrent Continuous MODA program work plan Results of ACPA widely published to promote transparency and increased incentives for MODA progress report, The Kenya performance Technical Client Recurrent Continuous Gazette Office of the Auditor General completes audit reports in time for grant allocations Fiduciary Systems Client Recurrent Continuous APA Grant conditions, including adherence to capacity and performance grants Manual, included in County Allocation National level verification reports, Revenue Act-CARA Technical Client Recurrent Continuous MODA progress reports, APA GoK will transfer capacity and performance grants to counties as per Program entitlement and CARA allocations in two tranches, with the first tranche disbursed before end August, and the second tranche disbursed before end February each year. Technical Client Recurrent Continuous APA, The Kenya Gazette Program Operating Manual includes system for tracking Program expenditures and outputs (including compliance with investment MODA progress reports. POM menus) Technical Client Recurrent Continuous completed Page 17 of 19 The World Bank Kenya Devolution Support Project (P149129) Audit Committee guidelines to be developed and issued Technical Client Recurrent Continuous MODA progress reports Joint Steering Committee operational, including county governor representative Technical Client Recurrent Continuous MODA progress reports Technical Committee operational Technical Client Recurrent Continuous MODA progress reports KDSP Secretariat operational: Coordinator and staff are assigned or appointed in the KDSP secretariat as per institutional arrangements and sufficient operating budget allocated Technical Client Recurrent Continuous National level verification reports National Treasury appoints a focal point/team to coordinate with Treasury departments and ensure adequate annual budget for the Program is reflected in annual printed budget estimates Technical Client Recurrent Continuous National level verification reports KSG appoints a focal point/team to coordinate KSG action plans, reports, budget submissions Technical Client Recurrent Continuous National level verification reports Chapter with methodology and ToR for value-for- money audits added to C&P Assessment Manual, compliant with PFMA Technical Client Recurrent Continuous APA Page 18 of 19 The World Bank Kenya Devolution Support Project (P149129) requirements Sensitization of counties includes training of technical staff responsible for environmental and social Environmental and Social management. Systems Client Recurrent Continuous APA Sensitization of counties includes training of county focal persons (county secretary’s offices, complaints officer) on complaints handling and management (in consultation with Regular training undertaken by the EACC and Environmental and Social MODA reported in the MODA other institutions) Systems Client Recurrent Continuous progress report Implementing agencies to develop risk management registers. KDSP Secretariat to develop and periodically update risk management registers Environmental and Social Systems Client Recurrent Continuous APA Sensitization and awareness campaigns on corruption reporting mechanisms Fiduciary Systems client Recurrent Continuous APA . Note to Task Teams: End of system generated content, document is editable from here. Please delete this note when finalizing the document Page 19 of 19