finalC3

 

SIGAR 17-27 Audit Report

Land Reform in Afghanistan: Full Impact 

and Sustainability of $41.2 Million 

USAID Program Is Unknown

SIGAR 17-27-AR/Land Reform

SIGAR

F E B R U A R Y

2017

Special Inspector General for 

Afghanistan Reconstruction 
For more information, contact SIGAR Public Affairs at (703) 545-5974 or sigar.pentagon.ccr.mbx.public-affairs@mail.mil. 

WHAT SIGAR REVIEWED

According to land reform experts, in 

Afghanistan, as in other developing countries, 

land administration is critical to economic 

growth and security. Since 2004, the U.S. 

Agency for International Development (USAID) 

has supported efforts to address land reform 

and land tenure in Afghanistan because of their 

effects on the economy and the lives of the 

Afghan people. According to a U.S. Institute of 

Peace land expert, the majority of Afghans do 

not have proper legal documentation for their 

land ownership, due in part to poor paper 

records and land titles. To address these 

problems and to help the Afghan government 

develop a sound land administration system, 

USAID spent a total of $96.7 million from 2004 

through 2014 to reform the existing system. 

The agency initiated its most recent effort—the 

Land Reform in Afghanistan (LARA) program—

when it awarded the contract to implement the 

program to Tetra Tech ARD in January 2011. 

The contract ended in November 2014 and 

cost $41.2 million. LARA’s three main 

components were to (1) formalize and upgrade 

informal settlements (i.e., supporting the 

Afghan government on mapping plots of land to 

show the value and ownership of land); (2) 

establish a legal framework to include 

supporting the Afghan government establishing 

laws to identify, manage, and obtain revenue 

from Afghan government lands; and (3) build 

the capacity of Afghan land-related ministries.

The objectives of this audit were to assess the 

extent to which: (1) USAID and Tetra Tech ARD 

measured the LARA program’s performance and 

whether it achieved its goals and objectives; (2) 

USAID conducted its required oversight of the 

contract; (3) USAID and Tetra Tech ARD 

designed and assessed LARA’s sustainability; 

and (4) the challenges USAID, Tetra Tech ARD, 

and the Afghan government faced threaten the 

sustainment of U.S. land reform efforts.

WHAT SIGAR FOUND

SIGAR found that USAID and Tetra Tech ARD did not fully measure the LARA 

program’s performance. Without such information, the agency cannot demonstrate 

the full extent to which LARA achieved its goals and objectives, or the impact the 

$41.2 million program had on improving land administration in Afghanistan. Delays 

by Tetra Tech ARD in submitting and USAID in approving key performance 

monitoring and evaluation documentation limited the contractor’s and the agency’s 

ability to track program performance. Tetra Tech ARD did not submit an approved 

performance monitoring plan until February 2012, more than a year after the 

contract was awarded and 11 months after it was due according to the contract. 

Therefore, USAID and Tetra Tech ARD did not have a detailed plan for how Tetra 

Tech ARD would accomplish the program’s requirements, objectives, and goals, or 

collect detailed information on LARA’s performance and progress during its first 

year. In addition, Tetra Tech ARD never reported on six key performance indicators 

that measured the impact of LARA. Finally, Tetra Tech ARD did not monitor and 

report on LARA’s performance consistently, as recommended by USAID guidance 

and required by the contract. USAID officials told SIGAR that they relied on Tetra 

Tech ARD and evaluations performed by Ernst & Young and Checchi and Company 

Consulting Inc. However, the evaluations show that Tetra Tech ARD’s monitoring was 

inconsistent, and SIGAR independently confirmed that finding.

Moreover, the extent to which USAID conducted contract oversight required by the 

Federal Acquisition Regulation and USAID is unknown because the agency did not 

maintain complete records of Tetra Tech ARD’s performance or its own oversight of 

the LARA contract. Although SIGAR found that Tetra Tech ARD completed eight of 

nine contract deliverables, it was unable to rely on the agency’s contract files due to 

the agency’s poor record keeping and had to seek additional information from Tetra 

Tech ARD. When asked, USAID did not have an explanation for why documents were 

missing from its contract files. Therefore, SIGAR questions how the agency was able 

to determine that the three LARA deliverables were completed when it closed out 

the contract. In addition, although USAID provided SIGAR with records and evidence 

of its oversight of LARA from August 2011 through September 2013, it did not

provide documentation for oversight it should have performed from September 

2013 through November 2014, when the program ended, accounting for more than 

a year—or one-fourth—of the contract. Without complete records for the LARA 

contract, the agency cannot demonstrate that it fully performed its required contract 

oversight of Tetra Tech ARD or confirm that the contractor met all of the terms of the 

$41.2 million LARA contract.

In addition, USAID did not, as required by its own internal guidance, fully assess the 

sustainability of LARA. USAID designed LARA to consider some elements of 

sustainability and addressed some sustainment objectives, as required by the 2011 

Administrator’s Sustainability Guidance for USAID in Afghanistan and other agency 

directives. However, the agency did not comply with other requirements of the 2011 

sustainability guidance that sustainability assessments include an “examination, 

both immediate and ongoing, of all USAID Mission for Afghanistan projects against 

the principles of 1) Afghan ownership and capacity, 2) their contribution to transition 

SIGAR February 2017

Land Reform in Afghanistan: Full Impact and Sustainability of $41.2 

Million USAID Program Is Unknown

SIGAR 17-27 AUDIT REPORT

Special Inspector General for 

Afghanistan Reconstruction
For more information, contact SIGAR Public Affairs at (703) 545-5974 or sigar.pentagon.ccr.mbx.public-affairs@mail.mil. 

and confidence, and 3) cost effectiveness and program effectiveness.” USAID completed an initial sustainabi lity assessment in 

June 2012 to report on all of its programs in Afghanistan, in which it stated that LARA “most closely emulate[s] the standards 

that USAID seeks to promote in all of its programming’ about sustainability. However, this analysis primarily addressed whether 

LARA’s overall program design met agency sustainability standards and did not discuss whether the Afghan government could 

sustain ongoing program efforts. USAID did not conduct subsequent sustainability assessments that address all the 

requirements in the 2011 sustainability guidance for LARA between June 2012 to the close of the program in November 2014, 

which amounted to a majority of the program’s implementation period. In its January 2017 response to SIGAR’s draft report, 

the USAID Mission for Afghanistan stated that Checchi’s November 2014 final performance evaluation of LARA, completed 

upon the program’s conclusion, also represented a sustainability assessment, in accordance with the June 2011 

Administrator’s Sustainability Guidance for USAID in Afghanistan. However, SIGAR maintains that USAID did not fully address 

all of the requirements in the 2011 sustainability guidance. For example, the 2014 final performance evaluation does not 

provide an “examination, both immediate and ongoing” of the LARA program’s “cost effectiveness and program effectiveness” 

and does not “estimate all recurrent costs [for LARA] required to maintain the services, infrastructure, and institutions, as well 

as ongoing capacity building investments...[and/or] Develop plans in partnership with GIRoA [Government of the Islamic 

Republic of Afghanistan], and other donors to ensure such costs are priorities and are within budgets in a scarce resource 

environment,” all of which the guidance requires. Without such assessments, the U.S. government has less insight into whether 

the reported achievements associated with its $41.2 million investment in land reform can be maintained. 

According to USAID, Tetra Tech ARD, and Afghan government officials, known systemic challenges in land reform pose a threat 

to sustaining the program’s achievements. The challenges include (1) political and judicial corruption; (2) an underdeveloped

legal system and lack of enforcement mechanisms to support land laws and property rights; and (3) a lack of Afghan 

government technical capacity, including the ability to use land administration information technology systems. The U.S. 

government currently does not have any planned programs that are specifically intended to support land reform in Afghanis tan. 

Nevertheless, by not performing a sustainability assessment of LARA, USAID missed an opportunity to inform the Afghan 

government about how it could address these systematic challenges in the future.

WHAT SIGAR RECOMMENDS

This report contains one recommendation. To better understand the impact of the LARA program on land reform efforts in 

Afghanistan, SIGAR recommends that the USAID Administrator:

1. In accordance with all of the requirements of the June 2011 Administrator’s Sustainability Guidance for USAID in 

Afghanistan, conduct a final sustainability assessment of the LARA program to fully determine whether sufficient 

capacity exists for the Afghan government to sustain the program’s achievements, and provide the results to the 

Afghan government. 

SIGAR received comments from the USAID Mission for Afghanistan. USAID did not concur with the recommendation. The agency 

asserted that the contractor’s 2014 final performance evaluation of the LARA program is evidence that it conducted a 

sustainability assessment, in accordance with its 2011 sustainability guidance. We reassessed the 2014 evaluation and 

maintain that USAID did not fully address the requirements of its 2011 sustainability guidance. We modified the 

recommendation to better reflect the need for the agency to meet all of the guidance’s requirements.
February 6, 2017 

The Honorable Wade Warren

Acting Administrator, U.S. Agency for International Development

The Honorable Hugo Llorens 

Special Chargé d’Affaires for Afghanistan 

Mr. Herbert B. Smith 

USAID Mission Director for Afghanistan 

This report discusses the results of SIGAR’s audit of the U.S. Agency for International Development’s (USAID) 

Land Reform in Afghanistan (LARA) program. In January 2011, USAID awarded Tetra Tech ARD a contract, 

which ultimately cost $41.2 million, to implement the program. This report focuses on the LARA program’s 

performance and sustainability, USAID’s oversight, and challenges to sustaining U.S. land reform efforts. 

We are making one recommendation. To better understand the impact of the LARA program on land reform 

efforts in Afghanistan, we recommend that the USAID Administrator in accordance with all of the requirements 

of the June 2011 Administrator’s Sustainability Guidance for USAID in Afghanistan, conduct a final 

sustainability assessment of the LARA program to fully determine whether sufficient capacity exists for the 

Afghan government to sustain the program’s achievements, and provide the results to the Afghan government. 

We received written comments on a draft of this report from the USAID Mission for Afghanistan, which are 

reproduced in appendix IV. USAID did not concur with our recommendation. The agency asserted that the 

contractor’s 2014 final performance evaluation of the LARA program is evidence that it conducted a 

sustainability assessment, in accordance with its 2011 sustainability guidance. After reassessing the 2014 

evaluation, we maintain that USAID did not fully address the requirements of its 2011 sustainability guidance. 

We modified the recommendation to better reflect the need for the agency to meet all of the guidance’s 

requirements. 

SIGAR conducted this audit under the authority of Public Law No. 110-181, as amended, and the Inspector 

General Act of 1978, as amended; and in accordance with generally accepted government auditing standards. 

John F. Sopko 

Special Inspector General 

 for Afghanistan Reconstruction
SIGAR 17-27-AR/Land Reform Page iv

TABLE OF CONTENTS

Background ......................................................................................................................................................................................2

USAID Did Not Fully Measure the LARA Program’s Performance .......................................................................................6

USAID is Missing Records on Contractor Performance and Oversight ..............................................................................8

USAID Did Not Fully Assess the Sustainability of LARA ......................................................................................................10

Challenges Threaten the Sustainability of USAID’s Land Reform Efforts, Including Activities Completed Under 

LARA ................................................................................................................................................................................................12

Conclusion ..................................................................................................................................................................................... 14

Recommendations ......................................................................................................................................................................14

Agency Comments .......................................................................................................................................................................15

Appendix I - Scope and Methodology ......................................................................................................................................16

Appendix II - List of All LARA Performance Indicators and Their Status .........................................................................18

Appendix III - Defining Terms Used in Land Administration and Land Reform .............................................................21

Appendix IV - Comments from the U.S. Agency for International Development ...........................................................22

Appendix V - Acknowledgments................................................................................................................................................26

TABLES 

Table 1 - LARA Contract Deliverables ........................................................................................................................................9

Table 2 - Description of LARA Performance Indicators Reported on in the LARA Final Report and Their Status 18

Table 3 - Description of LARA Performance Indicators Not Reported on in the LARA Final Report and Their 

Status..............................................................................................................................................................................................20

FIGURE 

Figure 1 - United Nations Definitions of Commonly Used Terms in Land Administration and Reform ...................21

 
SIGAR 17-27-AR/Land Reform Page v 

ABBREVIATIONS 

ADS Automated Directives System

ALRMIS Arazi Land Records Management Information System

COR contracting officer’s representative

FAR Federal Acquisition Regulation

IT information technology

LARA Land Reform in Afghanistan

MEC

Independent Joint Anti-Corruption Monitoring and Evaluation 

Committee

USAID U.S. Agency for International Development

USAID/Afghanistan USAID Mission for Afghanistan
SIGAR 17-27-AR/Land Reform Page 1 

In Afghanistan, as in other developing countries, land is critical to economic growth, and the ability of Afghans 

to protect and use this resource is central to survival and economic development.1 Decades of war, foreign 

involvement, and the mass displacement and return of Afghan citizens affected by conflict upended traditional 

approaches to local communal land management.2, 3 A U.S. Institute of Peace expert states that land is also 

increasingly a major source of conflict, involved in approximately half of personal and communal disputes in 

Afghanistan.4 

According to land reform experts, land reform is generally understood to be efforts to correct problems with 

land distribution and rights to its use.5 Since 2004, the U.S. Agency for International Development (USAID) has 

worked to address land reform in Afghanistan because of its effect on the economy and the lives of the Afghan 

people.6 The majority of Afghans do not have proper legal documentation of their land ownership due in part to 

poor paper records and land titles. Other factors affecting land reform include the influx of Afghan refugees 

returning from other countries, past governments and agencies issuing multiple titles for the same parcel of 

land, corrupt courts, and a lack of legal protection for land owners. To address these problems and help the 

Afghan government develop a sound land administration system, USAID spent a total of $96.7 million from 

2004 through 2014 to reform the existing system. The agency initiated its most recent effort—the Land Reform 

in Afghanistan (LARA) program—when it awarded the contract to implement the program to Tetra Tech ARD in 

January 2011. The contract ended in November 2014 and cost $41.2 million.

In September 2015, we completed a financial audit of the costs Tetra Tech ARD incurred under the LARA 

contract. We did not identify any material weaknesses or significant deficiencies in Tetra Tech ARD’s internal 

controls, or instances of noncompliance with the terms and conditions of the contract. As a result, we did not 

question any costs or make any recommendations to USAID.7

The objectives of this audit were to assess the extent to which (1) USAID and Tetra Tech ARD measured the 

LARA program’s performance and whether it achieved its goals and objectives; (2) USAID conducted its required 

oversight of the contract; (3) USAID and Tetra Tech ARD designed and assessed LARA’s sustainability; and (4) 

the challenges USAID, Tetra Tech ARD, and the Afghan government faced threaten the sustainment of U.S. land 

reform efforts.

 

1 John W. Bruce, et al., Land Law Reform – Achieving Development Policy Objectives, page ix, World Bank, 2006.

2 We have previously reported on U.S. assistance to support Afghan refugees and internally displaced people (s ee SIGAR,

Afghan Refugees: Corruption and Lack of Afghan Ministerial Capacity Have Prevented Implementation of a Lon g-term 

Refugee Strategy, SIGAR 15-83-AR, August 27, 2015; and SIGAR, Efforts to Support Afghan IDPs, SIGAR 16-47-AL, July 25, 

2016).

3 Liz Alden Wily, Land Governance at the Crossroads, Afghanistan Research and Evaluation Unit, October 2012.

4 Liz Alden Wily, Land, People, and the State in Afghanistan: 2002-2012, U.S. Institute of Peace/Afghanistan Research and 

Evaluation Unit, February 2013. 

5 E.g., Ben White, Saturnino M. Borras Jr., and Ruth Hall, “Land Reform,” in International Development: Ideas, Experience, 

and Prospects, ed. Bruce Currie-Alder, Ravi Kanbur, David M. Malone, and Rohinton Medhora (Oxford: Oxford University 

Press, 2014). October 2013. We identified several subject matter experts on the topic of land reform, including these 

authors.

6 The United Nations defines land tenure as “an institution, i.e., rules invented by societies to regulate behavior. Rules of 

tenure define how property rights to land are to be allocated within societies. They define how access is granted to rights to 

use, control, and transfer land, as well as associated responsibilities and restraints. In simple terms, land tenure systems 

determine who can use what resources for how long, and under what conditions.” See Food and Agriculture Organization of 

the United Nations, Land Tenure and Rural Development, Chapter 3, “What Is Land Tenure,” Rome, 2002. We have 

included the United Nations’ definitions of other common terms in land administration and reform in appendix III.

7 See SIGAR, USAID’s Land Reform in Afghanistan Program: Audit of Costs Incurred by Tetra Tech ARD, SIGAR 15-88-FA,

September 28, 2015.
SIGAR 17-27-AR/Land Reform Page 2 

To accomplish these objectives, we reviewed the LARA contract, modifications, deliverables, and work plans. 

We analyzed LARA program objectives, the LARA performance monitoring plan,8 and periodic performance 

reports, such as Tetra Tech ARD’s final report.9 We compared the performance indicators established in the 

performance monitoring plan to those reported in the contractor’s final report. Additionally, we reviewed U.S. 

government requirements and USAID policies for contract management, reporting, monitoring and evaluation, 

and sustaining programs. We also interviewed and requested information from current and former USAID 

officials responsible for overseeing the LARA contract in the Office of Afghanistan and Pakistan Affairs and 

USAID Mission for Afghanistan’s (USAID/Afghanistan) Office of Economic Growth and Infrastructure, and Office 

of Acquisition and Assistance; the Department of State’s Office of the Special Representative for Afghanistan 

and Pakistan; Tetra Tech ARD and Thomson Reuters, one of its subcontractors; Afghan government agencies, 

such as the Afghan Land Authority, now known as Arazi, and the Independent Directorate of Local Governance; 

nongovernment organizations, such as the Afghan Land Consulting Organization and the Afghan Women’s 

Network; and experts and international organizations involved with land reform, such as the U.S. Institute of 

Peace and the United Nations Human Settlements Programme. 

We conducted our work in Kabul, Afghanistan; Burlington, VT; and Washington, D.C., from May 2015 through 

February 2017 in accordance with generally accepted government auditing standards. A more detailed 

discussion of our scope and methodology is in appendix I. 

BACKGROUND 

Historical Challenges to Land Reform in Afghanistan 

Under the current Afghan government, millions of displaced Afghans have returned home, often seeking to 

reclaim the land they previously owned.10 The hundreds of thousands who have not been able to reclaim their 

land have resorted to squatting on the outskirts of urban areas in informal settlements unrecognized by the 

government. The U.S. Institute of Peace has previously reported that around 70 percent of urban residents in 

Afghanistan live in these types of informal settlement,11 and as a result, “Rights to and control over lands are 

frequently and violently contested...this is more common in 2012 than in 2002.”12 The United States’ and 

other donors’ land reform efforts in Afghanistan have sought to address multiple legal, technical, and capacitybuilding challenges the Afghan government faces in land administration, land tenure, and land rights, as well 

as with building Afghan land markets. 

 

8 According to Automated Directives System Chapter 200, a performance monitoring plan outlines USAID’s monitoring and 

evaluating requirements at the activity or project level. Performance monitoring is the ongoing and routine collection of 

performance indicator data to determine whether desired results are being achieved and whether implementation is on 

track. Performance monitoring continues throughout an activity or project. Performance indicators are the basis for 

observing progress and measuring the actual results of the activity or project as compared to the expected results, and 

help determine the extent to which the agency is meeting its objectives. 

9 The LARA contract required Tetra Tech ARD to issue a final report on the program’s performance that in cludes the 

performance indicators it and USAID established in the performance monitoring plan. 

10 Liz Alden Wily, Land Governance at the Crossroads, Afghanistan Research and Evaluation Unit, October 2012.

11 According to the Organization for Economic Cooperation and Development, informal settlements are areas where groups 

of housing units have been constructed on land that the occupants have no legal claim to or are unplanned settlements 

not in compliance with planning and building regulations (see OECD Glossary of Statistical Terms, 

https://stats.oecd.org/glossary/search.asp, accessed February 22, 2016).

12 Liz Alden Wily, Land, People, and the State in Afghanistan: 2002-2012, U.S. Institute of Peace/Afghanistan Research 

and Evaluation Unit, February 2013.
SIGAR 17-27-AR/Land Reform Page 3 

Land experts characterize Afghanistan’s land administration as an ad hoc system of overlapping formal and 

informal approaches to land titling and transfer, with the formal approach mainly based on paper documents 

that may be registered by multiple institutions. Moreover, only a third of the land in Afghanistan has ever been 

surveyed, and the last partial survey was carried out with U.S. assistance in the 1960s and 1970s, before the 

1978 revolution, which marked the beginning of the Soviet occupation. The Afghan government continues to 

lack a comprehensive cadastral system—a set of records showing the extent, value, and ownership of plots of 

land—or a modern titling system that maintains adequate documentation and uses digital records. The current 

titling system relies on multiple Afghan government institutions maintaining paper records. Experts at the 

Independent Joint Anti-Corruption Monitoring and Evaluation Committee (MEC) and the U.S. Institute of Peace 

note that the locally maintained paper records are poorly archived, incomplete, more susceptible to damage, 

and at risk of forgery or replacement, all of which make it easier for land to be taken illegally. 

Additionally, corruption is endemic in land administration in Afghanistan, in part due to the judiciary, which 

Afghans perceive as one of the country’s most corrupt institutions, as we reported in our 2015 audit of U.S. 

rule of law efforts.13 Courts are involved in land administration, including titling and records management, and 

resolving disputes, both of which are susceptible to corruption. For example, because of this perceived 

corruption, in Kunduz province, the majority of disputes are handled through informal approaches, including 

councils of elders, or shuras. However, according to a U.S. Institute of Peace report, Afghans in Kunduz would 

prefer to have formal titles rather than informal land deeds to help prevent disputes.14 

As the MEC reported, proper land registration is critical to development because it provides financial security 

and opportunity to land owners who can, for example, more easily sell the land or use it as collateral on a 

loan.15 However, ongoing problems, such as the lack of proper registration of land, and corruption in Afghan 

land administration have a significant economic impact. By some estimates, land values have increased by 

1,000 percent in urban areas since 2001, creating increased economic incentives for theft and fraud.16

Afghan land reform experts say the scramble for land will accelerate over the next decade as economic 

development increases. Furthermore, as SIGAR has noted previously, despite the hundreds of millions of 

dollars the United States has spent to encourage foreign business to invest in Afghanistan, large corporations 

have not done so in part because of the lack of strong land rights and other legal protections, which put any 

long-term investment at risk.17 

Experts say changes to the land administration system are also needed to help promote the rights of women in 

Afghanistan to inherit and own land. As discussed in a 2014 U.S. Institute of Peace report on land issues in 

Kunduz province, women are particularly vulnerable to corruption and land usurpation under the current 

system because their rights to inheritance are frequently ignored.18 Despite guidance under both Islamic 

jurisprudence and current Afghan laws, men often do not let female family members own or inherit land, and 

such cases are difficult or impossible to resolve through the courts or informal paths. 

 

13 SIGAR, Rule of Law in Afghanistan: U.S. Agencies Lack a Strategy and Cannot Fully Determine the Effectiveness of 

Programs Costing More Than $1 Billion, SIGAR 15-68-AR, July 1, 2015.

14 Fareeda Miah, U.S. Institute of Peace, Land Titling in Kunduz, Afghanistan, July 2014.

15 Independent Joint Anti-Corruption Monitoring and Evaluation Committee, Report of the Public Inquiry Into Land 

Usurpation, November 2014.

16 Liz Alden Wily, Land, People, and the State in Afghanistan: 2002-2012, U.S. Institute of Peace/Afghanistan Research 

and Evaluation Unit, February 2013.

17 SIGAR, Afghanistan’s Oil, Gas, and Minerals Industries: $488 Million in U.S. Efforts Show Limited Progress Overall, and 

Challenges Prevent Further Investment and Growth, SIGAR 16-11-AR, January 11, 2016.

18 Fareeda Miah, U.S. Institute of Peace, Land Titling in Kunduz, Afghanistan, July 2014.
SIGAR 17-27-AR/Land Reform Page 4 

USAID’s Land Reform Efforts in Afghanistan 

Between 2004 and 2014, the U.S. government, through two USAID programs, conducted efforts to reform 

Afghanistan’s land administration system. These efforts aimed to: 

 Improve the documentation and recording of land records and ownership; 

 Update and promote laws supporting land management, land dispute resolution, and property rights 

to reduce usurpation; 

 Build the capacity of Afghans to perform land administration; and 

 Strengthen land markets for improved economic growth and increased investment. 

USAID/Afghanistan’s Office of Economic Growth and Infrastructure managed both the 2004 to 2009 Land 

Titling and Economic Restructuring in Afghanistan program and the 2011 to 2014 LARA program, and both 

programs aligned with the U.S. Economic Growth Strategy for Afghanistan Fiscal Year 2009-2011 and the U.S. 

Foreign Assistance for Afghanistan Post Performance Management Plan 2011-2015. 

The “ultimate goal” of the Land Titling and Economic Restructuring in Afghanistan program “was to introduce a 

consolidated land administration system and to support the [Afghan] Ministry of Finance with the production of 

maps of land and buildings of state-owned enterprises that are earmarked for divestment.”19 As part of this 

effort, existing informal settlements in Kabul, Kunduz, Mazar-e Sharif, and Taloqan were to be formally 

established, and paper records within the local archives of the appeals court’s registries (known as the 

Makhzans) were to be converted to digital records. Following the completion of the program in 2009, USAID 

sought to continue land reform efforts it deemed successful, such as digitizing records and formalizing 

informal settlements, through the follow-on LARA program. 

Tetra Tech ARD and its subcontractors implemented LARA between January 2011 and November 2014. 

According to USAID’s fifth modification of the LARA contract, the three main components of the program were: 

1. Formalizing and upgrading informal settlements—to include upgrading informal infrastructure, 

surveying and documenting land parcels, supporting land rights through the courts and informal 

dispute resolution mechanisms, and supporting the Afghan government on mapping plots of land to 

show the value and ownership of land. 

2. Establish a legal framework—to include supporting the Afghan government’s establishment of laws to 

identify, manage, lease, and obtain revenue from Afghan government lands. 

3. Capacity building—to include providing Afghan land-related ministries and other Afghan agencies with 

training, information technology (IT) equipment and software, and technical support.20

Ultimately, USAID modified the LARA contract 12 times, which extended the program twice for a total of 

approximately 3 years and 11 months, through November 2014. The contract’s final cost was $41.2 million.21 

 

19 USAID, Land Titling and Economic Reconstruction in Afghanistan Project Completion Report, November 2009.

20 Under LARA, Tetra Tech ARD and its subcontractors worked primarily with Afghan land-related ministries and 

organizations such as Arazi; the Ministry of Agriculture, Irrigation, and Livestock; the Ministry of Urban Development Affair s; 

the Afghan Geodesy and Cartography Head Office; the Independent Directorate of Local Governance; the Afghan Land 

Consulting Organization; the Afghan Land and Capacity Building Organization; and the Cooperation for Reconstruction of 

Afghanistan.

21 In 2010, USAID planned for the program to cost $140 million over 5 years. However, on January 30, 2011, under a 

competitive bid, USAID awarded the LARA contract and estimated that the program would last 36 months and cost 

approximately $69.2 million. In December 2012, USAID reduced LARA’s budget and scope as a result of a cut to 

USAID/Afghanistan’s budget. In response to the budget cut, USAID/Afghanistan reduced the program’s scope. For example, 

activities in the first component were to be implemented in one province instead of the five initially planned. Training 
SIGAR 17-27-AR/Land Reform Page 5 

USAID Requirements and Guidance for Managing Contracts, Measuring Program 

Performance, and Conducting Sustainability Assessments of Program Activities 

The Federal Acquisition Regulation (FAR) requires U.S. government agencies, including USAID, to clearly define 

their requirements when contracting for services,22 safeguard the interests of the United States in their 

contractual relationships,23 and perform contract quality assurance “as may be necessary to determine that 

the supplies or services conform to contract requirements.”24 The FAR also requires contracting officers to 

designate contracting officer’s representatives (COR)25 to “assist in the technical monitoring or administration 

of a contract,” including maintaining contract files documenting “actions taken in accordance with the 

delegation of authority” from the contracting officer.26

USAID also has agency guidance for measuring the performance of its programs and contractors. For example, 

USAID’s Automated Directives System (ADS) Chapter 200, “Introduction to Programming Policy,” recommends 

that the agency’s missions plan how they will systematically monitor and evaluate programs’ progress toward 

meeting their intended results, regularly monitor their achievements, and collect and analyze performance 

information to track progress toward the planned results, through the use of, for example, performance 

monitoring plans and quarterly and annual performance reports.

27

USAID also has guidance to conduct assessments on certain programs throughout their implementation to 

help ensure they are sustainable. The Consolidated Appropriations Act, 2012, states that fiscal year 2012 

funds appropriated for the Economic Support Fund, which USAID used to fund the LARA program, could not be 

obligated for assistance for the Afghan government “until the Secretary of State, in consultation with the 

[USAID] Administrator, certifies to the Committees on Appropriations that — (A) The funds will be used to design 

and support programs in accordance with the June 2011 Administrator’s Sustainability Guidance for USAID in 

Afghanistan.”28 This sustainability guidance applies to LARA and states that “if our [USAID’s] work establishes 

recurrent costs, then we [USAID] must determine with our Afghan partners and other donors whether they will 

have the interest and resources, amongst many competing demands and decreasing resources, to maintain 

the investment over time, so that it is sustainable.”29 

 

activities in the capacity-building component were decreased from being implemented in multiple private organizations and 

government agencies to a smaller group of government agencies, focusing mainly on Arazi. When we asked USAID officials 

for an explanation of the budget cut, the agency in technical comments to our report stated that in December 2012, “most 

Governmental agencies were asked to make voluntary budget cuts. USAID honored this request and made across the 

board cuts in Afghanistan, to include the budgets of multiple Economic Growth activities including LARA, in order to fund 

many of the important infrastructure projects in Afghanistan.”

22 FAR 37.503. 

23 FAR 1.602-2.

24 FAR 46.401. 

25 This is done unless the contracting officer retains and executes the COR duties. 

26 FAR Subpart 1.6. 

27 USAID, ADS Chapter 200.3.5.5, “Evaluation and Monitoring,” effective January 17, 2012. Prior to the 2012 update to 

ADS Chapter 200, the agency’s USAID 2011 Evaluation Policy highlights the importance of measuring and documenting 

project achievements, using performance monitoring of indicators, collecting and analyzing performance information to 

track progress toward planned results, and using performance information to influence decision making and resource 

allocation.

28 Consolidated Appropriations Act, 2012, Pub. L. No. 112-74, § 7046(a)(1)(A), 125 Stat. 786, 1234 (2011). This limitation 

applies to planned and ongoing programs, such as LARA, that were supported by appropriations made to the Economic 

Support Fund for fiscal year 2012. 

29 USAID, Administrator’s Sustainability Guidance for USAID in Afghanistan, June 2011.
SIGAR 17-27-AR/Land Reform Page 6 

USAID DID NOT FULLY MEASURE THE LARA PROGRAM’S PERFORMANCE

USAID was unable to fully measure the program’s performance because of (1) delays by Tetra Tech ARD in 

submitting and in USAID approving key performance monitoring and evaluation documentation; (2) neither 

USAID nor Tetra Tech ARD reported on some key performance indicators established in LARA’s performance 

monitoring plan; and (3) Tetra Tech ARD did not consistently monitor or report on program performance. 

Because USAID did not fully measure LARA’s performance during or after implementation, the agency cannot 

fully establish whether LARA achieved its goals and objectives, or what impact the $41.2 million program had 

on improving land administration in Afghanistan. 

USAID guidance and the LARA contract required USAID and Tetra Tech ARD to measure program performance 

during the program’s implementation. ADS 200.3.5.5, “Evaluation and Monitoring,” recommends that USAID 

missions “plan how they will systematically monitor and evaluate the progress of programs toward meeting 

their intended results,” “monitor the achievements of the programs regularly,” and “collect and analyze 

performance information to track progress toward the planned results,” through, for example, periodic quarterly 

and annual performance reports.30 In addition, ADS 203.3.2, “Performance Monitoring,” stated that 

performance indicators, such as those in a performance monitoring or measurement plan, “are the basis for 

observing progress and measuring actual results compared to expected results.”31 It further stated, “data for 

performance indicators are collected periodically and analyzed in order to inform judgments about the 

characteristics and outcomes of programs and projects as a basis to improve effectiveness, and/or inform 

decisions about current and future programming.”32

Delays in Tetra Tech ARD submitting and USAID approving key performance monitoring and evaluation 

documentation limited USAID’s ability to assess the program’s performance. Specifically, Tetra Tech ARD 

submitted an approved performance monitoring plan in February 2012, more than a year after the contract 

was awarded and 11 months after it was due. As a result, USAID and Tetra Tech ARD did not collect detailed 

information on LARA’s performance and progress during its first year. In addition, USAID did not approve Tetra 

Tech ARD’s first annual work plan until November 8, 2011, more than 11 months after the contract was 

awarded and 9 months after it was due to the agency.33 As a result of these delays, USAID and Tetra Tech ARD 

did not have a detailed plan for how the contractor would accomplish the program’s requirements or achieve its 

goals and objectives for almost the entire first year of implementation. Previous Checchi and Company 

Consulting Inc. evaluations of LARA confirm these delays. Tetra Tech ARD staff and USAID officials both 

acknowledged the delays, but they could not explain why they occurred. 

USAID and Tetra Tech ARD did not report on 6 of the 35 performance indicators established in LARA’s 

performance monitoring plan.34 USAID Mission Order 203.02, “Mission Order on Monitoring and Evaluation,” 

states that USAID should “ensure that a project’s Final Report includes an internal assessment of project 

performance and details final results of the indicators in the project’s PMP [performance monitoring plan] in 

order to inform program management and decision making, as well as provide feedback and lessons learned 

 

30 USAID, ADS Chapter 200.3.5.5, “Evaluation and Monitoring,” effective January 17, 2012. 

31 USAID, ADS Chapter 203.3.2, “Assessing and Learning, Performance Monitoring,” effective November 2, 2012.

32 In October 2016, we briefed USAID on the results of our audit. During that meeting, agency officials stated that “ the new 

ADS 201, and previously ADS 203, both represent the definitive policy reference for Agency monitoring and evaluation 

requirements.” At the time the LARA program was being implemented, ADS 203.3.2, dated November 2, 2012, still applied 

as referenced.

33 USAID uses the terms annual work plan and project work plan interchangeably in the original contract description. LARA’s 

work plans were divided into two periods: (1) the original 18-month contract and (2) the 18-month contract option period.

34 Appendix II has a description of the 35 indicators and their status.
SIGAR 17-27-AR/Land Reform Page 7 

to improve performance and learning.”35 The six unreported indicators included the “percentage of surveyed 

Afghan community members that report satisfaction with land tenure security in targeted informal settlement 

communities” and the “percentage increase of surveyed Afghans that report satisfactory land service delivery 

by the Makhzan [local Afghan repository of deeds].” The six indicators were important because they helped 

measure the extent to which LARA increased the sense of satisfaction that Afghan citizens had when working 

with the Afghan government on land rights. By not measuring and reporting on all of the performance 

monitoring plan’s performance indicators, USAID did not have the information it needed to make decisions, 

properly allocate resources, gather lessons learned, and adapt LARA to achieve its goals and objectives. 

Because the program ended in November 2014 and USAID closed the contract without fully measuring the 

contractor’s performance in meeting program goals and objectives, the opportunity to measure and 

understand any gains for those indicators has passed. 

Tetra Tech ARD and USAID measured the remaining 29 indicators in the final report and reported mixed results 

in LARA’s three main components, stating that they met targets for 23 indicators, missed targets for 4, and 

modified 2. For example, they reported program achievements in meeting indicators such as “number of policy 

and procedural reforms improving tenure security for informal settlers,” “enhancing revenue collection 

capabilities,” and “Land Management Law improvements agreed and drafted by the government,” while 

missing indicator targets such as “number of community upgrade development plans approved” and “number 

of private sector firms bidding on donor-funded requests for application.” The four missed indicators’ targets 

measured progress in LARA’s components to improve the legal environment for land reform efforts and to build 

capacity within the Afghan government. 

ADS Chapter 203.3.10, “Changing Performance Indicators,” advises USAID to be “cautious about changing 

performance indicators because it compromises the comparability of performance data over time.”36 Despite 

this, USAID and Tetra Tech ARD modified 2 of the 29 LARA indicators in December 2012; and therefore, 

potentially compromised the comparability of the performance data.37 We could not determine whether these 

2 modified indicators were fully measured or met. We determined that Tetra Tech ARD partially met the target 

for one of the modified indicators because the contractor created an IT system, but it was not operational. We 

could not determine whether Tetra Tech ARD met the target for the second modified indicator because the unit 

of measurement changed from “number of people” to “percentage increase.” 

Finally, Tetra Tech ARD did not consistently report on program performance. USAID did not produce its own 

reports evaluating LARA’s performance and instead relied on Tetra Tech ARD and evaluations performed by 

Ernst & Young and Checchi and Company Consulting Inc.38 Ernst & Young and Checchi previously reported, and 

we also found, that Tetra Tech ARD did not monitor or report on LARA’s progress consistently, as ADS 200 

guidance recommends.39 For example, in its November 2014 evaluation, Checchi reported that it could not 

fully assess the LARA program because of limited or no access to contractor records, which, according to Tetra 

Tech ARD, were in transit to the company’s headquarters in Burlington, VT. We reviewed the records at that 

office in September 2015 and found that some records, such as contractor training manuals, training records, 

 

35 USAID, Mission Order 203.02, “Mission Order on Monitoring and Evaluation,” October 24, 2012.

36 USAID, ADS Chapter 203.3.10, “Changing Performance Indicators,” effective November 2, 2012.

37 The two performance indicators that were modified are (1) “Service delivery management and monitoring systems 

established and operational” and (2) “Number of people employed by private sector partners as a result of project 

activities.”

38 Ernst & Young, Regulatory Compliance (Vetting and Procurement) Review of USAID Afghanistan Awards – Land Reform 

in Afghanistan (LARA), July 2012; Checchi and Company Consulting Inc., Land Reform in Afghanistan Mid-term Evaluation, 

March 2013; and Checchi and Company Consulting Inc., Land Reform in Afghanistan Final Performance Evaluation, 

November 2014.

39 USAID, ADS Chapter 200.3.5.5, “Evaluation and Monitoring,” effective January 17, 2012.
SIGAR 17-27-AR/Land Reform Page 8 

and trainee test results that could help measure training impact were still missing, thus reinforcing Checchi’s 

conclusion that the program could not be fully assessed.

USAID IS MISSING RECORDS ON CONTRACTOR PERFORMANCE AND 

OVERSIGHT 

USAID was missing some records on Tetra Tech ARD’s performance and USAID’s contractor oversight. While we 

were able to obtain some of these records on our own, the fact that USAID did not have the information raises 

questions as to whether or not the agency appropriately monitored the contractor’s performance during 

implementation. 

To facilitate the monitoring and evaluation of the program, the LARA contract contained nine “deliverables” 

including the performance monitoring plan, periodic status reports, and a final contractor report. USAID did not 

have complete LARA contract records for three deliverables requiring Tetra Tech to produce periodic 

performance reports to USAID. Specifically, it did not have weekly reports for 84 of the 195 weeks LARA was 

active, quarterly reports for 3 of the 16 quarters, or 26 of the 39 required short-term consultant reports.40

USAID contracting officials could not explain to us why the records were missing. Without these reports, USAID 

was missing the equivalent of nearly a year’s worth of quarterly reports and more than a year and a half’s 

worth of weekly reports that would have provided updates and information on how LARA was performing. We 

were able to determine that Tetra Tech ARD completed most of the periodic performance reports USAID was 

missing—the quarterly reports and the short-term consultant reports—after following up with Tetra Tech ARD 

staff. After this additional work, we were able to determine that the contractor completed 8 of 9 deliverables. 

USAID’s lack of records raises questions as to whether or not USAID had this information during LARA’s 

implementation or used it to measure and adjust the program’s activities to ensure goals and objectives were 

being met. Table 1 lists the LARA contract deliverables and whether Tetra Tech ARD completed them. 

 

40 As part of the LARA contract, Tetra Tech ARD hired subject matter expert consultan ts to conduct various trainings for 

Arazi and Afghan government officials throughout the program, and documented the “consultancy” through short -term 

consultant reports. According to the contract, short-term consultant reports are brief written reports that describe the 

purpose of the consultancy, progress made, and any observations to be shared; identify issues and problems encountered; 

and detail expected follow-on activities by resident contractor staff, as well as actions to be performed by participatin g 

counterparts.
SIGAR 17-27-AR/Land Reform Page 9 

Table 1 - LARA Contract Deliverables

Source: SIGAR analysis of USAID and Tetra Tech ARD data

a USAID’s approved performance monitoring plan states, “The term ‘performance management’ is considered to be 

synonymous with ‘performance monitoring,’ but reflects terminology used in the USAID Performance Management 

Toolkit and in USAID ADS 200.”

b The option period consisted of an additional 18-month period of performance, which USAID exercised based on Tetra 

Tech ARD’s performance during the initial 18 months.

c According to Tetra Tech ARD, it did not complete the missing 28 weekly reports with USAID’s approval because of 

holidays, reduced work weeks, or staff being out of the office. In some cases, the weekly reporting was discussed 

through e-mail or telephone with USAID staff but was not documented. 

While USAID provided records and evidence of oversight it performed of LARA from August 2011 through 

September 2013, it did not provide documentation for oversight it should have performed from September 

2013 through November 2014. This apparent gap in oversight accounted for more than a year—or over a 

quarter of the contract. The FAR requires contracting officers to designate CORs to assist in the contract 

activities, unless the contracting officer retains and executes the COR duties.41 The FAR also requires agencies 

to directly manage and oversee the administration of their contracts,42 and follow an effective quality 

assurance and monitoring process.43 ADS 202 further instructs USAID missions to conduct oversight of 

contract implementation, by, for example, reviewing contractor reports and conducting site visits, to determine 

 

41 FAR 42.3.

42 FAR 37.504.

43 FAR 46.401.
SIGAR 17-27-AR/Land Reform Page 10

that the contractor has completed work in accordance with the terms of the contract, and maintain a work file 

documenting performance reports and program variations and problems.44 Additionally, the FAR requires that 

CORs maintain complete records in their files that document their activities and any significant decisions made 

during contract execution.45 For example, in accordance with the FAR, contracting officers should formally 

designate CORs in writing with appointment letters and document that they received training to oversee the 

LARA contract. According to the COR’s appointment letter, the COR files should have (1) a copy of all 

correspondence between the COR and the contractor, including property reports; (2) a copy of records of COR 

inspections and receiving/acceptance documents, invoices, and other administrative paperwork and 

correspondence; and (3) documentation of any other actions the COR takes in accordance with this delegation 

of authority.46 All of these contractor oversight records help provide USAID reasonable assurance that the 

contractor has implemented the contract appropriately. However, inadequate files affect the CORs, and 

successive CORs’, ability to manage and oversee the contract. 

From September 2013 through the end of the contract in November 2014, USAID did not have any 

documentary evidence of these types of oversight records, such as USAID site visit reports for training 

conducted or records of meetings with Tetra Tech ARD staff. Furthermore, USAID did not have an explanation 

for this lack of documentation, and the CORs in charge of the oversight during this time were no longer 

employed by the agency.47 Without complete records for the LARA contract, USAID cannot demonstrate that it 

fully performed its required oversight of Tetra Tech ARD or, just as importantly, cannot confirm that the 

contractor met the terms of the $41.2 million LARA contact. 

USAID DID NOT FULLY ASSESS THE SUSTAINABILITY OF LARA 

While USAID did not have complete records on Tetra Tech ARD’s performance, the agency did have some 

information on the LARA program’s achievements. However, these achievements are at risk because USAID did 

not assess the sustainability of key elements of the LARA program in areas key to transitioning ownership to 

the Afghan government. 

USAID’s own guidance, which it is legislatively mandated to follow, requires the agency to conduct 

sustainability assessments on programs throughout their implementation in order to help ensure they are 

sustainable once they are transferred to a host nation government.48 The 2011 Administrator’s Sustainability 

Guidance for USAID in Afghanistan, which applies to LARA, states that “if our [USAID’s] work establishes 

recurrent costs, then we [USAID] must determine with our Afghan partners and other donors whether they will 

have the interest and resources, amongst many competing demands and decreasing resources, to maintain 

the investment over time, so that it is sustainable.”49 According to USAID’s 2011 guidance, sustainability 

 

44 USAID, ADS Chapter 202, “Achieving,” effective January 25, 2012.

45 FAR 1.604.

46 USAID, ADS Chapter 203, “Assessing and Learning,” effective September 1, 2008.

47 Although we were unable to interview the CORs for this period of the program, we interviewed the alternate COR, and he 

had no explanation for why the COR records were missing.

48 As previously stated, the Consolidated Appropriations Act, 2012, states that fiscal year 2012 funds appropriated for the 

Economic Support Fund, which USAID used to fund the LARA program, could not be obligated for assistance for the Afghan 

government “until the Secretary of State, in consultation with the [USAID] Administrator, certifies to the Committees on 

Appropriations that — (A) The funds will be used to design and support programs in accordance with the June 2011 

Administrator’s Sustainability Guidance for USAID in Afghanistan.” (See Consolidated Appropriations Act, 2012, Pub. L. No. 

112-74, § 7046(a)(1)(A), 125 Stat. 786, 1234 (2011). This limitation applies to planned and ongoing programs, such as 

LARA, that were supported by appropriations made to the Economic Support Fund for fiscal year 2012.)

49 USAID, Administrator’s Sustainability Guidance for USAID in Afghanistan, June 2011.
SIGAR 17-27-AR/Land Reform Page 11

assessments are important to ensure that its development efforts focus on critical priorities to achieve the 

goals of stability, economic growth, and increased Afghan confidence in the government. 

USAID and Tetra Tech ARD reported some achievements in addressing LARA’s three major components—

formalization, legal reform, and capacity building. According to Tetra Tech ARD’s periodic reports, its effort to 

formalize and upgrade informal settlements in Jalalabad, Nangarhar province, was a readily adaptable model 

that could be used in the majority of the informal settlements in every large city of Afghanistan. For legal 

reform, Tetra Tech ARD reported that its efforts to revise the drafts of the Land Management Law and Land 

Acquisition Law resulted in proposed laws being submitted by Arazi to the Afghan Parliament for adoption. For 

capacity building, Tetra Tech ARD reported training more than 4,700 Afghan government officials and privatesector staff in technical and organizational development, land law procedures, land rights, and using land 

survey equipment. 

We found that USAID and Tetra Tech ARD designed LARA to consider some elements of sustainability and to 

address some sustainment objectives. For example, the contract had detailed sustainment plans for 

formalizing and upgrading informal settlements; contract language that stated legal reforms will be embedded 

within institutions, especially training institutions to ensure sustainability; and a capacity-building objective that 

included management training, IT systems installation and related training, and “train the trainer” efforts that 

were intended to enable Arazi and other Afghan ministries to sustain program activities after LARA ended.50

However, USAID did not fully address other requirements in the 2011 sustainability guidance, such as that 

sustainability assessments include an “examination, both immediate and ongoing, of all USAID Mission for 

Afghanistan projects against the principles of 1) Afghan ownership and capacity; 2) their contribution to 

transition and confidence; and 3) cost effectiveness and program effectiveness.” USAID completed an initial 

sustainability assessment in June 2012 of all of its programs in Afghanistan, in which it stated that LARA “most 

closely emulate[s] the standards that USAID seeks to promote in all of its programming” about sustainability.51

However, this analysis primarily addressed whether LARA’s overall program design met agency sustainability 

standards and did not discuss whether the Afghan government could sustain ongoing program efforts, as 

required by the 2011 guidance. Moreover, USAID did not conduct subsequent, sustainability assessments that 

address all the requirements in the 2011 sustainability guidance for LARA between June 2012 to the close of 

the program in November 2014, which amounted to a majority of the program’s implementation period. In its 

January 2017 response to our draft report, USAID/Afghanistan stated that Checchi’s November 2014 final 

performance evaluation of LARA, completed upon the program’s conclusion, represented the agency’s 

sustainability assessment, in accordance with the June 2011 Administrator’s Sustainability Guidance for

USAID in Afghanistan.52 However, we maintain that USAID did not fully address the requirements in the 2011 

sustainability guidance. For example, the 2014 final performance evaluation does not provide an 

“examination, both immediate and ongoing” of the LARA program’s “cost effectiveness and program 

effectiveness” and does not “estimate all recurrent costs [for LARA] required to maintain the services, 

infrastructure, and institutions, as well as ongoing capacity building investments...[and/or] Develop plans in 

partnership with GIRoA [Government of the Islamic Republic of Afghanistan], and other donors to ensure such 

costs are priorities and are within budgets in a scarce resource environment,” all of which the guidance 

 

50 Based on our analysis and interviews, we found that Tetra Tech ARD produced several documents aimed at sustaining 

LARA efforts, such as an Arazi IT operations sustainability plan, a private sector needs assessment, an Arazi institutional 

core competencies framework, and an informal settlement upgrading handbook. In addition, LARA’s initial 2011 work plan 

described upgrading Afghan government strategies and plans, improving legal frameworks for urban planning, increasing 

ministerial revenues, and reforming processes related to land rights and record keeping.

51 USAID, USAID/Afghanistan Sustainability Report, Part 1, June 2012.

52 Checchi and Company Consulting Inc., Land Reform in Afghanistan Final Performance Evaluation, November 2014.
SIGAR 17-27-AR/Land Reform Page 12

requires.53 Without such assessments, the U.S. government has less insight into whether the reported 

achievements associated with its $41.2 million investment in land reform can be maintained. 

CHALLENGES THREATEN THE SUSTAINABILITY OF USAID’S LAND REFORM 

EFFORTS, INCLUDING ACTIVITIES COMPLETED UNDER LARA

USAID officials, Tetra Tech ARD, and Afghan government officials told us that systemic challenges in land 

reform affected LARA during its implementation and pose a threat to sustaining the program’s activities. The 

sustainability of the program’s legal reform and capacity-building efforts, such as the establishment of land 

management IT systems, are particularly threatened. The challenges include (1) political and judicial 

corruption; (2) an underdeveloped legal system and lack of enforcement mechanisms to support land laws and 

property rights; and (3) a lack of Afghan government technical capacity, including the ability to use land 

administration IT systems. Currently, the U.S. government does not have any programs planned to continue to 

support land reform in Afghanistan, placing the onus solely on the Afghan government to address these 

problems. 

Political and Judicial Corruption Prevent Land Reform Efforts from Being Sustained 

We found that endemic corruption remains a significant obstacle to land reform. Both the MEC report and a 

senior Arazi official told us that private citizens and many current and former members of the Afghan 

government, including judges, ministers, and parliamentarians, have stolen public and private land, or have 

been involved in facilitating corruption and fraud in the land titling process.54 Land reform experts, senior 

Afghan officials with Arazi and the Independent Directorate of Local Governance, and a U.S. official in the 

Department of State’s Office of the Special Representative for Afghanistan and Pakistan told us that because 

many powerful Afghans, such as warlords and government officials, have connections to the Afghan Parliament 

and the judiciary, the government has had little incentive to tackle corruption or enact new anti-land theft 

legislation developed with LARA support. A senior Arazi official said approximately 60 percent of all corruption 

in the Afghan judiciary involves land ownership. 

The 2014 MEC report states that land grabbing remains rampant and the government has lacked the political 

will over the past decade to address corruption, land theft, and land reform.55 In addition, Tetra Tech ARD 

officials told us that while a few Afghan officials they worked with on LARA were highly receptive to reform, 

many other officials, including some at the Supreme Court, lacked the will to implement and sustain the 

technical changes the contractor proposed to prevent corruption. 

Senior Afghan officials with Arazi and the Independent Directorate of Local Governance told us the focus on 

land reform at various levels of the government is increasing. They pointed to support for land reform and 

fighting corruption from the Afghan President and some ministers, including frequent discussion of land reform 

issues in cabinet-level meetings with the President. However, none of the Afghan officials we met with provided 

specific examples of key actions taken to counter the challenges political and judicial corruption pose for land 

reform efforts. 

 

53 USAID, Administrator’s Sustainability Guidance for USAID in Afghanistan, June 2011.

54 Independent Joint Anti-Corruption Monitoring and Evaluation Committee, Report of the Public Inquiry into Land 

Usurpation, November 2014.

55 Independent Joint Anti-Corruption Monitoring and Evaluation Committee, Report of the Public Inquiry into Land 

Usurpation, November 2014.
SIGAR 17-27-AR/Land Reform Page 13

Afghan Legal System Is Underdeveloped and Has Weak Enforcement Mechanisms 

to Support Land Laws and Property Rights 

The Department of State’s June 2015 Afghanistan Climate Statement report lists obstacles to growth in 

Afghanistan, including “underdeveloped and irregularly implemented” legal and regulatory frameworks and 

enforcement mechanisms that are plagued by corruption, bureaucratic delays, anticompetitive behaviors aided 

by wealth and social connections, and weak property-rights protection; lack of capacity within commercial 

courts; and corruption.56 Similarly, a 2014 U.S. Institute of Peace report on land titling in Kunduz province 

found that Afghan citizens viewed the institutions responsible for land titling and managing land conflicts as 

having performed poorly on land administration and records management. As a result of these systemic 

deficiencies, Afghan citizens—such as those not possessing formal proof of ownership to land from Afghan 

courts—have sought recourse from “informal” approaches to recording land ownership, such as acquiring 

customary documents provided by a shura, which are widely used yet not legally binding under constitutional 

law. 

Afghanistan’s underdeveloped legal system places past efforts by the LARA program to develop the Afghan 

government’s land administration capacity and enact land rights legislation at risk of quickly being undone. For 

example, according to Tetra Tech ARD and Afghan officials, the program helped the Afghan government 

develop two draft laws on improving urban planning and regulating land use. However, to date, the Parliament 

has not enacted those laws. In addition, according to the 2015 Afghanistan Climate Statement, some 

enforcement mechanisms, such as “government officials [who] levy unofficial taxes and inflict bureaucratic 

delays in order to engage in corrupt practices,” jeopardize land laws and continue to threaten LARA’s efforts to 

improve the protection of current property rights, such as women’s inheritance rights. According to an Afghan 

official in the Independent Directorate of Local Governance, the Afghan government is now discussing how to 

create revenue through tax and penalties for stolen land, in particular the land stolen by warlords who are not 

developing the land. However, it will be difficult for the Afghan government to collect from the warlords due to 

corruption and delays within enforcement mechanisms. 

Afghan Government Officials Working in Land-Related Ministries Lack Technical 

Capacity, Hampering Their Ability to Use IT Systems Established under LARA 

As part of the LARA contract, Tetra Tech ARD and one of its subcontractors, Thomson Reuters, developed the 

$2.8 million Arazi Land Records Management Information System (ALRMIS) to increase transparency and 

security of land records. However, an Arazi official and Tetra Tech ARD contractors working on LARA told us 

that Arazi officials lack the technical ability to use land registration IT systems established by the program.57

Specifically, they told us that ALRMIS was no longer in use, and Arazi did not have plans to use it in the future. 

Arazi officials said ALRMIS was “too complicated” and not properly designed to meet the needs of the Afghan 

staff who have low technical capacity and knowledge of IT systems and software. For example, Arazi staff could 

not fix small errors they encountered in the software without technical assistance. Additionally, an Arazi official 

said the agency could not afford to maintain the system. Despite conducting training on how to use ALRMIS, 

Tetra Tech ARD and Thomson Reuters’ management agreed that Afghan officials still lacked the technical 

capacity to use the system. 

 

56 Department of State, Afghanistan Investment Climate Statement, June 2015. 

57 The purpose of IT systems, such as ALRMIS, is to provide a land administration IT platform that provides increased 

transparency and security of property records, reduces opportunities for administrative corruption, contributes to the 

streamlining of procedures and processes, and enables increased government revenue collection and management from 

the land sector.
SIGAR 17-27-AR/Land Reform Page 14

Additionally, an Arazi official told us the agency would like an assessment to determine whether ALRMIS can be 

modified or another system should be created in the future to better meet the needs and capabilities of Arazi 

staff. Arazi also has plans to help address the challenge of low technical capacity in the land sector by creating 

an Institute for Land Administration, with a goal of establishing a 2-year program for land administration and 

reform in Kabul and other regions of the country. In addition, many employees who worked on LARA and its 

predecessor, the Land Titling and Economic Restructuring in Afghanistan program, have joined Arazi and other 

land-related ministries, boosting their technical capacity. However, an Arazi official said they have not yet 

identified funding to support future IT efforts. 

Although USAID is funding projects related to and supporting land issues, such as the Strong Hubs for Afghan 

Hope and Resilience project, USAID and U.S. Embassy in Kabul officials told us they do not have any current or 

future programs that specifically focus on land reform.58 Therefore, it remains to be seen whether the U.S. 

government will continue to assist the Afghan government with addressing land reform sustainment challenges 

in the future. 

CONCLUSION

USAID has supported land reform in Afghanistan on the basis that it will help promote economic growth and 

help secure the rights of Afghans to inherit and own land. From January 2011 through November 2014, USAID 

implemented LARA to support land reform efforts, including helping the Afghan government map plots of land 

to show ownership and value, and establishing laws to identify, manage, and obtain revenue from government 

lands. However, USAID does not know the full extent to which LARA achieved its goals and objectives. USAID’s 

incomplete effort in assessing LARA’s performance leaves the agency without a sound basis to fully determine 

its return on a $41.2 million investment.

Although the U.S. government does not have any plans to undertake future land reform programs in 

Afghanistan, its work under LARA remains unfinished and the funds spent on that program may end up being 

wasted, given that USAID did not follow all of its legislative and internal requirements for conducting

sustainability assessments during the implementation and at the conclusion of the LARA program. Although we 

recognize the difficulties in conducting sustainability assessments in Afghanistan, the assessments would not 

only give USAID a better understanding of the outcomes, impact, and lessons learned from its efforts, but 

would also help determine whether the Afghan government will continue LARA’s stated achievements in land 

reform.

RECOMMENDATIONS

To better understand the impact of the LARA program on land reform efforts in Afghanistan, SIGAR 

recommends that the USAID Administrator: 

1. In accordance with all of the requirements of the June 2011 Administrator’s Sustainability Guidance 

for USAID in Afghanistan, conduct a final sustainability assessment of the LARA program to fully 

determine whether sufficient capacity exists for the Afghan government to sustain the program’s 

achievements, and provide the results to the Afghan government. 

 

58 The objective of the $38 million Strong Hubs for Afghan Hope and Resilience project is to create well-governed, fiscally 

sustainable Afghan municipalities capable of meeting the needs of a growing urban population.
SIGAR 17-27-AR/Land Reform Page 15

AGENCY COMMENTS 

We provided a draft of this report to USAID for review and comment. USAID/Afghanistan provided written 

comments, which are reproduced in appendix IV. 

USAID did not concur with our recommendation. USAID stated that it believes its contractor’s—Checchi and 

Company Consulting Inc.—November 2014 final performance evaluation of LARA “sufficiently provides 

recommendations for improving the Afghan institution’s capacity to sustain the LARA Project achievements.” 

USAID further stated that this final performance evaluation is evidence that USAID conducted “subsequent 

sustainability assessments of LARA between June 2012 to the close of the program in November 2014” and 

requested we remove a sentence in our draft audit report that states otherwise. USAID also broadly 

summarized Checchi’s recommendations for the Afghan government and stated that Arazi has increased its 

annual revenue stream, “provided support to the private sector and contributed to a decrease in landgrabbing.” USAID also noted that the “Cabinet” approved Afghanistan’s National Land Management Law, but it 

has not yet been enacted. 

During the course of our audit, USAID did not provide additional sustainability assessments upon our multiple 

requests and did not characterize Checchi’s final performance evaluation as a sustainability assessment in 

response to these requests. Furthermore, during a discussion of our audit findings in October 2016, the 

agency did not challenge our finding that USAID did not conduct a sustainability assessment between June 

2012 and November 2014. Despite this, based on the agency’s comments, provided in January 2017, we 

reassessed Checchi’s 2014 report to determine if the report meets the 2011 sustainability guidance. This 

assessment confirmed our finding that USAID did not fully address the requirements of its 2011 sustainability 

guidance. For example, Checchi’s 2014 final performance evaluation does not provide an “examination, both 

immediate and ongoing” of the LARA program’s “cost effectiveness and program effectiveness,” as required by 

the guidance. As we already stated, Checchi reported that it could not fully assess the LARA program’s 

performance—and therefore program effectiveness—because of limited or no access to contractor records. We 

also determined that the report does not “estimate all recurrent costs [for LARA] required to maintain the 

services, infrastructure, and institutions, as well as ongoing capacity building investments...[and/or] Develop 

plans in partnership with GIRoA [Government of the Islamic Republic of Afghanistan], and other donors to 

ensure such costs are priorities and are within budgets in a scarce resource environment,” which are 

requirements in the guidance. As such, we maintain that USAID has not fulfilled its 2011 sustainability 

guidance requirements, thus justifying our recommendation. However, we modified the recommendation to 

better reflect the need for the agency to meet all of the guidance’s requirements. 
SIGAR 17-27-AR/Land Reform Page 16

APPENDIX I - SCOPE AND METHODOLOGY 

This audit examined the U.S. Agency for International Development’s (USAID) efforts to support land reform 

efforts in Afghanistan from 2004 through 2014, with a focus on the Land Reform in Afghanistan (LARA) 

program, implemented by Tetra Tech ARD from January 2011 to November 2014. The objectives of this audit 

were to determine the extent to which (1) USAID and Tetra Tech ARD measured the LARA program’s 

performance and whether it achieved its goals and objectives; (2) USAID conducted its required oversight of 

the contract; (3) USAID and Tetra Tech ARD designed and assessed LARA’s sustainability; and (4) the 

challenges USAID, Tetra Tech ARD, and the Afghan government faced threaten the sustainment of U.S. land 

reform efforts. 

For all of the objectives, we interviewed current and former agency officials from the Department of State, 

USAID, and the U.S. Embassy in Kabul. With respect to the Department of State, we met with officials from the 

Office of the Special Representative for Afghanistan and Pakistan and the Office of the Coordinating 

Directorate for U.S. Embassy Kabul. For USAID, we interviewed officials from the Office of Afghanistan and 

Pakistan Affairs, and the USAID Mission for Afghanistan’s Office of Economic Growth and Infrastructure and 

Office of Acquisition and Assistance. We also interviewed officials from Tetra Tech ARD and Thomson Reuters, 

one of its subcontractors; Afghan government officials agencies from the Afghan Land Authority, commonly 

referred to as Arazi, and the Independent Directorate of Local Governance; and nongovernmental

organizations’ staff from the Afghan Land Consulting Organization and the Afghan Women’s Network. 

Additionally, we interviewed land reform experts that we identified through independent research of land 

reform and land-related issues in Afghanistan from the Fletcher School at Tufts University and the U.S. Institute 

of Peace, and the international organization United Nations Human Settlements Programme. We also collected 

information from these sources through requests for information and additional independent research. 

To determine the extent to which USAID and the contractor measured the program’s performance and can 

determine the extent to which the goals and objectives were met, we requested information from USAID and 

Tetra Tech ARD to identify LARA’s goals and objectives, obtain performance documents on the program, and 

understand how USAID and Tetra Tech ARD assessed performance. We reviewed Tetra Tech ARD’s, Ernst & 

Young’s, and Checchi and Company Consulting Inc.’s evaluations of LARA.59 In addition, we followed up on the 

findings from Checchi’s final performance evaluation to verify Tetra Tech ARD training and workshop reco rds. 

We assessed USAID and Tetra Tech ARD performance monitoring activities against the Federal Acquisition 

Regulation (FAR), USAID’s Automated Directives System (ADS) Chapter 203, and LARA contract requirements 

describing how the performance monitoring should be conducted. We also analyzed Tetra Tech ARD’s 

performance monitoring plan and final report to determine the extent to which the contractor measured and 

reported on all of LARA’s performance indicators. 

To determine the extent to which USAID completed its required oversight activities of the contractor, we 

reviewed the LARA contract and contract modifications to identify the list of deliverables that Tetra Tech was 

required to provide USAID to assess the contractor’s level of compliance with the contract and the extent of 

USAID oversight.60 For our analysis, we focused on nine deliverables the contractor had to produce to help 

ensure the LARA program met its objectives. There were two additional deliverables included in the contract, 

 

59 Tetra Tech ARD, Land Reform in Afghanistan (LARA) -- Final Report, November 2014; Ernst & Young, Regulatory 

Compliance (Vetting and Procurement) Review of USAID Afghanistan Awards – Land Reform in Afghanistan (LARA), July 

2012; Checchi and Company Consulting Inc., Land Reform in Afghanistan Mid-term Evaluation, March 2013; and Checchi 

and Company Consulting Inc., Land Reform in Afghanistan Final Performance Evaluation, November 2014.

60 In September 2015, we completed a financial audit of the costs Tetra Tech ARD incurred under the LARA contract. We 

did not identify any material weaknesses or significant deficiencies in Tetra Tech ARD’s internal controls, or instances of 

noncompliance with the terms and conditions of the contract. As a result, we did not identify any question ed costs or make 

any recommendations to USAID. See SIGAR, USAID’s Land Reform in Afghanistan Program: Audit of Costs Incurred by Tetra 

Tech ARD, SIGAR 15-88-FA, September 28, 2015.
SIGAR 17-27-AR/Land Reform Page 17

but they were for reporting repetitive information into two different databases USAID used to track program 

activities. USAID provided us evidence that the contractor met these requirements, but we did not conduct an 

in-depth analysis of this information because it repeated what was included in the nine deliverables we did 

review. Therefore, we did not include these two additional deliverables in our analysis. In addition to the 

reports required in the contract, we used the contracting officer’s representative LARA Activity Tracker, which 

USAID developed to identify what deliverables Tetra Tech ARD was to provide to USAID, as required by the 

contract. We then reviewed USAID documentation explaining or demonstrating the oversight USAID performed 

of Tetra Tech ARD and compared the evidence against application sections of the FAR, which lays out 

government contracting requirements for a contractors implementing contracts and the government agency’s 

management and oversight of the contracts, and USAID’s ADS, which provides further guidance on contract 

planning, implementation, performance, and oversight. With respect to the ADS, we specifically referred to 

Chapter 200, “Introduction to Programming Policy,” and Chapter 203, “Assessing and Learning,” to understand 

the extent to which USAID completed required oversight. 

To determine the extent to which USAID and the contractor designed and assessed LARA for sustainability, as 

required, and USAID, the contractor, and the Afghan government identified and overcame challenges to help 

sustain LARA’s efforts to date, we interviewed USAID and Afghan government officials, Tetra Tech ARD 

contractors, and land reform experts to identify assessments or evaluations regarding the sustainability of 

LARA and challenges to sustaining LARA efforts and land reform in Afghanistan. We identified LARA contract 

and USAID requirements for sustaining program activities. We obtained documentation and records from 

USAID and Tetra Tech ARD regarding their approach to sustainability in the LARA program. Through interviews 

and document analysis, we determined whether USAID and Tetra Tech ARD met the requirements of the 

Administrator’s Sustainability Guidance for USAID in Afghanistan, June 2011. We then determined the extent 

to which USAID ensured the Afghan government intended to and was prepared to sustain LARA’s efforts 

through document analysis and interviews with Tetra Tech ARD, USAID, and Afghan government officials. 

Finally, we identified the challenges USAID and Tetra Tech ARD reported in conducting and sustaining LARA 

program efforts, and assessed if and how USAID and Tetra Tech ARD have addressed those challenges. 

We utilized some computer-processed data from USAID to identify the programs the agency implemented from 

2004 through 2014 that supported land reform efforts in Afghanistan. We determined the data was sufficiently 

reliable for the purposes of this audit by corroborating information USAID provided us with other sources, such 

as the contract and modifications, and interviews with agency officials. We also assessed internal controls to 

determine the extent to which the agencies had systems in place to oversee and report on their efforts 

specifically supporting the land reform efforts in Afghanistan. The results of our assessment are included in the 

body of the report. 

We conducted our work in Kabul, Afghanistan; Burlington, VT; and Washington, D.C., from May 2015 through 

February 2017 in accordance with generally accepted government auditing standards. Those standards 

require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our audit objectives. This audit was 

performed by SIGAR under the authority of Public Law No. 110-181, as amended, and the Inspector General 

Act of 1978, as amended. 
SIGAR 17-27-AR/Land Reform Page 18

APPENDIX II - LIST OF ALL LARA PERFORMANCE INDICATORS AND THEIR 

STATUS 

In total, the U.S. Agency for International Development (USAID) and Tetra Tech ARD identified 35 performance 

indicators to be monitored, evaluated, and reported on in the final report on the Land Reform in Afghanistan 

(LARA) program.61 See table 2 for information on the 29 indicators Tetra Tech ARD reported on in the LARA 

final report and table 3 for the 6 indicators on which it did not report. 

Table 2 - Description of LARA Performance Indicators Reported on in the LARA Final Report and Their Status

 

61 Tetra Tech ARD’s final report on LARA included35 performance indicators from the contractor’s USAID-approved final 

performance monitoring plan, dated October 2012. However, neither Tetra Tech ARD nor USAID measured six of these 

indicators.
SIGAR 17-27-AR/Land Reform Page 19

Source: SIGAR analysis of information provided by USAID and Tetra Tech ARD

* We took the baselines and targets from Tetra Tech ARD’s final performance monitoring plan, unless the indicator was only 

noted in the initial performance monitoring plan. In the latter cases, we got the baselines and targets from the original 

performance monitoring plan.

a We were unable to determine whether Tetra Tech ARD met the target because it was partially met. An IT system was 

developed; however, it was also partially not met because the IT system was not operational.

b We could not determine whether Tetra Tech ARD met the target because the unit of measurement changed from number 

of people to percentage increase.
SIGAR 17-27-AR/Land Reform Page 20

Table 3 - Description of LARA Performance Indicators Not Reported on in the LARA Final Report 

and Their Status

Source: SIGAR analysis of information provided by USAID and Tetra Tech ARD

Note: *Tetra Tech ARD reported in the final report that it did not have final data for these six indicators.
SIGAR 17-27-AR/Land Reform Page 21

APPENDIX III - DEFINING TERMS USED IN LAND ADMINISTRATION AND LAND 

REFORM 

The United States’ and other donors’ land reform efforts in Afghanistan have sought to address multiple legal, 

technical, and capacity-building challenges the Afghan government faces in land administration, land tenure, 

and land rights, as well as building land markets.62 Figure 1 lists the United Nations’ definitions of common 

land administration and land reform terms. 

Figure 1 - United Nations Definitions of Commonly Used Terms in Land 

Administration and Reform 

Source: Food and Agriculture Organization of the United Nations, Land Tenure and Rural 

Development, Chapter 3, “What Is Land Tenure,” Rome, 2002.

Note: The definitions reprinted here cover a broad range of activities that fall under land 

reform efforts. We use the term “land reform” in this report to refer to the U.S. Agency for 

International Development’s efforts, including the redistribution of property rights and 

land; land administration, for example, surveying land, recording land plots, issuing titles

and digitizing records into databases; and land tenure and other legislation related to 

land rights and land laws.

 

62 U.S. Agency for International Development, Land Reform in Afghanistan Overview, December 2013.
SIGAR 17-27-AR/Land Reform Page 22

APPENDIX IV - COMMENTS FROM THE U.S. AGENCY FOR INTERNATIONAL 

DEVELOPMENT 
SIGAR 17-27-AR/Land Reform Page 23

SIGAR Comment 1

SIGAR Comment 2

SIGAR Comment 3
SIGAR 17-27-AR/Land Reform Page 24
SIGAR 17-27-AR/Land Reform Page 25

SIGAR Response to USAID Comments 

SIGAR Comment 1. We reviewed the U.S. Agency for International Development’s (USAID) “broadly 

summarized” programmatic recommendations. However, it is not clear to us what specifically USAID is 

highlighting and summarizing from Checchi’s evaluation or how this addresses the requirements in USAID’s 

2011 sustainability guidance. Furthermore, the recommendations included in the 2014 evaluation do not 

address our concerns that a sustainment assessment was fully conducted. 

SIGAR Comment 2. USAID states that “ARAZI is generating its own annual revenue stream, which has 

increased...” However, USAID did not explain whether this revenue stream is adequate to fund and sustain 

Land Reform in Afghanistan (LARA) activities, such as the Arazi Land Records Management Information System 

(ALRMIS) IT system to ensure the security of land records. Without an assessment of revenues and 

expenditures, USAID does not know if Arazi can sustain LARA’s achievements. 

SIGAR Comment 3. In response to USAID’s comment, we have modified the sentence to say “USAID did not 

conduct subsequent sustainability assessments that address all of the requirements in the 2011 sustainability 

guidance for LARA between June 2012 to the close of the program in November 2014, which amounted to a 

majority of the program’s implementation period.” 
SIGAR 17-27-AR/Land Reform Page 26

APPENDIX V - ACKNOWLEDGMENTS 

Eugene Gray, Senior Program Manager 

James Smith, Analyst-in-Charge 

Michael Graham, Senior Program Analyst 
SIGAR 17-27-AR/Land Reform Page 27

This performance audit was conducted 

under project code SIGAR-108A.
Obtaining Copies of SIGAR 

Reports and Testimonies

To Report Fraud, Waste, and 

Abuse in Afghanistan 

Reconstruction Programs

Public Affairs

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The mission of the Special Inspector General for Afghanistan 

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