SIGAR Audit-10-13 Development/Women and Girls

OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR AFGHANISTAN RECONSTRUCTION

Greater Coordination Needed in Meeting Congressional 

Directives to Address and Report on the Needs of 

Afghan Women and Girls

July 30, 2010
SIGAR Audit-10-13 Development/Women and Girls Page i 

OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR AFGHANISTAN RECONSTRUCTION

July 30, 2010

The Honorable Hillary R. Clinton

U.S. Secretary of State

The Honorable Robert Gates

U.S. Secretary of Defense

The Honorable Karl Eikenberry

U.S. Ambassador to Afghanistan

Dr. Rajiv Shah 

Administrator

U.S. Agency for International Development

Mr. Earl Gast

Mission Director to Afghanistan

U.S. Agency for International Development

This report discusses the results of SIGAR’s review of appropriated funds earmarked for Afghan women 

and girls’ activities. This report includes recommendations to ensure the needs of Afghan women and 

girls are addressed as intended in the congressional directives.

A summary of this report is on page ii. This performance audit was conducted by the Office of the 

Special Inspector General for Afghanistan Reconstruction under the authority of Public Law No. 110-181

and the Inspector General Act of 1978, as amended. When preparing the final report, we considered 

comments from the U.S. Embassy Kabul, Department of State, and U.S. Agency for International 

Development. In their comments, State and USAID concurred with the four recommendations in this 

report. A copy of the comments is included in appendix VI. 

John Brummet

Assistant Inspector General for Audits

Office of the Special Inspector General 

 for Afghanistan Reconstruction
SIGAR Audit-10-13 Development/Women and Girls Page i 

 Special inspector General for Afghanistan Reconstruction

i

.

`

 

What SIGAR Reviewed 

From 2003 to 2010, Congress earmarked $627 million in appropriated funds to address the needs of Afghan women and 

girls. Congress also directed the Department of State to report on the use of these funds. This report assesses (1) the 

approach State and the U.S. Agency for International Development (USAID) used to attribute and report on the use of 

funds covering activities for Afghan women and girls during fiscal years 2008 and 2009, (2) the extent to which specific 

earmarks to certain organizations met congressional directives, and (3) whether reported activities were consistent with 

Afghan national strategies, including the National Action Plan for the Women of Afghanistan (NAPWA) which the U.S. 

supports. We analyzed legislation pertaining to Afghan women and girls and reviewed the 2008 and 2009 reports 

submitted to Congress describing U.S.-funded activities for women and girls in Afghanistan. We discussed the earmark 

attributions and reported activities with officials from USAID, State, and the government of the Islamic Republic of 

Afghanistan. We conducted our work in Kabul, Afghanistan, and Washington, D.C., from November 2009 to July 2010 in 

accordance with generally accepted government auditing standards. 

 SIGAR Special Inspector General for Afghanistan Reconstruction

What SIGAR Found 

State and USAID did not coordinate their approach to reporting on the use of funds earmarked for Afghan women and girls. 

The reports submitted to Congress in 2008 and 2009 did not provide complete and consistent information about the 

reported activities in which women and girls were intended beneficiaries, such as relating the activities to numbers of 

female beneficiaries or services provided. Although State and USAID took action in the past year to coordinate genderrelated issues in Kabul, State did not develop guidelines or a rationale for determining and reporting earmark attributions.

As a result, the reports to Congress did not provide a clear picture of how the funds were used to address the needs of 

Afghan women and girls. 

State and USAID partially met specific congressional directives, which directed support to organizations such as the Ministry 

of Women’s Affairs (MoWA), the Afghanistan Independent Human Rights Commission, and Afghan women-led nongovernmental organizations and civil society organizations. MoWA, for example, did not receive appropriated funds in each 

year in which it was mentioned in legislation. 

Although U.S. policy is to support women’s rights and Afghanistan national strategies, the 2009 report did not show 

linkages between U.S.-funded activities and Afghan goals and benchmarks detailed in the NAPWA—a key benchmark of the 

Afghan government through which the Afghanistan government seeks to realize its gender equity goals. Such linkage is 

important to ensure that the reported activities address the needs of Afghan women and girls. 

SIGAR Audit-10-13 July 2010

Greater Coordination Needed in Meeting Congressional 

Directives to Address and Report on the Needs of Afghan 

Women and Girls

What SIGAR Recommends 

SIGAR recommends that the Secretary of State, in consultation with the USAID Administrator: (1) develop consistent 

reporting requirements for all USAID and State programs and activities to provide data on female beneficiaries and 

measurable impacts of activities intended to address the needs of Afghan women and girls; (2) develop a coordinated 

approach for determining the earmark attribution amounts and reporting on the use of earmarked funds that provides 

consistent information about each activity, identifies funding sources, and provides the rationale for reporting activities; 

(3) align activities to ensure consistency with the goals and benchmarks stated in the U.S.-supported Afghanistan’s national 

strategies, particularly the NAPWA; and (4) target funds to address the organizations specified in the legislation, including 

MoWA, the Afghanistan Independent Human Rights Commission, and Afghan women-led non-governmental organizations

and civil society organizations to ensure appropriated funds are used as directed by Congress and address the needs of 

Afghan women and girls.

In response to a draft of this report, State and USAID concurred with SIGAR’s recommendations.

For more information contact: SIGAR Public Affairs at (703)602-8742 or PublicAffairs@sigar.mil
SIGAR Audit-10-13 Development/Women and Girls Page ii

TABLE OF CONTENTS

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

State Did Not Coordinate With USAID On An Approach to Report and Attribute 

Earmarks for Activities to Address the Needs of Afghan Women and Girls......................................... 5

Specific Earmarks to Designated Afghan Organizations Partially Met Congressional 

Directives.............................................................................................................................................10

Reported Activities for Women and Girls Are Not Aligned With Afghanistan’s 

National Strategies..............................................................................................................................14

Conclusion...................................................................................................................................................15

Recommendations......................................................................................................................................16

Comments...................................................................................................................................................16

Appendix I: Scope and Methodology.........................................................................................................17

Appendix II: Legislative References to Afghan Women and Girls and Earmark 

Amounts, 2001-2010 .................................................................................................................................. 18

Appendix III: Afghanistan Independent Human Rights Commission Earmarks.......................................... 31

Appendix IV: Ministry of Women's Affairs Earmarks.................................................................................. 32

Appendix V: NGO and CSO Earmarks......................................................................................................... 33

Appendix VI: Comments from Department of State and U.S. Agency for 

International Development......................................................................................................................... 34

TABLES

Table 1: Summary of Earmark Legislation Regarding Afghan Women and Girls, Fiscal 

Years 2003 to 2010................................................................................................................................ 3

Table 2: Reporting Requirements to Describe Use of Funds for Afghan Women and Girls, 

Fiscal Years 2001 - 2010........................................................................................................................ 6

Table 3: Earmark Attributions by Sector for USAID Activities for Afghan Women and 

Girls, Fiscal Years 2008 and 2009.......................................................................................................... 7

Table 4: Programs Pending Approval or Not Started During Fiscal Years 2008 and 2009........................... 8

Table 5: USAID Programs by Sector Showing Earmark Attributions as a Percentage of 

Total Programs, Fiscal Years 2008 and 2009.......................................................................................10

Table 6: ASGP Grants By Amount and Purpose as of March 2010 ............................................................13
SIGAR Audit-10-13 Development/Women and Girls Page iii

ACRONYMS

AIHRC Afghanistan Independent Human Rights Commission

ANDS Afghanistan National Development Strategy

ASGP Ambassador’s Small Grants Program

CSO Civil society organization

ESF Economic Support Fund

INCLE International Narcotics Control and Law Enforcement

I-PACS Initiative to Promote Afghan Civil Society

MoWA Ministry of Women’s Affairs

NAPWA National Action Plan for the Women of Afghanistan

NGO Non-governmental organization

SIGAR Special Inspector General for Afghanistan Reconstruction

USAID U. S. Agency for International Development
SIGAR Audit-10-13 Development/Women and Girls Page 1 

Greater Coordination Needed in Meeting Congressional Directives to Address 

and Report on the Needs of Afghan Women and Girls

From 2003 through 2010, Congress has earmarked $627 million in appropriated funds to address the 

needs of Afghan women and girls and has periodically directed the Department of State to report on the 

use of these funds.1

 Congress has earmarked appropriated funds, in part, to express its concern that, 

without greater attention to the specific challenges facing women and girls in Afghanistan, the country’s 

prospects for broad-based economic growth and democratic development would be sharply reduced, 

according to a 2004 conference report.2

 Although the United States and its allies cited the defense of 

women’s rights as one of the primary reasons for the commitment to rehabilitate Afghanistan after the 

defeat of the Taliban, Afghan women continue to be among the worst off in the world, according to a 

December 2009 Human Rights Watch Report.3

This report assesses (1) the approach State and the U.S. Agency for International Development (USAID) 

used to attribute and report on the use of funds covering activities for Afghan women and girls during 

fiscal years 2008 and 2009, (2) the extent to which specific earmarks to certain organizations met 

congressional directives, and (3) whether reported activities were consistent with U.S. and Afghan 

national strategies, including the National Action Plan for the Women of Afghanistan (NAPWA). 

 This report describes the situation of Afghan women as 

“dismal” in health, education, employment, freedom from violence, equality before the law, and 

political participation. 

We focused our analysis on legislation pertaining to Afghan women and girls from 2001 to 2010 and on 

the State Department’s October 2009 report on U.S.-funded activities for women and girls in 

Afghanistan.4

 We also reviewed a prior report submitted to Congress in October 2008.5

 

1 According to the Glossary of Terms Used in the Federal Budget Process, designating any portion of a lump-sum 

amount for particular purposes by means of legislative language is called “earmarking.”

 Our analysis of 

the prior years’ earmarks and earmark attributions was limited due to a lack of information in the 2008 

report. We discussed the earmark attributions and reported activities with officials from USAID and 

State; the government of the Islamic Republic of Afghanistan, including the Afghanistan Embassy, 

2 Making Emergency Supplemental Appropriations for Defense and for the Reconstruction of Iraq and Afghanistan 

for the Fiscal Year Ending September 30, 2004, and For Other Purposes, Conference Report 108-337 to accompany 

H.R. 3289, October 30, 2004.

3 Human Rights Watch, “Afghanistan: We Have the Promises of the World”: Women’s Rights in Afghanistan, 

December 2009.

4 Department of State, Report on U.S. Government Activities 2008-2009 for Women and Girls in Afghanistan, 

October 20, 2009.

5 Department of State, Report on U.S. Government Activities 2001-2008 for Women and Girls in Afghanistan, 

October 2, 2008.
SIGAR Audit-10-13 Development/Women and Girls Page 2 

Washington, D.C., Ministry of Women’s Affairs (MoWA), and Afghanistan Independent Human Rights 

Commission (AIHRC); and with program managers of four implementing partners. We conducted our 

work in Kabul, Afghanistan, and Washington, D.C., from November 2009 to July 2010 in accordance with 

generally accepted government auditing standards. Appendix I provides a detailed scope and 

methodology.

BACKGROUND 

In December 2001, Congress passed the Afghan Women and Children Relief Act,6 demonstrating the 

U.S. government’s concern for the welfare of Afghan women and children. The Act authorized the 

President “to provide educational and health care assistance to women and children in Afghanistan and 

neighboring countries . . . in a manner that protects and promotes the human rights of all people in 

Afghanistan, utilizing indigenous institutions and nongovernmental organizations, especially women’s 

organizations.” The Act stated that funds were to be made available from the September 2001 

Emergency Supplemental Appropriations Act for Recovery from and Response to Terrorist Attacks on 

the United States,7

In the December 2002 Afghanistan Freedom Support Act,

which appropriated $40 billion for disaster recovery and national security. 

8 Congress stated the U.S. objectives for 

assistance to Afghan women and girls, directing that political and human rights, health care, education, 

training, security, and shelter were areas in which the United States would provide support. The Act 

authorized $20 million for each fiscal year from 2003 to 2006 for MoWA and the National Human Rights 

Commission of Afghanistan.9

In 2003, Congress began earmarking appropriations to address the needs of Afghan women and girls, 

generally, and specifically directed earmarks to certain Afghan organizations. MoWA was specifically 

designated as a recipient of assistance starting in 2003; AIHRC and Afghan women-led nongovernmental organizations (NGOs) and civil society organizations (CSOs) were designated beginning in 

2004.

 

From fiscal years 2003 to 2010, Congress earmarked a total of $627 million in appropriated funds to 

State and USAID to support activities specifically for Afghan women and girls. This report focuses on the 

reported activities for Afghan women and girls during fiscal years 2008 and 2009, which includes $225 

million in appropriated funds. Table 1 shows the specific legislation, earmark amounts, and intended 

purposes of the earmarked funds during that time frame. The table does not include any portion of the 

 

6

 Afghan Women and Children Relief Act of 2001, Public Law 107-81, December 12, 2001. 

7 Emergency Supplemental Appropriations for Fiscal Year 2001, Public Law 107-38, September 18, 2001.

 

8 Afghanistan Freedom Support Act of 2002, Public Law 107-327, December 4, 2002. 

9 The Act authorized $5 million each year for the National Human Rights Commission of Afghanistan and $15 

million for the Ministry of Women’s Affairs from 2003 to 2006. 
SIGAR Audit-10-13 Development/Women and Girls Page 3 

$110 million10

Table 1: Summary of Earmark Legislation Regarding Afghan Women and Girls, Fiscal Years 2003 to 

2010

in fiscal year 2003 funds earmarked for a variety of purposes, which included, but was not 

solely for, Afghan women and girls. The table also does not include all U.S. government-funded 

activities in Afghanistan for women and girls. For example, a total of $34 million was made available to 

provide maternal health services to Afghan women through the Department of Health and Human 

Services from fiscal years 2004 to 2010.

Fiscal 

Year Reference Earmark

($millions) Purpose 

2010 Consolidated 

Appropriations Act, 

2010

$175 Address the needs and protect the rights of Afghan women and 

directly improve the security, economic, and social well-being, 

and political status of Afghan women and girls; including for the 

AIHRC, MoWA and women-led NGOs. Of the $175 million, not 

less than $20 million for capacity building of Afghan women-led 

NGOs and $25 million for programs and activities of such NGOs. 

2009 Making Supplemental 

Appropriations for 

the Fiscal Year ending 

September 30, 2009 

and for other 

Purposes

$150 Address the needs of Afghan women and girls, including for the 

AIHRC, MoWA and women-led NGOs. Of the $150 million, not 

less than $5 million for capacity building of Afghan women-led 

NGOs and $25 million for programs and activities of such NGOs. 

2008 Consolidated 

Appropriations Act, 

2008

$75 Address the needs of Afghan women and girls, including for the 

AIHRC, MoWA, and women-led nonprofit organizations in 

Afghanistan; State Department to provide a report on how 

funds have been used since fiscal year 2002 for each sector, 

amounts provided, types of activities, best practices and 

measurable impacts on Afghan women and girls.

2007 Making further 

continuing 

appropriations for 

the fiscal year 2007, 

and for other 

purposes

$50 Address the needs of Afghan women and girls and provide 

grants of not less than $7.5 million to support training and 

equipment for to improve the capacity of women-led Afghan 

NGOs. $2 million for AIHRC and other Afghan human rights 

organizations.

2006 Making 

Appropriations for 

Foreign Operations, 

Export Financing, and 

Related Programs for 

the Fiscal Year Ending 

September 30, 2006

$50 Address the needs of Afghan women and girls and provide 

grants of not less than $7.5 million to support training and 

equipment for to improve the capacity of women-led Afghan 

NGOs. $2 million for AIHRC and other Afghan human rights 

organizations. 

 

10 Making Further Continuing Appropriations for the Fiscal Year 2003 and for Other Purposes (Conference Report 

108-110) includes $60 million in International Disaster Funds for humanitarian and reconstruction assistance, 

including health and education programs . . . to improve the status of women . . . and for victims of war and 

displaced persons; and $50 million in Economic Support Funds for rehabilitation of primary road . . . and women’s 

development.
SIGAR Audit-10-13 Development/Women and Girls Page 4 

Fiscal 

Year Reference Earmark

($millions) Purpose 

2005 Making 

Appropriations for 

Foreign Operations, 

Export Financing, and 

Related Programs for 

the Fiscal Year Ending 

September 30, 2005

$50 Address the needs of Afghan women and girls; make available 

$2 million for the AIHRC and other human rights organizations; 

provide not less than $7.5 million for small grants to improve 

the capacity of women-led Afghan NGOs and the activities of 

these NGOs. 

2004 Making Emergency 

Supplemental 

Appropriations for 

Defense and for the 

Reconstruction of 

Iraq and Afghanistan 

for the Fiscal Year 

Ending September 

30, 2004

$65 $60 million for Afghan women and girls and $5 million for the 

AIHRC; include the participation of women and advance the 

social, economic and political rights and opportunities of 

women; when possible implement programs by local civil 

society groups. The conferees are concerned that without 

greater attention to the specific challenges facing women and 

girls in Afghanistan, the country's prospects for broad-based 

economic growth and democratic development will be sharply 

reduced.

2004 Making 

Appropriations for 

Agriculture, Rural 

Development, FDA, 

and Related Agencies 

for the Fiscal Year 

ending September 

30, 2004

$5 Address the needs of Afghan women through training and 

equipment to improve the capacity of women-led Afghan NGOs 

and to support the activities of such organizations.

2003 Making Further 

Continuing 

Appropriations for 

the Fiscal Year 2003

$7 Not less than $50 million from Economic Support Funds for 

rehabilitation of primary roads, implementation of the Bonn 

Agreement and women's development, of which not less than 

$5 million is to support activities coordinated by MoWA, 

including the establishment of women's centers. For 

humanitarian and reconstruction assistance including health 

and education programs, housing, to improve the status of 

women, infrastructure and assistance for victims of war and 

displaced persons. Up to $2 million for the National Endowment 

for Democracy to establish a program for women's rights in 

Afghanistan. $60m in International Development Assistance 

funds for humanitarian and reconstruction assistance for the 

Afghan people to include improving the status of women.

Total $627

Source: SIGAR analysis of legislation as noted.

Note: The complete citations for each earmark are provided in appendix II.

An October 1982 USAID policy paper on Women in Development stated that USAID should incorporate 

women into all USAID programs and projects. On March 16, 2008, USAID issued Mission Order 201.02 to 

establish implementation procedures for USAID/Afghanistan budgeting, programming, and reporting 

relative to gender, as well as women’s earmarks as appropriate. Specifically, the order states that 
SIGAR Audit-10-13 Development/Women and Girls Page 5 

USAID/Afghanistan will implement a budgeting process that allocates women’s earmarks at the start of 

each fiscal year’s budgeting cycle. The order also directed that gender, as a cross-cutting issue, shall be 

addressed in all USAID Afghanistan project designs. Furthermore, a gender team was to be established 

to provide guidance, coordination, and support on gender issues throughout programming. To assist 

monitoring, evaluation, and reporting, members of the gender team would, among other activities:

• advise on gender methodologies;

• review planning documents, annual operational plans, and scopes of work for assessments and 

evaluations;

• maintain a centralized list of activities, indicators, and information and data on women-focused 

and gender activities and results; and

• analyze gender indicator data.

This gender team, established in 2008 and led by a USAID advisor on cross-cutting issues (gender 

advisor) includes appointed staff members from each USAID technical office. Each technical office 

director has the responsibility for including women-focused and gender consideration in the Mission’s 

existing and new activities, for budgeting adequately for women and gender, and for addressing 

women’s needs in its programs, action plans, and operational plan. The 2009 conference report also 

directs USAID and the Special Envoy for Afghanistan and Pakistan to consult with the Department of 

State’s Ambassador-at-Large for Global Women’s Issues concerning the use of the $150 million 

earmark.11

STATE DID NOT COORDINATE WITH USAID ON AN APPROACH TO REPORT AND ATTRIBUTE 

EARMARKS FOR ACTIVITIES TO ADDRESS THE NEEDS OF AFGHAN WOMEN AND GIRLS

State did not coordinate with USAID on a standard approach to report on and attribute earmarks to 

address the needs of Afghan women and girls. The reports submitted to Congress in 2008 and 2009 did 

not provide consistent and complete information about the reported activities in which women and girls 

were intended beneficiaries, such as relating the activities to numbers of female beneficiaries or services 

provided. In addition, the reports used different timeframes for and approaches to the data presented. 

Further, although State and USAID took action in 2009 to coordinate gender-related issues in Kabul, 

State did not develop guidelines or a rationale for determining and reporting earmark attributions. As a 

result, the reports to Congress did not provide a clear picture of how the funds were used to address the 

needs of Afghan women and girls.

State Required to Report on Activities for Afghan Women and Girls Since 2001

From 2001 to 2010, Congress requested periodic reporting from State on the use of funds regarding 

Afghan women and girls (as shown in table 2). The first reporting requirement established in 2001 

under the Afghan Women and Children Relief Act directed the Secretary of State to submit a minimum 

of three reports to Congress between 2002 and 2004. However, this reporting requirement was not 

fulfilled by State. State and USAID officials and congressional committee staff members were unable to 

identify any reports prepared and submitted in association with this requirement. In 2008, Congress 

established another reporting requirement for State on the use of funds for Afghan women and girls 

 

11 The 2009 conference report refers to the legislation titled Making Supplemental Appropriations for the Fiscal 

Year Ending September 20, 2009 and for other purposes, Report 111-151, June 12, 2009.
SIGAR Audit-10-13 Development/Women and Girls Page 6 

from 2002 through 2008, to include how funds have been used for each sector, amounts provided, types 

of activities, and best practices and measurable impacts on the livelihood and status of Afghan women 

and girls. A similar requirement was repeated in 2009, to describe the use of funds provided in fiscal 

years 2008 and 2009 to address the needs of Afghan women and girls. In 2010, the requirement was 

expanded to include in the reporting the results to date of efforts undertaken to prevent discrimination 

and violence against women and girls, provide economic and leadership opportunities, and improve 

security for women and girls. Congress also required that State prepare the report in consultation with 

USAID.

Table 2: Reporting Requirements to Describe Use of Funds for Afghan Women and Girls, Fiscal Years 

2001 - 2010

Act Reporting Requirement Report Date

Afghan Women 

and Children 

Relief Act, 2001

Beginning 6 months after the date of enactment of this Act, and at least 

annually for the 2 years thereafter, the Secretary of State shall submit a 

report describing the activities carried out under this Act, including the 

condition and status of women and children in Afghanistan and persons in 

refugee camps while United States aid is given to displaced Afghans.

Reports 

were not 

prepared 

and/or not 

submitted 

to Congress

Consolidated 

Appropriations 

Act, 2008

The Department of State is directed to provide a report as recommended in 

Senate Report 110–128 under the ‘‘Development Assistance’’ heading. The 

report should describe how funds have been used since fiscal year 2002 by 

sector, the amounts provided, types of activities supported, best practices 

identified, and measurable impacts on the livelihood and status of women 

and girls. 

Report 

dated 

October 2, 

2008

Omnibus 

Appropriations 

Act, 2009

The Department of State shall submit a report to the Committees on 

Appropriations not later than September 30, 2009, describing the use of 

funds provided in fiscal years 2008 and 2009 to address the needs of 

Afghan women and girls.

Report 

dated 

October 20, 

2009

Departments of 

Transportation 

and Housing and 

Urban 

Development, 

and Related 

Agencies 

Appropriations 

Act, 2010

Not later than September 30, 2010, the Secretary of State, in consultation 

with the USAID Administrator, shall submit a report to the Committees on 

Appropriations detailing the uses of funds provided in fiscal years 2009 and 

2010 to address the needs and protect the rights of Afghan women and 

girls, including results to date.

Due 

September 

30, 2010

Source: SIGAR analysis of legislation as noted. 

Note: The complete citations for each earmark are provided in appendix II.

State submitted two reports to Congress, one dated October 2008 and another in October 2009. The 

2008 report described activities for women and girls by development sector in a narrative format but did 

not provide a detailed list of activities, the earmarks and funds attributed to them, or funding amounts.

The October 2009 Report on U.S. Government Activities 2008-2009 for Women and Girls in Afghanistan, 

October 20, 2009, used a narrative format but also included an appendix that listed the activities and the 

earmarks attributed to them. The next report is due September 30, 2010, and directs the Secretary of 
SIGAR Audit-10-13 Development/Women and Girls Page 7 

State, in consultation with USAID Administrator, to detail the use of funds provided in fiscal years 2009 

and 2010 to address the needs and protect the rights of Afghan women and girls.

Reports Submitted to Congress in 2008 and 2009 Did Not Provide Consistent and Complete

Information about Activities that Benefitted Women and Girls 

The reports submitted to Congress did not provide consistent and complete information about U.S.-

funded activities that benefitted women and girls. State did not attribute any of the earmarked funds, 

whereas USAID attributed the full earmarks to its activities for Afghan women and girls for fiscal years 

2008 and 2009. USAID reported that as of August 2009, it had spent $78.3 million in fiscal year 2008, 

exceeding the earmark of $75 million for that year. USAID reported that for fiscal year 2009 it spent $60 

million and anticipated spending $93 million for a total of $153 million, exceeding the earmark for that 

year. Table 3 shows the earmark attributions that USAID made by sector for fiscal years 2008 and 2009. 

Table 3: Earmark Attributions by Sector for USAID Activities for Afghan Women and Girls, Fiscal Years 

2008 and 2009

Sector

FY 2008 FY 2009

No. of 

Programs Attribution

No. of 

Programs Attribution

Agriculture and Alternative 

Development 9 $5,260,314 10 $33,088,431

Cross-cutting Programs 2 $19,000,000 2 $24,000,000

Democracy and Governance 8 $12,008,317 12 $18,714,053

Economic Growth 2 $7,050,000 2 $11,000,000

Education 4 $7,076,806 2 $10,375,000

Health 2 $16,058,600 2 $28,294,420

Infrastructure 3 $7,075,930 3 $9,858,898

Provincial Reconstruction Teams 1 $4,800,000 5 $17,700,000

Total 31 $78,329,967 38 $153,030,802

Source: SIGAR analysis and Report on U.S. Government Activities 2008-2009 for Women and Girls in Afghanistan, October 

20, 2009, Department of State and USAID.

In the 2009 report submitted to Congress, State and USAID reported their activities and funds in 

separate sections that used different approaches and timeframes, which presented an incomplete 

picture of the use of funds for fiscal years 2008 and 2009. Although State was not reporting earmarks, it 

provided information by programs within department bureaus. USAID, on the other hand, reported its 

activities by sector, such as alternative development and agriculture, as shown in the table above. 

Although USAID was to allocate women’s earmarks at the start of each fiscal year’s budgeting cycle, 

some of the reported activities included those funded in prior years (2006 and 2007). A USAID official 
SIGAR Audit-10-13 Development/Women and Girls Page 8 

stated that fiscal year allocations are received at the end of the fiscal year; thus, reporting on fiscal years 

2008 and 2009 spending could not technically take place until after fiscal year 2009. The 2009 report, 

therefore, covers many activities that were funded with prior years’ appropriations and includes 

activities that were anticipated to begin in fiscal year 2010. In USAID’s section of the 2009 report, we 

identified six programs that had received earmark attributions in fiscal years 2008 and 2009, but had not 

started by the time the 2009 report was issued. According to USAID officials and details in the 2009 

report, the programs had not been approved, were pending approval, or had not started by the end of 

fiscal year 2009. The earmark attributions for these six programs may have overstated total 

attributions. The programs total $42.3 million, or about 18.8 percent of attributions for fiscal years 2008 

and 2009, as shown in table 4.

Table 4: Programs Pending Approval or Not Started During Fiscal Years 2008 and 2009

Program Fiscal Year 2008 

($millions)

Fiscal Year 2009 

($millions) 

Total ($ millions)

Program/Total Earmark $75.0 $150.0 $225.0

Ambassador’s Small Grant Program $8.3 $10.0 $18.3

Provincial Governors Incentive Fund $0.7 $0.7

Municipal Governance Strengthening Fund $2.0 $2.0

Youth Workforce Development Project $6.3 $6.3

Sustainable Water and Sanitation Program $4.6 $8.3 $12.9

Community Based Stabilization Grants $2.2 $2.2

Total $12.9 $29.4 $42.3

Percentage of Annual Earmark 17% 19.6% 18.8%

Source: SIGAR analysis and Report on U.S. Government Activities 2008-2009 for Women and Girls in Afghanistan, October 20, 

200, Appendix One. 

Note: Discrepancies in addition due to rounding.

Also, although many of the reported activities spanned several years (beyond the 2-year reporting 

window), the report did not include enough detail to identify which activities took place in a particular 

fiscal year or whether the funds were obligated or spent in that year. 

The report did not clearly state whether the funds were Economic Support Fund (ESF) or International 

Narcotics Control and Law Enforcement (INCLE) funds and did not clearly state what amount of these 

funds were spent in which year. According to legislation, the 2009 report should have covered the use of 

(1) $75 million in earmarked appropriated funds in fiscal year 2008, and (2) $150 million in earmarked 

ESF and INCLE appropriated funds in fiscal year 2009.12

 

12 The Omnibus Appropriations Act, 2009 includes an earmark of $100 million for Afghan women and girls, while 

the Supplemental Appropriations Act, 2009, states a $150 million earmark. According to a congressional 

appropriations committee staff member, Congress intended the total earmark to be $150 million, an increase of 

$50 million from the Omnibus Appropriations Act earmark of $100 million.

 In addition, the State Department section of the 

report included activities funded from sources other than INCLE and from fiscal years other than 2008 

and 2009. Other funding sources included Migration and Refugee Assistance funds, funds raised through 

the private sector, and Afghanistan Security Forces Funds transferred from the Department of Defense.
SIGAR Audit-10-13 Development/Women and Girls Page 9 

State Did Not Coordinate with USAID on an Approach to Develop Guidelines for Determining

and Reporting Earmark Attributions

State did not have a process with USAID to develop guidelines or coordinate an approach to determining 

and reporting earmark amounts for fiscal years 2008 and 2009. Although State and USAID took action in 

the past year to coordinate gender-related issues in Kabul through the establishment of an interagency 

group, the group did not participate in determining earmark attributions. The U.S. Embassy, Kabul, 

established an Interagency Gender Policy Working Group around July 2009, chaired by the Coordinating 

Director for Development and Economic Affairs, to strengthen and coordinate gender-related efforts. 

In commenting on a draft of this report, State and USAID proposed creating a Gender Task Force for 

Afghanistan—co-chaired by the Ambassador-at-Large for Women’s Issues and the Embassy’s 

Coordinating Director for Development and Economic Affairs—to improve coordination among agencies 

and offices providing foreign assistance to benefit Afghan women. According to State and USAID, the 

Gender Task Force will be responsible for ensuring coordination of programs and policies affecting 

Afghan women and girls, ensuring that indicators and performance outcomes are consistent with the 

NAPWA, and certifying the creation of a unified tracking mechanism for monitoring progress of 

programs and informing Congress about the use of resources. 

Even though State officials said that not all State activities for Afghan women and girls were included in 

the 2009 report, no explanation was provided in the report as to why certain activities were included 

and others were not. The report included details about, but no earmark attributions for, activities in 

three State bureaus: (1) Bureau of Population, Refugees, and Migration; (2) Bureau for International 

Narcotics and Law Enforcement Affairs; and (3) Bureau of Democracy, Human Rights and Labor, and the 

Office to Monitor and Combat Trafficking in Persons. Total estimated amounts of $10.3 million in fiscal 

year 2008 and $17.4 million in fiscal year 2009 allocated through INCLE to support activities benefitting 

women and girls were listed in a chart, but these amounts were not included in the earmarks.13

According to USAID Mission officials, earmark attributions for USAID-funded activities were made based 

on discussions with gender team members, program and finance officials, gender specialists, and the 

gender advisor. USAID began tracking attributions in 2008 in an earmark “tracker” that was updated 

throughout the year. However, we were unable to correlate information in the tracker with information 

in the 2009 report. 

USAID’s rationale for attributing earmarks to reported activities was unclear. Although USAID’s policy is 

to incorporate gender-related concerns into all its programs, we found that not all USAID programs with 

female beneficiaries received earmark attributions, as might be expected. As shown in table 5, 38 

percent of USAID programs in Afghanistan in fiscal year 2008 and 44 percent in fiscal year 2009 had 

earmark attributions. In the health sector, for example, where it states in the 2009 report that women 

and girls account for 61 percent of outpatient visits and 56 percent of inpatient admissions, 2 of 16 

programs in fiscal year 2008 and 2 of 19 in fiscal year 2009 received attributions. No explanation was 

provided in the report as to why programs with substantial numbers of female beneficiaries did not 

receive attributions.

 

13 INCLE includes $4.2 million in fiscal year 2008 and $2.5 million in fiscal year 2009 transferred from the 

Department of Defense.
SIGAR Audit-10-13 Development/Women and Girls Page 10

Table 5: USAID Programs by Sector Showing Earmark Attributions as a Percentage of Total Programs, 

Fiscal Years 2008 and 2009

Sector

Fiscal Year 2008 Fiscal Year 2009

Total 

Programs 

Programs With 

Attributions

Total 

Programs 

Programs with 

Attributions

Agriculture and Alternative 

Development 20 9 19 10

Cross-cutting Programs 1 *2 2 2 

Democracy and Governance 15 8 14 12

Economic Growth 8 2 7 2 

Education 13 4 12 2 

Health 16 2 19 2 

Infrastructure 7 3 8 3 

Provincial Reconstruction Teams 2 1 6 5 

Total 82 31 87 38

Programs with Earmark 

Attributions (Percentage) 38% 44%

Sources: SIGAR analysis; Report on U.S. Government Activities 2008-2009 for Women and Girls in Afghanistan, October 20, 2009; 

and USAID website: http://afghanistan.usaid.gov/en/Index.aspx, as of March 5, 2010.

Note: Two cross-cutting programs are listed with fiscal year 2008 attributions in the 2009 Report; however, the USAID website 

shows only one cross-cutting program for 2008.

In contrast, one program that represented 20 percent of all fiscal year 2009 attributions did not mention 

women as beneficiaries in USAID documentation describing the program. The program, the Afghanistan 

Vouchers for Increased Productive Agriculture received a $30 million attribution in 2009. The program, 

originally intended to respond to a food crisis in 2007-2008, was revised to undertake cash-for-work 

activities, a small grants program, and agricultural product distribution in two southern provinces in 

which the U.S. military planned a surge.14

SPECIFIC EARMARKS TO DESIGNATED AFGHAN ORGANIZATIONS PARTIALLY MET 

CONGRESSIONAL DIRECTIVES

The legislation specified that certain Afghan organizations receive earmarks of specific amounts. State 

and USAID partially met the 2001 to 2009 congressional directives in their support to activities for 

 

14 USAID Office of the Inspector General, “Audit of USAID/Afghanistan’s Afghanistan Vouchers for Increased 

Productive Agriculture (AVIPA) Program,” Audit Report No. 5-306-10-008-P, April 20, 2010. USAID’s Inspector 

General could not determine the precise number of farmers that had benefited from the activity and did not 

mention women as program beneficiaries.
SIGAR Audit-10-13 Development/Women and Girls Page 11

Afghan women and girls. In 2003 and 2004, legislation began to direct support to two Afghan 

organizations, MoWA and AIHRC, and Afghan women-led non-governmental organizations (NGOs) and 

civil society organizations (CSOs). However, the funding amounts to support these organizations only 

partially met the congressional directives.

Ministry of Women’s Affairs

Since 2003, the Afghan Ministry of Women’s Affairs (MoWA), which has responsibility for implementing 

Afghan government policies to secure and expand the legal rights of women and implement 

government political and social policies, received about $9 million in assistance through USAID. 

Legislation in 2003 directed that MoWA was to receive specific funding of $5 million. From 2008 to 

2009, Congress directed that MoWA was to be assisted with a portion of $225 million earmarked “to 

support programs that directly address the needs of the rights of Afghan women and girls, including . . . 

the Ministry of Women’s Affairs.” 15 Additionally, the Afghanistan Freedom Support Act of 200216

authorized the President to appropriate up to $60 million from 2003 to 2006 to support MoWA, though 

we did not include this amount in the table of earmarked appropriations.17

We identified only two programs totaling approximately $9 million that addressed the directives to 

support MoWA. The first was initiated in January 2003, by USAID’s Office of Transition Initiatives and

included $2.5 million to construct provincial women’s centers. A second program of $6.44 million was 

executed by USAID through a cooperative agreement with the Asia Foundation to implement the 

Ministry of Women’s Affairs Initiative to Strengthen Policy and Advocacy program.

 (Appendix III shows the 

legislation and funding amounts by fiscal year for the earmarks pertaining to the Ministry of Women’s 

Affairs.)

18

Afghanistan Independent Human Rights Commission 

 While the lowest 

threshold of specified funding, $5 million, was surpassed, MoWA did not receive support in each year in 

which it was mentioned in legislation. 

According the AIHRC chairperson, AIHRC received $5 million from USAID in 2004 for the 3-year period

2004 to 2007.19

 

15 The $400 million in earmarked appropriated funds includes $175 million in 2010, $150 million in 2009, and 

$75 million in 2008 (see Appendix III).

However, AIHRC was to receive not less than a total of $11 million from 2004 to 2007, 

according to the legislation. In addition, from 2008 to 2009, the legislation directed that AIHRC was to

be assisted with a portion of $225 million earmarked to “support programs that directly address the 

16 Afghanistan Freedom Support Act of 2002, Public Law 107-327.

17 The authorized funds are not included in the earmarked amounts since we could not identify any related 

appropriated funds.

18 The program began in January 2006 and was extended through January 2011, three years beyond its original end 

date.

19 AIHRC, also formed as a result of the December 2001 Bonn Agreement, is mandated to protect and promote 

rights and freedoms enshrined in Afghanistan’s Constitution, international declarations, international conventions 

on human rights, human rights protocols, and other international human rights instruments.
SIGAR Audit-10-13 Development/Women and Girls Page 12

needs and protect the rights of Afghan women and girls, including for the Afghanistan Independent 

Human Rights Commission.”20 Further, the 2002 Afghanistan Freedom Support Act authorized the 

President to appropriate up to $20 million to support the AIHRC from 2003 to 2006.21

The 2009 report submitted to Congress does not report on any funds provided to AIHRC. The $5 million 

was below the $11 million minimum directed by Congress to support the AIHRC, and AIHRC did not 

receive support in each year in which it was mentioned in legislation.

 Appendix IV 

shows the legislation and funding amounts by fiscal year for the earmarks pertaining to AIHRC. 

22

Afghan Women-Led Nongovernmental Organizations and Civil Society Organizations 

 According to the AIHRC 

chairperson, an additional $100,000 was received from the State Department’s Bureau of International 

Narcotics and Law Enforcement in 2008, but she stated that she had not had meetings or funding 

discussions with U.S. government representatives for several years. In commenting on a draft of this 

report, State and USAID stated that the U.S. government has been advised by the donor group not to 

provide any funds to the AIHRC until issues are resolved regarding the Afghan government’s 

contributions to AIHRC and guarantee of full independence. 

Legislation from 2004 to 2009 directed that a total of $57.5 million be used to support Afghan womenled NGOs and CSOs. In addition, an unspecified amount of the $75 million fiscal year 2008 earmark was 

also to be used to support Afghan women-led NGOs and CSOs. (Appendix V shows the legislation and 

funding amounts by fiscal year for the earmarks pertaining to NGOs and CSOs.) However, the 2009 

report provided a summary of four programs with attributions totaling $15 million. The four programs 

supporting the $15 million earmark, according to the 2009 report, are (1) the Ambassador’s Small Grants 

Program ($10 million); (2) Initiative to Promote Afghan Civil Society ($3 million), (3) Afghanistan Small 

and Medium Enterprise Development Project ($1 million), and (4) Local Governance and Community 

Development Project ($1 million).23

The Ambassador’s Small Grants Program (ASGP) was announced in June 2009 as a $26.3 million program 

to award small grants totaling $8.9 million. The program was re-launched in January 2010 and overall 

funds available were decreased to $20.3 million, according to a State official. Under the ASGP program, 

the implementing partner is to identify women-led and gender-focused organizations lacking capacity 

and award grants, including quick-impact grants of $4,000 to $5,000, based on a 12-step approval 

 

 

20 The $225 million in earmarked appropriated funds includes $150 million in 2009 and $75 million in 2008 (see 

Appendix IV).

21 As with MoWA, we did not include authorized funds in earmark totals.

22 In commenting on a draft of this report, State and USAID noted a $2 million subcontract under USAID’s 

Afghanistan Rule of Law Project that provided salary support to AIHRC staff in fiscal year 2007. This amount was 

not reported in State’s 2009 report.

23 The Omnibus Appropriations Act of 2009, included an earmark of $100 million, of which $15 million was to be 

provided for training and equipment to improve the capacity of women–led Afghan nongovernmental 

organizations, and to support the activities of such organizations. A similar earmark was included in the 

supplemental 2009 appropriations, Making Supplemental Appropriations for the Fiscal Year Ending September 30, 

2009, and for Other Purposes), which directed not less than $5 million for capacity building for Afghan women-led 

NGOs, and not less than $25 million to support programs and activities of such organizations. While the earmarks 

were similar in directives, the amounts and language differed. USAID interpreted and the 2009 report identified 

attributions only for the $15 million earmark.
SIGAR Audit-10-13 Development/Women and Girls Page 13

process. Approvals are to be made by a five-person grant evaluation team at the U.S. Embassy Kabul; a 

seven-person selection committee comprised of USAID, U.S. Embassy Kabul, implementing partner staff, 

and the U.S. Ambassador to Afghanistan. The first five grants were made in January 2010, as shown in 

table 6. 

Table 6: ASGP Grants By Amount and Purpose as of March 2010

Grant Amount Grant Purpose

$4,550 Purchase lace-making equipment for vocational training

$6,400 Purchase 20 milking cows for 40 women

$8,000 Purchase radio equipment to expand coverage for Morning Star Radio 

$7,850 Provide courses on computers and expanded English

$3,140 Provide eye care education

Source: USAID

In commenting on a draft of this report, State and USAID also noted that, as of June 2010, the ceiling on 

ASGP’s funding had been raised by more than $18.6 (from about $20.3 million to about $38.9 million), 

which will allow the program to expand to all 34 provinces in Afghanistan. Direct grants to Afghan 

women-focused NGOs will increase from $8.9 million to $16.9 million. 

USAID’s Initiative to Promote Afghan Civil Society program ($3 million) started in 2005 as a 3-year, $15 

million program.24

For the Afghanistan Small and Medium Enterprise Development Project ($1 million), a substantial 

portion of the funds ($500,000 in fiscal years 2008 and 2009) were provided to support the daily 

operations of one NGO, the Afghan Women Business Federation. The project does not build the capacity 

of multiple NGOs.

 The program surveyed 678 civil society organizations, including nongovernmental 

organizations and shuras, or traditional governing bodies, and based on this information, identified 

those that were women-led organizations and those with a gender focus. Key components of the I-PACS 

program were to select CSOs that had demonstrated potential for providing civil society leadership in 

Afghanistan and to devise effective ways to foster and build their capacity. Over time, the program 

produced a network of CSOs and NGOs. About 121 women-led organizations that have been vetted over 

time are now associated with I-PACS, as of February 2010. 

Local Governance and Community Development Project ($1 million) is a program managed through the 

Provincial Reconstruction Teams in partnership with local communities. Generally, the project is 

intended to strengthen local governments’ capacity for development projects and promote the inclusion 

of women in Provincial Development Councils and government training programs. However, the project 

description did not include specific support to women-led NGOs or CSOs and did not specifically 

mention the extent to which there were female beneficiaries.

 

24 I-PACS funding was increased to $25.5 million as of January 2010 and the program was extended. 
SIGAR Audit-10-13 Development/Women and Girls Page 14

Of the programs listed in the report, the two intended to support capacity building of NGOs and CSOs 

were the (1) Initiative to Promote Afghan Civil Society (I-PACS) and the (2) Ambassador’s Small Grants 

Program. Both programs had similar objectives—to support Afghan women-led NGOs and CSOs and 

provide small grants. Despite having similar objectives, State and USAID officials were unaware of the 

similarity of the programs and did not consult with or use already existing data from the earlier I-PACS 

program to identify potential NGOs and CSOs suitable for participation in ASGP. In commenting on a 

draft of this report, State and USAID noted that the agencies are now engaged in sharing information 

and are collaborating on a regular basis.

REPORTED ACTIVITIES FOR WOMEN AND GIRLS ARE NOT ALIGNED WITH AFGHANISTAN’S 

NATIONAL STRATEGIES

While the United States has a stated policy to support women’s rights, gender integration, and 

Afghanistan national strategies, the 2009 report does not clarify how U.S.-funded activities supported 

these goals, nor does the report provide linkages between U.S.-funded activities and Afghan goals and 

benchmarks detailed in the NAPWA. In addition, the 2009 report reinforces the importance of the 

NAPWA by stating that the “NAPWA enables the United States to ensure that gender-related activities 

support the goals of the Afghan government.”

The reported activities in the 2009 report are not specifically linked to the overall U.S. strategy for 

Afghan women and girls or the Afghan national strategies. In January 2010, the Secretary of State 

outlined a plan to support women’s initiatives in the Women’s Action Plan for Afghanistan, which states 

that the promotion of women’s rights is integrated into the overall U.S. strategy and all key programs. 

The Secretary stated that, “women are key to every element of this agenda—from strengthening the 

economic sector, to promoting good governance, to energizing civil society, to sustaining peace and

security. Progress is not possible if half a country’s population is left behind.” However, when the 

Secretary of State announced the Afghanistan and Pakistan Regional Stabilization Strategy25

Following congressional criticism about the omission, the strategy was re-released in February 2010 with 

a new section, “Advancing the Rights of Afghan Women.” The strategy now states that support for these 

goals is to be integrated throughout all U.S. programs in Afghanistan detailed in the Stabilization 

Strategy. Moreover, the Women’s Action Plan for Afghanistan, announced by the Secretary of State, 

states that “the United States Government is committed to the Afghan leadership of programs that 

directly enhance development, particularly as it relates to women’s issues, and as laid out in both the 

Afghan National Development Policy (ANDS), and more specifically, the 10-year National Action Plan for 

Women of Afghanistan (NAPWA).” The 2009 report on U.S. government-funded activities, however, 

does not state how the goals are integrated into the Afghan national strategies, particularly the NAPWA.

in January 

2010, it contained few references to Afghan women and girls. 

The NAPWA, a key tool of the Ministry of Women’s Affairs and Afghan government’s primary vehicle for 

promoting women’s rights and participation in rebuilding Afghanistan, provides direction to Afghan 

government ministries on working toward gender equality and achieving specific targets from 2008 to 

2018. The full implementation of the NAPWA is the primary measurable benchmark through which the 

 

25 The Secretary of State’s Afghanistan and Pakistan Regional Stabilization Strategy is intended to build long-lasting 

partnerships with Afghanistan and Pakistan, and according to Secretary Clinton, offers the best prospect for 

stabilizing Afghanistan and Pakistan.
SIGAR Audit-10-13 Development/Women and Girls Page 15

Afghanistan government seeks to realize its goals on gender equity, according to the NAPWA. The 

NAPWA identifies goals and key indicators for all sectors. With education, for example, goals are to 

increase girls’ enrollment by 50 percent in primary, secondary, and tertiary schools; achieve at least 

70 percent net enrollment in primary schools; and increase the retention rate of females to 50 percent. 

The NAPWA builds upon the Afghanistan National Development Strategy (ANDS), which establishes 

Afghanistan’s priorities for security, governance, economic growth, and poverty reduction. The U.S. 

government, along with other donors, agreed to align aid commitments to Afghanistan with the ANDS in 

the June 12, 2008, Declaration of the Conference in Support of Afghanistan. In addition, Afghan women 

civil society leaders support the NAPWA and have recommended that international donors make aid 

contingent on implementing policies that support the advancement of women in Afghanistan.26

CONCLUSION

Earmarks of appropriated funds for addressing the needs of Afghan women and girls have significantly 

increased over time, from $5 million in 2003 to $175 million for 2010. While Congress has directed State 

to report on the use of these funds for Afghan women and girls, the reporting has been incomplete and 

has not provided a clear picture of how the funds have been used to benefit Afghan women and girls. 

Additionally, organizations including MoWA, AIHRC, and Afghan women-led NGOs and CSOs received 

only partial amounts of the funds earmarked for them by Congress. The United States supports the 

Afghanistan government’s National Action Plan for the Women of Afghanistan, which established goals, 

strategies, and benchmarks for gender equity for women of Afghanistan. However, the 2009 report to 

Congress does not show how U.S.-funded activities support these goals or demonstrate the linkages 

between the U.S.-funded activities to the goals and benchmarks in the plan. Such linkage is important 

to ensure that the reported activities are addressing the needs of Afghan women, consistent with 

congressional directives.

 

26 In the lead-up to the January 28, 2010 London Conference on Afghanistan, Afghan women rights defenders 

released a statement with strong, specific recommendations on security, development, and governance priorities 

for Afghanistan on January 27, 2010.
SIGAR Audit-10-13 Development/Women and Girls Page 16

RECOMMENDATIONS

Prior to developing the next report to Congress, which is due by September 30, 2010, SIGAR 

recommends that the Secretary of State, in consultation with the USAID Administrator:

(1) develop consistent reporting requirements for all USAID and State programs and activities to 

provide data on female beneficiaries and measurable impacts of activities intended to address 

the needs of Afghan women and girls;

(2) develop a coordinated approach to reporting on the use of earmarked funds that provides 

consistent information about each activity, identifies funding sources, allocates earmarks at the 

start of each fiscal year’s budgeting cycle, and provides the rationale for reporting activities and 

for determining the earmark attribution amounts;

(3) align activities to ensure consistency with the goals and benchmarks stated in the U.S.-

supported Afghanistan’s national strategies, particularly NAPWA; and

(4) target funds to specifically address the organizations repeatedly specified in the legislation, 

including MoWA, AIHRC, and Afghan women-led NGOs and CSOs to ensure appropriated funds

are used as directed by Congress and address the needs of Afghan women and girls.

COMMENTS

State, USAID, and the U.S. Embassy in Afghanistan provided joint comments on a draft of this report. 

The comments are included in appendix VI. The U.S. Ambassador to Afghanistan, the Ambassador-atLarge for Women’s Issues, the Secretary’s Special Representative for Afghanistan and Pakistan, and the 

USAID Administrator concurred with the report’s recommendations and provided additional 

information. In their comments, they outlined actions they would take to address the report’s 

recommendations, including:

• developing language to insert into each agreement that specifies reporting requirements, 

including outcomes and performance measures;

• proposing the creation of a Gender Task Force, co-chaired by the Ambassador-at-Large for 

Global Women’s Issues and the Coordinating Director for Development and Economic Affairs, to 

ensure coordination among those providing assistance to Afghan women; 

• working to develop an interagency strategy aligned with the NAPWA, incorporating NAPWArelated indicators in the Mission’s performance management plan, and continuing to move 

toward Afghan-led development as a key component of all U.S. assistance in Afghanistan; and

• developing stronger earmark tracking within individual programs that focus on MOWA, AIHRC, 

and NGOs so that they can meet specific congressional directives.

In their comments, State and USAID noted that although our review focused on Congressional earmarks 

for over seven years, we only provided analysis of the 2009 fiscal year period. As stated in our scope 

and methodology, we analyzed legislation pertaining to Afghan women and girls from 2001 to 2010. We 

focused our analysis on the State Department’s October 2009 report to Congress, which was intended to 

cover fiscal year 2008 and 2009 activities. Our analysis of the prior years’ earmarks and earmark 

attributions was limited due to a lack of information in the 2008 report to Congress, which required 

reporting on activities from fiscal year 2001 through 2008. 
SIGAR Audit-10-13 Development/Women and Girls Page 17

APPENDIX I: SCOPE AND METHODOLOGY 

We focused our review on the October 2009 report on U.S.-funded activities for Afghan women and girls 

titled Report on U.S. Government Activities 2008-2009 for Women and Girls in Afghanistan, October 20, 

2009. We also reviewed the prior report submitted to Congress titled Report on U.S. Government 

Activities 2001-2008 for Women and Girls in Afghanistan, which described activities by sector in a 

narrative format but did not provide a detailed list of activities, the earmarks attributed to them, or 

funding amounts. Therefore, we could not rely on the 2008 report for detailed information about 

earmark attributions in prior years. 

To review the process for attributing and reporting on the use of funds, we interviewed USAID and State 

officials. State officials included representatives from the Office of Global Women’s Issues Ambassador 

at Large; Population, Refugees and Migration/Education and Cultural Affairs; Democracy, Human Rights 

and Labor; South and Central Asian Affairs/Afghanistan Desk; and International Narcotics and Law 

Enforcement/Afghanistan. USAID officials interviewed included gender and legislative affairs advisors; 

sector program officers for agriculture, democracy and governance, economic growth, education, and 

health; and program and finance officers.

To determine the extent to which the reported activities met the congressional directives, we identified 

the congressional directives in legislation from 2001 to 2010 and identified the reported activities that 

addressed the directives. We also verified legislative directives for fiscal year 2009 with congressional 

officials. We met with State and USAID officials to discuss the reported activities and obtain additional 

documentation.

To determine whether the reported activities were consistent with U.S. and Afghan national strategies, 

we reviewed State Department strategy documents, including the recently announced AfghanistanPakistan Regional Stabilization Policy, USAID agency-wide gender policy, and USAID Mission policy on 

gender integration in Afghanistan and USAID’s 5-year strategic plans for several years. We also 

reviewed the Afghanistan national strategies supported by the international community and those that 

addressed the needs of women, which included the 2008 National Action Plan for the Women of 

Afghanistan. We also met with four implementing partners and officials from the Government of the 

Islamic Republic of Afghanistan, including MoWA and AIHRC. 

We conducted our work in Kabul, Afghanistan, and Washington, D.C., from November 2009 to July 2010 

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 the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our audit objectives. 
SIGAR Audit-10-13 Development/Women and Girls Page 18
SIGAR Audit-10-13 Development/Women and Girls Page 19
SIGAR Audit-10-13 Development/Women and Girls Page 20
SIGAR Audit-10-13 Development/Women and Girls Page 21
SIGAR Audit-10-13 Development/Women and Girls Page 22
SIGAR Audit-10-13 Development/Women and Girls Page 23
SIGAR Audit-10-13 Development/Women and Girls Page 24
SIGAR Audit-10-13 Development/Women and Girls Page 25
SIGAR Audit-10-13 Development/Women and Girls Page 26
SIGAR Audit-10-13 Development/Women and Girls Page 27
SIGAR Audit-10-13 Development/Women and Girls Page 28 
SIGAR Audit-10-13 Development/Women and Girls Page 29
SIGAR Audit-10-13 Development/Women and Girls Page 30
SIGAR Audit-10-13 Development/Women and Girls Page 31
SIGAR Audit-10-13 Development/Women and Girls Page 32
SIGAR Audit-10-13 Development/Women and Girls Page 33
SIGAR Audit-10-13 Development/Women and Girls Page 34

APPENDIX VI: COMMENTS FROM DEPARTMENT OF STATE AND U.S. AGENCY FOR 

INTERNATIONAL DEVELOPMENT
SIGAR Audit-10-13 Development/Women and Girls Page 35

See SIGAR 

Comment 1.
SIGAR Audit-10-13 Development/Women and Girls Page 36
SIGAR Audit-10-13 Development/Women and Girls Page 37

See SIGAR 

Comment 2.
SIGAR Audit-10-13 Development/Women and Girls Page 38
SIGAR Audit-10-13 Development/Women and Girls Page 39

See SIGAR 

Comment 3. 
SIGAR Audit-10-13 Development/Women and Girls Page 40
SIGAR Audit-10-13 Development/Women and Girls Page 41

See SIGAR 

Comment 4.
SIGAR Audit-10-13 Development/Women and Girls Page 42

See SIGAR 

Comment 5.
SIGAR Audit-10-13 Development/Women and Girls Page 43
SIGAR Audit-10-13 Development/Women and Girls Page 44
SIGAR Audit-10-13 Development/Women and Girls Page 45

See SIGAR 

Comment 6.
SIGAR Audit-10-13 Development/Women and Girls Page 46
SIGAR Audit-10-13 Development/Women and Girls Page 47
SIGAR Audit-10-13 Development/Women and Girls Page 48

The following are SIGAR’s comments on State and USAID’s joint response to a draft of this report: 

1. State and USAID noted that our report did not address the entire 7 years. We focused our 

analysis on legislation pertaining to Afghan women and girls from 2001 to 2010, as stated in our 

scope and methodology. We focused on the State Department’s October 2009 report, which 

was intended to cover activities from 2008 to 2009. Our analysis of the prior years’ earmarks 

and earmark attributions was limited due to a lack of information in the 2008 report, which 

covered 2001 to 2008.

2. State and USAID commented that all activities are aligned with the goals stated in the NAPWA. 

However, the 2009 report to Congress did not demonstrate the alignment of activities with the 

goals. Further, State and USAID noted in its comments the actions they are undertaking to 

create a comprehensive strategy based on the NAPWA that will align with its goals and 

benchmarks. 

3. We have noted the additional AIHRC funding in this report. 

4. We have updated our information on the ASGP in this report.

5. We have updated our report to reflect this new information.

6. The 2009 report did not include this information but we agree that this type of information 

would be useful in identifying efforts that support the congressional directive. 
SIGAR Audit-10-13 Development/Women and Girls Page 49

(This report was conducted under the audit project code SIGAR-010A).
SIGAR’s Mission The mission of the Special Inspector General for 

Afghanistan Reconstruction is to enhance oversight of 

programs for the reconstruction of Afghanistan by 

conducting independent and objective audits, inspections, 

and investigations on the use of taxpayer dollars and 

related funds. SIGAR works to provide accurate and 

balanced information, evaluations, analysis, and 

recommendations to help the U.S. Congress, U.S. agencies, 

and other decision-makers to make informed oversight, 

policy, and funding decisions to: 

• improve effectiveness of the overall reconstruction 

strategy and its component programs; 

• improve management and accountability over funds 

administered by U.S. and Afghan agencies and their 

contractors;

• improve contracting and contract management 

processes;

• prevent fraud, waste, and abuse; and 

• advance U.S. interests in reconstructing 

Afghanistan. 

Obtaining Copies of SIGAR 

Reports and Testimonies

To obtain copies of SIGAR documents at no cost, go to 

SIGAR’s Web site (www.sigar.mil). SIGAR posts all 

released reports, testimonies, and correspondence on its 

Web site.

To Report Fraud, Waste, and 

Abuse in Afghanistan 

Reconstruction Programs

To help prevent fraud, waste, and abuse by reporting 

allegations of fraud, waste, abuse, mismanagement, and 

reprisal contact SIGAR’s hotline: 

• Web: www.sigar.mil/fraud

• Email: hotline@sigar.mil

• Phone Afghanistan: +93 (0) 700-10-7300 

• Phone DSN Afghanistan 318-237-2575 

• Phone International: +1-866-329-8893 

• Phone DSN International: 312-664-0378 

• U.S. fax: +1-703-604-0983 

Public Affairs Public Affairs Officer

• Phone: 703-602-8742 

• Email: PublicAffairs@sigar.mil 

• Mail: SIGAR Public Affairs

400 Army Navy Drive

Arlington, VA 22202