Key Questions 

To Inform USAID’s 

COVID-19 Response

USAID Office of Inspector General

May 21, 2020

ADVISORY 

NOTICE
ADVISORY NOTICE

DATE: May 21, 2020

TO: USAID Acting Administrator, John Barsa

FROM: USAID Inspector General, Ann Calvaresi Barr /s/

SUBJECT: Key Questions To Inform USAID’s COVID-19 Response

On January 30, 2020, the World Health Organization (WHO) declared a Public Health 

Emergency of International Concern for the novel coronavirus SARS-CoV-2 (COVID19) outbreak that began in the People’s Republic of China. The next day, the President 

of the United States declared a domestic Public Health Emergency. The virus 

subsequently spread worldwide, and on March 11, 2020, WHO characterized the 

outbreak as a pandemic. The President of the United States declared a national 

emergency on March 13, 2020. 

The President formed the White House Coronavirus Task Force to helm the U.S. 

Government’s overarching COVID-19 response.1 According to USAID, the Agency is 

working closely with the State Department, CDC, and other interagency partners to 

prioritize countries and allocate COVID-19 funding. To coordinate the Agency-wide 

approach to this global threat, the USAID Administrator activated the Crisis Action 

Team on January 31, 2020, and established a COVID-19 Task Force on March 3, 2020. 

In addition, USAID’s Office of U.S. Foreign Disaster Assistance (OFDA) activated a 

COVID-19 Response Management Team to support OFDA and Office of Food for 

Peace (FFP) operations and coordinate COVID-19 readiness and response activities in 

1 The White House Coronavirus Task Force oversees the Administration’s actions to monitor, contain, 

and mitigate the spread of COVID-19. Led by the Vice President, it includes members from the State 

Department; Department of Health and Human Services (HHS), including the U.S. Centers for Disease 

Control and Prevention (CDC); the Department of Homeland Security; the National Security Council; 

and other agencies. The U.S. Global AIDS Coordinator, head of the U.S. President’s Emergency Plan for 

AIDS Relief (PEPFAR), is the appointed COVID-19 Response Coordinator. USAID is not directly 

represented on the Task Force.

Office of Inspector General, U.S. Agency for International Development

Washington, DC 

https://oig.usaid.gov
Office of Inspector General, U.S. Agency for International Development 2

existing humanitarian crises. Other groups within USAID, like the Bureau for Global 

Health’s sustained crisis response group, further support Agency-wide coordination 

efforts. 

The State Department and USAID’s joint COVID-19 response strategy is multifaceted 

and aims to protect the safety and health security of its global workforce, ensure 

continuation of the Agency’s mission across the world, and support partner countries in 

their response to COVID-19. Congress has appropriated approximately $1.34 billion in 

supplemental funding for USAID’s programming and operations related to COVID-19

and $1 million for USAID Office of Inspector General (OIG) oversight.2 With additional 

funding from various Agency accounts and the State Department, the total investment in 

USAID’s COVID-19 activities approaches $2 billion—in addition to funding USAID 

redirected from existing development programs to support the COVID-19 response.

Our independent oversight informs USAID’s decisions to better safeguard taxpayer 

dollars and maximize the impacts of foreign assistance. To ensure we are being timely 

and proactive, this advisory notice poses key questions from past lessons learned for 

USAID to consider while planning and executing its response to the COVID-19 

pandemic. We drew upon the top management challenges we report annually to USAID, 

which provided the framework for this advisory.3 Accordingly, the lessons learned fall 

under four broad areas: (1) managing risks to humanitarian assistance amid a public 

health emergency of international concern; (2) maintaining responsibilities for planning, 

monitoring, and sustaining U.S.-funded development; (3) maximizing stakeholder 

coordination for a global COVID-19 response; and (4) addressing vulnerabilities and 

implementing needed controls in Agency core management functions. 

In developing these questions, we drew upon our prior and ongoing audit, investigative, 

and advisory work on public health emergency response, global health supply chain, 

humanitarian assistance, and other relevant topics. We also referred to our oversight 

work on overseas contingency operations that we conduct jointly with OIGs for the 

Departments of Defense, State, and Health and Human Services.4 In addition, we 

reviewed related work from other oversight organizations, Governmentwide best 

practices, information on USAID’s COVID-19 response from the USAID Task Force 

and other sources. USAID’s comments on the draft are included as an attachment to

this advisory. 

2 Coronavirus Preparedness and Response Supplemental Appropriations Act, Public Law 116-123 (March 

6, 2020) and Coronavirus Aid, Relief, and Economic Security (CARES) Act, Public Law 116-136 (March 27, 

2020).

3 As required by statute, we identify and report the most daunting challenges facing the agencies we 

oversee and the progress made in managing them. 4 We provide oversight of overseas contingency operations jointly with OIGs for the Departments of 

Defense, State, and Health and Human Services, and provide quarterly reports to Congress describing 

U.S. Government activities. Contingency operations we have reported on include Operation United 

Assistance, which was activated for the Ebola virus disease outbreak in West Africa.
Office of Inspector General, U.S. Agency for International Development 3

Managing Risks to Humanitarian Assistance Amid a 

Public Health Emergency of International Concern

USAID is a global leader responding to crises and reported expending $3.8 billion on 

humanitarian programs in 2019 alone. USAID’s Administrator recognized the potential 

humanitarian impacts of the pandemic and issued a global disaster declaration on April 3, 

2020, to allow USAID to use humanitarian assistance funding for broader COVID-19 

relief. According to USAID, the Agency will prioritize these funds for its ongoing 

humanitarian assistance programs, which will be adapted and contextualized for the 

pandemic, as well as for programs in fragile countries that the pandemic could tip into a 

full-blown crisis.5 USAID plans to coordinate humanitarian assistance with the United 

Nations Office for the Coordination of Humanitarian Affairs, World Food Programme, 

and other humanitarian partners that are participating in the global COVID-19 response. 

Our audits and investigations, both prior and ongoing, have identified significant risks 

that USAID encounters in crisis environments that could keep aid from reaching 

intended beneficiaries. Heightened security threats coupled with large amounts of 

money create prime opportunities for unscrupulous individuals to commit fraud and 

divert goods to the black market, advance other criminal schemes, or provide material 

support to terrorist entities. Before the COVID-19 pandemic, for instance, USAID 

implementer personnel in Syria falsified beneficiary lists and diverted food kits to known 

terrorists. Weaknesses in procurement, logistics, and fraud reporting systems made 

commodities intended for displaced Syrians particularly susceptible to fraud schemes like 

kickbacks and product substitution, criminal organizations, and corrupt officials. 

Moreover, limitations to USAID’s vetting and monitoring of national security 

information may affect its ability to fully assess, mitigate, and respond to threats to its 

humanitarian assistance programs—a concern that is compounded when visibility to 

fraud and misconduct in the field is already degraded for USAID and implementers due 

to COVID-19.6

COVID-19 adds new challenges to USAID’s ability to plan, implement, and monitor 

humanitarian assistance. The tools and data sources USAID has relied on in the past for 

understanding on-the-ground conditions and planning interventions may have 

unprecedented limitations, given the widespread challenges collecting and validating data 

from the field, even for longstanding data collectors like the United Nations. Border 

closures to stop the spread of the virus disrupt supply chains for lifesaving goods and 

services, could constrain aid workers’ ability to provide needed assistance, and make 

displaced communities more vulnerable. Non-pharmaceutical interventions like social 

distancing and contact tracing are also challenging to implement in high-density settings 

5 As of May 1, 2020, USAID provided humanitarian assistance programs in FY 2019 that predated COVID19 in Afghanistan, Burkina Faso, Central African Republic, Colombia, Democratic Republic of the Congo, 

Iraq, Libya, Myanmar, Nigeria, Somalia, South Sudan, Sudan, Syria, Ukraine, and Venezuela. 6 USAID OIG, “Limits in Vetting and Monitoring of National Security Information Pose Risks for USAID 

Humanitarian Assistance and Stabilization Programs [Classified],” Advisory Notice, January 15, 2020.
Office of Inspector General, U.S. Agency for International Development 4

like refugee camps, while restrictions on movements may impede food production, 

distribution, and access, with the potential to trigger a food crisis. USAID plans to 

support health, water, sanitation, and other activities to protect vulnerable populations 

and will need to remain nimble to address concerns as they emerge, as the Agency’s 

strategy effectively allowed for during the Ebola response in West Africa.7 It will also be 

important for USAID to consider how to effectively prioritize interventions, monitor 

implementation, and strengthen programmatic oversight when visibility is constrained 

and conditions are rapidly evolving.8

The pandemic may also affect USAID’s ability to appropriately assess humanitarian 

needs—a challenge we identified during USAID’s response to the Ebola virus outbreak 

in West Africa.9 We found that OFDA did not effectively assess initial needs or 

reevaluate them as the outbreak evolved, leading to millions of dollars in excess 

commodities and the construction of some healthcare units that were not used. In 

addition, OFDA did not adequately oversee what it funded and lacked the needed 

information to track activities and determine the funding’s effectiveness. In another case, 

for Ebola emergency food assistance, some FFP activities were months behind schedule, 

and beneficiary selection and documentation in one case were inadequate.10 USAID’s 

actions to address our Ebola-related recommendations should strengthen its COVID-19 

response and help ensure beneficiaries get the assistance they need. However, 

continued diligence is required to ensure policies and tools are implemented effectively, 

particularly as USAID works to build the capacity, function, and structure of its new 

Bureau for Humanitarian Assistance—which combines OFDA and FFP—in the midst of 

the pandemic.11

Given these challenges managing risks to humanitarian assistance during a public health 

emergency of international concern, we pose the following questions drawn from past 

lessons learned to inform USAID’s COVID-19 response:

1. Has USAID provided staff and implementers sufficient guidance for prioritizing, 

adapting, and contextualizing humanitarian assistance programs to enable timely and 

efficient funding decisions? Are processes in place to ensure decisions are made in a 

transparent manner and that decisions for new programs as well as changes to 

existing programs are appropriately documented? 

7 USAID OIG, “Lessons From USAID’s Ebola Response Highlight the Need for a Public Health Emergency 

Framework” (9-000-18-001-P), January 24, 2018. 8 USAID OIG, “Oversight in Challenging Environments: Lessons From the Syria Response,” Feature 

Report, November 9, 2017.

9 USAID OIG, “Assessment and Oversight Gaps Hindered OFDA’s Decision Making About Medical 

Funding During the Ebola Response” (9-000-18-002-P), January 24, 2018. 10 USAID OIG, “Audit of Select Activities From the USAID/Food for Peace Response to the Ebola Crisis 

in West Africa” (7-962-16-003-P), March 16, 2016. 11 On February 11, 2020, USAID legally established three new bureaus: the Bureaus for Resilience and 

Food Security, Humanitarian Assistance, and Conflict Prevention and Stabilization. According to USAID, 

these three bureaus make up the new “Relief, Response, and Resilience (R3) Family.” 
Office of Inspector General, U.S. Agency for International Development 5

2. What steps can USAID take to effectively assess implementer internal control 

systems and capacity to ensure aid is delivered to the intended beneficiaries? How 

can USAID obtain the information it needs to properly vet humanitarian assistance 

and avoid diversions to terrorist entities and other bad actors given limitations to 

accessing and monitoring national security information and directly observing field 

activities? 

3. Are there additional measures that USAID should put in place to prevent and detect 

fraud and other misconduct, such as exploitation of beneficiaries, diversion, and 

product substitution? What procedures has USAID established to ensure 

implementers comply with mandatory disclosure requirements for suspected fraud 

in USAID programs, given implementers’ restricted ability to identify fraud and other 

misconduct committed by their staff in the field? What best practices can USAID 

carry forward from its prior experiences, including those documented in OIG’s 

compliance and fraud prevention guide for program implementers?

4. Does USAID have accurate and comprehensive information to understand on-theground conditions and make sound decisions about COVID-19 interventions? What 

is USAID doing to ensure the tools and data sources USAID typically relies on are 

effective in the COVID-19 environment? What other data sources could USAID 

consider?

5. What innovative methods can USAID and implementers use to plan, implement, and 

monitor humanitarian assistance in the context of COVID-19? Are there measures 

USAID can take to anticipate and mitigate potential impacts from closed borders and 

movement restrictions on its programs and beneficiaries? Should these measures be 

built into any new or modified programs? Given that COVID-19 lockdowns and 

travel restrictions can exacerbate food insecurity by restricting food production, 

distribution, and access, how are USAID’s food and agriculture programs mitigating 

adverse effects?

6. As USAID stands up the new Bureau for Humanitarian Assistance, how can USAID 

leverage the strengths, best practices, and lessons learned by OFDA and FFP and 

ensure these are incorporated into the new bureau to help avoid past missteps? 

How will USAID promote improved policies and tools from the Ebola response in 

West Africa, like those that support evidence-based prioritized programming to 

ensure high-quality and effective humanitarian responses, and help staff conduct and 

update needs assessments?

Maintaining Responsibilities for Planning, Monitoring, and 

Sustaining U.S.-Funded Development 

USAID’s international development programs aim to help countries achieve selfreliance—and end the need for foreign assistance—through sustained advancements in 

global health, education, economic growth, governance, and other areas. These 

programs are designed to also advance U.S. national security and economic prosperity. 
Office of Inspector General, U.S. Agency for International Development 6

In fiscal year 2019, USAID obligated approximately $13 billion in non-emergency foreign 

assistance to 138 countries to achieve these objectives. As the COVID-19 pandemic 

threatens lives worldwide, USAID is leveraging its longstanding global health programs 

to bolster health institution capacity to address the pandemic. USAID is also preparing 

to mitigate longer term, second-order impacts that could undermine the valuable 

economic and development gains USAID has realized over many years. 

COVID-19 has already transformed the landscape for USAID’s international 

development work. A pandemic of this magnitude brings forth unanticipated challenges 

and opportunities that USAID must consider in its ongoing and future development 

programming. At a corporate level, for example, USAID may need to update guiding 

strategies, like the Joint Strategic Plan with the State Department for fiscal years 2018 to 

2022, to reflect new U.S. Governmentwide priorities.12 The Agency may also need to 

determine if and how its appetite for risk has changed and revisit its Agency Risk Profile 

to reflect new risks that have emerged from COVID-19.13 At a country level, USAID 

may need to consider the pandemic’s impact on country-specific plans, including 

Country Development Cooperation Strategies and Journey to Self-Reliance Country 

Roadmaps, to ensure the path to sustainability is clear, coordinated, and reflective of the 

post-COVID-19 context.14 At the implementation level, USAID may need to reassess its 

ongoing and planned work to determine what should be stopped, redirected, or 

expanded and if there are new initiatives for the Agency to explore. 

To sustain development outcomes and prevent development backsliding through the 

pandemic, USAID plans to augment its work with host-country governments, the private 

sector, and other partners. Yet, sustainability has been a top challenge we report 

annually to USAID, with sustainability shortfalls often occurring when USAID’s critical 

assumptions for a project, program, or activity do not hold true. In Haiti, for example, 

we found that USAID’s electricity project stalled when the Haitian Government and 

private sector did not take on roles and responsibilities as planned, leaving a power 

plant in USAID care for years longer than intended.15 Sustainability challenges extend to 

health system strengthening activities, which we found have been a secondary focus for 

12 The Joint Strategic Plan (JSP) presents the vision and direction that guide how the State Department and 

USAID implement U.S. foreign policy and development assistance. 13 In 2016, the Office of Management and Budget updated Circular A-123 to introduce a new requirement 

for the Agency to integrate enterprise risk management (ERM) with its internal control systems. ERM is a 

holistic, Agency-wide approach to risk management that addresses the full spectrum of risks, as an 

interrelated risk portfolio, rather than examining risks in silos. Under an ERM approach, the goal is not to 

control or avoid all risk, but rather to take advantage of opportunities while reducing or mitigating threats 

to maximize USAID’s overall likelihood of achieving its mission and objectives.

14 A Country Development Cooperation Strategy, typically a 5-year strategy, defines a USAID mission’s 

chosen approach in a country, articulates the country’s self-reliance trajectory, and details expected 

results. Journey to Self-Reliance Country Roadmaps serve as USAID’s visualization tool for assessing selfreliance in a given country, based on 17 third-party, publicly available metrics that capture the concepts of 

commitment and capacity.

15 USAID OIG, “Misjudged Demand, Stalled Reforms, and Deficient Oversight Impeded USAID/Haiti’s 

Sustainable Electricity Goals” (9-521-19-001-P), November 13, 2018.
Office of Inspector General, U.S. Agency for International Development 7

USAID and have achieved limited gains in preparing for large-scale health emergencies.

16

USAID agreed with our recommendations and, prior to the COVID-19 outbreak, was 

working to roll out a new vision by September 2020 that would balance broader health 

system strengthening activities with targeted health interventions. Important lessons 

from the COVID-19 response may serve to bolster this new vision. 

Monitoring projects, programs, and activities and holding implementers accountable 

have been other longstanding challenges for USAID that will be more difficult because of 

COVID-19, which turns the typical development context into a nonpermissive 

environment.17 For example, routine field visits by USAID and implementer staff are 

stymied by travel restrictions, underlying safety concerns, post evacuations, and 

mandatory telework. While USAID has issued basic guidance on how to maintain 

monitoring during the pandemic, such as adopting remote monitoring technology, 

putting these methods into practice will require staff and implementers to learn and 

deploy new techniques that work for their unique needs, and then validate them to 

ensure the data is good. Moreover, the pandemic will affect implementers’ ability to 

carry out established work plans and achieve preexisting targets. USAID must determine 

how it can provide needed flexibility to implementers while holding them accountable to 

the American taxpayer through clear policies and procedures for adapting work plans, 

monitoring plans, reporting requirements, implementer performance evaluations, and 

other essential components of USAID’s program cycle.18

As USAID continues to rely on its $9.5 billion Global Health Supply Chain –

Procurement and Supply Management (GHSC-PSM) project to procure and deliver 

health commodities around the world, USAID must stay vigilant to mitigate supply chain 

risks that may grow in the face of the pandemic.19 Since 2016, our investigations and 

joint operations with authorities have identified fraud, waste, and abuse at points along 

the supply chain, ranging from large-scale, illicit resale of USAID-funded commodities on 

the black market to false claims and kickbacks solicited by project staff and local 

vendors. In addition, some host-country governments that USAID relies on for 

warehousing and distribution have been unwilling or unable to implement needed 

controls to prevent theft and safeguard commodities. USAID is working to address 

these issues aided by information from our ongoing audits and investigations, but 

remaining risks may transfer to USAID’s unfolding response to the COVID-19 

16 USAID OIG, “More Guidance and Tracking Would Bolster USAID's Health Systems Strengthening 

Efforts” (4-936-20-001-P), October 21, 2019. 17 USAID defines a nonpermissive environment as a context in which uncertainty, instability, inaccessibility, 

or insecurity constrains USAID's ability to operate safely and effectively.

18 The program cycle is USAID’s operational model for planning, delivering, assessing, and adapting 

development programming in a given region or country to advance U.S. foreign policy. Policies and 

procedures are outlined in Automated Directives System, chapter 201, “Program Cycle Operational 

Policy.”

19 USAID OIG, “Advisory Update on Global Health Supply Chain-Procurement and Supply Management 

Project” Advisory Notice, October 11, 2018; and USAID OIG, “Global Health Advisory on Internal 

Control Concerns” Advisory Notice, June 7, 2017.
Office of Inspector General, U.S. Agency for International Development 8

pandemic. An emerging concern reported by multiple sources in the global COVID-19 

response is the growing risk of subquality commodities, product substitution, and price 

gauging, which causes more harm than good to beneficiaries. USAID has acknowledged

the increased risks of corruption within health systems, local governments, and the 

private sector and plans to address it by promoting citizen-responsive governance amid 

the COVID-19 pandemic. In leveraging its democracy, human rights, and governance 

programs to combat corruption, USAID staff will need to be aware of and have access 

to Agency expertise and resources to help strengthen this approach.

20 

To support the planning, monitoring, and sustainability of USAID’s development 

programs, we pose the following questions drawn from past lessons learned to inform 

USAID’s COVID-19 response:

1. How will USAID reassess and revise existing strategies and guiding documents at the 

headquarters, country, and implementation levels to reflect the challenges and 

opportunities brought on by COVID-19? Will USAID perform an overarching scan 

of its projects, programs, and activities to determine what may be stopped, 

redirected, expanded, or explored? 

2. How has USAID’s Agency Risk Profile and appetite for risk changed? How will this 

affect USAID ongoing and planned programs during the COVID-19 pandemic, as well 

as afterwards? How will USAID document and institutionalize these changes?

3. How does USAID plan to reevaluate critical assumptions for its development 

programs that may be affected by changing conditions brought on by COVID-19? 

What adjustments will USAID make if critical assumptions have changed, and what 

documented policies and procedures will USAID follow to make these adjustments? 

Are there short-term alternatives USAID should consider to mitigate direct and 

indirect effects of COVID-19 disruptions on the long-term sustainability of its 

development programs?

4. How can USAID build staff and implementer capacity to apply innovative monitoring 

methods to development programs? How will USAID ensure monitoring data from 

new methods meet USAID’s five data quality standards—validity, integrity, precision, 

reliability, and timeliness? Does USAID have a monitoring and evaluation framework 

to measure and assess its COVID-19 development programs and activities 

discretely, and as a whole to showcase USAID’s overarching response?

5. What additional development policies and procedures does USAID need to provide 

to ensure changes to work plans, monitoring plans, implementer performance 

evaluations, and other essential components of USAID’s program cycle are 

20 USAID OIG, “Additional Actions Are Needed to Improve USAID’s Democracy, Human Rights, and 

Governance” (8-000-20-001-P), November 26, 2019.
Office of Inspector General, U.S. Agency for International Development 9

appropriately documented and to maintain implementer accountability to the 

American taxpayer?

6. What additional measures could USAID implement to prevent and detect 

commodity theft, collusion, false claims, and other known risks to USAID-funded 

supply chains in its development programs, given a compromised ability to identify 

and report misconduct? How can USAID avoid procuring subquality commodities 

and product substitution to ensure its beneficiaries receive high-quality commodities 

that meet U.S. Government standards? When procuring commodities and services 

through GHSC-PSM and other sources, how will USAID verify and document that 

implementers, suppliers, and vendors are adhering to market rates and competing 

for the best value for the U.S Government?

7. How can USAID leverage its democracy, human rights, and governance programs to 

help combat corruption amid the COVID-19 response? Are staff aware of and do 

they have access to the Agency’s related expertise and resources?

Maximizing Stakeholder Coordination for a Global 

COVID-19 Response

The global reach of the COVID-19 pandemic, with lives at stake and resources limited 

both at home and abroad, requires unprecedented coordination between a broad range 

of stakeholders worldwide. In addition to coordination with internal and external U.S. 

Government entities, USAID is also collaborating with governments, public international 

organizations (PIOs), nongovernmental organizations (NGOs), the private sector, and 

other actors working on the ground to support the COVID-19 response. 21 As a lead 

implementer of the U.S. Government’s Global Health Security Strategy, USAID is well 

positioned to advance Governmentwide objectives for the international COVID-19 

response.

The U.S. Government response to the Ebola outbreak in West Africa demonstrated the 

importance of effective and efficient coordination for a public health emergency of 

international concern. Divergent approaches between USAID and CDC for combatting 

the disease and lack of a strategy to govern how the Agency works with external actors 

caused delays and complications.22 In response to our recommendations, USAID 

developed a policy framework, contributed input to the National Security Council 

pandemic playbook, and took other actions to improve preparedness for the next global 

health crisis. Some recommendations remain open, in particular the recommendation 

for USAID to work with other U.S. Government agencies to clearly identify roles, 

21 PIOs include U.N. organizations like the World Health Organization and the World Food Programme, 

as well as international finance institutions like the World Bank Group.

22 USAID OIG, “Lessons From USAID’s Ebola Response Highlight the Need for a Public Health 

Emergency Policy Framework” (9-000-18-001-P), January 24, 2018.
Office of Inspector General, U.S. Agency for International Development 10

capabilities, and responsibilities in an international public health emergency.23 HHS OIG 

made a similar recommendation for HHS to work with other U.S. Government agencies 

to develop a framework defining each agency’s roles and responsibilities for responding 

to a multiagency international public health emergency.24 Yet, these two 

recommendations remain outstanding in part due to ongoing difficulties in coordinating 

a joint operational policy with CDC. A new action plan (the SAFER package) 

summarizes the U.S. Government’s international response to COVID-19.25 However, it 

may still leave gaps in coordination, as the package does not replace or substitute 

agency-specific strategies that USAID, State Department, CDC, and other entities work 

concurrently to implement. 

The Ebola outbreak in West Africa also revealed how disease outbreaks can be difficult 

to predict and can quickly spread across national borders and continental boundaries, 

particularly when the capacity of local health authorities to detect and respond 

effectively to biological threats is limited.26 A critical component of the international 

COVID-19 response is to help affected and at-risk countries address gaps in laboratory 

diagnostics, surveillance and rapid response, border security, and other areas. Whereas 

the Ebola outbreak in West Africa was largely geographically contained, USAID and its 

partners face a global marketplace for critical goods and services to fight COVID-19. 

Effective coordination will be essential to ensure that like-minded donors do not 

become unnecessary competitors, drive up market prices, or duplicate efforts. Sharing

the burden with stakeholders, including with partner countries that receive foreign 

assistance and donors that make no-strings-attached contributions, is a unified U.S. 

Government priority dependent on effective coordination. 

Clear, consistent, and timely guidance is essential for harmonizing the complementary 

yet distinct missions of U.S. Government agencies and furthering shared national 

security objectives. Navigating the interagency sphere—particularly when decisions 

extend beyond USAID’s immediate control and authority—has been a top management 

challenge for USAID and one that has materialized at points in the COVID-19 response. 

For example, as USAID works to support the domestic response by transferring 

stockpiles of personal protective equipment (PPE) to the Federal Emergency 

Management Agency and restricting further PPE procurement, the Agency must find 

23 USAID OIG, “USAID’s Response to the Ebola Virus Disease Outbreak in the Democratic Republic of 

the Congo,” Advisory Notice, September 4, 2019. 24 HHS OIG, “HHS Did Not Always Efficiently Plan and Coordinate Its International Ebola Response 

Efforts” (A-04-16-03567), August 12, 2019. 25 State Department, “U.S. Government Action Plan to Support the International Response to COVID19,” Fact Sheet, April 16, 2020. The SAFER package outlines plans to Scale up community approaches; 

Address critical needs of healthcare; Find, investigate, and respond to COVID-19 cases; Employ strategies 

to address second-order impacts; and Ready plans for deployment of therapeutics and vaccines, 

diagnostics, and devices.

26 OIGs for USAID and Departments of Defense, State, and Health and Human Services, “Lead Inspector 

General Quarterly Report on U.S. Government Activities: International Ebola Response and 

Preparedness,” June 30, 2015.
Office of Inspector General, U.S. Agency for International Development 11

alternative ways to support its overseas COVID-19 response and normal global health 

programs for HIV/AIDS, tuberculosis, malaria, and other diseases that the U.S. 

Government also prioritizes. Similarly, USAID is supporting the “whole-of-America” 

communications strategy to help counter disinformation campaigns and emphasize the 

United States’ leading role fighting the virus worldwide. Flexibility with standard 

branding and marking policies and procedures will be needed to implement the 

Governmentwide strategy.

27 According to USAID, official guidance on these issues was

still working through the interagency clearance process by the end of April. Careful 

coordination will also be required if USAID encounters countries that may need critical 

help controlling the virus but face Governmentwide restrictions on foreign assistance, 

due to placement on the State Department’s Trafficking in Persons watchlist or the 

Treasury Department’s sanctions programs, for example.

As it did with the COVID-19 response, USAID turns to PIOs to ramp up an emergency 

response more quickly than can be done with other kinds of implementers. PIOs also 

have extensive networks and access to areas in dire need of humanitarian assistance that 

are typically off-limits to most Americans. These benefits, however, are not without risk 

or cost to the U.S. Government. We and other oversight organizations have questioned 

the U.S. Government’s ability to ensure that funds provided to PIOs are used effectively, 

efficiently, and with appropriate controls.28 While USAID has taken notable steps to 

implement our recommendations to strengthen PIO oversight, including establishing 

improved policies for risk management and fraud reporting, this pandemic may offer 

USAID the opportunity to further refine its relationship with PIOs to ensure the best 

use of taxpayer funds. The temporary hold on all U.S. Government funding to WHO—

one of USAID’s partners in the COVID-19 emergency response, other ongoing complex 

emergencies, and global health programs—underscores the importance of being ready 

to pivot from traditional partners for new circumstances and opportunities.

29 

The private sector is another critical partner in the global fight against the virus. In line 

with its COVID-19 strategy, USAID is engaging with the private sector to bridge gaps in 

the response and stimulate the economy. To diversify and expand its partner base, 

USAID announced solicitations for the New Partnerships Initiative in April 2020 to 

attract new and underutilized partners to help respond to the pandemic. In May 2020, 

27 The Automated Directives System, chapter 320, “Branding and Marking,” February 5, 2020 revision, lays 

out USAID’s procedures for identifying foreign assistance as American aid, which is required by Section 

641 of the Foreign Assistance Act of 1961 as amended and annual appropriations acts. 28 USAID OIG, “Insufficient Oversight of Public International Organizations Puts U.S. Foreign Assistance 

Programs at Risk” (8-000-18-003-P), September 25, 2018; Congressional Research Service, “United 

Nations Issues: U.S. Funding to the U.N. System” (IF10354), March 10, 2020; U.S. Government 

Accountability Office (GAO), “U.S. Agencies Conduct Financial Oversight Activities for Humanitarian 

Assistance but Should Strengthen Monitoring” (GAO-18-58), October 31, 2017; U.S. Government 

Publishing Office, “Oversight of Multilateral and Bilateral International Development Programs and 

Policies” Hearing Before the Subcommittee on Multilateral International Development, Multilateral, and 

International Economic, Energy, and Environmental Policy, May 6, 2015.

29 The White House, “President Donald J. Trump is Demanding Accountability From the World Health 

Organization” April 15, 2020.
Office of Inspector General, U.S. Agency for International Development 12

USAID announced it would move forward to finance the local production of medical

grade PPE and non-medical-grade PPE products, like face shields and gloves. USAID’s 

Grand Challenges for Development may be another private sector opportunity to seed 

new technology and scale up what works. USAID used this approach for both the Ebola 

outbreak in West Africa and the Zika outbreak in the Western Hemisphere, and we 

learned that improved timelines and indicators for measuring impact could help 

maximize USAID’s investments.30 Moreover, as USAID engagement with local 

organizations for the COVID-19 response grows, USAID will need to identify and 

mitigate internal control and fiduciary risks that are often associated with these 

entities.31 USAID is also coordinating with the U.S. Government’s International 

Development Finance Corporation (DFC), which can provide private sector solutions to 

ramp up healthcare and other services but may need to pay particular attention to 

strengthening interagency coordination based on past challenges.32

To strengthen stakeholder coordination, we pose the following questions drawn from 

past lessons learned to inform USAID’s COVID-19 response:

1. How can USAID enhance its interagency engagement with the White House 

Coronavirus Task Force and other entities to ensure that its efforts are effectively 

coordinated, and that it has the clear, consistent, and timely top-line guidance it 

needs to effectively respond to COVID-19 and continue ongoing development and 

humanitarian assistance programs? 

2. To what extent has USAID aligned its response and recovery strategies with those 

of the larger U.S. Government and other Federal agencies? To what extent does the 

Agency have processes for ensuring that its programs and activities align with these 

strategies and that its roles and responsibilities in the response and recovery efforts 

are clearly defined? 

3. Are there additional best practices from sources like the National Security Council 

playbook and the Global Health Security Strategy that USAID could apply to its own 

response, particularly to improve coordination internally and with external actors? 

4. How is USAID coordinating with local governments and other donors to advance 

shared priorities, address preparedness and response gaps, and avoid duplication of 

efforts? Is USAID prepared to navigate the global marketplace with other donors for 

goods and services that are in high demand? How is USAID tracking burden sharing, 

and how will USAID respond if its approach conflicts with that of other donors?

30 USAID OIG, “USAID’s Zika Response Efforts in the Western Hemisphere,” Memorandum, May 24, 

2018.

31 USAID OIG, “Despite Optimism About Engaging Local Organizations, USAID Had Challenges 

Determining Impact and Mitigating Risks” (5-000-19-001-P), March 21, 2019. 32 USAID OIG, “Letter To International Development Finance Corporation CEO Adam Boehler 

Regarding Key Considerations on the Transition and Standup of the USDFC,” October 9, 2019.
Office of Inspector General, U.S. Agency for International Development 13

5. How effective is USAID’s communication strategy in showcasing American aid and 

countering the spread of disinformation by malign actors? Should revised branding 

and marking guidance be enacted, and how will USAID work with suppliers, 

implementers, and staff to ensure timely and consistent adjustments and appropriate 

documentation for any deviations from standard practice? 

6. What guidance has USAID received about providing COVID-19 foreign assistance to

countries and populations facing U.S. Government restrictions, such as those related 

to Trafficking in Persons and economic sanctions? Should USAID be permitted to 

engage with these affected countries and populations, does the Agency have 

necessary waivers in place to enable timely delivery of COVID-19-related foreign 

assistance? Have related policies and procedures been effectively communicated to 

staff, implementers, and other stakeholders?

7. Has USAID evaluated the costs and benefits of partnering with PIOs and explored 

feasible alternatives with other types of implementers and approaches? How does 

USAID assess if foreign assistance provided through new implementers is more or 

less effective than existing implementers? What support should USAID provide to 

new implementers to ensure compliance with appropriate laws, rules, and reporting 

requirements?

8. How can USAID bolster private sector relationships to augment the global COVID19 response and fill gaps that USAID, its implementers, and other stakeholders may 

be facing? What steps should USAID implement to identify and mitigate risks of 

working with local organizations for the COVID-19 response? What are USAID’s 

roles and responsibilities for ensuring appropriate quality control and manufacturing 

practices for locally produced PPE and medical supplies?

9. How can USAID work with DFC to advance mutual missions? Are there new 

opportunities to coordinate that would help both USAID and DFC maximize the 

impacts of their unique responses to COVID-19?

10.What lessons can USAID learn from prior Grand Challenges for Development to 

advance innovative ideas and solutions suitable for COVID-19 preparedness and 

response in low-resource settings? How can USAID measure and assess the impact 

of innovations? What steps can the Agency take to improve its readiness to scale up 

successful innovations to maximize investments? 

Addressing Vulnerabilities and Implementing Needed 

Controls in Agency Core Management Functions

USAID’s ability to carry out its mission and safeguard Federal funds depends on the 

integrity and reliability of its core business practices and systems. Our audits and 

investigations show that the Agency recognizes the importance of sound controls but 

faces a variety of challenges implementing them. USAID now faces a new wave of 
Office of Inspector General, U.S. Agency for International Development 14

challenges from COVID-19, as the Agency altered—essentially overnight—how it does 

business to protect staff, continue operations, and address the global threat of the 

pandemic. In its response, USAID must strive to achieve an appropriate balance of both 

timeliness and sufficiency of controls.

New procurement flexibilities, for example, temporarily waive requirements for 

competition, source, and nationality of goods and services, and expand procurement and 

purchasing capabilities of non-U.S. direct-hire personnel.33 Federal guidance provides 

additional temporary relief for administrative, financial management, and audit 

requirements.34 These measures, which enable USAID to act swiftly and offset risks its 

implementers may face, require a different approach to fiscal prudence. Notably, under 

normal circumstances, we found that USAID’s award process lacked the rigor needed to 

ensure results were achieved because contracting and agreement officers and their 

representatives did not adhere to documented processes, and because record-keeping 

practices Agency-wide were poor.35 USAID reported to us that, by late April 2020, only 

7 percent of its U.S. direct-hire staff and TCN PSCs were working from their regular 

operating location, while 47 percent were teleworking from post and 36 percent had 

left the country. This shifted and constrained management structure may compound 

weaknesses in USAID oversight that could lead to waste by well-meaning staff, or fraud 

by bad actors who seek to exploit the situation for personal gain. 

As USAID is called upon to move substantial sums of money for the COVID-19 

response, the Agency has established processes for approving funding decisions and has 

provided some guidance to staff, including for reprogramming and redirecting existing 

awards. In addition, to streamline the overall planning burden for new COVID-19 

activities, the Agency waived its standard requirement for new activities to be approved 

with a Project Appraisal Document, noting that all pre-obligation requirements must still 

be documented. The Agency will need to ensure that written guidance and staff capacity 

are sufficient to implement the processes consistently across bureaus, missions, and 

independent offices; through multiple layers of review; and within the timeframes 

established for an effective and controlled response. Our audit work has found this area 

to be challenging for USAID in some instances, and it may be exacerbated by the 

33 The USAID Administrator communicated these authorities through “Expedited Procedures Package 

(EPP) for Responding to Outbreaks of Contagious Infectious Disease,” approved March 24, 2020, and 

“Reinforcing the Capabilities of Our Foreign Service Nationals During the COVID-19 Pandemic,” 

Executive Message sent April 10, 2020, which included Foreign Service Nationals and Cooperating 

Country/Third-Country National Personal Service Contractors (CCN/TCN PSCs). 34 Office of Management and Budget, “Administrative Relief for Recipients and Applicants of Federal 

Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) Due to Loss of 

Operations” (M-20-17), March 19, 2020. 35 USAID OIG, “USAID’s Award Oversight Is Insufficient To Hold Implementers Accountable for 

Achieving Results” (9-000-19-006-P), September 25, 2019. 
Office of Inspector General, U.S. Agency for International Development 15

complexities of the new pandemic.36 Notably, during the Ebola response in West Africa 

USAID lacked written policies or procedures for staff to follow in making and 

documenting certain funding decisions, and GAO determined that USAID’s process 

could not provide reasonable assurance that it complied with certain provisions of 

applicable appropriations laws.37

Amid the pandemic USAID is continuing its longstanding structural transformation, 

initiated in response to directives from the White House and the Office of Management 

and Budget.38 USAID’s redesign efforts, which we found had shifted over time, are 

progressing in spite of new challenges presented by COVID-19.39 USAID legally 

established three new Bureaus for Resilience and Food Security, Humanitarian 

Assistance, and Conflict Prevention and Stabilization on February 11, 2020, less than 2 

weeks after the declaration of a public health emergency of international concern. On 

April 21, 2020, about 6 weeks after recognition of a pandemic, the Agency legalized the 

new Bureau for Asia, which merged the former Office of Afghanistan and Pakistan 

Affairs with other Asia programs. Meanwhile, USAID is working to increase the size of 

its workforce and reach authorized staffing levels through accelerated recruitment, 

hiring, and onboarding. While these actions demonstrate USAID’s ability to make big 

changes even under challenging circumstances, USAID must consider how to mitigate 

the impact of large-scale structural and management changes on its workforce, reporting 

relationships, and decision-making processes, particularly as these new bureaus are tied 

to USAID’s humanitarian response and the region where the pandemic originated. 

The COVID-19 pandemic also tests USAID’s ability to manage its information 

technology (IT) systems and security. Maximizing telework for its global workforce 

limits workplace exposure to the virus but increases risks of security breaches and data 

loss. USAID has been proactive in expanding telework readiness and disseminating 

information to staff through email.40 Yet, risks remain as staff access official systems and 

36 USAID OIG, “Award Oversight Is Insufficient To Hold Implementers Accountable for Achieving 

Results” (9-000-19-006-P), September 25, 2019; USAID OIG, “USAID Zika Response Efforts in the 

Western Hemisphere,” Special Report, May 24, 2018; USAID OIG, “Lessons From USAID’s Ebola 

Response Highlight the Need for a Public Health Emergency Policy Framework” (9-000-18-001-P), January 

24, 2018; and USAID OIG, “Ebola Experience Highlights Opportunities To Strengthen USAID’s Award 

Process and Reprogram Funds” (9-000-17-001-P), December 27, 2016. 37 GAO, “Emergency Funding for Ebola Response: Some USAID Reimbursements Did Not Comply With 

Legislative Requirements and Need To Be Reversed” (GAO-17-35), November 2, 2016. 38 Executive Order 13781 (March 13, 2017) and OMB Memorandum M-17-22 (April 12, 2017) both 

related to carrying out the President’s vision to improve the effectiveness, efficiency, and accountability of 

the Federal Government. 39 USAID OIG, “USAID’s Redesign Efforts Have Shifted Over Time” (9-000-18-003-P), March 8, 2018. We 

also prepared an advisory notice to inform USAID’s approach to its redesign: “Key Considerations for 

Developing USAID’s Comprehensive Plan on Reforming and Reducing the Federal Workforce,” Advisory 

Notice, June 21, 2017. 

40 Including “Cyber Awareness Notice: Home Network Security: What Is It and Why Does It Matter?” 

April 15, 2020; “Records Management Responsibilities During COVID-19 Event,” April 3, 2020; and 

“Information Protection Reminders While Teleworking,” March 25, 2020.
Office of Inspector General, U.S. Agency for International Development 16

information remotely and with personally owned devices, and USAID has yet to 

strengthen certain IT controls or the authority of its chief information officer.41 And, 

while USAID has reminded staff about policies against using nonofficial electronic 

systems like WhatsApp, personal emails and texts, and videoconferencing systems like 

Zoom, to conduct official business, staff may be more prone to use them in the at-home 

COVID-19 environment. Furthermore, USAID may need to consider additional 

precautions to ensure classified information is appropriately safeguarded under the new 

environment, where staff access to classified information systems is altered due to the 

temporary closure of USAID’s physical office space.42

Managing data from initial collection to final reporting has been an ongoing top 

management challenge for USAID and one that may be exacerbated in the COVID-19 

response. For example, our work on USAID’s Ebola response in West Africa found that 

the lack of an Agency-wide system for capturing and sharing data obstructed 

communication and coordination, with USAID’s missions, bureaus, and independent 

offices using unique systems to fit their own needs.43 USAID pointed to its nascent 

Development Information Solution as the fix to consolidate these disparate systems, but 

implementation of the new centralized system has been delayed and only partially rolled 

out on a pilot basis, and the Agency is still without a complete, centralized portfolio 

management system for tracking its response. 

Accordingly, we pose the following questions drawn from past lessons learned to 

strengthen the Agency’s core management functions in USAID’s COVID-19 response:

1. Has USAID taken appropriate measures to manage the shift in the management 

structure of its field operations and composition of staff on the ground with clear 

roles, responsibilities, and chains of authority? How has USAID ensured employees 

with temporarily expanded procurement and purchasing capabilities have the 

requisite training, bandwidth, and supervision to carry out their new responsibilities?

2. As USAID’s contracting and agreement officers and their representatives handle 

case-by-case requests from implementers for no-cost extensions and pre-approval 

of COVID-19-related costs, has USAID provided sufficient, documented guidance to 

ensure uniformity in decision making? How will USAID monitor and enforce 

compliance, particularly given reported staffing constraints in key positions? Has 

USAID provided clear requirements for documenting approvals and their 

justifications?

41 USAID OIG, “USAID Generally Implemented an Effective Information Security Program for Fiscal Year 

2019 in Support of FISMA” (A-000-20-005-C), February 7, 2020; USAID OIG, “USAID Has Gaps in 

Conforming With the Federal Information Technology Acquisition Reform Act” (A-000-19-004-C), 

November 9, 2018.

42 USAID OIG, “USAID’s Implementation of Executive Order 13526, Classified National Security 

Information, Needs Significant Improvement” (9-000-16-001-P), September 30, 2016. 43 USAID OIG, “Lessons From USAID’s Ebola Response Highlight the Need for a Public Health 

Emergency Policy Framework” (9-000-18-001-P), January 24, 2018.
Office of Inspector General, U.S. Agency for International Development 17

3. What controls has USAID implemented to ensure that eased procurement 

requirements like the Expedited Procedures Package are not used to extend poorly 

performing programs, partner with unqualified new recipients, or circumvent 

competition, source, and nationality requirements for ineligible programs, goods, and 

services? Has USAID documented and communicated requirements to employees 

and implementers for maintaining documented records of COVID-19-related 

exceptions, like pre-approvals and delayed reporting timelines, and established plans 

for monitoring and enforcing compliance?

4. What steps can USAID take to ensure that written guidance and staff capacity are 

sufficient to implement processes for making programming and funding decisions, 

including reprogramming and redirecting existing awards and approving new 

activities, consistently across bureaus, missions, and independent offices; through 

multiple layers of review; and within the timeframes established for an effective 

response? How will USAID ensure the provisions of all applicable laws and 

requirements are met?

5. What measures does USAID have in place to ensure staff follow procedures limiting 

the use of nonofficial electronic systems to conduct official business? How does 

USAID monitor compliance with requirements to copy or forward all record 

content to an official USAID electronic messaging account within 20 days in 

accordance with the Federal Records Act, or obtain a waiver from the Office of the 

Chief Information Officer for exceptions? 

6. How will USAID keep its data secure and implement effective controls for accessing 

its primary external Agency systems, particularly from personally owned devices? Is 

USAID positioned to recover data from a catastrophic loss given that the Agency 

has not fully defined its process, strategy, and technologies for information system 

backups and storage?44 What additional steps has USAID taken to safeguard 

classified information in the COVID-19 context?

7. Although USAID’s information systems may be functioning, has the Agency 

developed processes for critical non-IT-related functions, such as clearing and 

obtaining badges and network access for its COVID-19 direct-hire staff and 

contractors, and have those processes been documented in the Agency’s 

contingency plan? 

8. Has USAID implemented controls to standardize how its missions, bureaus, and 

independent offices will measure, collect, and report on their COVID-19 activities in 

the Development Information Solution or other data collection systems? How will 

USAID ensure the integrity of data manually keyed into these systems?

44 USAID Federal Information Security Modernization Act of 2014 (FISMA) Metrics, #65.
Office of Inspector General, U.S. Agency for International Development 18

Concluding Observations

As the U.S. Government’s lead international development agency and a world leader in 

providing humanitarian assistance, USAID has the experience and expertise to drive an 

effective COVID-19 response while protecting the health and safety of its staff 

worldwide. In doing so, USAID must take necessary steps to ensure that the funding 

entrusted to it by Congress and the American taxpayer is used effectively, efficiently, 

and with appropriate oversight—while balancing the need to implement a timely and 

agile response to the pandemic across the globe. This advisory notice serves to inform

USAID of key questions drawn from past lessons learned as it continues to define and 

execute its response to the COVID-19 pandemic. 

USAID OIG will monitor USAID’s COVID-19 response as it unfolds and tailor our 

oversight approach based on risks, emerging issues, and stakeholder interests. We will 

also continue to fulfill the audit, investigative, and other oversight activities outlined in 

our annual oversight plan to safeguard and strengthen U.S. foreign assistance. 

We appreciate your ongoing commitment to cooperation with our office. Please 

continue to encourage staff to report fraud, waste, and abuse through our OIG Hotline, 

which remains fully staffed through the pandemic. 

If you have any questions or comments about this advisory, you may reach me or 

Deputy Inspector General, Thomas J. Ullom, at 202-712-1150.

CC: Bonnie Glick, USAID Deputy Administrator

William Steiger, USAID Chief of Staff

Chris Milligan, Counselor to the Agency

Ken Staley, USAID COVID-19 Task Force Executive Director
Office of Inspector General, U.S. Agency for International Development 19

Attachment: Agency Comments

May 20, 2020

The Honorable Ann Calvaresi Barr

Inspector General

Office of Inspector General

United States Agency for International Development

1300 Pennsylvania Avenue, N.W.

Washington, D.C. 20523

Dear Madam Inspector General:

The U.S. Agency for International Development (USAID) appreciates the 

Advisory Notice on Key Questions to Inform USAID’s COVID-19 Response issued by the 

USAID Office of Inspector General (OIG) on May 13, 2020. 

USAID maintains staff and operations in more than 80 countries around the 

world; the pandemic of COVID-19 is affecting them all. The Agency agrees with the 

OIG on the importance of safeguarding taxpayer dollars to maximize the impact of 

foreign assistance, and remains committed to protecting the health and safety of our staff, 

while continuing appropriate oversight of our programs to ensure the accountable and 

effective use of U.S. taxpayer funds. 

The enclosed Management Comments outline many of the Agency’s 

considerations in planning and executing our response to the COVID-19 pandemic and 

describe the actions we have taken to date. USAID has issued guidance on innovative 

monitoring strategies; established a webpage and resource center on COVID-19 for 

implementing partners; and made additional tools and authorities available to our 

Missions that expand the telework, procurement, and supervisory capabilities of our 

Foreign Service National (FSN) workforce.

The Agency’s effort to manage risks, maintain our monitoring responsibilities, 

maximize coordination with stakeholders, and implement controls in core Agency 

functions is ongoing during our response to COVID-19. USAID welcomes the OIG’s 

Key Questions, which provide a valuable opportunity to assess and improve upon our 

policies, procedures, and programs. Thank you again for the opportunity to respond to 

your Advisory Notice. 

Sincerely, 

/s/

John Barsa

Acting Administrator

Attachment
Office of Inspector General, U.S. Agency for International Development 20

COMMENTS BY THE U.S. AGENCY FOR INTERNATIONAL DEVELOPMENT 

ON THE ADVISORY NOTICE ISSUED BY THE 

USAID OFFICE OF INSPECTOR GENERAL TITLED, 

KEY QUESTIONS TO INFORM USAID’S COVID-19 RESPONSE 

Please find below the Management Comments from the U.S. Agency for International 

Development (USAID) on the Advisory Notice issued by the USAID Office of Inspector 

General (OIG) titled, Key Questions to Inform USAID’s COVID-19 Response: 

Managing Risks to Humanitarian Assistance Amid a Public Health Emergency of 

International Concern (PHEIC)

USAID recognizes that the pandemic of COVID-19 adds new challenges to our ability to 

plan, implement, and monitor humanitarian-assistance activities during a PHEIC. Given 

these challenges, the Offices of U.S. Foreign Disaster Assistance (OFDA) and Food for 

Peace (FFP) in our Bureau for Democracy, Conflict, and Humanitarian Assistance 

(DCHA) have stood up a COVID-19 Response Management Team (RMT) to work 

closely with our Agency-wide COVID-19 Task Force. 

The RMT is assessing implementers’ proposed beneficiary plans, including for the 

procurement and distribution of commodities. For high-threat operating environments, 

the Agency requires implementers to submit risk-mitigation plans, which specifically 

examine their internal-control systems. Using a post-award vetting approach consistent 

with the Agency’s Standard Operating Procedures for Vetting in Syria, DCHA and its 

successor Bureau for Humanitarian Assistance (BHA) plan to vet implementing partners 

in Northeast and Northwest Syria that will receive funds from the International Disaster 

Assistance (IDA) account appropriated from the Coronavirus Preparedness and Response 

Supplemental Appropriations Act, 2020 (COVID-19 Supplemental). In addition, USAID 

will initiate pre-award vetting of implementing partners who receive COVID-19 

supplemental IDA funds in the West Bank and Lebanon.

USAID takes preventing and detecting fraud and other misconduct very seriously. Both 

DCHA/FFP and DCHA/OFDA require all applications from potential implementers to 

integrate fraud-prevention measures, and the recently released Guidance for Applicants 

Engaging in the COVID-19 Response contains additional guidance on risk-management 

for organizations that are submitting proposals. Both Offices offer training and guidance 

for our staff and have coordinated with the OIG to provide training to our implementers

to ensure they report and follow up on all instances of fraud and other programmatic 

irregularities promptly.

While many of the available data sources have helped measure vulnerability to COVID19 and the epidemiologic situation at a national level, a scarcity of sub-national level data 

remains, especially on humanitarian locations and conditions. The COVID-19 RMT 

developed an external/contextual data-analysis framework that maps the potential chain 

of events of a COVID-19 health emergency (when community transmission causes a 

cascading collapse of health care) as well as how shocks from the pandemic causes a 
Office of Inspector General, U.S. Agency for International Development 21

broader humanitarian emergency and secondary effects (increased food-insecurity, 

livelihoods erosion, displacement, etc.). The COVID-19 RMT has identified multiple 

external data sources and indexes, such as the Index for Risk-Management (INFORM)45, 

the Global Health Security Index (GHSI), the Global Severity Crisis Index (GSCI), the 

Food and Agricultural Organization (FAO) of the United Nations, the Famine EarlyWarning System Network (FEWSNET)46, the International Organization for Migration

(IOM), the World Bank, and others. DCHA has matched these data sources to key points 

on the contextual data-analysis framework that could inform the RMT which countries 

could be more vulnerable to COVID-19 and the different health and humanitarian 

consequences they could face as a result of the pandemic. Additionally the RMT has 

been using modeling analysis from Lincoln Laboratories at the Massachusetts Institute of 

Technology, funded by DCHA/OFDA, to look at specific country-level vulnerability and 

assist with our global COVID-19 planning.

USAID is committed to providing as much information as possible to our partners during 

these uncertain times. The Agency maintains regular communication with our 

implementing partners at the field and headquarters levels to enable timely and efficient 

funding decisions. USAID is working with our partners to ensure maximum 

programmatic flexibility in the face of restrictions related to COVID-19 across the entire 

humanitarian portfolio, including emergency food assistance. Programs are adapting by 

adjusting distribution methods to limit the risk of transmission, pre-positioning 

commodities in countries to mitigate the impact of closed borders, and using technology 

such as electronic transfers. 

USAID is leveraging strengths, best practices, and lessons learned from previous 

responses to contribute to a more effective strategy against COVID-19. Using previous 

internal evaluations and audits of responses, including the OIG’s audits of USAID’s 

response to the Ebola crisis in West Africa, DCHA/OFDA developed policies, guidance, 

and tools on monitoring, evaluation, accountability, and learning (MEAL) and 

assessment and analysis that guide humanitarian responses on the use of data analytics 

for prioritization and evidenced-based programming. In addition, DCHA/OFDA 

developed two new positions, the Monitoring and Evaluation Specialist and Data, 

Assessment, and Analytics Specialist, both activated on the COVID-19 RMT, to assist 

with the implementation of policies, tools, and guidance.

Maintaining Responsibilities for Planning, Monitoring, and Sustaining U.S.-Funded 

Development

USAID’s Pillar and Regional Bureaus have mobilized to synthesize, develop, and 

disseminate the best available evidence and promising practices to respond to the impact 

45 A collaboration of the Inter-Agency Standing Committee Reference Group on Risk, Early Warning, and 

Preparedness and the European Commission,

46 Funded by USAID.
Office of Inspector General, U.S. Agency for International Development 22

of COVID-19 across the sectors in which we work. In addition, Bureaus are engaging 

actively with USAID’s field staff and partners to provide these guidance documents to 

field teams. This includes holding webinars, conference calls, and virtual training to 

build the capacity of staff and partners to respond to new challenges and opportunities 

during this crisis. With the assistance of USAID’s COVID-19 Task Force, our Pillar and 

Regional Bureaus have developed guidance and metrics specifically for the response to 

COVID-19 that our Operating Units (OUs) and implementing partners will use to gauge 

the performance of the programs we fund and enable better adaptive management. 

The vast sums of resources required to respond to the COVID-19 pandemic, combined 

with chaotic situations, are creating unprecedented opportunities for corrupt actors. In its 

response, USAID is considering ways to do the following: (1) strengthen public 

financial-management systems to oversee the planning, budgeting, and use of COVID-19 

funds to ensure we are targeting them to reduce the effects of the virus; (2) funds 

programs aimed at mitigating the risks of corruption in health care; and, (3) enhance the 

ability to detect, prevent, respond to, and sanction general COVID-19-related corruption. 

USAID’s Center of Excellence on Democracy, Human Rights, and Governance is 

providing support to our Missions and partners to implement these strategies effectively 

across the globe. Some examples include the following:

● USAID’s new anti-corruption and integrity program (the Transparent 

Accountable Public Investment [TAPI] activity), is providing technical assistance 

so the Government of the Republic of Perú can procure its own medical supplies 

in response to the COVID-19 crisis and develop regulations needed to purchase 

goods and services transparently during future emergencies. 

● USAID’s National Accountability Program in the Republic of Indonesia, CEGAH

(which means “prevent” in Bahasa Indonesia), will upgrade and enhance the 

system for national complaints, LAPOR! (Layanan Aspirasi dan Pengaduan 

Online Rakyat) to support an effective response to COVID-19. The program will 

also expand its procurement-transparency work to cover COVID-19-related 

purchases, and will conduct rapid assessments for the risk of corruption for the 

Inspector General of the Ministry of Health, and provide online training for its 

staff on Procurement Preparedness for Emergency and Disaster Response.

To respond to on-the-ground conditions and needs, USAID uses a criteria-based, bottomup approach that prioritizes programs for funding in line with the Strategy for 

Supplemental Funding to Prevent, Prepare for and Respond to Coronavirus Abroad. 

USAID’s Missions recommend proposals for supplemental funding that respond to local 

needs and fill gaps related to health, social, economic, and governance-related impacts. 

At a global level, USAID uses tools and data sources to monitor on-the-ground 

conditions, including FEWSNET to monitor acute food-insecurity; data from the Global 

Monitoring of School Closures of the Institute for Statistics of the United Nations 

Educational, Scientific, and Cultural Organization (UNESCO) to track school closures 

during COVID-19; and the COVID-19 Disorder Tracker of the Armed Conflict Location 
Office of Inspector General, U.S. Agency for International Development 23

and Event Data Project (ACLED) to monitor the impact of the pandemic on political 

violence.

Even during the current crisis, we must continue to monitor and evaluate our programs, 

and we have tasked our Agreement and Contracting Officers’ Representatives 

(AORs/CORs) to work with our implementing partners to find innovative, effective, and 

safe ways to do so. The Agency released guidance on April 10, 2020, with 

considerations and resources, including information on remote monitoring and existing 

Agency mechanisms through which OUs can procure supplemental monitoring capacity. 

Lessons learned from the response to the outbreak of Ebola in West Africa in 2014 

suggest that platforms that are already in place, in use, and trusted by local stakeholders 

are more effective for collecting data. The Acting Administrator and the Agency’s 

COVID-10 Task Force has encouraged our OUs to pursue innovative monitoring 

approaches, including conducting remote monitoring through cell phones, leveraging big 

data, accessing data from institutional-monitoring systems, and using satellite data and 

geospatial information. OUs can deploy these approaches individually, or in 

combination, to supplement existing monitoring. Before using any new tools or datacollection methodology, OUs first must consider what tools or de-identified data are 

already in use and can be repurposed. OUs will consider appropriate data-privacy and 

data-security protections and protocols when making the transition to remote monitoring. 

The Global Development Lab (LAB), with support from the Bureau for Policy, Planning, 

and Learning (PPL), released a guidebook on remote monitoring for USAID and its 

partners. The teams also established a resource page for partners to share best practices 

and lessons learned on monitoring during COVID-19 on the website of the USAID’s 

Learning Lab. 

USAID’s CORs/AORs are working with our implementing partners to document updated 

approaches in each agreement’s plans for monitoring, evaluation, and learning (MEL), 

and will upload these amended plans into the Agency Secure Image and Storage Tracking 

System (ASIST).

Finally, PPL issued guidelines for reflecting COVID-19 in our five-year, country-specific 

Regional and Country Development Cooperation Strategies (R/CDCSs). The Agency is 

updating all these strategies by December 2020 to incorporate the principles of the 

Journey to Self-Reliance. Many R/CDCSs will now also incorporate COVID-19 by 

considering either a new operating environment or the medium- and long-term effects the 

pandemic will have in-country.

Maximizing Coordination with Stakeholders in the Global Response to COVID-19 

USAID’s COVID-19 Task Force engages regularly with the U.S. Government 

interagency to ensure our response activities are coordinated, strategic, and nonduplicative. This includes standing and ad-hoc meetings with the U.S. Department of 

Defense (DoD) and USAID’s DoD liaisons; USAID’s embedded experts at the U.S. 
Office of Inspector General, U.S. Agency for International Development 24

Missions to the United Nations (USUN) Geneva, New York, and Rome, and the U.S. 

Mission to the European Union in Brussels; the Coronavirus Global Response 

Coordination Unit (CGRCU) at the U.S. Department of State (State); the U.S. 

Department of Health and Human Services (HHS), including the Centers for Disease 

Control and Prevention (CDC); and the Foreign Agricultural Service within the U.S. 

Department of Agriculture (USDA). The Agency is in regular contact with the White 

House Coronavirus Task Force for overall policy guidance and prioritization for foreign 

assistance, and participates in National Security Council meetings that focus on White 

House priorities in the pandemic response. USAID contributes to interagency cables to 

All Diplomatic and Consular (ALDAC) posts that describe the unified U.S. Government 

(USG) framework for addressing COVID-19 under the Strategy for Supplemental 

Funding to Prevent, Prepare for and Respond to Coronavirus Abroad.

As part of USAID’s responses to mitigate the second-order economic impact of the 

pandemic, we are collaborating closely with the U.S. International Development Finance 

Corporation (DFC) and other similar institutions to catalyze private-sector investment. 

The leadership of USAID and the DFC are in regular contact about strategic approaches 

to COVID-19 response, and we have established bi-weekly meetings of a USAID 

technical working group with the DFC’s Mission Transaction Unit to coordinate 

responses to requests for technical assistance from our Missions and build a pipeline of 

potential deals with private-sector partners. USAID is collaborating with the DFC to 

explore opportunities that support innovators focused on COVID-19, local manufacturers 

that wish to retool to produce personal protective equipment and other pandemic-related 

products, companies that are developing diagnostics or therapeutics for COVID-19, and 

health-care providers. USAID and DFC are also exploring emergency liquidity workingcapital facilities for micro, small and medium-sized enterprises (MSMEs).

In addition, USAID is applying best practices in global coordination developed in 

responding to Ebola and advancing the Global Health Security Agenda. USAID has 

convened multiple donor roundtables to share information and learn about the priorities 

of key bilateral donors in response to COVID-19. USAID’s Task Force is tracking other 

donors' commitments by geographic region, including responses to various United 

Nations appeals and investments in vaccines, diagnostics, and therapeutics.

USAID recognizes that to respond to the global COVID-19 pandemic effectively, while 

also optimizing the positive impact of our funding and continuing to advance the Journey 

to Self Reliance (J2SR), we must continue to leverage the approaches and innovations of 

Effective Partnering and Procurement Reform (EPPR) and the New Partnerships 

Initiative (NPI). By permitting streamlined, rational, and diverse processes for 

acquisition and assistance through the Expedited Procedures Package (EPP) approved by 

former Administrator Mark Green, we are saving both time and resources. This will 

allow us to reinvest in strengthening current partners and forging partnerships with new 

and underutilized ones, including small businesses; locally-established partners (LEPs); 

private philanthropy; and for-profit, and faith- and community-based organizations. 

These partnerships can provide in-country efficiencies in the delivery of assistance and 

build a crisis-response capacity that will endure beyond USAID’s engagement. In doing 
Office of Inspector General, U.S. Agency for International Development 25

so, the Agency will advance our Transformation to reflect innovations adopted by the 

global assistance and development communities and exercise prudent stewardship of 

taxpayer dollars.

As a central part of the J2SR, USAID will continue and strengthen private-sector 

engagement (PSE) during the COVID-19 pandemic. USAID will identify and mitigate 

risks through the steps outlined in our Private-Sector Engagement Policy (2018), 

specifically through dedicated consultation with commercial firms for greater scale, 

sustainability, and effectiveness of outcomes. USAID is consulting with U.S. and local 

businesses and non-governmental stakeholders to mitigate and respond to the secondorder impacts of COVID-19 across a range of sectors, including governance, the 

economy, rule of law, education, energy, tourism, agriculture, water, and food security. 

Together we seek to understand and mitigate the disruptions to economic and financial 

systems and address both short- and long-term repercussions on self-reliance across a 

range of economic sectors and supply-chains. Additionally, we are drawing guidance 

from the ongoing OIG audit, USAID’s Use of Partnerships Through Private-Sector 

Engagement (Task No. 55100218). 

Finally, we are committed to making sure our beneficiaries know they are receiving 

assistance because of the generosity of the American people. The Agency's branding and 

marking follows Chapter 320 of our Automated Directives System (ADS), Part 700.16 of 

Title 2 of the Code of Federal Regulations, as well as the Foreign Assistance Act (as 

amended). Our Bureau for Legislative and Public Affairs (LPA) is creating a “look and 

feel” to accompany USAID’s branding that will promote the All-of-America response to 

COVID-19. This “look and feel” visual identity to promote that our assistance related to 

COVID-19 is “from the American people” does not violate USAID’s branding policy, 

and LPA’s Senior Advisor for Brand Management is providing guidance on the matter. 

Additionally, the Acting Administrator has told OUs they should aim for the maximum 

level of branding possible, and that waivers will be exceedingly rare and subject to 

approval. The enforcement of branding is ultimately the responsibility of each 

Contracting and Agreement Officer (CO/AO), who is cognizant of our leadership’s 

intent. The Agency’s COVID-19 Task Force and LPA have reinforced that OUs must 

follow the guidance in ADS Chapter 320. 

Addressing Vulnerabilities and Implementing Needed Controls in the Agency’s 

Core Management Functions

To manage the shift in the management structure of field operations required by the 

COVID-19 pandemic and continue key overseas operations to the best of our ability, our 

Bureau for Management (M) and Offices of Human Capital and Talent Management 

(HCTM) and the General Counsel (GC) made additional tools and authorities available to 

Missions that expand the telework, procurement, and supervisory capabilities of our 

Foreign Service National (FSN) workforce. The Office of Acquisition and Assistance 

within the M Bureau requests for waivers for temporary warrants carefully to maintain 

the integrity of the warrant program; all holders of temporary warrants have earned a 

certification at Level One of the Federal Acquisition Certification - Contracting training 
Office of Inspector General, U.S. Agency for International Development 26

offered by the Federal Acquisition Institute, and an after-action review by the supervisory 

CO is required (which is also true for the permanent warrant program).

USAID’s COVID-19 Task Force is working to publish clear and effective guidance on 

programming and funding processes related to responding to the pandemic. Where 

existing guidance is insufficient, the Task Force has released supplemental material. The 

Task Force developed all supplemental guidance in coordination with our Office of 

Budget and Resource Management (BRM), GC, the M Bureau, and the Office of Foreign 

Assistance at the Department of State (State/F).

USAID is implementing controls to ensure our OUs do not use the EPP to extend poorly 

performing programs; sign agreements with unqualified recipients; or circumvent 

competition, source, and nationality requirements for ineligible programs, goods, and 

services. Each Activity Planner/COR/AOR is responsible for identifying the specific 

activities and awards to which the authorities within the EPP may apply. Technical 

offices must coordinate with the cognizant CO/AO, GC and Resident Legal Officer 

(RLO) as far in advance as possible to discuss how they intend to use the authorities, 

applications, and requirements for a specific action in acquisition and assistance. The 

EPP’s authorities do not replace or remove any clearance or approval requirements in 

ADS Chapter 300, Agency Acquisition and Assistance Planning, such as the Senior 

Obligation Alignment Review (SOAR).

While our employees are teleworking, USAID is using the full range of our capabilities 

to educate and enforce that our staff follow procedures to limit the use of non-official 

electronic systems to conduct official business. This includes official policies, annual 

training, Agency-wide communications, and reminders, as well as taking enforcement 

action when the Agency learns that staff are not following the rules. USAID conducts 

periodic audits of staff who are known to have received approval to forward record 

content to an official USAID electronic-messaging account, and investigates any cases 

that could come to the Agency’s attention. 

During this period of maximum telework, the Agency continues to use our normal 

operating procedures to keep our data secure, including through controls for accessing 

our primary Agency systems via two-factor authentication; Virtual Desktop functionality; 

a suite of information-security tools, including Data-Loss Prevention and log-monitoring; 

and new initiatives such as implementing a Cloud-Access Security Broker (CASB). 

USAID has fail-safes in place that allow us to recover data from a catastrophic loss, 

including approved, tested, Federally compliant cloud systems and our own hybrid cloud 

enterprise data center. In 2018, USAID completed the migration of our sole data center 

to a hybrid cloud solution with full disaster-recovery capability. The new USAID 

Enterprise Data Center/Disaster-Recovery (EDC/DR) solution provides government 

Infrastructure as a Service (IaaS) as a standardized, highly automated offering, as well as 

redundancy for the Agency’s network and our business-critical systems. USAID also 

gained the ability to capitalize on more modern technology that has several benefits, 

including the ability to restore data in several hours versus days or weeks. Safeguarding 
Office of Inspector General, U.S. Agency for International Development 27

classified information falls under ADS Chapters 568 and 552 during normal operations, 

and in the COVID-19 context.

USAID’s COVID-19 Task Force, in coordination with BRM, the M Bureau, and State/F, 

is working to ensure the standard collection and reporting of data for activities across the 

Agency related to COVID-19. This includes adaptations to existing data-collection 

systems (USAID Info, Phoenix, FACTS Info, etc.).
Office of Inspector General

U.S. Agency for International Development

1300 Pennsylvania Avenue NW

Washington, DC 20523

https://oig.usaid.gov