Human Trafficking: State and USAID Should Improve Their Monitoring of International Counter-trafficking Projects
Released: 2018-12-04T00:00:00

Letter

Background

Human trafficking exploits individuals and often involves transnational criminal organizations, violations of labor and immigration codes, and government corruption. Many forms of trafficking—including sex trafficking and labor trafficking—can take place anywhere in the world and occur without crossing country boundaries. As discussed in State’s annual Trafficking in Persons Report, trafficking victims include, for example, Asian and African women and men who migrate to the Persian Gulf region for domestic labor but then suffer both labor trafficking and sexual abuse in the homes of their employers. Some victims are children. For example, Pakistani children as young as 5 years are sold or kidnapped into forced labor to work in brick kilns, some of which are owned by government officials. Other victims are subjected to sexual exploitation. In some cases, women and girls have been bought and sold as sex slaves by members of the Islamic State. In other cases, adult men and women have been forced to engage in commercial sex, and children induced to do the same. Individuals, including men, are exploited in forced labor in a variety of industries. Burmese men, for example, have been forced to labor 20 hours a day, 7 days a week on fishing boats in Thailand. See figure 1 for examples of victims of trafficking in persons.

Among other U.S. agencies involved in counter-trafficking in persons, State, DOL, USAID, DOD, and Treasury have various roles and responsibilities related to international counter-trafficking in persons, including some internationally-focused programs and activities that do not involve awards made to implementing partners, as follows:

State. State leads the global engagement of the United States, and supports the coordination of efforts across the U.S government in counter-trafficking in persons. State’s Office to Monitor and Combat Trafficking in Persons (TIP Office), established pursuant to the Trafficking Victims Protection Act of 2000, is responsible for bilateral and multilateral diplomacy, targeted foreign assistance, and public engagement on trafficking in persons. The office also prepares and issues an annual Trafficking in Persons Report that assesses the counter-trafficking efforts of governments and assigns them tier rankings. Furthermore, the TIP Office develops annual regional programming strategies, awards projects to implementing partners and oversees the project award process, and provides technical assistance to implementing partners. Other parts of State, including regional bureaus that cover geographic regions and functional bureaus that cover global issues such as human rights, are also responsible for work related to combating trafficking in persons.

DOL. Within DOL, the Bureau of International Labor Affairs’ (ILAB)

Office of Child Labor, Forced Labor, and Human Trafficking (OCFT) conducts research, publishes reports, and administers projects awarded to implementing partners on international child labor, forced labor, and trafficking in persons. ILAB’s reports include the annual Findings on the Worst Forms of Child Labor report, which assesses the efforts of approximately 140 countries and territories to eliminate the worst forms of child labor in the areas of laws and regulations, institutional mechanisms for coordinating and enforcement, and government policies and programs. ILAB also reports on the List of Goods Produced by Child Labor or Forced Labor showing goods and their source countries which ILAB has reason to believe are produced by child labor or forced labor in violation of international standards.

USAID. USAID administers projects awarded to implementing partners that address counter-trafficking in persons, including increased investments in conflict and crisis areas, and integrating such projects into broader development projects. USAID field missions manage the majority of these counter-trafficking activities through projects that address trafficking challenges specific to the field mission’s region or country. USAID’s Center of Excellence on Democracy, Human Rights and Governance (DRG Center) in Washington, D.C. is responsible for oversight of USAID’s counter- trafficking policy. The DRG Center is responsible for coordinating and reporting on USAID-wide counter-trafficking in persons efforts; oversees the implementation of USAID’s counter-trafficking in persons policy in collaboration with regional bureaus and country missions; works with regional bureaus and country missions to gather counter- trafficking best practices and lessons learned; provides technical assistance and training to field and Washington-based staff on designing, managing, and monitoring and evaluating trafficking in persons projects; and conducts and manages research and learning activities related to combating trafficking in persons to collect data to inform the design of field projects.

DOD. DOD’s Combating Trafficking in Persons Program Management Office, under the Under Secretary of Defense for Personnel and Readiness in the Defense Human Resources Activity, develops trafficking awareness and training material for all DOD components. On December 16, 2002, the President signed National Security Presidential Directive 22, which declared the United States had a zero tolerance policy for trafficking in persons. The Combating Trafficking in Persons Program Management Office is responsible for overseeing, developing, and providing the tools necessary for implementing National Security Directive 22 within DOD. The office has developed several different training programs, designed to provide an overview of trafficking in persons (including signs of trafficking, key policies and procedures, and reporting procedures), as well as awareness materials for distribution to DOD components and defense contractors overseas.

Treasury. Treasury has activities, but not specific programs, that may support wider U.S. efforts to address counter-trafficking in persons, according to Treasury officials. Pursuant to its mandate, components of Treasury’s Office of Terrorism and Financial Intelligence (TFI), including Financial Crimes Enforcement Network (FinCEN), Office of Terrorist Financing and Financial Crimes (TFFC), and Office of Foreign Assets Control (OFAC) work on addressing illicit finance activities that support the wider goal of combating global trafficking in persons.

Pursuant to the Trafficking Victims Protection Act of 2000, the President established the President’s Interagency Task Force to Monitor and Combat Trafficking in Persons (PITF), which is a cabinet-level entity that consists of agencies across the federal government responsible for coordinating implementation of the Trafficking Victims Protection Act of 2000, among other activities. It is chaired by the Secretary of State; State, DOL, USAID, DOD, and Treasury are all PITF agencies. In addition, the Trafficking Victims Protection Act, as amended in 2003, established the Senior Policy Operating Group, which consists of senior officials designated as representatives of the PITF agencies.

During Fiscal Year 2017, State, DOL, and USAID Managed 120 Counter- Trafficking in Persons Projects

State, DOL, and USAID managed 120 projects in counter-trafficking in persons carried out by implementing partners during fiscal year 2017, according to information provided by officials with these agencies. These projects, as identified by agency officials, ranged from those focused on counter-trafficking in persons, to those in which counter-trafficking in persons was integrated into but was not the primary goal of the project. At these agencies, project officers work with the implementing partner on the administration and technical guidance of the project, such as reviewing progress reports. Table 1 shows a summary of these agencies’ project information; appendix II provides more detailed information on all 120 projects.

During fiscal year 2017, State managed 79 counter-trafficking projects, from those focused on individual countries, to regional and global ones that covered several countries, with a total award amount of approximately $62 million, according to information provided by State officials. State TIP Office managed 75 projects with total awarded amount of around $57 million. Award amounts per project ranged from approximately $150,000 to $2.55 million. For example,

State TIP Office had 11 global projects totaling about $10 million and 6 regional projects in Africa amounting to about $4 million.

State TIP Office had two projects in Ghana that received the highest amount of awards, approximately $2.5 million for each project.

State TIP Office had four projects in India amounting to around $3 million, and four in Thailand totaling around $2.35 million.

In addition to State TIP Office’s projects, State’s Bureau of Democracy, Human Rights, and Labor (DRL) managed four counter-trafficking projects with a reported total award amount of about $5 million, with two projects in Mauritania making up around 70 percent of DRL’s total awarded amount.

DOL’s ILAB/OCFT managed six projects in fiscal year 2017 with a total award amount of approximately $31 million, according to DOL officials. These projects ranged from one scheduled to last for 5 years with an awarded amount of about $1 million, to one scheduled to last for about 4 years with an awarded amount of about $14 million. Three of DOL’s projects were global projects, while two others focused on two countries each and one project focused on one country.

USAID’s projects during fiscal year 2017 consisted of 2 regional projects in Asia, and 33 individual projects in 22 different countries. Some of these USAID-identified projects were integrated projects with a broader development focus that includes USAID programmatic objectives other than counter-trafficking in persons. According to information provided by USAID officials, the award amount for all counter-trafficking in persons projects active in fiscal year 2017, including all integrated projects and standalone projects with a sole focus on combatting trafficking in persons, totaled around $296 million; and USAID’s committed funding to these projects’ activities related to counter-trafficking in persons was about $79 million as of September 2018. During fiscal year 2017, USAID focused on a few countries where the agency awarded multiple counter-trafficking projects, such as four projects in Nepal and four projects in Burma.

According to officials, State, DOL, and USAID generally design projects to align with the “3Ps approach”—prevention, protection, and prosecution— and to consider trends and recommendations identified in agency reports on foreign governments’ counter-trafficking efforts. According to State’s publicly available information, the “3Ps” approach serves as the fundamental counter-trafficking in persons framework used around the world, and the U.S. government follows this approach to 1. prevent trafficking in persons through public awareness, outreach, education, and advocacy campaigns; 2. protect and assist victims by providing shelters as well as health, psychological, legal, and vocational services; and 3. investigate and prosecute trafficking in persons crimes by providing training and technical assistance for law enforcement officials, such as police, prosecutors, and judges.

State’s publicly available information on the 3Ps noted that prevention, protection, and prosecution efforts are closely intertwined. Prosecution, for example, can function as a deterrent, potentially preventing the occurrence of human trafficking. Likewise, protection can empower those who have been exploited so that they are not victimized again once they re-enter society. A victim-centered prosecution that enables a survivor to participate in the prosecution is integral to protection efforts.

In addition to the “3Ps,” a “4th P”—for partnership—serves as a complementary means to achieve progress across the “3Ps” and enlist all segments of society in the fight against human trafficking, according to State’s publicly available information. Addressing the partnerships element, USAID’s counter-trafficking policy seeks to increase coordination across a broad range of national, regional, and global stakeholders from civil society, government, the private sector, labor unions, media, and faith-based organizations.

DOL and USAID Fully Documented Their Monitoring Activities for All Selected Projects, but State Did Not Fully Document Its Activities for 16 of 37 Selected Projects

State, DOL, and USAID Use Similar Tools to Monitor Performance of Their Counter-Trafficking in Persons Projects

Monitoring is the collecting of data to determine whether a project is being implemented as intended and the tracking of progress through preselected performance indicators during the life of a project. State, DOL, and USAID use a number of similar tools—according to their current policies, guidance, and agency officials—to monitor the performance of their counter-trafficking in persons projects, including monitoring plans, indicators and targets, periodic progress reports, and final progress reports. The agencies also conduct site visits, but their policies vary on whether site visits are required for every project during implementation.

Monitoring plan. The monitoring plan—according to monitoring policies of the three agencies—documents, among other things, all of the indicators and targets for the project as well as data collection frequency for each indicator. In addition, according to State TIP Office officials, the monitoring plan’s indicators and targets for TIP Office- managed counter-trafficking in persons projects are to be organized in a logic model, which is a visual representation that shows the linkages among the project’s goals, objectives, activities, outputs, and outcomes (see table 2). The logic model is intended to show relationships between what the project will do and what changes it expects to achieve.

Indicators and Targets. Performance indicators—according to monitoring policies of the three agencies—are used to monitor progress and measure actual results compared to expected results. Targets are to be set for each performance indicator to indicate the expected results over the course of each period of performance. According to agency officials, the monitoring plan documents indicators and targets to be tracked and reported on through periodic progress reports to assess whether the project is likely to achieve the desired results. GAO has also found that a key attribute of effective performance measures is having a measurable target.

Periodic progress reports. The reporting templates for the three agencies show that periodic progress reports—which are submitted at established intervals during the project’s implementation—compare actual to planned performance and indicate the progress made in accomplishing the goals and objectives of the project, including reporting on progress toward the monitoring plan’s indicator targets.

Final progress report. The final progress report—according to monitoring policies of the agencies or agency officials—is a stand- alone report that provides a summary of the progress and achievements made during the life of the project.

Site Visits. The three agencies policies vary on whether site visits are required for every project during implementation. For example, State’s policy notes that site visits may be conducted to review and evaluate recipient records, accomplishments, organizational procedures, and financial control systems, as well as to conduct interviews and provide technical assistance as necessary. In 2015, the State TIP Office established a goal to conduct at least one site visit during the life time of every project. While site visits during a project’s implementation are not required under DOL’s policy, DOL officials explained that they use site visits when deemed necessary to supplement information from other forms of oversight. USAID’s policy requires that a site visit be conducted for every project during implementation to provide activity oversight, inspect implementation progress and deliverables, verify monitoring data, and learn from activity implementation.

In addition to these monitoring tools, State, USAID, and DOL officials told us that they rely on frequent communication with implementing partners as part of their monitoring process. Overall, monitoring is intended to help agencies determine whether the project is meeting its goals, update and adjust interventions and activities as needed, and ensure that funds are used responsibly.

DOL and USAID Fully Documented Their Monitoring Activities for Selected Projects, while State Did Not

We found, based on our review of 54 selected counter-trafficking in persons projects (37 State, 3 DOL, and 14 USAID), that DOL and USAID had fully documented their performance monitoring activities, while State did not fully document its activities for 16 of 37 (43 percent) of the projects we reviewed with project start dates between fiscal years 2011 to 2016.

DOL’s documented monitoring activities included the monitoring plan for each project as well as fiscal year 2017 semi-annual progress reports, including indicators and targets. USAID’s documented monitoring activities included the monitoring plan for each project; fiscal year 2017 progress reports at the reporting frequency specified in the agreements for each project; the final progress report, including indicators and targets, for the three projects that ended as of December 2017; and evidence that at least one site visit was conducted during each project’s implementation. Overall, the three agencies reported having conducted at least one site visit during the life time of the project for 47 of 54 (87 percent) of the selected projects.

As shown in table 3, State did not fully document its monitoring activities (monitoring plan; fiscal year 2017 quarterly progress reports; and final progress report, including indicators and targets, for projects that ended as of December 2017) for 16 of the 37 selected projects we reviewed. Specifically, State did not have nine monitoring plans, five complete progress reports, or targets for each indicator in six of seven final progress reports for projects that ended as of December 2017. (See appendix III for detailed information on each of the 37 projects.)

For the nine projects for which the monitoring plan was not documented, the State TIP Office indicated that it was unable to locate these documents or they were not completed because the projects were finalized when the TIP Office was beginning to institute the monitoring plan requirement. Although TIP Office officials told us that the TIP Office piloted and began to phase in the monitoring plan requirement over the course of 2014 and early 2015, eight of the nine projects without monitoring plans started in September or October 2015. We found that each of the nine projects had a logic model used to report progress in the fiscal year 2017 quarterly progress reports we reviewed, which would have provided TIP Office officials a basis for monitoring project performance at that point. However, federal standards for internal control call for agency management to design monitoring activities so that all transactions are completely and accurately recorded and so that management can evaluate project results. Specifically, internal controls specify that monitoring should be ongoing throughout the life of the project, which is consistent with State’s current policy that generally requires completion of the monitoring plan prior to award. Without timely documentation of the monitoring plans at the start of the project, TIP Office officials may not be able to ensure that projects are achieving their goals, as intended, from the beginning of project operations.

For the three projects for which the quarterly progress report for the first quarter of fiscal year 2017 had been partially completed, the State TIP Office indicated that the implementing partners began to use the TIP Office’s quarterly reporting template for subsequent reports after TIP Office officials instructed the implementing partner to do so. For the one project where the quarterly progress report was not completed for the third quarter of fiscal year 2017, or partially completed for the fourth quarter of fiscal year 2017, the project officer provided possible reasons why the documents were not in the project’s file, including that the implementing partner lacked the capacity to design a logic model. The project ended December 31, 2017. Federal standards for internal control call for agency management to design monitoring activities, such as performance reporting, so that all transactions are completely and accurately recorded, and project results can be continuously evaluated. As previously discussed, performance progress reports should compare actual to planned performance and indicate the progress made in accomplishing the goals and objectives of the project. Therefore, the TIP Office may lack information needed to assess project performance if it does not have access to complete monitoring documentation.

For the six projects for which targets were not fully documented in the final progress reports, we found that targets were lacking for 110 of 253 (43 percent) of indicators across the six final progress reports. Our prior work on performance measurement identified 10 key attributes of performance measures—such as having a measurable target—that GAO has found are key to successfully measuring a project’s performance. For example, our prior work has shown that numerical targets or other measurable values facilitate future assessments of whether overall goals and objectives are achieved because comparisons can be easily made between projected performance and actual results. State TIP Office officials explained that the final progress reports we reviewed lacked targets because the TIP Office had not required targets for each indicator for the projects we reviewed that started in fiscal years 2011 to 2016. State TIP Office officials also said that project officers may not have set targets due to limited resources in previous years. A lack of actual targets limits the TIP Office’s ability to assess project performance, including effectiveness, and determine if implementation is on track or if any timely corrections or adjustments may be needed to improve project efficiency or effectiveness.

According to State TIP Office officials, the TIP Office has taken steps to improve its documentation of monitoring activities, such as instituting a monitoring plan requirement; increasing staff, including hiring a monitoring and evaluation specialist; and developing standard templates for implementing partners to use for reporting. Moreover, in November 2017, State established a new policy asserting that, building on the logic model or project charter, bureaus and independent offices must set targets for each performance indicator to indicate the expected change over the course of each period of performance. It further notes that bureaus and independent offices should maintain documentation of project design, including the logic model. Additionally, State TIP Office officials said that State is developing a department-wide automated information management system (State Assistance Management System - Domestic, or SAMS-D) that officials expect to standardize entry of performance information and, under the new system targets, must be recorded for each indicator. State TIP Office officials have worked to pilot- test SAMS-D to provide feedback on the system, including suggestions to improve the completeness of data collection, according to TIP Office officials.

Despite these efforts, the TIP Office’s documentation of all monitoring activities, and implementation of its November 2017 requirement to set targets for all performance indicators, is uncertain. For example, even though the TIP Office informed us that it began to institute a monitoring plan requirement over the course of 2014 and early 2015, as previously noted, eight projects we reviewed that started in September or October 2015 did not have monitoring plans. In addition, according to State officials, in SAMS-D, targets could be recorded as “to be determined” and there are no controls in place to ensure that “to be determined” entries are replaced with actual targets. State officials said that SAMS-D has the capability to implement controls to alert users to update “to be determined” targets, but pilot users of SAMS-D, which include the TIP Office, have not provided feedback for this capability so far. Furthermore, State TIP Office officials informed us that the TIP Office cannot require all implementing partners to set targets, but that the TIP Office aspires to update relevant targets regularly in the future and would encourage implementing partners to update target values when appropriate. Without controls to ensure full documentation of monitoring activities and established performance targets, State is limited in its ability to assess project performance, including project efficiency or effectiveness.

State and USAID Do Not Have Sufficient Controls to Ensure the Reliability of Project Information, while DOL Had Consistent and Complete Performance Information in the Project We Reviewed

In our review of selected indicators in two State TIP Office and two USAID projects, we found that State and USAID used inconsistent and incomplete performance information to monitor these projects. We found that State TIP Office and USAID do not have sufficient controls in place to ensure that the performance information they use is reliable. In contrast, we found that DOL had consistent and complete performance information in a project we reviewed, and we identified no controls in DOL’s process that were insufficient for assuring the reliability of this information.

State and USAID Projects We Reviewed Showed Inconsistent and Incomplete Performance Information

For selected indicators in two State TIP Office and two USAID projects, we found numerous errors or omissions in progress reports we reviewed, which resulted in inconsistent and incomplete performance information agencies used to monitor these projects. Specifically, we found examples of inconsistent information, which included many instances in which quarterly indicator totals differed from annual or cumulative totals reported separately on the same projects, and numbers reported in narrative information that differed from numbers reported as indicator values. In addition, we found examples of incomplete information, including narrative elements that were missing in whole or in part.

Inconsistent Performance Information. We found numerous instances in which quarterly totals differed from annual or cumulative totals reported separately on the same projects. When these errors occurred, it was not possible to independently determine project performance based on report information. For example,

For one State TIP Office project, reported cumulative progress overstated quarterly progress for at least 11 indicators (3 of which by 25 percent or more) and understated quarterly progress for at least 5 indicators (once by 25 percent or more). For example, for the indicator “number of standardized reintegration protocols/guidelines/tools developed (case forms, family assessment, etc.,)” State’s cumulative performance report as of the 4th quarter of fiscal year 2017 indicated that two tools had been developed, whereas quarterly reports showed that only one had been developed.

For one USAID project, the indicator “number of assisted communes allocating and accessing funds for trafficking in persons prevention activities” showed that annual results were 60, while quarterly report data combined showed that the number was 6, which USAID officials confirmed was the correct figure.

For another USAID project, the indicator, “number of food security private enterprises (for profit), producers organizations, water users associations, women’s groups, trade and business associations, and community-based organizations receiving U.S. government assistance” showed an annual result of one, while quarterly totals combined showed a total of three, which USAID officials confirmed was the correct figure.

For the projects we reviewed, implementing partners produced narrative descriptions of progress made to accompany indicator results. We found cases in which numbers reported in narrative information were not consistent with numbers reported as indicator values. For example, for the State TIP Office indicator “number of criminal justice practitioners trained” for one project, indicator results for two quarters differed from results presented in the corresponding narrative during fiscal years 2016 to 2017. State officials found that the narrative information was correct for one of these inconsistencies and the indicator result was correct for the other. In addition, for one USAID indicator—number of public awareness tools on trafficking in persons developed and disseminated—the narrative report for one quarter described distributions that added up to 21,765 products, while the reported quantitative indicator total was 21,482. USAID officials confirmed that 21,765 was the correct figure.

Incomplete Performance Information. Additionally, some quarterly reports had narrative elements that were incomplete in whole or in part, which made independent interpretation of project performance difficult or impossible.

The implementing partner in one State TIP Office project copied and pasted significant portions of narrative information in quarterly reports for 2 years and, according to State TIP Office officials, did not fulfill a request by State TIP Office to include only current quarterly information in formal quarterly reports because it was focused on other activities. For nearly the entire period, the implementing partner indicated that it was “following up” with government entities in three countries to set up counter-trafficking in persons training for government officials, but no indication was made in formal quarterly reports about the results of any of these follow-up activities.

For one State TIP Office project, the indicator “number of children receiving care, whose cases are reported to the police” had no narrative information or incomplete narrative information provided for three of the four quarters in which activity occurred during our period of review (comprising almost 90 percent of reported performance under this indicator).

For a USAID project, the implementing partner reported a combined performance number of approximately 200 from the first through third quarters of fiscal year 2017 for the indicator “number of members of producer organizations and community based organizations receiving U.S. government assistance.” However, annual performance for fiscal year 2017 was reported as nearly 1,700 organizations. USAID officials explained that this difference was the result of the implementing partner’s misinterpretation of the indicator’s definition when producing the quarterly reports, but the annual report narrative did not explain this correction.

Additionally, for USAID’s indicator on the “number of public awareness tools on trafficking in persons developed and disseminated,” no narrative information in the quarterly or annual reports explained how the last quarter of fiscal year 2016 performance approximately doubled from that of the previous quarter. Narrative information in the annual report described performance for the year only in general terms and did not clarify this significant change.

In addition to direct project oversight, State TIP Office and USAID officials stated that performance information from progress reports that the agencies use to monitor counter-trafficking in persons projects is regularly used for internal and external reporting, program decisions, and lessons learned. For example, according to officials, this information is used by senior agency officials to inform their decision-making, in reports such as the Attorney General’s Annual Report to Congress and Assessment of U.S. Government Activities to Combat Trafficking in Persons, and to fulfil other requests from Congress.

Neither State TIP Office nor USAID Has Sufficient Controls to Ensure the Reliability of Performance Information

Neither State TIP Office nor USAID has sufficient controls to ensure consistent and complete performance information, and both face challenges to data reliability stemming from information reported in non- standard formats, implementing partners with limited capacities to report performance information, and the time-consuming nature of reviewing reported information. Federal internal control standards state that management should obtain data from reliable internal and external sources. According to these standards, reliable internal and external sources should provide data that are reasonably free from error and bias and faithfully represent what they purport to represent; and management should evaluate both internal and external sources of data for reliability. Without implementing additional controls to ensure that performance information are consistent and complete, State and USAID officials may not fully or accurately understand what projects are, or are not, achieving and, therefore, how their efforts could be altered as needed. Further, reports that are prepared or program decisions that are made using the TIP Office monitoring reports could be based on inconsistent or incomplete information that does not accurately present project results.

State Lacks Adequate Controls to Ensure the Reliability of Performance Information

State TIP Office currently receives performance information using documents submitted by implementing partners, although this information is not compiled into a single data system and is not in a standardized format. While State provides suggested templates for reporting information, officials said that they cannot require implementing organizations to use these templates and we found that implementing partners provided information in varying formats.

According to State TIP Office officials, project officers perform manual reviews of quantitative information in monitoring reports but have insufficient time to carry out detailed reviews of data reliability for all indicators. State TIP Office project officers also stated that the process of comparing narrative information to indicator information was time consuming and difficult. According to these officials, the quality of the information in progress reports also depends on the priorities and resources—which can be limited—of the implementing partner. In addition to reviewing progress reports, State project officers we spoke to said that they rely on site visits and frequent, less formal communication as part of their oversight process.

Project officers for the State TIP Office projects we reviewed stated that they did not always examine performance trends over time or review consistency in reported cumulative totals—which should be the sums of the previous and current quarters’ reported results—with quarterly totals, for reasons including the difficulty in assembling quarterly information in this manner and resource limitations. State TIP Office officials noted that they are aware of data quality problems in counter-trafficking in persons monitoring reports.

State is developing SAMS-D, a system that officials expect to standardize entry of information from common performance indicators and logic models, according to State officials. These officials stated that if SAMS-D is deployed, State TIP Office could find it easier to analyze and revise logic models that implementing partners submit, as well as examine performance indicator results over time, since standardized data would be available in a centralized location. According to State officials, SAMS-D could be programmed with automatic checks or alerts under conditions defined by the TIP Office and the database programmer. For example, the system could require that fields be filled out in particular formats or provide an alert if performance under a certain indicator has significantly deviated from prior quarters or the indicator’s target.

State TIP Office officials said they were uncertain whether SAMS-D would become operational in 2019, as currently planned. According to officials, State TIP Office has participated in planning and pilot activities for SAMS- D, including testing monitoring tools with implementing partners. According to these officials, additional work is needed to develop rules and controls necessary to operationalize SAMS-D to meet the TIP Office’s particular needs and ensure improved data. Another challenge to implementation of SAMS-D, according to these officials, is that some implementing partners are unable to maintain consistent internet connections necessary to upload information, impeding full roll-out of the system, and an alternative upload mechanism does not yet exist.

USAID Lacks Adequate Controls to Ensure the Reliability of Performance Information

According to USAID officials, overseas missions currently set many of their own policies and procedures for data quality oversight. For the two projects we reviewed, USAID relied on implementing partners to manage information, while it reviewed this information in addition to conducting site visits and communicating with implementing partners on a regular basis to monitor the projects. USAID officials attributed errors in the project reports we reviewed to factors including implementing partners’ errors in manual computation and misunderstandings of indicator definitions. According to USAID officials, data quality errors due to factors such as transcription errors can also occur in the performance information USAID uses to monitor counter-trafficking in persons projects.

USAID project officers for the projects we reviewed said that they regularly conducted manual analysis of information received from implementing partners, but USAID and implementing partners are often pressed for time during the quarterly reporting cycle. According to these project officers, some of the errors GAO found had already been identified by USAID implementing partners during their annual review process and corrected in the annual reports we reviewed. For example, for the USAID indicator “value of new private sector investments in select value chains,” quarterly totals overstated corrected annual results by more than $120,000—approximately $170,000 instead of approximately $50,000. USAID officials said that they and the implementing partner had identified that the implementing partner was incorrectly including additional, unrelated data when producing its quarterly totals and while the annual total had been corrected to approximately $50,000, the annual report did not indicate that this error had occurred in the quarterly reports. USAID officials noted that the quality of the information in the progress reports also depends on the experience and capacity—which can be limited—of the implementing partner.

According to USAID officials, USAID is currently building the Development Information Solution (DIS), an agency-wide information system that would provide USAID’s operating units (such as headquarters bureaus or field missions) with a tool to better collect, track, and analyze information to improve how they manage their projects and overall strategies. Implementing partners would be able to access the DIS via a portal where they would directly enter project information and upload reports and supporting information, according to this official. In addition, this information would better inform USAID’s decision-making at the operating unit level and agency level. A USAID official explained that USAID developed DIS partly as a result of USAID senior management’s concern about the lack of one corporate system to collect data in a timely fashion and improve efficiency.

A USAID official responsible for managing DIS informed us that the business case for DIS was approved in fiscal year 2016. Developers have regularly solicited input from across the agency, according to this official, and a pilot with six missions is expected to begin in November 2018. This official explained that USAID plans to have DIS operational by the end of 2019, but DIS’s timeframe has been accelerated by a year, to 2019 from 2020, which may create programming and budget challenges, and unexpected challenges may also arise during the pilot process as mission needs for DIS are more fully assessed. USAID is currently developing training, deployment, and communications plans to prepare the agency for implementing DIS, according to officials.

DOL Had Consistent and Complete Performance Information for the Selected Project and We Identified No Controls Insufficient to Ensure the Reliability of Performance Information

We reviewed selected indicators and targets information in one DOL project and identified no significant consistency or completeness issues beyond early project stages. For example, for the indicator “number of countries that ratify the International Labor Organization Protocol on Forced Labor,” the October 2016 report contained no reported value for this indicator, while the subsequent report (April 2017) updated this figure to indicate a value of “4” for October 2016. DOL officials explained that a data reporting form had not yet been developed as of October 2016, but indicator performance was discussed in the October 2016 narrative and added to the data reporting form when it was developed. While DOL does not require that a project progress report discuss every indicator associated with an activity in the performance report narrative, according to officials, we found that explanations were present for every significant performance-related event that we identified for the fiscal year 2016 and fiscal year 2017 period.

We did not identify any controls in DOL’s process that were insufficient to ensure the reliability of performance monitoring information. DOL officials said that they use a system of spreadsheets with automated calculations and validation checks that are intended to standardize information submission and assure consistency and completeness of submitted information. These officials said that the project’s Comprehensive Monitoring and Evaluation Plan defines rules for how information for indicators is to be collected and how indicators are to be computed from this information. According to these officials, DOL develops a customized indicator reporting form for each project in conjunction with implementing partners, which implementing partners complete as part of their regular reporting requirements. According to these officials, these spreadsheets contain formula checks to mitigate the risk of implementing partners making undisclosed changes to indicator results and array information in a standardized manner across reporting periods. Officials also commented that for internal reporting purposes, such as the Government Performance and Results Act, project officers can extract information from indicator templates in a manner that is not overly burdensome. According to officials, DOL is developing an enhancement to existing tools, expected in late 2019, which will provide a traceable way to send and receive reports from grant recipients; timestamps when reports are sent, received, and accepted; and tracking of performance monitoring communications between DOL and implementing partners. They plan to continue to use a spreadsheet-based system for tracking indicator information.

State Does Not Have a Process to Ensure that All Performance Indicators are Useful, while USAID and DOL Have Established Processes to Regularly Review the Usefulness of Indicators State TIP Office Does Not Have a Process to Review All Indicators to Ensure Their Usefulness

State TIP Office does not have a process to regularly review the number and content of indicators for counter-trafficking in persons projects to ensure that these indicators are useful and that collecting and reviewing information for them is not overly burdensome. State TIP Office officials acknowledged there are too many indicators for many counter-trafficking in persons projects. Project officers have the discretion to revise indicators if the scope of the project is not altered, according to State officials. In addition, according to these officials, changes that alter the project scope are possible with the consent of the implementing partner. However, State TIP Office project officers do not formally indicate which indicators they have determined are most useful and informed us that they have insufficient time and resources to do so as projects progress. One official who focuses on monitoring issues stated that, ideally, there should be three to five indicators per activity, and efforts have been made to reduce the number of indicators in some projects. For example, in one of the State TIP Office projects we reviewed—which was designed prior to the hiring of this official—had more than 230 indicators across 20 activities as of the first quarter of fiscal year 2017, which had been reduced to about 150 by the fourth quarter of fiscal year 2017.

Our review of two State TIP Office projects showed that indicators did not change in some situations even when the project officer considered the indicator to have become less relevant. State project officers explained that, instead of only relying on indicator information, they regularly spoke with implementing partners for an understanding of what performance level to expect. While acknowledging errors in the numerical information for some indicators, project officers for the two projects we reviewed said that they sometimes overlooked reviews of all reported indicators in the quarterly progress reports because they consider some indicators to be less useful or unimportant and not needed for monitoring purposes, and burdensome to review in depth. These officials said that project officers focus on the indicators that they consider to be most important for project oversight or congressional requests.

State TIP Office officials said that logic models, which include indicators, have improved significantly in recent years (including improvements to the suggested logic model template and the glossary of definitions), partly due to hiring additional monitoring staff, but that State has found the analysis of logic models to be difficult because of the absence of centralized and standardized information and a lack of staff capacity. In addition, project officers stated that they often rely on implementing partners for suggestions with regard to changing indicators. However, according to State officials, these implementing partners may be reluctant to bring up challenges they encounter out of concern that doing so may damage their relationship with State.

State’s Program Design and Performance Management Toolkit, rolled-out in 2017, states that indicators can be costly to collect and manage and should therefore be “useful,” which includes having a clear utility for learning, tracking, informing decisions, or addressing ongoing program needs. This policy further states that indicators should also be “adequate,” which includes having only as many indicators in overall monitoring plan as are necessary and feasible to track key progress and results, inform decisions, conduct internal learning, and meet any external communication or reporting requirements. Further, federal internal control standards state that management should establish and operate monitoring activities, and, after doing so, may determine how often it is necessary to change the design of the internal control system as conditions change to effectively address objectives. Without a process to ensure that the number and content of counter-trafficking in persons project indicators are reviewed and modified as needed, project monitoring may be less efficient and effective as implementing partners and State TIP Office staff spend time collecting and reviewing indicator information that is not useful for project monitoring and management.

DOL and USAID Have Established Processes to Regularly Review the Usefulness of Indicators

DOL and USAID had processes in place to regularly review indicators for the projects we selected. DOL officials told us that project officers work with subject-matter experts to review the relevance of indicators in each semi-annual reporting period. These officials also stated that grantees are required to review their monitoring and evaluation plan annually, which includes the project’s indicators, and to provide the most recent work plan with each semi-annual report. According to DOL officials, while not a DOL requirement, the project we reviewed incorporated a work plan for each component of the project defining when important activities were planned under each output indicator. We found that DOL and the implementing partner made regular changes to these project plans in response to changing conditions. These plans were consistently included in the monitoring documents and most elements were discussed in the associated narrative text.

USAID conducts its project oversight primarily out of its overseas missions, according to USAID officials. According to USAID officials associated with the projects we reviewed, these officials should review the project’s indicators annually, as well as when they determine a review is needed, such as when projects have changes in planned activities. USAID officials stated that this annual review process may be explicitly required in some agreements. According to these officials, missions or other operating units are required to manage and update reference sheets for indicators, which officials said are intended to define each indicator and the information to be collected to measure each indicator. Changes to these reference sheets are tracked, according to these officials. Projects we reviewed showed evidence of regular changes to indicators and associated targets. We spoke to project officers about several specific changes that we had identified. For many of these changes, the project officers provided information about their work with implementing partners to appropriately adjust program goals and expectations, such as adapting the project indicators and targets to unexpected or changing conditions.

Conclusions

Given the grave suffering of victims and damaging effects on society that trafficking in persons imposes, and the U.S. government’s reliance on implementing partners to carry out its counter-trafficking projects, performance monitoring is important to ensure that the United States funds projects that are effective, efficient, and achieve their intended counter-trafficking goals. In fiscal year 2017, State, DOL, and USAID managed 120 counter-trafficking projects and monitored the performance of the projects. However, weaknesses in State’s and USAID’s monitoring processes limit their ability to collect reliable performance information and assess project performance. First, we found that the State TIP Office did not fully document its monitoring activities for many of the projects we reviewed that started in between fiscal years 2011 to 2016. Monitoring the implementation of projects and fully documenting the results of such monitoring are key management controls to help ensure that project recipients use federal funds appropriately and effectively. The State TIP Office was also not setting targets for some project indicators, which may have limited the TIP Office’s ability to determine if implementation was on track or if corrections needed to be made. Furthermore, we found that the State TIP Office and USAID used project performance information reported by the implementing partners—used for internal and external reporting purposes—that was not always consistent or complete, and did not have sufficient controls to ensure the reliability of performance information. Finally, to ensure effective and efficient monitoring, projects need to establish a reasonable number of indicators and update them as needed. However, we found that the State TIP Office does not regularly evaluate and revise all of its indicators for counter-trafficking in persons projects, which can have large numbers of indicators. As a result, the State TIP Office may be using information to monitor project performance that that is less useful and relevant for understanding project progress, and requires more resources and time for the implementing partners to produce and agency officials to review.

State TIP Office officials noted that the TIP Office has taken steps to improve its monitoring process, and State and USAID officials explained that State and USAID are developing information management systems that may increase the quality and usefulness of the monitoring information they use. However, these systems are not fully designed or operational and their capabilities are not yet known. Thus, the potential of these systems to strengthen the ability of State and USAID to collect reliable performance information and assess their efforts to combat the serious problem of global trafficking in persons is unclear. State and USAID could benefit from making additional improvements to ensure their projects are being implemented as intended and achieving project goals to prevent trafficking in persons, protect victims, and prosecute trafficking crimes.

Recommendations for Executive Action

We are making a total of five recommendations, including four to State and one to USAID. Specifically: The Secretary of State should ensure that the Director of the TIP Office establishes targets for each performance indicator. (Recommendation 1)

The Secretary of State should ensure that the Director of the TIP Office maintains documentation of all required monitoring activities, including monitoring plans, progress reports, and performance targets. (Recommendation 2)

The Secretary of State should ensure that the Director of the TIP Office establishes additional controls to improve the consistency and completeness of performance information that the TIP Office uses to monitor counter-trafficking in persons projects. (Recommendation 3)

The Secretary of State should ensure that the Director of the TIP Office establishes a process to review and update performance indicators, with the participation of implementing partners, to ensure that project monitoring remains efficient and effective. (Recommendation 4)

The Administrator of USAID should establish additional controls to improve the consistency and completeness of performance information that USAID uses to monitor counter-trafficking in persons projects. (Recommendation 5)

Agency Comments and Our Evaluation

We provided a draft of this report to State, DOL, USAID, DOD, and the Treasury for review and comments. In State’s and USAID’s letters, reproduced in appendixes IV and V, respectively, both agencies concurred with our recommendations and described their planned actions to address the recommendations. In addition, State’s letter indicated that our draft report did not fully recognize the investment State has made, and the changes underway, to improve the TIP Office’s performance measurement and ensure complete and consistent documentation. State cited additional dedicated financial and personnel resources for monitoring and evaluation added over the past two years. We acknowledge and report on these positive steps, including the hiring of a monitoring and evaluation specialist and other TIP Office staff, in our report. USAID’s letter included other comments that we have responded to in appendix V. Furthermore, State, DOL, USAID, and the Treasury provided technical comments, which we incorporated as appropriate. DOD had no comments.

We are sending copies of this report to the appropriate congressional committees; the Secretaries of State, Labor, Defense, and Treasury; and the Administrator of USAID. In addition, the report is available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please contact me at (202) 512-7141, or groverj@gao.gov. Contact points for our Office of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made major contributions to this report are listed in appendix VI.

Appendix I: Objectives, Scope, and Methodology

The National Defense Authorization Act for Fiscal Year 2017 includes a provision for GAO to report on the programs conducted by the Department of State (State), the Department of Labor (DOL), the United States Agency for International Development (USAID), the Department of Defense (DOD), and the Department of the Treasury (Treasury) that address human trafficking and modern slavery, including a detailed analysis of the effectiveness of such programs in limiting human trafficking and modern slavery. Three of these agencies—State, DOL, and USAID—have programs that design and award counter-trafficking projects to implementing partners, through contracts, grants, or cooperative agreements. These agencies then oversee and monitor these projects. Since DOD and Treasury officials did not identify these types of projects as part of their counter-trafficking in persons efforts, we provided background information on their efforts but did not cover these agencies in our reporting objectives. This report (1) identifies the recent projects in international counter-trafficking in persons that key U.S. agencies have awarded to implementing partners, and for selected projects, assesses the extent to which key agencies have (2) documented their monitoring activities, (3) ensured the reliability of the performance information they use in monitoring projects, and (4) reviewed the usefulness of the performance indicators they use in monitoring projects.

To address these objectives, we reviewed relevant agency documents and interviewed agency officials. To report on agencies’ programs, we asked knowledgeable officials at State, DOL, USAID, DOD, and Treasury to identify their projects that (1) had an international focus; (2) were delivered by implementing partners to external recipients, such as trafficking victims or host governments, as project beneficiaries; and (3) addressed trafficking in persons, modern slavery, or forced labor. Because State, DOL, and USAID managed such projects, we focus on them as the three key agencies for the purposes of our reporting objectives. According to officials from these three agencies, the projects they identified range from those with counter- trafficking in persons as a primary goal, to those in which this goal was integrated as part of each agency’s activities. We used the lists of projects that these agencies provided to report the relevant counter- trafficking projects that agencies awarded to implementing partners to carry out the projects. For our first objective, we determined the projects that were active during fiscal year 2017, including those which began, were ongoing, or ended during fiscal year 2017, and interviewed agency officials to confirm project information.

To analyze the effectiveness of agencies’ programs in limiting human trafficking and modern slavery, we assessed the key agencies’ monitoring efforts for selected projects by examining the extent to which agencies have documented their monitoring activities, ensured the reliability of the performance information, and reviewed the usefulness of the performance indicators they use in monitoring projects.

To assess the extent to which State, DOL, and USAID documented their monitoring activities for selected counter-trafficking in persons projects, we reviewed these agencies’ monitoring policies and related guidance as well as the full agreements for the projects to identify specific required monitoring activities. The policies and related guidance included State’s Grants Policy Directive Number 42 (GPD-42) related to monitoring assistance awards; Federal Assistance Policy Directive (FAPD), which according to a State official superseded State’s grants policy directives, including GPD-42; Federal Assistance Directive, which superseded the FAPD; Program Design and Performance Management Toolkit; and Program and Project Design, Monitoring, and Evaluation Policy. We also reviewed State’s Office to Monitor and Combat Trafficking in Persons standard operating procedures. For DOL, we reviewed its Management Procedures and Guidelines (MPG) as well as the Comprehensive Monitoring and Evaluation Plan Guidance Document referenced in the fiscal year 2017 MPG. For USAID, we reviewed—from its Automated Directives System or ADS—Chapter 203 on Assessing and Learning and Chapter 201 on Program Cycle Operational Policy, which according to USAID officials superseded Chapter 203. Once we determined what tools the agencies use to monitor their counter-trafficking in persons projects, we sought documentation of those tools to determine whether agencies were implementing those tools.

To assess the agencies’ monitoring efforts, we identified all of State’s, DOL’s, and USAID’s projects that started before or during October 2015, which corresponds to the first quarter of fiscal year 2016, and were active through September 30, 2017, which corresponds to the fourth and last quarter of fiscal year 2017. This produced a list of a total of 57 State, DOL, and USAID projects. Out of these 57 projects, we excluded 3 projects from our selection for various reasons. We excluded one DOL project because DOL identified the project as being a research project for which certain agency performance monitoring requirements (e.g., indicators, targets) are not applicable. We also excluded two USAID projects because USAID identified each project as including several projects with various start and end dates, thus making it difficult to determine their time frames for inclusion in our report. This resulted in a selection of 54 projects—37 from State, 3 from DOL, and 14 from USAID. We reviewed documentation of key monitoring activities as specified in agency policy or the project award agreements to determine the extent to which the agencies had full documentation of key monitoring activities. We also applied federal standards for internal control, which call for agency management to design monitoring activities so that all transactions are completely and accurately recorded, and GAO’s key attributes of effective performance measures, specifically the attribute of having a numerical target. We made our determinations of the extent to which agencies had full documentation of key monitoring activities, as follows:

State (37 projects). To determine whether State had fully documented its monitoring activities, we reviewed the monitoring plan for each project; fiscal year 2017 quarterly progress reports for each project; and the final progress report, including indicators and targets, for the seven projects that ended as of December 2017.

We determined that State had “fully documented” the monitoring plan, if State provided a monitoring plan worksheet for the project. If State did not provide a monitoring plan worksheet for the project, we determined the monitoring plan was “not documented.”

For each quarterly progress report for fiscal year 2017 as well as the final progress report for projects that ended as of December 2017, we determined that State had “fully documented” the report, if the report included both a qualitative and quantitative summary of progress. For the State TIP Office projects we reviewed, the qualitative summary of progress is captured in a narrative and the quantitative summary of progress is captured in the logic model. For the State DRL project we reviewed, the qualitative summary of progress is captured in a narrative and the quantitative summary of progress is captured in the monitoring plan. If either component—narrative or quantitative summary—was not documented, we determined that the report was “partially documented.” If both components were not documented, we determined that the report was “not documented.”

We determined that State had “fully documented” indicators and targets for projects that ended as of December 2017, if the final progress report for the project included indicators as well as targets for each indicator. If the final progress report included indicators but did not specify targets for each indicator, we determined that indicators and targets were “partially documented.” If the final progress report did not include indicators and targets, we determined that indicators and targets were “not documented.” (We did not find any instances of “not documented.”)

DOL (3 projects). To determine whether DOL had full documentation of its monitoring activities, we reviewed the monitoring plan as well as fiscal year 2017 semi-annual progress reports for each project. Because DOL’s three projects were ongoing as of December 2017, we reviewed the second semi-annual progress report for fiscal year 2017 to determine whether DOL had “fully documented” indicators and targets for each project. Overall, we determined that DOL had “fully documented” (1) the monitoring plan for each project, if the monitoring plan documented the performance metrics and data collection frequency for the project; (2) each fiscal year 2017 semi- annual progress report for the project, if the report included a qualitative and quantitative summary of progress for the period of performance; and (3) indicators and targets for the project, if the second semi-annual progress report included indicators as well as targets for each applicable indicator.

USAID (14 projects). To determine whether USAID had full documentation of its monitoring activities, we reviewed the monitoring plan for each project; fiscal year 2017 progress reports at the reporting frequency specified in the agreements for each project; and the final progress report, including indicators and targets, for the three projects that ended as of December 2017. We also reviewed evidence of site visits conducted during the life time of the projects. Overall, we determined that USAID had “fully documented” (1) the monitoring plan for each project, if the monitoring plan documented performance metrics for the project; (2) the periodic progress reports for fiscal year 2017 as well as the final progress report for projects that ended as of December 2017, if the report included a qualitative and quantitative summary of progress for the period of performance; and (3) indicators and targets for the three projects that ended as of December 2017, if the final progress report included indicators as well as targets for each applicable indicator. We determined that USAID “fully documented” a project’s site visit, if USAID provided evidence of having conducted at least one site visit during the life time of the project.

Additionally, we interviewed knowledgeable monitoring officials from each agency to understand agencies’ monitoring process and application of monitoring requirements for counter-trafficking in persons projects. Because State and DOL officials also identified site visits as a key tool they use to monitor their counter-trafficking in persons projects, we reviewed evidence of site visits conducted during the life time of the projects to report on these efforts. We also interviewed State TIP Office officials to discuss instances in which the agency did not have full documentation of key monitoring activities.

To assess the extent to which key agencies have ensured the reliability of the performance information they use to monitor selected projects, we selected for review a nongeneralizable sample of 5 projects—2 State projects, 1 DOL project, and 2 USAID projects—out of the 54 counter- trafficking in persons projects identified by agencies that started before or during October 2015 and were active through fiscal year 2017. We based our selection of these projects primarily on largest total award amounts. For these selected projects, we obtained 2 years of progress reports and other documents to assess the quantitative and qualitative performance information. We developed a standardized template to capture all quarterly or semi-annual indicator performance information reported for each of these projects and assessed whether quarterly or semi-annual totals were consistent with annual and cumulative totals where these were reported. Using this quantitative information, we judgmentally selected indicators for inclusion in agency interviews where it appeared likely that numerical errors had occurred or there appeared to be significant project events, such as large over- or under-performance or the elimination of the indicator. We interviewed agency officials, including managers of these five projects, about the consistency and completeness of monitoring information in these projects for about 60 indicators identified through our analysis. Additionally, we questioned these officials about performance report narrative information describing project activities that, in our judgement, appeared to be incomplete or inconsistent with respect to indicator results. We also used these interviews to determine whether our findings for these selected projects reflected general agency policies and procedures. We assessed the completeness and consistency of project performance data that State, DOL, and USAID use to monitor projects as part of our data reliability assessment. We found State and USAID data to be unreliable in the projects we reviewed. We discuss the implications of these unreliable data for State and USAID’s project management and reporting in our findings and recommendations. We found the performance data that DOL used were consistent and complete for the project we reviewed. While we examined indicator data and narrative information for consistency and completeness, we did not verify the accuracy of performance information.

To assess the extent to which key agencies have reviewed the usefulness of the performance indicators they use to monitor selected projects, we used the same nongeneralizable sample of five projects— two State projects, one DOL project, and two USAID projects. We interviewed agency officials, including managers of these five projects, about processes and systems they use to review the usefulness of indicators on an ongoing basis, such as when conditions in the project activity region change or if the agency and implementing partner learn that certain project activities are less effective than expected. We identified examples of indicators that had apparently been discontinued, as well as continued indicators that showed minimal progress, and we asked these officials to explain what had or had not been discontinued. We also used these interviews to determine whether our findings for these selected projects reflected general agency policies and procedures.

We conducted this performance audit from October 2017 to December 2018 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Three Key U.S. Agencies’ Counter-trafficking in Persons Projects, Active in Fiscal Year 2017

The Departments of State (State) and Labor (DOL), and U.S. Agency for International Development (USAID) managed 120 projects in counter- trafficking in persons carried out by implementing partners during fiscal year 2017, according to information provided by officials with these agencies. The three agencies used different approaches to identify relevant projects. For example, State reported projects with a primary goal of counter-trafficking in persons, while DOL and USAID included projects that may not have counter-trafficking in persons as a primary goal. Table 4 lists these agencies’ reported project information for projects that were active during fiscal year 2017.

Appendix III: State Documentation for Its Performance Monitoring Activities for 37 Counter-Trafficking in Persons Projects

The Department of State (State) did not fully document its monitoring activities (monitoring plan; fiscal year 2017 quarterly progress reports; and final progress report, including indicators and targets, for projects that ended as of December 2017) for 16 of the 37 selected projects we reviewed with start dates between fiscal years 2011 to 2016. (See table 5.) For example, State’s Office to Monitor and Combat Trafficking in Persons did not have monitoring plans for nine projects or targets for each indicator in six of seven final progress reports for projects that ended as of December 2017.

Appendix IV: Comments from the Department of State

Appendix V: Comments from the U.S. Agency for International Development

GAO Comments

1. USAID commented that it does not believe that our draft report reflected the existing controls the USAID mission in Ghana shared with us, and that the mission had furnished us with a file that, according to USAID, contained correct information for all indicators and their results from the time the activity began until our audit. While the mission provided us with a spreadsheet, this document included only annual performance totals for several years without accompanying quarterly totals, or quarterly or annual narrative information. We focused our analysis on the quarterly and annual performance reports to understand the extent to which USAID was ensuring the consistency and completeness of performance information, including associated narratives, underlying its aggregate and higher-level performance reports. We reported on inconsistent or incomplete performance information only after discussing and substantiating the specific errors we identified with USAID officials. Further, we recognize USAID’s efforts to address errors that the agency identified prior to our review and we provide an example of such efforts in the report. 2. We have incorporated USAID’s comment. Our report no longer characterizes USAID’s regular activity monitoring and conversations with implementing partners as “informal.” 3. USAID noted that our report does not discuss how the USAID mission in Ghana uses its third-party monitoring project—Monitoring, Evaluation and Technical Support Services (METSS)—to work with local organizations to improve their collection and analysis of data. We have added a reference to USAID’s third-party monitoring project to the report where we discussed limited capacity of local partners as a cause of data reliability issues. 4. USAID commented that one of the Ghana counter-trafficking in persons indicators we examined in the integrated project (“value of new private sector investments in selected value-chains”), was not related to trafficking in persons and, therefore, was not directly related to the focus of our audit. As discussed in the Objectives, Scope, and Methodology section of our report (see app. I), we selected projects, including the integrated project in Ghana, based on a list of counter- trafficking in persons projects provided by USAID. Because the same operational policy that sets the monitoring and evaluation standards for the agency applied to all indicators within a given project, we examined available quarterly or semi-annual indicator data for all reported indicators in selected projects to determine the completeness and consistency of the data. We then conducted interviews with agency officials to discuss instances in which we identified potentially incomplete and inconsistent performance information, as well as whether our findings about the management of performance information for these selected projects reflected general agency policies and procedures.

Appendix VI: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, Leslie Holen (Assistant Director), Victoria Lin (Analyst-in-Charge), Esther Toledo, and Andrew Kurtzman made key contributions to this report. The team benefited from the expert advice and assistance of Neil Doherty, Justin Fisher, Benjamin Licht, Grace Lui, and Aldo Salerno.

Related GAO Products

Human Trafficking: State Has Made Improvements in Its Annual Report but Does Not Explicitly Explain Certain Tier Rankings or Changes, GAO-17-56 (Washington, D.C.: December 5, 2016).

Human Trafficking: Oversight of Contractors’ Use of Foreign Workers in High-Risk Environments Needs to Be Strengthened. GAO-15-102 (Washington, D.C.: November 18, 2014).

Human Trafficking: Monitoring and Evaluation of International Projects Are Limited, but Experts Suggest Improvements. GAO-07-1034 (Washington, D.C.: July 26, 2007).

Human Trafficking: Better Data, Strategy, and Reporting Needed to Enhance U.S. Antitrafficking Efforts Abroad. GAO-06-825 (Washington, D.C.: July 18, 2006).