Ghana: Integrated Financial Information Systems Project

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AIDE-M?MOIRE

 

REPUBLIC OF GHANA

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Joint Development Partners? Mid-Term Implementation Support Mission

Ghana: Integrated Financial Information Systems Project – Component of the eGhana Project.

(May 20 ? 31, 2013)

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I.????????? MISSION OBJECTIVES AND ACKNOWLEDGEMENT

 

1. The World Bank, UK Department for International Development, the Danish International Development Assistance and the Delegation of the European Union[1] carried out a joint implementation support mission of Component 4 (GIFMIS) of the eGhana project in Ghana during the period May 20 – 23, 2013.? The mission visited the project site at the Controller and Accountant General?s Department (CAGD), as well as two of the rolled-out sites – Ministry of Local Government & Rural Development and the Ministry of Education in Accra to see the progress of implementation of the Accounting/Financial Reporting aspects of GIFMIS. Meetings were held with various officials from the Ministry of Finance (MoF) including the CAGD, Budget Division, key officials (including the Chief Directors) from the roll-out sites visited, and the GIFMIS Project management and implementation teams.? The mission reviewed progress achieved so far against agreed milestones and provided technical implementation support to the Government of Ghana (GoG) stakeholders and the project management team. The list of persons met during the mission is attached as Annex-1.? The mission wishes to record its appreciation for the assistance, cooperation and courtesy extended to it by all the persons met and, in particular the Controller and Accountant General, the GIFMIS project team, and all other officials met.? This aide memoire sets out the mission?s findings, agreements reached, and recommendations, which were discussed at the wrap-up meeting held on May 31, 2013, chaired by the Deputy Minister of Finance and Economic Planning and supported by the Heads of Missions of the GIFMIS Participating Financing Agencies/organizations.

 

 

II.??????? KEY PROJECT DATA

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Project Data			? Project Performance Ratings
Financier	Allocation	Disbursed (US$ Equiv.)
IDA (Credit) EU (Grant) DFID (Grant) DANIDA (Grant)????? ?	$28.44m ?9m ?10m $4.5m	$21.79m $3.855m $9.418m $1.226m ?	Summary Ratings:????????????? Last???????? Now Achievement of PDO??????????? S???????????????? S Implementation Progress???? S??????????? ?????S   PDO = Project development Objectives
Ratings: HS=Highly Satisfactory;?? S=Satisfactory;?? MS=Moderately Satisfactory,?? MU=Moderately Unsatisfactory,??? U=Unsatisfactory;?? HU=Highly Unsatisfactory; NA=Not Applicable;?? NR=Not Rated

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III.?????? ACHIEVEMENT OF DEVELOPMENT OBJECTIVES

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1. The overarching development objective of GIFMIS is to improve the effectiveness of service delivery and the allocation of scarce resources, using the new tools and processes resulting from the GIFMIS, and assure an accountable, more effective, and transparent government.

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1. ?The GIFMIS is expected to: (a) build capacity to improve accuracy, comprehensiveness, reliability, and timeliness of financial and fiscal reporting at all levels government; (b) improve pubic financial management, accountability, and transparency commensurate with international standards and under Treasury Single Account principles; (c) enhance the capacity of government officials and budget managers to use credible financial information for better and informed decision-making; and (d) facilitate oversight of the use of public monies, and increase the national and international credibility of government?s financial statements.? These fall into two broad areas: (i) fiscal and budget management controls under the leadership of the Budget Director at MoFEP; and (ii) financial management, accounting and reporting controls primarily under the control of the CAGD but including the strengthening of the internal management of MDAs, MMDAs and the Internal Audit function.

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IV.?????? IMPLEMENTATION STATUS, PROSPECTS, AND PLANNING

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1. Based on satisfactory progress achieved against milestones in the various components, overall project implementation progress has been rated as Satisfactory. However, since implementation issues raised against mostly component 2 activities, which have a direct nexus to component 3, remain outstanding[2], the mission reiterates its prior recommendations for a committed focus on strategic segments (SSs) within the defined component. These are sub-groups of activities tasked with achieving key PFM outcomes. Assessment relative to project outcomes^[3] is critical to alert management to weak progress against project objectives and expected outcomes–particularly those identified as priority in the preceding AM Action Matrix. Strategic segments 1 and 2 are discussed below under component 1; the other four are under component 2.

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COMPONENT ? I: PFM Information Systems (SS1)

 

1. Under the component, the project aims at establishing a country-wide Integrated Financial Management Information System (GIFMIS). As per the project charter, when fully implemented, GIFMIS is intended to serve as the single system for official budget creation and management, cash and treasury management, and financial control and reporting for the entire country.

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1. Overall Assessment: ?The Mission is pleased to record that very significant progress has been achieved, particularly as pertaining to the implementation of the P2P across all MDAs in respect of the Consolidated Fund (Treasury Funds).? Progress on payroll upgrade, roll-out the system to other Funds, budget module selection and implementation, and HRMIS are at varying levels of design and implementation.? Overall, therefore, the implementation of this component is rated ?satisfactory? as noted in the details below.

 

1. P2P roll-out on the Consolidated (Treasury) Fund: Out of 200 total spending units in Accra (including 30 MDA HQs), the P2P has been rolled-out to 148 locations of the 200 spending units. ?The remaining 52 spending units still process their transactions off-site, through 22 Transaction Processing Centers (TPCs) connected with the main GIFMIS server. The Mission recommends that the Project Director ensure completion of connectivity to the remaining 52 spending units and on-site ?go-live? well before December 31, 2013.

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1. Regional Treasuries: P2P has also been rolled-out to all the 350 Regional Spending Units and 10 regional treasuries since November 2012, one month ahead of the agreed schedule. All the MDAs bring their CF-related transactions to these regional treasuries and the RCCs for recording their commitments and getting payments through the P2P. The Mission underscores its appreciation to the project team for achieving this milestone ahead of time
2. All the Consolidated Fund (CF) related transactions, constituting around 46% of the core government spending, are being captured in the system at every step of the expenditure cycle- requisition, purchase order, good receipts, invoice and payment. The GoG budget for FY2013 was loaded on the GIFMIS from legacy budget management software- ACTIVATE. All in-year budget changes, including releases against which commitments are recorded, are being made by the MoF using GIFMIS. The mission was informed that the monthly financial reports by the CAGD on the CF are being produced from the system. However, the BERs at the MDAs still need to be institutionalized. The annual financial statements on CF for FY2012 were produced- in March 2013, within three months of financial period close- using GIFMIS. The number of transactions processed from the system was reported to be 31,441- an indication of system usage that has increased exponentially (more than 600 per cent till December 2012, compared to October 2012 for CF related transactions). However, 54% of the? overall core government expenditures, related to non-CF transactions including IGFs, DFs and SFs, are still not captured in the system as discussed in more detail in later sections.
3. On-line check printing: The Mission was informed that the contract for supplying pre-printed check stationery has been awarded. Though this activity has been delayed considerably, the mission was informed that the delivery of the stationery is expected by June 15, 2013.? The Mission recommends that the PD tightly track this timeline given that its importance to ensuring that on-line check printing for all payments, with concomitant withdrawal of manual checks, is completed by August 1, 2013.
4. IGF: The Mission was encouraged to note that the project authorities have hired a consultant to carry out a study, and design the detailed business processes of IGFs, DFs and SFs to support subsequent implementation. Even more encouraging was the remarkable interest from the Ministry of Health and Education to pilot the implementation of the system for the IGFs in their respective ministries. Given the strong demand from these ministries as noted during these discussions, the mission recommends the project director ensures that the consultant, together with Oracle functional expert, completes IGF related section of the study/business process specifications by June 30, 2013 and the technical team subsequently implement the system at 4 pilot IGF collecting entities; 2 each at each of the Ministries of Health and Education for to the pilot go-live by August 1, 2013.
5. Roll-out to MMDAs: The consultants engaged to prepare a study on MMDAs have documented the various FM systems currently being used by the MMDAs and have updated the draft Accounting Manual for the MMDAs. The Mission recommends PD ensures that a detail technical design of the GIFMIS solution for the MMDAs is validated by the end users by August 15, 2013; user acceptance test completed by August 31, 2013; and system rolled-out to 7 pilot MMDAs by October 1, 2013 covering all fund sources. While the mission notes with appreciation that a significant work in this regard has already been accomplished by the project management even ahead of the agreed schedule, the implementation of the pilot should ensure that the systems stability is first assured before the full roll-out is embarked upon.? Importantly, the mission opines that the MMDAs can be the first vehicle that should see the piloting of ?all funds? rather than just the meager consolidated funds.? The MMDAs, as local governments, should be considered as discrete entities that would need to generate information on ?all funds? received, regardless of source, and all expenditures made against those funds, even if a ?fund accounting? system has to be maintained.? It is only by these means that the outcome of implementation of GIFMIS at MMDAs can be meaningful as attested to at the meeting with the MLGRD
6. Budget Preparation Software: Satisfactory progress has been achieved in advancing on the procurement of a budget module that will seamlessly integrate with the Oracle financials as a uniform platform.? The Mission recommends that the contract for the budget management system be awarded by July 31, 2013 to the selected bidder; and implementation started at the earliest to allow sufficient time for the MOF to test the system(i.e. before March 2014) with final acceptance, after fine-tuning in the identified areas of improvement, expected by May 2014. The Budget for FY2015 is planned to be prepared during FY2014 on the new system.
7. The scope of this implementation will be budget compilation at the MOF only.? The MDAs will continue to prepare their budgets using ACTIVATE or excel as the case may be (including other MDA budget submission forms) ? which will be enhanced to prepare an electronic file/spreadsheet on the PBB format for eventual upload into the budget module at the MOF.? ?
8. Contracts database: The mission recommends that the Oracle experts be deployed to configure multi-year commitment recording and tracking functionality in the GIFMIS by October 1, 2013 to allow tracking of contracts. The Oracle P2P system has capability, by way of a sub-module, to generate a contract database so that ongoing commitments against multi-year contracts can be tracked, and obligations or arrears clearly identified.
9. Interfaces: The EFT through SWIFT has not been operationalized yet. The mission recommends that this be accomplished and the system operationalized by August 1, 2013. The interface with TRIPS (Total Revenue Integrated Processing System) and GCMS has undergone long delays due to issues in the development and testing of these systems. Both interfaces are still in the testing stage. The mission recommends the completion of the testing phase, in cooperation with the GRA and the operationalizing of these interfaces by August 1, 2013.? The mission also recommends that the interfacing of GIFMIS with e-Monitor (for non-tax revenues) be operationalized by August 1, 2013.
10. Site Visits: Three MDAs- Ministry of Education, Ministry of Local Government and CAGD- were visited and meetings were held with the Financial Controller, Ministry of Health, to assess the usage and associated challenges in the roll-out of P2P[4]. The Ministry of Health team (including the Financial Controller) was also invited to a discussion session to enable the mission identify the challenges and expectations under the project. At the end of all these consultations and reviews, the mission recommends that the project ensure: (a) 2 training workshops on report generation (details provided in the training sub-component) are completed by June 30, 2013; (b) a power engineer is deployed, by June 30, 2013, to design the most cost-effective power solution (generator, battery banks, UPS) and prepare associated specifications to support GIFMIS operations for the large MDAs; with the subsequent procurement documentation expected to be completed for Bank clearance by July 15, 2013; (c) the installed and configured systems be fine-tuned and intensive training provided to all users on the processes (journalizing) to be undertaken to make changes to data already entered and stored as this has been highlighted as a challenge; and (d) ensure that the GIFMIS-trained users are not transferred out before a 3 year-tenure and a copy of the transfer orders sent to user administrator to update access authorizations.
11. Quality Assurance of the system: Though the GIFMIS was tested through test scripts before pilot implementation, these test scripts have not been updated and do not fully capture the updates made to the system during the implementation on account of additional requirements, user roles, and reports, amongst others. The project authorities have hired E&Y consultants to provide support including the QA of deliverables. Even though this scope does not explicitly mention the QA of GIFMIS, which is a deliverable of OCS, it is pertinent to have a QA of the GIFMIS done at this stage. The Mission recommends project authorities ensure that E&Y QA consultants complete the QA of GIFMIS by June 30, 2013. ?
12. RAC Implementation: The Mission conveyed its views on the technical proposal (draft bidding documents) submitted by the project for the procurement of RAC and associated components, through a competitive bidding process, and has advised that much more detailed technical requirements, like the number of license needed, scope of implementation, amongst others, should be included and the request resubmitted by May 31, 2013 for further processing.
13. Business Continuity Planning and Disaster Recovery (BC/DR): In the light of the critical importance of the BC/DR: The mission recommends PD ensure that the BC/DR related deliverables under the existing PwC consultancy are completed by July 15, 2013 and a comprehensive set of bidding document for the procurement of hardware and software components as recommended by PWC be submitted to the Bank for clearance by July 31, 2013.
14. Technical- Support: The Mission recommends PD: ( a) issue appointment letter to the 2 techno-functional individual Oracle technical/functional consultants being currently hired to provide Oracle support, by July 1, 2013; (b) finalize the support agreement with NetSolutions for extended support by May 31, 2013;(c) finalize the SLA with NITA by June 30, 2013; and (d) review the technical and functional staffing requirements of the project at this phase of implementation, recruit the required staff, to ensure there are no gaps that would weaken timely completion of activities especially in the light of the project?s current closure date of June 30, 2014.
15. Non-Oracle tools: The IT infrastructure layer of the GIFMIS needs some technology components for better monitoring, security, coordination and help desk. The Mission recommends PD ensure the revised bidding documents are submitted for bank clearance by May 31, 2013.

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Payroll and HRMIS (SS2)

Payroll Review

1. The Mission was also informed of the progress in implementing the recommendations of KPMG with regards to (i) payroll data and program clean-up; and (ii) controls and process improvements. On payroll data and program clean-up, 9 out of the 11 IT-related recommendations have been addressed by Provision – a national consulting firm contracted for this purpose.? The outstanding 2 recommendations, which pertain to data and program cleansing, access controls weaknesses and responsibility authorization matrix (RAM), will be completed by June 2013.? On controls and process improvements, out of the 19 recommendations pertaining to business process improvements, 15 has been implemented by CAGD while work on the remaining 4, is expected to be completed by June 30, 2013.
2. The payroll performance problems of IPPD2 as highlighted in the previous AM- it took 21days to run the payroll- have been largely addressed.? Now it takes 7 days to run the payroll.? This has been based on the decision of the Government to off-load GES salaries from the main IPPD2; update the master files; and run retro off-line on a custom developed payroll application. Thereafter, an electronic file for the payroll of GES employees is uploaded into IPPD2 to run their final payroll- without running retro. This has contributed to the improvements in the salary processing time for GES as explained in the annex.
3. During the site visits, the mission also noted that the mapping of the payroll codes with GIFMIS codes needs to be reviewed as the compensation-related posting of payroll in the GL is not accurate in some cases. Equally, options including selection of appropriate utilities should be explored to ensure that payroll positing to the General Ledger (GL) is done immediately the payroll checks are issued; the current manual process of uploading the payroll on to the GL is not only tedious, but also undermines the timeline for completion of the monthly financial statements of the government.? This activity need not await the upgrade of the payroll system but would require accomplishment by the July 2013 payroll cycle.
4. Despite improvement of payroll processing time for GES, the Mission was informed of delays in processing salaries for newly recruited teachers continue due to such reasons as process in-efficiencies and redundancies. For instance, salary payment delays of up to six months for new teachers – following the issuance of the appointment letter and submission of charge assumption report ? due to the several approval steps, including financial clearance from MOF.
5. In order to address the above issue, the mission recommends that the Chairman, PSC work with the GES and MOF, amongst others; to reach a consensus on a standard process through the forum of the HRMIS Steering Committee to remove all the redundant steps and establish service standards for the non-redundant steps, including ensuring that salaries are paid in the same month that new hires commence work. ?The mission also recommends CAGD develop a report on new hires, showing the months between the first salary processing date and charge assumption date. This report should be delivered to Deputy Minister, Education, and also the Chairman PSC, for monthly monitoring at the highest level.
6. Payroll Upgrade Proposal: The project authorities have submitted a revised proposal from Oracle for payroll upgrade. This proposal includes functional improvements like faster retro calculations as well as full integration with GIFMIS. The Mission notes that there have been significant delays- earlier agreed date for final submission was October 2012- in finalizing this proposal. The timeframe of 9 months in the new proposal for completing the upgrade appears to the mission as too long. The mission recommends to compress the timeframe by 2-3 months and to use these time savings for enhanced post “go-live? support.

HRMIS

1. The mission concurred with the proposal of the PSC on packaging all components of HRMIS- Core and non-Core- in a comprehensive 3-phase bid. The contract to emerge from the bid will have two parts: Part 1(core elements only) will be implemented during the course of this project and the other part (for phase 2 and 3) to be activated only?upon confirmation of the availability of funds and government’s priority at that time, to be determined after successful completion of the first part. All parts will be individually priced.
2. The mission agreed with the Chairperson of the PSC that the revised bidding documents be completed for clearance by June 7, 2013 and issued to the bidders by July 1, 2013 or earlier. The mission also recommends that the PSC complete collection of information, currently on-going, on approved establishment strength for each MDA? ?by August 30, 2013 to serve the purpose of position management.

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COMPONENT ? 2: PFM Business Processes and Control Systems

 

1. The progress towards the achievement of the objectives of this component[5] is rated as moderately satisfactory, as a number of activities agreed for completion since the last mission remains work in progress as detailed in the paragraphs that follow.? This is despite the good progress being made in establishing clear plans for implementing PBB and a clear orientation towards addressing fundamental fiscal policy constraints. However, efforts to establish comprehensive budget coverage and a TSA are highly reliant on progress on including IGFs, donor funds, and statutory funds in GIFMIS; these activities are priorities that have been delayed relative to original expectations. Delay in this area also impacts on the production of reliable system-generated fiscal operations reports, which will be important in strengthening monitoring fiscal policy implementation.? As noted under component 1, GIFMIS implementation has proceeded at a satisfactory pace. Full realization of the benefits of the P2P and improved control functionality of the system, however, will require progress against a number of strategic activities under component 2.

 

1. The mission would like to reiterate its prior recommendations for a committed focus on strategic segments (SSs) within each component. These are sub-groups of activities tasked with achieving key PFM outcomes. Their non-achievement will affect other activities and, if lack of progress is not addressed, may impede attainment of the overall project objectives. A critical role for the M&E Unit^[6] is to alert management to weak progress in any of the six strategic segments of the M&E framework–particularly those identified as priority in the preceding AM Action Matrix. SSs 1 and 2 have been discussed under component 1 above. Progress on the remaining four, which are under component 2, are discussed below.

 

Budget Reform (SS3)

 

1. Budget reform involves a range of activities under this Component ? all aimed at fully using GIFMIS functionality to allocate and control resources. Most importantly, these budget activities when implemented will address the long-standing issues[7] that have made the budget unrealistic and have been the major contributor prolonged to delays in release of funds during budget implementation.

 

1. The Ministry of Finance is strongly considering or actively implementing key policies in this area to achieve the necessary fiscal control and predictable releases.? These include the following: (i) developing and maintaining a government-wide system of forward estimates; (ii) developing and encouraging effective commitment management and cash management; (iii) consolidation and strengthening of the Budget Framework Paper as the basis for determining fiscal policy and realistic budget deficit targets; (iv) seeking to establish wage negotiations prior to budget approval;(v) review of the institutional structure; and (vi) implementation of PBB reforms (see below) to reduce inefficiencies and waste within MDAs

 

1. While the implementation of many of these policies is, under the mandate of the MoF, the effective implementation of commitment control under GIFMIS is itself an important element of strengthening fiscal policy implementation, and its success is highly dependent on the establishment of a rigorous fiscal policy environment. It is recommended, therefore, that the Budget Department commence immediately with providing regular and empirically-based briefing to the Project Directorate on key developments in these areas as part of a quarterly GIFMIS M&E process.? Key quantitative or evidence-based indicators of success in these areas are: (1) reduction of domestic payment arrears^[8]; (2) improvement in predictability of availability of funds for commitment (PEFA PI-16)^[9]; and (3) the budget deviation index as defined in the M&E framework (DFID indicator).? It is recommended that the Budget Department provide these data too and projected milestones to the GIFMIS Project Directorate as part of the GIFMIS M&E process, going forward.?

 

1. Implementation of Program-based Budgeting (PBB): The major reform underway in budgetary management is the planned transition from the long-standing system of Activity Based Budgeting (ABB) to a new system of Programme Based Budgeting (PBB). Substantial progress has been made in laying the foundations for the introduction of PBB, now scheduled for full roll-out in 2014, which will be prepared in the latter half of 2013. A robust conceptual structure centred on a 3-level programmatic hierarchy has been established, based on programs, sub-programs and budget operations/projects which broadly align to outcomes, outputs and activities. This structure has been successfully tested through pilots in 34 MDAs.

 

1. ?To date, attention in planning for roll-out of PBB has concentrated on budget preparation. However, the design of appropriate systems within MDAs for the establishment of programs as management units is equally important for achieving the benefits of PBB. It is important to avoid conflicts that may arise between the management requirements of the newly defined programs and the legacy structure of the management hierarchy in the MDAs. It is recommended that steps are taken to ensure that program managers are selected within MDAs for all budget programs by August 31 2013 so that they can participate fully in the preparation of the PBB-based budget for 2014.

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1. ?In moving to the implementation of PBB in 2014 attention needs to be paid to the legal basis of appropriation and whether to shift to a system appropriation based on budget programs. In principle this change could be made either in 2014 or at later stage. Any change to the basis for appropriation should also be reflected in changes to the rules for virement which should in due course be modified to reflect the new management structure based on programs. It is recommended that an initial review be completed by 31 August 2013 on the issues of appropriation and virement so that any amendments to legislation or regulations required for the implementation of PBB in MDAs in 2014 can be completed on a timely basis.

 

1. The Budget Department of MoF has prepared a roadmap for comprehensive PBB reform, in the form of a work plan for 2013 and 2014. In its current form this work plan envisages the completion of the roll-out of PBB to the MDAs in the context of the preparation of the 2014 budget and the extension of this process to include all MMDAs in the preparation of the 2015 budget (in other words during 2014). The mission recommends that, in order to allow sufficient time and resources to complete and consolidate the roll-out of PBB to MDAs, the rollout to MMDAs should be deferred to at least the 2016 budget. This would ensure that the pre-conditions for an effective PBB implementation have been adequately assessed and strengthened[10]

 

1. Ghana Fiscal Operations Reports: The policy of establishing and publishing systems-based Ghana Fiscal Operations Reports (GFORs) that track the fiscal deficit and its financing (as defined in GFSM 2001) on a quarterly basis with the aim of publishing such reports one month after the end of the quarter remains in place. However, it is clear that it will not be feasible to establish timely and reliable system-generated reports until most revenue, expenditure, and financing transactions are fully on GIFMIS and processes for reconciling the more comprehensive CAGD accounts and BoG financing data are fully operational. System-generated GFORs will play a major role in timely tracking of fiscal policy implementation and strengthening fiscal controls, so action to incorporate IGFs, donor funds, and statutory funds on GIFMIS and on the TSA is a very high priority, as discussed below under cash management reforms (SS4). It is recommended that the MOF liaise with the GIFMIS Cash Management team to identify issues regarding IGFs, Statutory Funds, and Donor Accounts and develop timelines for producing and publishing a reliable systems-generated GFO Report by end of December 31, 2013.

 

1. Review of Legislation and Regulations: The objective here is to establish a program of reform for rules and regulations that are: (1) appropriate to the major changes in PFM practice as a result of the reforms underway; and (2) support the needed changes in business processes as part of the ICT platform. As at the end of 2012, no significant progress has been made. It is becoming clear that legislative and regulatory reform will need to respond to a variety of significant changes in current practice, as PBB becomes established (involving potential changes in the appropriation and virement laws and regulations), and IGFs and donor funds are incorporated in GIFMIS and the TSA.

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1. It is therefore recommended that a legislative working group (LWG) be re-invigorated by June 2013 to address both urgent and long-term concerns of legislative reform. The LWG should:

(i)?? Establish a work plan for legislative and regulatory reform in liaison with the GIFMIS teams handling budget reform and cash management to take into account the likely timelines of business process reform to accommodate PBB and inclusion of IGFs, donor funds, and statutory funds. The plan should include:

1. A plan for legislative reform and hiring of consultants in relation to these needs; and
2. An ?issues and options? paper, with assistance of the consultants that will guide decisions on what constitute the core and priority areas for revision of the existing legal framework.

(ii) Develop a GoG draft Bill for urgently needed revisions by November 2013.

 

Cash Management (SS4)

 

1. This set of activities has the primary objectives of reducing public sector borrowing costs and improving the predictability of expenditure commitments and timely liquidation of obligations. ?The establishment of systems and business process concepts have taken longer than envisaged.? The mission considers that priority should be given to configuring the system to comply with existing IGF rules and extending practices already in place for some donor projects. Revision of IGF rules will be more practicable, once IGFs are on the system and basic accountability is established. Inclusion of donor funds will also ensure that the GoG and donors move to compliance with the Paris Declaration (and subsequent declarations on aid effectiveness) on using country systems.? It has been agreed that more emphasis will be placed on developing cooperative arrangements with major ministries and donors to accelerate implementation. ?On donor funds, the World Bank has volunteered full cooperation for piloting inclusion of investment projects in the country system

 

1. Good progress has been made on establishing the basic framework for a TSA and cash management. Efforts have been focused mainly on rationalising the central BoG accounts, establishing interfaces with the BoG, GRA, and E-monitor (for non-tax revenue), and establishing coordination of cash management supported by a newly proposed Loans and Fiscal Agency Agreement (LFAA) between the BoG and MoF, which has now been drafted and should be signed by June 2013. Under these arrangements it has been agreed that progress toward establishing the TSA and estimating the savings in interest costs to the GoG will be measured and tracked by regular reports on the proportion of government balances held in BoG accounts in, or linked to, the CF relative to those outside the CF.? It is recommended that the implementation of the TSA for all funds held with the BoG (including its 5 branches) ? being the first step in achieving a robust and comprehensive TSA arrangement ? will take place as of July 1, 2013.

 

1. The 2^nd phase of establishing a TSA will require that all GoG official Bank accounts held in Commercial Banks are denominated as public accounts under the TSA.? To this end, the mission recommends that a strategy be developed and completed by September 30, 2013 and a fiscal agency agreement concluded between the BoG (as custodian of public finances) and the commercial banks for implementation to start by January 01, 2014. In the design of the strategy, it is recommended that the Government take a phased implementation approach starting with Accra-based commercial banks.??

 

1. Once the basis for effective cash management is established as outlined above, procedures for coordinating domestic debt and cash management can be further strengthened. A common arrangement is for a coordinating committee comprising representatives of Treasury (CAGD), Finance Ministry and Central Bank to meet regularly to assess government?s needs for domestic borrowing. A Joint Working Group with CAGD, GRA, MoF, and the BoG has been established to coordinate development of cash management and, as noted an LFAA between the MoF and BoG will provide strong support to the establishment of a TSA; The availability of better data on government balances and the consolidation of balances will allow the existing Cash Management Committee, to operate more effectively. Although established in 2008, its operations have been ineffective largely because of the lack of available reliable data on likely inflows and outflows and overall cash balances. It is recommended that a work plan to strengthen cash flow forecasting and coordinate debt and cash management be prepared in line with the implementation of the TSA by end September, 2013.^[11]

 

Financial Reporting (SS5)

 

1. This SS focuses on using GIFMIS functionality to improve the standard of budget and accounts documentation consistent with relevant international standards and covers budget presentation as well as financial reporting as part of overall fiscal transparency. Improved budget documentation, principally by including the current year?s revised budget, past year?s budget, and a budget summary in the annual budget document has become feasible with implementation of GIFMIS. As recommended in the previous AM, improvements in this area could significantly improve transparency and PEFA PI-6 score. The budget for FY2014 will incorporate these elements to improve fiscal transparency for the public and parliament.

 

1. Monthly Financial Statements are by law required to be produced by the 15^th of the following month. They are not, however, comprehensive budget execution reports (do not show budget data, do not include most of IGF transactions amongst others, do not yet include commitment data). Moreover, because of transitional problems, including the recent change of administration structure and delays in budget releases, they have not been produced in compliance with the law regarding timeliness; since December 2012, they have not been gazetted. It has been agreed that issuance of monthly statements for 2013 will be brought into compliance with the law in terms of timeliness by September 15, 2013 (for the August monthly report) and published on the CAGD website[12]. It has been agreed that the CAGD will aim to increase transparency and publish monthly statements on its website as well as move toward publication of more comprehensive budget execution reports. ?It is recommended that the CAGD (i) publish monthly financial statements up to August 2013 on the CAGD website by September 15, 2013; and (ii) prepare a road map for publishing a comprehensive budget execution report incorporating all funds as these are brought into GIFMIS.?

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1. GIFMIS will also provide tools to help improve the quality of Annual Financial Statements to achieve compliance with IPSAS, initially on a cash basis, and then eventually toward accrual basis statements. Inclusion of donor accounts on the system will help ensure recording of third party payments, as required by IPSAS. Inclusion of IGFs will help with consolidation of accounts. Work has started and a consultant has been appointed to prepare a roadmap to achieve IPSAS compliance. The work-plan should be completed by end of September, 2013 and should include immediate needs for preparation of the 2013 accounts and longer term implications of phased incorporation of donor accounts and IGFs.

 

 

MDA and MMDA Capacity Development (SS6)

 

1. MDA and MMDA capacity development activities aim at initiating a long-term program to establish effective financial control and management authority and capacity at MDA level, and to provide a basis for longer-term systems and capacity development in MMDAs. Enhanced MDA management capacity will be central to ensuring effective implementation of PBB.

 

 

1. With the introduction of composite budgeting to harmonize treatment of district and devolved centrally budgeted activities at MMDA level, GIFMIS has taken on more responsibilities for development/selection of MMDA systems and harmonizing MMDA budgets and accounts with the COA. This work is coordinated by a Committee, comprising the Local Government Service Secretariat, the GIFMIS Secretariat, and the Fiscal Decentralization Unit of MoF. Continuing collaboration with the MLGRD is critical to realizing the success of this and the mission is encouraged by the current level of cooperation with the MLGRD.

 

1. It is recommended that the MoF and MLGRD develop a work plan for training and capacity development for MDAs and MMDAs in their respective areas. The MoF will focus on training and business process change to meet the needs of PBB and financial management in both MDAs and MMDAs. The GIFMIS Training Team should provide support and incorporate this in its overall training work plan

 

1. The timeframe for these activities will extend well beyond that of GIFMIS, but several projects are being supported to assist with the decentralization process and there is a need for continuing coordination of these activities to avoid overlap. The mission is encouraged that this form of collaboration is already in existence. Meanwhile, GIFMIS is being implemented on a pilot basis at 7 MMDAs.? The mission opines that the 7 pilots would require proper testing for stability and based on re-engineered business processes rather than on replication of systems that themselves require changes, before the full roll-out is embarked upon.? Nevertheless, the roll-out to all 216 MMDAs would need to be accomplished by June 30, 2014 (the current closing date of the project). ?

 

1. There will also be a need eventually to configure GIFMIS reports to cover MMDAs as a component of general government. This will be required both for macro-fiscal reporting and for effective sector reports on service delivery (PI-23). It is recommended that these requirements be taken into account in the proposed GFOR roadmap.

 

 

COMPONENT ? 3: Project Component Management

 

1. The last mission rated this component as ?moderately satisfactory? owing to the uneven implementation progress against key sub-activities within the component.? Owing to the pace of progress since the last mission and the significant efforts made by the project management in reinforcing implementation across all fronts, albeit with some down sides particularly in terms of monitoring and evaluation; coordination with development partners as defined in the MoU particularly in the area of reporting the component is now rated ?satisfactory?.

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Project Management and Coordination

 

1. The mission observed greater collaboration between the CAGD and Budget Division teams in support of a more holistic, rather than segmental, implementation coordination under the project.? To ensure that the GIFMIS is not an accounting or ICT project but a PFM improvement project that also uses ICT as tools to achieve overall PFM outcomes, the mission underscore the necessity for the core GIFMIS management to sustain the strength and momentum of coordination. Since the project is designed to also support the strengthening of the internal management of MDAs and MMDAs for enhanced and efficient delivery of services, it remains a critical requirement for the project management to deepen the partnership it has started building with entities whose operations it is to support. While the mission recognizes that coordination among key project teams is being facilitated, it encourages the project management to sustain the empowerment of the two deputy directors so that they are able to directly deliver on their mandates even more effectively. In the same vein, internal collaboration and exchange of views amongst thematic teams – cultural change and process management, Budget, Finance and Accounting, Treasury and Cash Management, Payroll, Technical, M&E, Quality Assurance, and Legal ? would need to remain a continuing feature as part of project management and coordination especially at this critical juncture when a number of far reaching PFM reforms are under implementation. The mission has been assured that this system of enhanced collaboration will be sustained.

 

1. As regards the strategic direction of the project, the mission is encouraged to note that the high-level Steering Committee established for both the expenditure and revenue management functions and an Executive Committee for the GIFMIS project continue to meet occasionally and that the Minister himself chairs these meetings.? Again, the mission would further encourage the Executive Committee to discuss, agree, and give directives aimed at resolving policy issues that may have impact on the timely and orderly implementation of the GIFMIS, since positive PFM outcomes can be realized only when the environment is conducive.

 

1. Extension of Project:? The project sponsor has conveyed the interest of the Government to extend the project for development to consider a possible extension of the projects closing by six months to December, 2014.? This is to enable the completion of several activities critical to the achievement of the development objectives of the project.? The mission opines that the justification of the extension will need to be articulated in a formal request from the Government to the development partners citing elements of the program that will be implemented during the extended period as well as a procurement plan that clearly demonstrates that those activities can indeed be completed during the period.? The formal request must be submitted no later than September 15, 2013 for consideration by the development partners.

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Monitoring and Evaluation

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1. A Harmonized Monitoring and Evaluation Framework (HM&EF)[13] has been developed with the fundamental aim of establishing a GOG-centered system for assessing the extent to which the GIFMIS project is contributing to the Government?s objective of strengthening PFM.? ?The last mission particularly stressed the need for central PFM MDAs to be fully involved in ensuring that GIFMIS is used effectively as a tool to address the country?s key fiscal and financial management issues. As discussed in Annex 5, it was recommended that work planning and M&E should focus on groups of activities, designated as strategic segments (SS), and that the relevant GIFMIS team, in consultation with the responsible MDAs, should be primarily responsible for managing the process.

 

1. ?However, a number of misunderstandings have arisen in implementing the recommendations of the last AM. First, rather than assigning activities to strategic segments and ensuring clear oversight by the relevant GIFMIS team and by M&E, activities were assessed simply according to technical responsibilities within the project. Thus interfaces that are seen as critical to cash management, which is operationally under the direction of component 2, for example, was re-designated as an element of component 1, which treats it as purely a technical systems function.?? In practice, the Cash Management Team took an active interest in interface development, but the sense of strategic importance and the connections to a range of outputs and outcomes is greatly reduced in the final reporting format–and it is much more difficult for M&E to assess its strategic importance. A second example, discussed under component 2, is that the strategic significance of incorporating IGFs and donor funds in GIFMIS and the TSA was given a lesser priority than urged by the previous AM. ?Undoubtedly there are significant systems configuration issues, but the importance of establishing a TSA and achieving comprehensive budget coverage warrants a major effort as is now again being urged. It is recognized, however, that the strategic segments approach involves a significant change from past practice, but any disagreements with AM recommendations should be discussed transparently.

 

1. Progress to date is assessed as being moderately satisfactory, but it is critical that the following actions be taken with regard to the present operations of the M&E function:

 

1. a.????? The HM&EF should be used as the primary GoG monitoring and evaluation instrument;
2. b.????? M&E reports based on the HM&EF should be distributed to all DPs once they are approved by Project Management;
3. c.?????? Major changes in the approach to M&E should be discussed with DPs prior to implementation;
4. d.????? M&E itself needs to be strengthened under the direction of a near full-time technically qualified officer supported by the M&E advisor. Preparation and monitoring of work plans should be done largely by the GIFMIS teams–and these teams should also generally be led by a near-fulltime officer qualified in the requisite area; the M&E role should focus much more on assessing the significance of performance relative to critical outcomes; and
5. e.?????? Increasingly M&E should be concerned with evaluation of GIFMIS and the basis for continuing PFM reform after GIFMIS ends; linkages with the recent PEFA assessment are particularly important in this context.

 

1. Because the recommended approach has not yet been followed, this mission was not provided with up-to-date data on activity work plans with clear links to expected milestones and outcome areas. The M&E report did not show performance against agreed milestones or updates and amendments to milestones.? During this mission it has been possible only to draft revised templates for some of the strategic segments to clarify the need to identify clear milestones, report performance against milestones, and identify critical weaknesses and strengths in each reporting period. As described in Annex 5, these templates are to be further developed and agreed by the Project Directorate and a full strategic segments report prepared incorporating milestones for all activities and linking each activity to the relevant outcome area to facilitate evaluation of the overall project outcomes and impact. Annex 5 includes (as Part II) updated World Bank Results Framework incorporating key changes. This framework meets the Bank?s internal requirements, but covers only a subset of the total data required for full analysis of GIFMIS performance against its objectives.

 

1. In light of the lack of up-to-date data available on activity work plans and performance against agreed (or in some cases amended) milestones, it is recommended that: The Project Directorate (i) provide DPs with GIFMIS work plan based on strategic segments and an up-dated M&E report on work plans and performance against milestones and outcomes by July 31, 2013, and (ii) ensure that timely reports are prepared each quarter and are (a) reviewed internally, and (b) subsequently made available to the DPs.

 

Change management and Communications Strategy

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1. The Change Management team is continuing to lead in championing and reinforcing the needed cultural and behavioral changes at the end user level to enhance ownership and acceptance of GIFMIS. Based on the communication strategy for GIFMIS, a number of actions have since been taken towards this end including: (i) exhibition of GIFMIS at policy fairs, production and dissemination of newsletters; (ii) development of a GIFMIS website; (iii) establishment of internal support teams to serve as focal persons at the MDAs, in addition to advocates; and training workshops. While progress has been made towards sensitizing MDAs and pilot MMDAs on the general use of GIFMIS, a lot remains to be done in terms of customizing the change management initiatives to cater to the specific concerns of certain groups of users of GIFMIS such as Internal Auditors and Accountants.

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1. The mission noted the apprehension among Internal Auditors in particular that GIFMIS implementation will ?take over? their role and hence render them redundant or even cause them to lose their jobs – i.e. their traditional pre-audit function – since such a role will no longer be required under GIFMIS automated controls and work flow environment. The mission explained that the performance of pre-audit is not consistent with the mandate of internal audit since it puts internal auditors in the transaction processing cycle and thus may impair their independence in performing ex-post transactions reviews. Accordingly, the role of Internal Auditors is to conduct system reviews, identifying risks and assisting management in designing mitigation measures for risks identified.? Although, the mission was informed that special training has been developed for Internal Auditors to help ease their transition to the automated GIFMIS environment and to also train them on the use CAATs, further work is required by the cultural and change management team to reverse the perceptions relating to the impacts of changes in processes, practices, and systems that result from the use of GIFMIS in financial management.

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1. Another area where change management initiatives need to be strengthened relate to Budget reforms. Although, the mission was informed that the Budget Department has hired a consultant to scope out a change management plan, this activity could be better and more productively performed when coordinated seamlessly with the GIFMIS project change management team. The wide range of budget reforms occasioned by the implementation of Composite Budgeting and PBB will require fundamental changes in processes, policies, controls, responsibilities and behaviors across government in relation to budget preparation and execution. In view of this, a comprehensive as well as an integrated change management strategy is required to build stakeholder acceptance of the reforms. Lack of coordination and integration may undermine reforms. The mission therefore recommends that the work of the change management consultant be fed into the overall change management strategy of GIFMIS to ensure a coordinated effort, consistency of themes and change management actions across government.

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1. ?Further to this, the mission noted that concrete improvements in fiscal management and efficiencies in processes and their direct or indirect impact on service delivery outcomes are not visibly highlighted by the change management team as part of their communications strategy. Change management and communication actions have emphasized more on outputs and activities and less on linkages to services delivery and outcomes. The mission therefore recommends that the communications team liaise more with the M&E team to better document and share information on the concrete benefits and intermediate results that the project has achieved, and the remaining actions to be implemented to achieve the overall project outcomes within defined timeframes as part of the communication strategy.

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Training

 

1. With regards to training, the mission noted that training activities lack emphasis on measurement of results or outcomes that the training activities are expected to lead to. Without a strong emphasis on outcomes, the plan continues to be activity based without clear performance benchmarks to measure effectiveness. Although, the mission was informed that the Training team undertakes evaluation after each training session, feedback obtained after trainees have returned to their jobs remain very informal and ad hoc. The mission underscored the need to ensure that the team measures the impact of training in a structured and an institutionalized manner. To this end, the mission recommends that post-training feedback and results measurement criteria be designed and implemented as part of the training plan effective July 1, 2013.

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1. IT Certifications: No progress has been made for ensuring professional certifications for the IT staff for enhancing the sustainability of the system. The Mission recommends PD nominate at least 5 technical staff for IT certifications- 2 for CCNA, 1 for OCP, 2 for database administration- by June 30, 2013 with a timeline for first attempt set as December 31, 2013. Staff should be encouraged to enroll in on-line certification programs paid for by the project, to balance the work with the studies

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1. Another area of concern noted by the team relates to training in report generation and reversal of entries wrongly recorded in GIFMIS. Although the mission was informed that all Controllers and their staff in these rolled-out ministries have been trained on report generation, it was noted during field trips to the Ministries of Health and Local Government that, in general, GIFMIS Advocates, rather than staff of the Controllers? Department or Ministries own management and staff, have the required proficiency to generate reports from the system.? Other issues raised during the site visits relate to the lack of clarity on how to reverse erroneous accounting entries in GIFMIS. Without strong proficiency in report generation on a real-time basis to aid decision making, the mission opined GIFMIS will have limited benefits to users beyond transaction processing.? Equally, inability to correct errors in transaction recording could lead to unreliability of financial reports. The mission therefore recommends that the training team design customized training programs on report generation and reversal of erroneous entries, among others, to address the weaknesses identified by June 15, 2013 for implementation as of July 1, 2013.

 

1. While the mission was encouraged to note that the project team has developed a performance evaluation process to measure the effectiveness of Advocates at the various roll-out sites, the mission noted that further work needs to be done to ensure that a dependency is not created on Advocates for the performance of routine processing functions of users. As expected, given that the system is still very new to users, the Advocate?s role is very pivotal in providing guidance to end users and trouble -shooting basic system issues encountered. However, the mission opined that strong emphasis should be placed, even in these nascent stages of the system, on skills transfer from the Advocate to end-users. This is critical to ensure the sustainability of the system. The mission therefore, advises the project team to assess the effectiveness of skills transfer to end-users as part of the performance evaluation of the Advocates, among others.

 

Procurement

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1. Given that the project has just about one year to close, the mission met and held fruitful discussions with the GIFMIS Project management team to, among others, (i) review the status of procurement carried out by the project to date; (ii) review and agree on plans for outstanding procurement; (iii) discuss main procurement challenges encountered and propose solutions; and (iv) examine procurement documentation to assure conformance with agreed procurement procedures and processes per the legal agreement. The objective is to ensure that all outstanding procurement activities would be delivered and consultancy assignments completed and reports submitted to contribute to the project development targets before the project closing date of June 30, 2014. It was noted that although appreciable progress has been made, the team will have to put in more efforts as there still remains a number of critical procurement activities lagging behind planned schedules.? More importantly, technical efforts need to be raised to provide the needed input of TORs and technical specifications in a timely manner to avoid any further delays in the procurement process. Where capacity does not exist or is low within client?s internal organizations, short term consultants could be recruited to provide the needed support and inputs.

1. The review found that, in general, the project continues to adhere to the procurement arrangements put in place in the legal agreement and the PAD. The mission found that all procurement activities carried out so far are based on items in the previously approved Procurement Plan. However certain minor shortfalls were identified and should be corrected. They include non-compliance with contractual payment condition for services contract within the agreed time limit in the contract, non-compliance with Bank Guidelines on change from post to prior review, non-publication of contract awards on PPA?s website per the requirement of the Ghana Public Procurement Act, non-submission of quarterly procurement management report to the Bank (refer PAD-Annex 8, para.23), Non-submission of annual procurement audit report to the Bank within three (3) month after the end of the fiscal year. No indication of fraud or corruption, however, was noted in the course of this review.

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1. Procurement Risk Rating: ?Following the review, the overall Procurement arrangement for the project is rated as Satisfactory while procurement risk is rated as moderate. Refer to Annex 3 for the full procurement assessment report.

 

1. The project should submit to DPs an updated Procurement Plan based on a revised and costed Work Plan by June 30, 2013.

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Financial Management

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1. The financial management arrangements of the project were reviewed and assessed to ascertain the continuing adequacy or otherwise of the FM arrangements for implementing the project.? The review sought, inter alia, to determine the extent to which the key FM sub systems such as budgeting, accounting, internal controls, funds flows processes, financial reporting and external auditing have been mainstreamed into the Government?s accounting systems as per the PAD.? In addition, all transactions incurred prior to effectiveness as well as a sample of financial transactions incurred since October 2012 (SOE) were reviewed for verification of controls and eligibility of expenditure.

 

1. Per the review, the existing FM arrangements continue to be satisfactory and meet the minimum requirement for financial management under the World Bank guidelines.? Notwithstanding, the mission noted areas of improvement that will further enhance the quarterly and annual financial reporting arrangements of the project. To further improve upon the quality of financial reporting, both the client and the DPs agreed that the following enhancements be made to the Interim Financial Report (IFR) effective the June 30, 2013 reporting period:

(a)?? Project Component expenditures in the ?Statement of Uses of Funds? should be analyzed into the following expenditure categories: (i) Goods, (ii) Consultancy /non-consulting services (iii) Training& Workshops and; (v) Operating Costs.? Additional columns should be provided that show cumulative expenditures amounts for ?year to date? and from ?project inception?;

(b)?? On the Statement of Uses of Funds, variances at the expenditure category level should be shown and narrative explanations for large variances provided;

(c)??? Budgeting: As part of the variance analysis, the IFRs should provide more details on activities as per the approved annual work plan, including estimated cost;

(d)?? Include quarter-end bank statements for the Dollar and Cedi bank accounts. The balance in the Cedi statement should be converted and added to the Dollar balance on the face of the pooled Designated Account reconciliation statement; and

(e)?? Commitment control: Project Accountant working with Procurement Unit should include a section in the IFRs that shows by component the following: originally committed amount, disbursed amount, outstanding commitments, planned /new commitments, and balance. Such information will help as a basis for making request to the DPs for fund releases.

 

1. Regarding annual audited financial reports, the following improvement areas were agreed upon and are to be implemented effective the FY 13 audit report.

 

(a)?? Ghana Audit Service (GAS) should include a statement in the audit report for CAGD, to the effect that GIFMIS donor funds are included in the scope of the audit; and

(b)?? The project?s statement of sources and uses of funds should be included in the Notes to the CAGD annual audited financial statements.

 

1. A snapshot of the sources and uses of funds as at March 31, 2013 is included in Annex 6
2. Forecast Activities. The Project was expected to prepare, at the time of the mission, an eighteen-month forecast of expenditures based on the procurement plan and approved activities to June 30, 2014. At the date of the mission this had not been finalized; however the initial six months projection to September 2013 for an estimated amount of US$20.7 million was provided. Based on this plan, a formal withdrawal request was submitted to the participating DPs for release of funds. Based on the forecast of activities to be implemented over the next 6 months, the allocation of contributions already due is as follows: IDA ? US$-7.74million, DFID– US$4.06million, EU ? US$6.03million and DANIDA– US$2.9milion.

 

V. OTHER ISSUES DISCUSSED

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BOOST

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1. Following preliminary discussions with the Ministry of Finance about the introduction of the BOOST in Ghana, a representative of the BOOST Team from the World Bank Institute joined the mission and made a presentation to the Government team consisting of officials from MoF, the CAGD, and others. Separate presentations were also made to the Payroll Unit of CAGD, the Expenditure Monitoring Unit of the Budget Division at MoF and the Public Financial Management Sector Working Group. The presentations highlighted that the main objective of BOOST is to clean data and create a database for the analysis of public expenditures.

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1. The BOOST as a tool uses Microsoft Excel pivot tables. The following steps are essential and critical in the construction of a BOOST database: (i) data to be provided by public officials from the Treasury system; (ii) the BOOST Team (from the Bank) in coordination with government officials will clean and classify the data according to the country?s chart of accounts and create an Excel file for the data analysis; and (iii) The BOOST Team will provide capacity-building to the appropriate government officials on how to create, update, maintain and use the database for economic analysis.

 

1. The presentation was well received by Government as a useful tool that will support Government’s efforts in analyzing and tracking budget implementation, taking advantage of the budget and expenditure data being generated through GIFMIS. The mission emphasized that the reports that will be generated from the BOOST are to complement reports produced from the GIFMIS.? The mission noted that since GIFMIS currently covers only the Consolidated Fund, it is possible to add and analyze data from other sources ? statutory funds, IGFs and donor funds when they are provided by the Government.

 

1. The following agreements were reached with the Government team; (i) develop the BOOST database in Ghana, (ii) the database should be anchored at the Ministry of Finance within the Budget Division; (iii) Government will select, by June 30, 2013, a focal person and team (one leader plus at least four officials, including two from the CAGD) who will work directly under the auspices of the Director of Budget to support the development of the database and; (iv) the World Bank will support the development of Ghana?s BOOST database, in coordination with the Government team within three months after the required data have been provided by government.

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VI: DISCLOSURE:

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1. The World Bank and Government of Ghana confirm their understanding and agreement to publicly disclose this aide-m?moire. The disclosure of this Aide Memoire was discussed and agreed to with GIFMIS project counterparts and representatives of the Ministry of Finance, at the wrap-up meeting that took place on May 31, 2013 in Accra.