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Click to edit Master title style • Click to edit Master text styles –

Click to edit Master title style • Click to edit Master text styles – Second level The Pathfinder International Presentation • Third level on US– Government Legislative and Policy Fourth level » Fifth level Requirements for Family Planning 10/28/2020 Slide #1 DECEMBER 2011 1

Volunteerism and Informed Choice Click to edit Master title style At Pathfinder, we believe

Volunteerism and Informed Choice Click to edit Master title style At Pathfinder, we believe volunteerism and • informed choice are essential to our contraceptive Click to edit Master text styles – Second level programs. • Third level – Fourth level The US government (USG) also believes in » Fifth level volunteerism and informed choice and has put in place legislative and policy requirements to ensure that these values are adhered to in all USG funded programs. 10/28/2020 Slide #2 DECEMBER 2011 2

Characteristics of Requirements and Policies Click to edit Master title style USG Requirements •

Characteristics of Requirements and Policies Click to edit Master title style USG Requirements • • Mandated by the USG Click to edit Master text styles • Generally relate to “volunteerism, ” “informed choice, ” or “abortion – Second level services” • Third level • Apply to different kinds of assistance—some for family planning – Fourth level (FP) only and some for all foreign assistance » Fifth level • If Pathfinder accepts funds for FP activities we are obligated to comply with the laws and policies applicable to the assistance. • We are required to be knowledgeable about the policies and to ensure that all of our implementing partners and their service providers are knowledgeable about the requirements. 10/28/2020 Slide #3 DECEMBER 2011 3

Overview of Requirements Click to edit Master title style General Topic Year Enacted/Applicable Requirement

Overview of Requirements Click to edit Master title style General Topic Year Enacted/Applicable Requirement Tiahrt Amendment Volunteerism 1999 – funds for FP activities • Click to edit Master text styles 1985 – all foreign assistance funds Kemp-Kasten Amendment Volunteerism – Second level Method Mix De. Concini Amendment 1985 – funds for FP activities Livingston Amendment Method Mix 1986 – funds for FP activities Helms Amendment Abortion 1973 – all foreign assistance funds Leahy Amendment Abortion 1994 – all foreign assistance funds Biden Amendment Abortion (biomedical research) 1981 – all foreign assistance funds Siljander Amendment Abortion (lobbying) 1981 – all foreign assistance funds • Third level – Fourth level Voluntary Sterilization 1977 – direct support for VS Policy Determination 3 » Fifth level (VS) services 10/28/2020 Slide #4 DECEMBER 2011 4

Definitions of Volunteerism and Informed Choice Click to edit Master title style Pathfinder and

Definitions of Volunteerism and Informed Choice Click to edit Master title style Pathfinder and USG support the freedom of individuals to choose voluntarily the number and spacing of their children. • Click to edit Master text styles Guiding principles for USG assistance: – Second level • Third level • Volunteerism = making decisions independently, without – Fourth level the influence of any special incentives or forms of coercion » Fifth level • Informed Choice = full access to information on contraceptive choices and to counseling, services, and supplies that allow a client to choose freely 10/28/2020 Slide #5 DECEMBER 2011 5

Tiahrt Amendment Overview Click to edit Master title style 1. No targets or quotas

Tiahrt Amendment Overview Click to edit Master title style 1. No targets or quotas for service providers or referral agents • Click to edit Master text styles Second level 2. – No incentives or payment to clients or program • Third level personnel 3. – Fourth level » Fifth level No denial of benefits for not accepting FP 4. Comprehensible information required on the FP method chosen 5. Restriction on use of experimental FP methods 10/28/2020 Slide #6 DECEMBER 2011 6

Tiahrt Applicability Click to edit Master title style To which kinds of “assistance” does

Tiahrt Applicability Click to edit Master title style To which kinds of “assistance” does Tiahrt apply? Any FP service delivery activity funded by USG • • Click to edit Master text styles • –More specifically: FP services that receive USG Second level assistance • Third level – Fourth level • FP assistance in the form of funds, technical assistance, » Fifth level FP commodities, and training To which entities does Tiahrt apply? • It applies to US NGOs, foreign NGOs, and foreign governments. 10/28/2020 Slide #7 DECEMBER 2011 7

Requirement 1: No Targets or Quotas Click to edit Master title style • Service

Requirement 1: No Targets or Quotas Click to edit Master title style • Service providers or referral agents may not • Click to edit Master text styles implement or be subject to quotas or targets for – Second level total number of births, number of FP acceptors, • Third level or acceptors of a particular method of FP. – Fourth level » Fifth level • Quantitative estimates or indicators for budgeting or planning purposes are permitted. 10/28/2020 Slide #8 DECEMBER 2011 8

Requirement 2: No Incentives or Financial Rewards Click to edit Master title style No

Requirement 2: No Incentives or Financial Rewards Click to edit Master title style No payment of incentives, bribes, gratuities, or rewards to: • financial Click to edit Master text styles – A. Second level An individual in exchange for becoming an • FP acceptor Third level – Fourth level » Fifth level B. Program personnel for achieving a numerical target or quota of total number of births 10/28/2020 Slide #9 DECEMBER 2011 9

Requirement 3: No Denial of Rights or Benefits Click to edit Master title style

Requirement 3: No Denial of Rights or Benefits Click to edit Master title style • No denial of rights or benefits as a consequence • Click to edit Master text styles of an individual’s decision not to accept FP. – Second level • Third level • Rights or benefits include access to participation – Fourth level in any general welfare program and the right of » Fifth level access to health care. 10/28/2020 Slide #10 DECEMBER 2011 10

Requirement 4: Comprehensible Information Required Click to edit Master title style • FP acceptors

Requirement 4: Comprehensible Information Required Click to edit Master title style • FP acceptors must receive comprehensible • Click to edit Master text styles information on the health benefits and risks of –the FP method chosen. Second level • Third level • – Fourth level Comprehensible information can be provided » Fifth level in many forms (e. g. counseling, posters, brochures, flip charts, and package inserts). 10/28/2020 Slide #11 DECEMBER 2011 11

Requirement 5: Experimental FP Methods Click to edit Master title style • Experimental contraceptive

Requirement 5: Experimental FP Methods Click to edit Master title style • Experimental contraceptive drugs, devices, and medical procedures may only be provided in • Click to edit Master text styles the context of a scientific study in which – Second level participants are advised of potential risks and • Third level benefits. – Fourth level » Fifth level • USG has regulations regarding research on human subjects. Support for any such research must be carried out in accordance with these regulations. 10/28/2020 Slide #12 DECEMBER 2011 12

When Does Tiahrt Apply? Click to edit Master title style • Tiahrt applies to

When Does Tiahrt Apply? Click to edit Master title style • Tiahrt applies to USG-funded FP service delivery projects (i. e. projects that deal directly with “acceptors”). • Click to edit Master text styles • Tiahrt applies to mobile clinics, private and government – Second level clinics, outreach clinics, services for internally displaced • Third level persons (IDPs) or refugees, and community-based services. – Fourth level • Tiahrt applies when any kind of assistance (cash, technical » Fifth level assistance, FP commodities, or training) is provided to an FP service delivery project. • Tiahrt applies when a project enhances the ability to provide FP services (e. g. systems strengthening or the ability to conduct surveys). 10/28/2020 Slide #13 DECEMBER 2011 13

When does Tiahrt Not Apply? Click to edit Master title style • When assistance

When does Tiahrt Not Apply? Click to edit Master title style • When assistance is for non-FP-related activities such as maternal health (even if FP is provided in same clinic) • Click to edit Master text styles • When assistance is for broad information campaigns, surveys or – Second level data collection, strategic planning, evaluation, research or publications • Third level – Fourth level • When assistance is used to pay for a regional or international conference » Fifth level • When assistance is used to pay for travel or per diem for a widely attended training conference • When assistance funds mass media campaigns conducted by organizations that do not implement service delivery projects 10/28/2020 Slide #14 DECEMBER 2011 14

The Tiahrt Amendment Permits: Click to edit Master title style • Free distribution of

The Tiahrt Amendment Permits: Click to edit Master title style • Free distribution of FP methods or selling methods at a reduced price • Click to edit Master text styles • Fee-for-service or per case payments to providers – Second level • Third level • Non-financial small items provided to project personnel – Fourth level or individuals to acknowledge good performance (e. g. » Fifth level caps, aprons, backpacks, boots, umbrellas, etc. ) • Special training or promotions for project personnel who are considered good performers. 10/28/2020 Slide #15 DECEMBER 2011 15

Specific Situations Click to edit Master title style • Targets are permitted if they

Specific Situations Click to edit Master title style • Targets are permitted if they are for planning purposes. Targets are permitted in social marketing programs where • • Click to edit Master text styles targets are set for manufacturers, distributors, and retailers. – Second level • If FP commodities are paid for with USG funds and are donated • Third level to the country’s national supply, then Tiahrt applies to all service – Fourth level delivery sites that receive these supplies. If other donors supply » Fifth level FP commodities, Tiahrt applies unless the logistics system can identify clinics that only receive non-USG FP commodities. • Performance-based financing mechanisms may incorporate FP indicators as long as individual service providers are not required to meet targets. 10/28/2020 Slide #16 DECEMBER 2011 16

Frequently Asked Questions on Tiahrt Compliance Click to edit Master title style 1. What

Frequently Asked Questions on Tiahrt Compliance Click to edit Master title style 1. What kinds of projects are covered by the Tiahrt Amendment? • Click to edit Master text styles – Second level 2. Are there some population activities funded • Third level by USG where Tiahrt does not apply? – Fourth level » Fifth level 3. Under Tiahrt, is a USG-funded implementing partner organization (IPO) allowed to set goals for FP in its clinics, for the clinic as a whole, or for individual service providers? 10/28/2020 Slide #17 DECEMBER 2011 17

Frequently Asked Questions, continued Click to edit Master title style 4. Does the Tiahrt

Frequently Asked Questions, continued Click to edit Master title style 4. Does the Tiahrt incentive restriction prohibit payment on a per case or method basis? • Click to edit Master text styles – Second level 5. Are items provided to project personnel (e. g. • Third level caps, work aprons, mugs, or backpacks) – Fourth level » Fifth level incentives that would be prohibited under the Tiahrt clause? 6. When does the provider need to obtain written consent for an FP method? 10/28/2020 Slide #18 DECEMBER 2011 18

Additional Requirements Related to Volunteerism and Choice Click to edit Master title style De.

Additional Requirements Related to Volunteerism and Choice Click to edit Master title style De. Concini Amendment: “Funds should be available only to voluntary • FP projects which offer, either directly or through referral to, or Click to edit Master text styles information about a broad range of information and services. ” – Second level Livingston Amendment: “In awarding grants for natural FP… no • Third level applicant shall be discriminated against because of such applicant’s – Fourth level religious or conscientious commitment to only offer natural FP. ” » Fifth level Kemp-Kasten Amendment: No foreign assistance funds “may be available to any organization or program which, as determined by the President of the United States, supports or participates in the management of a program of coercive abortion or involuntary sterilization. ” 10/28/2020 Slide #19 DECEMBER 2011 19

Requirements on Voluntary Sterilization Click to edit Master title style Policy Determination 3 (PD-3)

Requirements on Voluntary Sterilization Click to edit Master title style Policy Determination 3 (PD-3) • is complementary to Tiahrt and has 3 key Click to edit Master text styles requirements: – Second level • Third level 1. Informed consent is required before a sterilization – Fourth level procedure and must be documented. » Fifth level 2. Incentive payments for sterilization are prohibited. 3. Compensation for service providers can be acceptable under certain circumstances. 10/28/2020 Slide #20 DECEMBER 2011 20

PD-3 Guidance on Payments Click to edit Master title style • Payments cannot be

PD-3 Guidance on Payments Click to edit Master title style • Payments cannot be used as an incentive to accept, provide, or refer clients for voluntary sterilization service. • Click to edit Master text styles – Second level • Certain payments to clients are not considered incentives, • Third level as long as they are reasonable (e. g. transportation to and – Fourth level from the procedure or food provided during confinement). » Fifth level • Determination of what is a “reasonable” payment must be made by the USAID Mission based in-country and on a program-specific basis, using knowledge of social and economic circumstances. 10/28/2020 Slide #21 DECEMBER 2011 21

MCP Rescinded Click to edit Master title style • The Mexico City Policy (MCP)

MCP Rescinded Click to edit Master title style • The Mexico City Policy (MCP) has • Click to edit Master text styles been rescinded. – Second level • Third level • MCP was removed as a government – Fourth level policy» by President Obama in 2009. Fifth level • We can now discuss all pregnancy options. 10/28/2020 Slide #22 DECEMBER 2011 X MCP 22

Requirements on Abortion Click to edit Master title style Currently there are 4 requirements

Requirements on Abortion Click to edit Master title style Currently there are 4 requirements that relate to • abortion. Click to edit Master text styles Helms Amendment: Written in 1973 and states, “No – Second level foreign assistance funds may be used to perform or • Third level motivate or coerce people to practice abortions. ” – Fourth level » Fifth level Leahy Amendment: Clarifies the Helms Amendment. Specifically, it clarifies the term “motivate. ” Motivate does not prohibit the provision of information, counseling or referral for all pregnancy options including abortion when this is consistent with local laws in the country. 10/28/2020 Slide #23 DECEMBER 2011 23

Requirements on Abortion, continued Click to edit Master title style The Biden Amendment: Prohibits

Requirements on Abortion, continued Click to edit Master title style The Biden Amendment: Prohibits using funds for • any biomedical research that relates to abortion. Click to edit Master text styles – Second level • Third level The Siljander Amendment: States that “no funds – Fourth level may be used to lobby for or against abortion. ” » Fifth level 10/28/2020 Slide #24 DECEMBER 2011 24

Postabortion Care Click to edit Master title style Postabortion care (PAC) is the treatment

Postabortion Care Click to edit Master title style Postabortion care (PAC) is the treatment of complications, • injuries or illness caused by legal or illegal abortion. PAC is Click to edit Master text styles not affected by USG policies related to abortion. USG – Second level supports the provision of PAC services. • Third level However, USG funds cannot be used to purchase manual – Fourth level vacuum aspiration (MVA) equipment. » Fifth level Equipment must be clearly separated from abortion services where both are offered. Equipment that can be used for multiple obstetric purposes (e. g. uterine sounds) must be labeled “for PAC only”. 10/28/2020 Slide #25 DECEMBER 2011 25

Identifying Potential Vulnerabilities Click to edit Master title style The first step towards ensuring

Identifying Potential Vulnerabilities Click to edit Master title style The first step towards ensuring compliance to USG policy and legislative requirements is to identify • potential vulnerabilities in the country. Click to edit Master text styles – Second level Vulnerabilities may stem from various factors • Third level • Abortion or menstrual regulation is legal or widely – Fourth level available. » Fifth level • There is a movement to change the status or availability of abortion in the country. • There is a history of targets or coercion in FP programs. • The service package includes permanent methods. 10/28/2020 Slide #26 DECEMBER 2011 26

Potential Vulnerabilities, continued Click to edit Master title style • Clients are compensated for

Potential Vulnerabilities, continued Click to edit Master title style • Clients are compensated for costs associated with voluntary sterilization. • Click to edit Master text styles • There have been changes in the IPO or their staff. – Second level • Local governments have significant autonomy in implementing FP • Third level programs. – Fourth level • PAC and/or abortion are part of the IPO’s program. » Fifth level • The IPO’s program has a social marketing component for FP. • The program includes performance-based financing components. • The program includes distribution of FP commodities to the national government. 10/28/2020 Slide #27 DECEMBER 2011 27

Ensuring Compliance: HQ and Country Office Click to edit Master title style 1. Standard

Ensuring Compliance: HQ and Country Office Click to edit Master title style 1. Standard Provisions related to the voluntary population policies are included in every cooperative agreement, contract, and sub • Click to edit Master text styles agreement. – Second level 2. All Pathfinder country office staff members have completed a • Third level yearly half-day training using the Pathfinder Training Guide on – Fourth level USG Legislative and Policy Requirements for FP. » Fifth level 3. All new staff members at the country, regional, state, and satellite offices have been briefed on Tiahrt and other USG legislative and policy requirements on family planning programs, during their orientation as new personnel. 10/28/2020 Slide #28 DECEMBER 2011 28

Ensuring Compliance: HQ and Country Office, continued Click to edit Master title style 4.

Ensuring Compliance: HQ and Country Office, continued Click to edit Master title style 4. Pathfinder country offices will conduct Tiahrt assessments, using Pathfinder’s compliance tools with all Pathfinder staff and IPOs. • Click to edit Master text styles 5. Tiahrt questions will be included in standard monitoring visits. – Second level • Third level 6. Pathfinder will provide compliance tools to its staff and IPO staff to assess compliance with USG requirements. – Fourth level » Fifth level 7. Each Pathfinder country office will develop a compliance monitoring plan. 10/28/2020 Slide #29 DECEMBER 2011 29

Ensuring Compliance: HQ and Country Office, continued Click to edit Master title style 8.

Ensuring Compliance: HQ and Country Office, continued Click to edit Master title style 8. Each Pathfinder country office will maintain a compliance file which should include a record of all compliance activities: • Questionnaires and monitoring Compliance monitoring plan • • Click to edit Master text styles forms used during field visits • Copy of the Pathfinder International – Second level Training Materials on USG Legislative & Policy Requirements • Third level for FP – Fourth level • Notes on training sessions, including » Fifth level dates, attendance sheet signed by all participants, and a summary of key points • Copies of presentations and handouts from training • Reports on monitoring visits, including dates, sites visited, and a summary of results • Documentation of any changes recommended and progress on their implementation • Copy of procedures followed in investigating a suspected violation (if applicable) • Correspondence, meeting minutes, and internal memos 10/28/2020 Slide #30 DECEMBER 2011 30

Ensuring Compliance: IPO (NGO) 1. Click to edit Master title style All IPO staff

Ensuring Compliance: IPO (NGO) 1. Click to edit Master title style All IPO staff members have completed a yearly half-day training on USG legislative and policy requirements using the Pathfinder International Training Guide on USG Legislative and Policy Requirements for FP. • Click to edit Master text styles 2. – All NGO IPOs funded under the project have agreed (in writing) to comply Second level with the Voluntary Population Activities Provision. • Third level 3. – Fourth level The IPO has conducted an annual half-day training for clinic- and community -level providers on Tiahrt and other USG legislative and policy requirements » Fifth level using the Pathfinder International Training Guide on USG Legislative and Policy Requirements for FP. 4. The IPO has a “Tiahrt poster” or equivalent poster providing comprehensible (i. e. , clear and comprehensive) information on FP methods displayed on the wall of the office, or it has equivalent informational materials (e. g. , flip charts or other counseling materials) describing the benefits and risks of different FP methods. 10/28/2020 Slide #31 DECEMBER 2011 31

Ensuring Compliance: IPO (NGO), continued Click to edit Master title style 5. Each IPO

Ensuring Compliance: IPO (NGO), continued Click to edit Master title style 5. Each IPO will maintain a compliance file which should include a record of all compliance activities: • • Click to edit Master text styles The compliance monitoring plan • Correspondence, meeting minutes, – Second level • Copy of the Pathfinder International Reference Guide on • Third level USG Legislative & Policy Requirements for FP – Fourth level » Fifth level • Notes on orientation sessions, including dates, attendance sheet signed by all participants in the training, and a summary of key points • Copies of presentations and handouts 10/28/2020 Slide #32 and internal memos • Questionnaires and monitoring forms used during field visits • Reports on monitoring visits, including dates, sites visited, and a summary of results • Documentation of any changes recommended and progress on their implementation • Copies of all signed agreements with sub-recipients DECEMBER 2011 32

Ensuring Compliance: IPO (government) Click to edit Master title style 1. All IPO staff

Ensuring Compliance: IPO (government) Click to edit Master title style 1. All IPO staff members have completed a yearly half-day training on Tiahrt and other USG legislative and policy • Click to edit Master text styles requirements using the Pathfinder International Training – Second level Guide on USG Legislative and Policy Requirements for FP. (Pathfinder will conduct this training. ) • Third level 2. Government IPOs should conduct joint monitoring visits – Fourth level with Pathfinder. » Fifth level Note: Government partners at all levels should be briefed about Tiahrt and all USG legislative and policy requirements. Records should be kept on personnel briefed and dates of briefings. 10/28/2020 Slide #33 DECEMBER 2011 33

Ensuring Compliance: IPO (Government) Click to edit Master title style 3. Each IPO will

Ensuring Compliance: IPO (Government) Click to edit Master title style 3. Each IPO will maintain a compliance file which should include a record of all compliance activities: • Click to edit Master text styles – Copy of the Pathfinder International Reference Guide on USG – Second level Legislative and Policy Requirements for FP (translated into local languages where appropriate) • Third level – Questionnaires, checklists, and monitoring tools used during field – Fourth level visits, including the Pathfinder International Monitoring Tools for » Fifth level Compliance with USG Legislative and Policy Requirements FP – Reports on monitoring visits (including dates, sites visited, and a summary of results) – Completed compliance checklists and questionnaires from the Pathfinder International Monitoring Tools for Compliance with USG Legislative and Policy Requirements for FP from field visits 10/28/2020 Slide #34 DECEMBER 2011 34

Ensuring Compliance: Service Delivery Level Click to edit Master title style Documentation and Systems:

Ensuring Compliance: Service Delivery Level Click to edit Master title style Documentation and Systems: The clinic has a copy of the Pathfinder International Reference • 1. Click to edit Master text styles Guide on USG Legislative and Policy Requirements for FP (in the –local language where appropriate) in a folder, with a copy of the Second level attendance sheet demonstrating that each service provider • Third level completed the half-day training. – Fourth level 2. A “Tiahrt poster” or equivalent poster providing comprehensible » Fifth level information on FP methods is displayed on the wall. 3. If the clinic performed voluntary sterilization services, client consent forms were reviewed. 4. A variety of FP methods are available to ensure that the client has a free choice of approved methods. 10/28/2020 Slide #35 DECEMBER 2011 35

Ensuring Compliance: Service Delivery Level (cont’d. ) Click to edit Master title style Documentation

Ensuring Compliance: Service Delivery Level (cont’d. ) Click to edit Master title style Documentation and Systems (cont’d. ): • Where NGO clinics are involved the following apply: Click to edit Master text styles Second level • –Staff contracts were reviewed to ensure that no bonus payments, targets, or quotas were given for attaining number of • Third level total births, numbers of FP acceptors, or numbers of acceptors – Fourth level of a particular FP method. » Fifth level • The NGO clinic funded under the project has agreed (in writing) to comply with the Voluntary Population Policy Provisions. 10/28/2020 Slide #36 DECEMBER 2011 36

Ensuring Compliance: Service Delivery Level (cont’d. ) Click to edit Master title style Service

Ensuring Compliance: Service Delivery Level (cont’d. ) Click to edit Master title style Service Providers: Clinic staff members have completed a yearly half-day training on • 1. Click to edit Master text styles Tiahrt and other USG legislative and policy requirements using the –Pathfinder International Training Guide on USG Legislative and Policy Second level Requirements for FP. • Third level 2. Random interviews with service providers were conducted using the – Fourth level compliance tool to verify that they were giving comprehensible » Fifth level information on the different FP methods, and that clients were not pressured to accept a particular method. Results of these interviews were recorded. 3. Counseling on FP was observed to identify any informed choice issues 4. No “service providers” or “referral agents” are subject to or required to meet targets or quotas. 10/28/2020 Slide #37 DECEMBER 2011 37

Ensuring Compliance: Service Delivery Level (cont’d. ) Click to edit Master title style Service

Ensuring Compliance: Service Delivery Level (cont’d. ) Click to edit Master title style Service Providers (cont’d. ): No program personnel receive bribes, gratuities, incentives, or financial • 5. Click to edit Master text styles rewards in exchange for achieving a quota or target. – Second level 6. Information about the health benefits and risks and known adverse • Third level side effects of the specific FP method being provided is available. – Fourth level 7. All providers are using the “Tiahrt poster” or equivalent informational » Fifth level materials to provide clients with information about the health benefits and risks and known adverse side effects of the specific FP method. 8. No USG funds are being used to fund abortion services or abortion equipment. 9. If experimental contraceptives or drugs are included as part of a scientific study, clients are advised of potential risks and benefits. 10/28/2020 Slide #38 DECEMBER 2011 38

Ensuring Compliance: Service Delivery Level (cont’d. ) Click to edit Master title style Clients:

Ensuring Compliance: Service Delivery Level (cont’d. ) Click to edit Master title style Clients: Random interviews with clients were conducted using the • 1. Click to edit Master text styles questionnaires in this compliance tool to verify that they were given –comprehensible information on the FP method they selected, and Second level were not pressured to accept a particular method. Results were • Third level recorded. – Fourth level 2. Clients are allowed to freely choose their FP method. » Fifth level 3. Clients are given an explanation of the risks and benefits of their chosen methods. 4. No clients receive incentives for accepting an FP method of any kind. 5. No clients are denied rights or benefits as a consequence of not accepting FP. 10/28/2020 Slide #39 DECEMBER 2011 39

Investigation of a Suspected Violation Click to edit Master title style There are 3

Investigation of a Suspected Violation Click to edit Master title style There are 3 things to remember if a violation • of USG policy is suspected: Click to edit Master text styles – Second level • Third level • Inform – Fourth level » Fifth level • Investigate • Correct 10/28/2020 Slide #40 DECEMBER 2011 40

In Case of a Suspected Violation Inform Click to edit Master title style At

In Case of a Suspected Violation Inform Click to edit Master title style At the Pathfinder HQ or country office level If a concern or issue is raised during monitoring: • Click to edit Master text styles 1. Inform the Project Manager – Second level • Third level 2. Project Manager informs Head of Operations (if – Fourth level none exists, then the Country Representative) » Fifth level 3. Country Representative informs Program Director at HQ who informs Program Systems Unit (PSU) Director at HQ 4. PSU Director notifies the Executive Team 10/28/2020 Slide #41 DECEMBER 2011 41

In Case of a Suspected Violation Inform, (cont’d. ) Click to edit Master title

In Case of a Suspected Violation Inform, (cont’d. ) Click to edit Master title style 5. Country office and Executive Team make a joint decision about whether the issue or concern • Click to edit Master text styles –might plausibly constitute a violation of a USG Second level policy or legislative requirement. • Third level 6. – Fourth level » Fifth level If it is determined that a violation may have occurred, the Executive Team will inform the USAID PHN officer or the AOTR immediately about the suspected violation and the project’s plan to investigate the situation. 10/28/2020 Slide #42 DECEMBER 2011 42

In Case of a Suspected Violation Investigate Click to edit Master title style the

In Case of a Suspected Violation Investigate Click to edit Master title style the Country Office Level: • At Click to edit Master text styles • – Second level Conduct a detailed investigation of the suspected violation. • Third level • – Fourth level These basic questions must be addressed: » Fifth level Where? When? Who? How? Why? 10/28/2020 Slide #43 DECEMBER 2011 43

In Case of a Suspected Violation Investigate, (cont’d. ) Click to edit Master title

In Case of a Suspected Violation Investigate, (cont’d. ) Click to edit Master title style • Keep careful records of the investigation and corrective actions taken. • • Click to edit Master text styles Select a point person to track the process of the investigation. • –Examine the credibility/legitimacy of the allegation or report. Conduct Second level interviews with IPO clinic and project staff. • Third level • Determine the magnitude of the problem. Is the problem in more than – Fourth level one location? Investigate widely. » Fifth level • Conduct a detailed review of clinic records and other clinic materials. • If the suspected violation is related to incentives, conduct a community survey of acceptors and of staff who may have received incentives. • Keep Pathfinder Program Director at HQ involved in the ongoing investigation. 10/28/2020 Slide #44 DECEMBER 2011 44

In Case of a Suspected Violation Correct Click to edit Master title style •

In Case of a Suspected Violation Correct Click to edit Master title style • Click to edit Master text styles – Second level • Third level – Fourth level » Fifth level 10/28/2020 Slide #45 DECEMBER 2011 45

In Case of a Suspected Violation Correct, (cont’d. ) Click to edit Master title

In Case of a Suspected Violation Correct, (cont’d. ) Click to edit Master title style • As soon as a potential violation is discovered, take action to correct the problem. • Click to edit Master text styles Second level • –Resolving the situation may require systems • Third level strengthening, training, or changing the IPO’s – Fourth level policies. » Fifth level • A serious violation may require the suspension of funds to the IPO. 10/28/2020 Slide #46 DECEMBER 2011 46

At the IPO Level Click to edit Master title style • Inform the Project

At the IPO Level Click to edit Master title style • Inform the Project Director and Country • Click to edit Master text styles Representative immediately. – Second level • Provide any assistance needed to correct the • Third level situation. – Fourth level » Fifth level 10/28/2020 Slide #47 DECEMBER 2011 47

At the Clinic Level Click to edit Master title style • Inform the IPO

At the Clinic Level Click to edit Master title style • Inform the IPO senior staff. • Click to edit Master text styles – Second level • Inform the Pathfinder country office. • Third level • – Fourth level » Fifth level If necessary, suspend suspected staff until the investigation is completed. 10/28/2020 Slide #48 DECEMBER 2011 48

Pathfinder Monitoring Tools for Compliance Click to edit Master title style The Pathfinder International

Pathfinder Monitoring Tools for Compliance Click to edit Master title style The Pathfinder International Monitoring Tools for • Compliance include: Click to edit Master text styles • –A summary of requirements and checklist of Second level compliance requirements for the field office, IPO, • Third level clinic, clinic service provider, community-based – Fourth level worker, and hospital levels. » Fifth level • Detailed monitoring tools to be used at Pathfinder – supported clinics, with clinic providers, community health workers, sterilization clients, and FP acceptors. 10/28/2020 Slide #49 DECEMBER 2011 49

Click to edit Master title style • Click to edit Master text styles –

Click to edit Master title style • Click to edit Master text styles – Second level • Third level THANK YOU – Fourth level » Fifth level For more information, please email csolter@pathfind. org 10/28/2020 Slide #50 DECEMBER 2011 50