A Look at the Report on the Management of the Ebola Fund

A deeply concerning report was published in the papers last week; it centred on the publication of an audit report of the management of Ebola funds in Sierra Leone. The Audit Service Sierra Leone (ASSL) had published the report about the Ministry of Health and Sanitation (MoHS) and National Ebola Response Centre’s (NERC) management of the Ebola response in respect to three key areas. The Audit Service assessed the methods and procedures of disbursement, procurement, and handling of donations during the period of May to October 2014.

It is very difficult to comprehend the internal situation of the MoHS during the outbreak, and there must have understandably been a huge strain on the facilities and human resources as a whole. With this in mind, this blog post focuses on the Auditor’s publication; while many may posit allegations towards those in charge of the MoHS, the report does not do so. The report has requested that the Ministry supplies all missing documentation within 1 week; at that point, the Auditor’s duty will be to sift through this information and identify which, if any, of the queries raised were of a fraudulent nature, or borne of a public service stretched to the limits.

Unfortunately for the Sierra Leonean government the report has revealed some major concerns, and the scale of potential mismanagement has put this story centre on the global stage. At best, it’s a deficiency in crisis management and adherence to procedure; at worst, it’s wide scale corruption and embezzlement within Sierra Leonean government.

The audit looks at the 84bn Leones (£12m) that the government had for fighting the virus from the start of the outbreak. This pot of money came primarily from domestic institutions and individuals donating from within Sierra Leone as well as from domestic tax revenue. It is important to note that the audit is focussed on internal tax revenue and donations, and not money raised or donated externally.

As you will have gathered from other news items, the report reveals that the MoHS and NERC had not properly accounted for around 25 billion Leones of the allocated funds. To put that figure in to context, 25 billion Leones (£3.7 million) is 1% of total domestic revenue for 2013. It is just under half of the 60 billion Leones spent on the entire country’s police force in 2013, and one fifth of the 125 billion Leone education budget. Make no mistake; this is a huge amount of money in Sierra Leone.

At the beginning of the report, made available here from the ASSL website, the Auditors outline the objectives of the investigation:

“Due to the public emergency the country is facing, following the Ebola outbreak, there is a sudden surge in the inflow of funds specifically for

that purpose from the government and other generous individuals and institutions. In this regard, it is not unusual for Supreme Audit Institutions such as the Audit Service Sierra Leone (ASSL), to carry out audits as and when such funds are being disbursed. Generally, this is to ensure that funds are fully and solely directed to the cause at hand and where there are anomalies, these are promptly dealt with. As such, since the Ministry and the NERC have been in charge of the management of the Ebola Response Funds which are public funds, the ASSL conducted a real time audit.”

“The primary objective of the audit was to ascertain whether public funds allocated to the Ministry and NERC were utilised for their intended purposes in accordance with applicable public financial management rules and regulations. Other secondary objectives were to establish whether:

• Donations received were receipted and banked promptly;
• Correct amount of incentives were paid to the right healthcare workers and on time;
• Expenditures were undertaken with due regard to the law, economy and efficiency, and were supported by sufficient and appropriate documentary evidence;
• Goods and services procured were been done in accordance with the law;
• Value for money was obtained in the procurement contracts awarded; and
• There was interaction between the Ministry and the National Ebola Emergency Centre.”

The report covers the three areas of operations by the Ministry of Health and Sanitation and the National Ebola Response Centre (NERC): disbursement of funds; procurement of services; and the handling of donations. Below I have condensed each item of contention to the query and the amount in order to show the scale of misappropriation.

In the executive summary of the report, the auditor concluded that “There were inadequate controls over the disbursement of funds. In the absence of a well coordinated sensitisation plan to raise awareness on Ebola and its prevention, the auditors observed an overwhelming number of requests from various individuals, Non-Governmental Organisations, parliamentarians etc, for sensitisation activities to be carried out in different parts of the country.

Withholding taxes were not deducted and paid over to the National Revenue Authority from payments to various suppliers and contractors. Several weaknesses were observed in the payment of incentives to healthcare workers. Furthermore, a spot review of incentive payments at the Connaught Hospital revealed that the Republic of Sierra Leone Armed Forces and the Sierra Leone Police security personnel were included on the list of workers to receive hazard payment even though funds had been transferred to both forces to meet the deployment of their officers.

Procurement procedures were not followed for a number of contracts undertaken by the Ministry. There was a complete disregard for the law on public procurement in an emergency situation. For instance, contracts were entered into without any clear guidelines on the specification of items required. Furthermore, contracts were badly drawn up as if to allow for additional costs to be incurred thereby preventing a transparent, competitive and cost effective procurement. The Ministry failed to produce any documentation for contract agreements that amounted to Le17billion.

A review of the donations register and bank statements of the Health Emergency Response Account held at the Sierra Leone Commercial Bank revealed that a number of donations totalled at Le1,670,000,000 were returned dishonoured.”

A précis of the risks mentioned in the report reveals the following concerns raised by the Auditor: “Monies set aside for the purpose of combatting the Ebola outbreak may have been used for unintended purposes, thereby slowing the government’s response to eradicating the virus,” whilst the “possible mismanagement of the procurement process creates a leeway for the wastage of limited resources. It ignores value for money and increases the likelihood of inappropriate service delivery.” These procedures “create the avenue for individuals to exploit the limited resources meant for the fight against the epidemic, thereby hindering the early response to the outbreak.”

It will be very interesting to read how this report progresses, and whether there are any serious allegations of fraud made by the Auditor. Whilst the Audit Service Sierra Leone is responsible for auditing public accounts, it does not hold any enforcement powers over those involved.[1] It will be down to those within government to decide upon the fate of those proved to be involved in the misappropriation, misallocation, and misuse of funds.

The Audit service notes it’s efficacy in the introduction of the report, and re-iterates its previous delings with the Ministry of Health and Sanitation. It writes: The Ministry of Health and Sanitation being one of the key ministries with a large share of the National Expenditure Budget, has been classified as a priority audit for the Audit Service Sierra Leone. Over the years, we have identified a number of weaknesses and made an equal number of recommendations to improve service delivery by the Ministry. For instance, for the financial years 2010 to 2012 inclusive, we made a total of 76 recommendations to the Ministry, but only 26 (i.e 34%) were implemented.

As the documentary evidence is due to be returned to the ASSL on Monday 23rd February, we will wait to see how the investigation progresses and what steps are taken to resolve the key issues.

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For those of you who are interested in understanding the key queries that the ASSL made against the Ministry of Health and Sanitation and the National Ebola Response Centre, I have condensed the report in to the following bullet points, and included the total queried value in both payment currency and Pound Sterling for reference.

If you would like to view the report yourself, it can be found at this link.

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The queries over disbursements made by the Ministry of Health and Sanitation are:

1. Withdrawals from Ebola Operations and Miscellaneous accounts without supporting documents (Le16,269,066,620 / £2,412,339);
2. Payments from the Ebola Operations accounts without supporting documents (Le12,265,769,650 / £1,818,739);
3. Loan to the Health for All Coalition made in the director’s name, rather than the organisation’s, and without any loan agreement or proof of repayment (Le7,827,000,000 / £1,160,514);
4. Duplication of Ebola Sensitisation payment to MP for Constituency 93 (Le110,640,000 / £16,404);
5. Payments for Radio and Television Ebola sensitisation made through the Ministry ICT Director rather than the service providers (Le171,360,000 / £25,408);
6. Not withholding the 5% tax for the National Revenue Agency, nor paying across the amounts (Le525,721,555.36 and US$ 70,500 / £123,739);
7. Not providing adequate supporting documents for the Hazard Payment incentives to casual/volunteer workers (Le25,500,900,000.00 / £3,781,213.31);
8. Overstatement of Hazard Pay and inconsistencies in serial numbers of recipients in the Bombali District (Le216,800,000 / £32,146.59);
9. Hazard Payments made to unauthorised recipients at the Connaught Hospital (Le 251,000,000 / £ 37,217.69); and
10. Disparity between accounted surplus of Hazard Pay allocation and the money which was returned to the Ministry by Rokupa Government Hospital (Le 1,800,000 / £ 266.900).

The queries over procurement practices by the Ministry of Health and Sanitation are:

1. Procurement documents such as signed contracts, test and examination report on delivery, procurement committee minutes, bidders documents, building plan etc. were not submitted for four contracts including: the construction of Port Loko Treatment and Isolation centre by the CL Group; purchase of 50 ambulances from Premier Logistics & Supplies; supply of chlorine powder from Amjam Company Limited, and the electrical works at Kenema Hospital by Echo Construction Enterprise. (Le 16,746,197,620 / £ 2,483,087);
2. Payments to the Ministry of Health and Sanitation for the construction of Lakka Government Hospital made through the wrong account were not justified, and the construction process was not accompanied by progress reports nor expenditure returns including invoices and receipts. (Le1,225,685,300 / £ 181,742);
3. Multiple issues in procurement of construction services the from CL Group for Kerry Town treatment centre, including missing records and reports, contractual errors, unverified performance incentives, early disbursement of contingency fee and several others. (Le1,760,000,000 / £260,968.65);
4. As above, the procurement of twenty ambulances from Kingdom Security Logistics was riddled with missing minutes, reports, unverified advanced payments, and a lack of inspections and test upon delivery of the vehicles. (US$1,050,000 / £681,928.88);
5. Again, the procurement process of thirty used vehicles from Royal International Supplies revealed several short fallings including a lack of minutes, invoices, and purchase orders. The vehicles were also not specified as to vehicle make, model, year of manufacture; this lack of information also suggests that there was no knowledge as to the road worthiness of the vehicles. (Le1,350,000,000 / £200,175);
6. The procurement of 10 ambulances, 5 Toyota Hilux, 1 Toyota Landcruiser, and 48 Motorbikes from Ramesco General Supplies was not accompanied by appropriate minutes and reports of procurement meetings, nor procurement documents relating to the bidding process or specifications of services and goods. Nor were there any accompanied due diligence documents on the supplier company. (US$1,031,000 / £669,589); and
7. The procurement for the supply of medical supplies from Ramesco General Supplies was, again, missing vital records. Aside from the same lack of competition evidence as above, the performance bond clause from the contract was not available for audit inspection. (US$6,465,424 / £4,199,009).

The query over the handling of donations by the Ministry of Health and Sanitation are as follows:

1. Cheque donations not honoured by the Sierra Leone commercial bank; cheques totalling over Le50 million exceed the limit handled by the bank and were therefore dishonoured. The auditors managed to track over Le1.5 billion from donors and return it to the Health Emergency Response Accounts.

The queries over the Disbursements made by the NERC are:

1. Payments from the Ebola Emergency Operations Account were made without adequate supporting documents, such as: expenditure returns, invoices, receipts etc. (Le7,252,309,452 and USD$ 6,183.53 / £1,079,371);
2. The Ministry failed in its obligation to withhold 5% tax for payments made to various suppliers (Le72,891,142 / £10,808); and
3. Owing to the vagueness of contractual agreement for the procurement of 20 ambulances, an extra US$48,000 was paid as air freight charges over the pre-agreed and paid amount of US$360,000. In addition, the amounts of Le39,330,000 and US$12,590 were paid to the IPC Travel Agency and Mr. Kawasu Kebbay of the MoFED respectively for air ticket and daily subsistence for 21 days. A review of the travel itinerary revealed that Mr. Kebbay spent only 8 days on this assignment and has not provided evidence of the return of US$7,546.50 for the daily subsistence allowance. (US$60,590 and Le39,330,000 / £45,182).

The query over the procurement procedures of the NERC follows:

1. The NERC did not follow procurement practices in the sourcing of food supplies to quarantined homes, and only solicited one supplier despite the provision of a prequalified list of existing suppliers. In addition, the procurement of furniture, cleaning materials, and a generator for the Ebola Treatment Centre at the Police Training School did not include a technical valuation or pre-signed contract before delivery. (Le1,349,889,500 / £200,158).

[1] https://freedomhouse.org/report/countries-crossroads/2012/sierra-leone#.VOntzFOsW4Q