The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) Integrated Safeguards Data Sheet Appraisal Stage Appraisal Stage | Date ISDS Prepared/Updated: 16-May-2018| Report No: ISDSA24885 Regional Vice President: Victoria Kwakwa Country Director: Rodrigo A. Chaves Senior Global Practice Director: Ede Jorge Ijjasz-Vasquez Practice Manager/Manager: Nina Bhatt Task Team Leader: Dewi Susanti The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) Note to Task Teams: The following sections are system generated and can only be edited online in the Portal. . I. BASIC INFORMATION 1. BASIC PROJECT DATA Project ID Project Name INDONESIA: IMPROVING TEACHER PERFORMANCE AND P167216 ACCOUNTABILITY (KIAT Guru) Phase 2 Task Team Leader(s) Country Dewi Susanti Indonesia Approval Date Environmental Category 25-Feb-2019 B-Partial Assessment Managing Unit Is this a Repeater project? GSU21 No PROJECT FINANCING DATA (US$, Millions) SUMMARY -NewFin1 Total Project Cost 1.35 Total Financing 1.35 Financing Gap 0.00 DETAILS -NewFinEnh1 Non-World Bank Group Financing Trust Funds 1.35 Indonesia - Program for Community Empowerment 1.35 2. PROJECT DEVELOPMENT OBJECTIVE Project Development Objective The Project Development Objective (PDO) is to improve teacher presence and teacher service performance in pilot . schools. The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) Note to Task Teams: End of system generated content, document is editable from here. 3. PROJECT DESCRIPTION A key principle to the intervention design of KIAT Guru Phase 2 (KGP2) is the scalability of the mechanism for government-led nation-wide policy implementation. KIAT Guru Phase 1 (KGP1) Impact Evaluation (IE), qualitative research, and process monitoring attributed the success of the interventions to four key elements: (a) actively engaging external stakeholders in monitoring and evaluating teacher performance; (b) increasing parental involvement in learning; (c) keeping teacher performance evaluation to a few simple and objective indicators; and (d) paying teacher allowance based on objective performance indicator (Gaduh et al, forthcoming). This finding is in line with international evidence, including in Indonesia, which show that making teachers accountable to different groups of education stakeholders, as opposed to solely being accountable to higher level supervisors within the education system, can be effective in improving education service delivery (Pradhan et al, 2014; Brinkerhoff & Wetterberg, 2013; Joshi, 2013; Barr et al, 2012; Ringold et al, 2012; WB, 2004). In addition, KGP1 is also in line with key recommendations from the World Development Report (WDR) 2018, which identifies the use of both pecuniary and nonpecuniary incentives to improve teachers’ motivations and align teaching with learning to improve student learning outcomes. These findings were also shared in “Growing Smarter,� the World Bank EAP Education Flagship Report (WB, 2018). While GoI is encouraged by KGP1 results in improving learning outcomes, it seeks to test several improvements for government-led scalability through KGP2. These improvements include refinements to improve the simplicity, sustainability, and scalability of the KGP1 design. KGP1 was implemented by an NGO and involved a long process of Community Empowerment Mechanism (CEM) led by NGO facilitators. In addition, the Pay for Performance Mechanism (PPM) created an administrative burden for government officials. The section below will present first the proposed support for GoI to sustain implementation in KGP1 schools and convert them to Group 2 intervention, and second the rationale and intervention design for the KGP2. The first part of the project will convert all 203 intervention schools to Group 2. Through the KGP1, which will end in March 2019, Yayasan BaKTI as the Grant Recipient provides TA for the GoI to revise the Ministerial and Head of District regulations, decrees, and technical guidelines so that the payment of TKG can be tied with teacher presence. The Grant Recipient also prepares capacity development training modules for the schools’ stakeholders, which will be disseminated through government-funded socialization events at the district and village levels. Key stakeholders from 68 KGP1 Group 2 schools will be selected to provide peer-to-peer mentoring and supports for neighboring 135 KGP1 Group 1 and Group 3 schools in the process of converting the interventions. Key stakeholders from all KGP1 schools will be selected to provide further peer-to-peer mentoring and supports for the expansion to 183 new schools. The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) International evidence shows that interventions found to be successful at a smaller scale and implemented by NGO pilots could not be sustained when later adopted by the government (Bold et al, 2018; Banerjee et al, 2017; Banerjee, Glennester & Duflo, 2008; Banerjee & Duflo, 2006; Duflo et al, 2012). Two reasons are often put forward. First, government workers face a different set of incentives and operational budgets compared to those working for NGO’s. This led to weaker implementation arrangements. Second, over a longer period of time, the stakeholders’ behavior may change, and they may learn how to work the system, the initial effectiveness of the interventions became muted. In the case of KIAT Guru, parents and community members may lose interest in the monthly teacher-evaluation meetings or reduce their efforts to support learning at home. Teachers could realize, perhaps, that they could use a portion of their allowance to incentivize parents and community members to provide good scores. In other words, the stakeholders will likely adjust their behaviors over time. While little evidence exists on how to scale up successful education pilots, a few related literatures offers important lessons. As a pilot expands its scope, it is very important to continue evaluating the key mechanism behind the successful intervention and identify and implement more cost-effective variations that can be applied by the government staff who will scale the intervention. Initial support by external actors will likely be needed, but by design, this should be reduced over time, while continuing to monitor for administrative, institutional, and political challenges (Kerwin & Thornton, 2018; Banerjee et al, 2017; Muralidharan, 2017). KGP1 IE provided proof of concept for the efficacy of the intervention. GoI support for the implementation expansion in five districts provides a rare opportunity to identify more cost-effective implementation strategies. The KGP1 CEM consisted of three phases. The initial phase consisted of eight meetings to produce a bottom-up Service Agreement (SA) between teachers and User Committee1 (UC) and a Community Score Card (CSC), with five to eight service indicators for teachers to deliver, including teacher presence. In the implementation phase, the stakeholders reviewed the implementation of SA and the UC evaluated each teacher’s CSC monthly. During evaluation phase, at the end of every semester, a village-wide meeting was held to evaluate the SA, CSC, and the membership of the UC. A few stakeholders at the village level were trained to administer an adaptive Diagnostic Student Learning Assessment (Diagnostic SLA). Results of the Diagnostic SLA were shared during the evaluation meeting, to better informed the stakeholders on learning outcomes. For more details on the KGP1 CEM, see Annex 2 of Integrated PCN and Project Paper. The initial set up phase of KGP1 was led by NGO facilitators, each covered between five to six villages. In each village the NGO facilitators trained and provided a Village Cadre with on-the-job mentoring. Over time, during implementation phase, the Village Cadres took over the role of the NGO facilitators, and by end 2017, the NGO facilitators were discharged. There was clearly a lot of 1 The UC consists of a minimum of 9 elected members, 3 community or religious leaders, and 6 parents from each grade level. At least half of the UC members should be female The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) hand-holding in KGP1 that would be difficult to scale up through a government-led expansion. Therefore, the second part of the KGP2 proposes to test two mechanisms for government-led implementation expansion to new schools: with and without project facilitators. As KGP2 will focus the PPM on teacher presence (in line with Group 2 of KGP1), various aspects of KGP1 implementation can be streamlined. The development of SA can be simplified by providing the stakeholders with a consolidated list of KGP1 indicators that have been analyzed as the most effective in improving learning outcomes. For each stakeholder, only three indicators will be agreed upon. To optimize government-led expansion, we propose two CEM mechanisms for KGP2 (Group A and Group B). The first mechanism, KGP2 Group A, will initially be implemented by NGO facilitator, and later handed over to village stakeholders. The NGO facilitator will identify in each village three village cadres who will be trained along with representatives from village government, school, parents, and community members. However, the NGO facilitator’s visits to the village will be limited to a maximum of four visits (instead of an average of 14 visits during the KGP1), with each covering seven villages (instead of five villages during the KGP1). The NGO facilitators will set up the UC, membership to which will now include the School Committee to formally link the UC with school governance. Three Village Cadres (instead of one during KGP1) will be trained to reduce the risk of personnel turnover and improve sustainability of capacity building and peer-to-peer supports. Like in KGP1, the UC will be established by a Village Head decree and its institutional arrangement will be under the village government (instead of with the school governance), who will provide supports and funding. KGP2 Group A aims at maintaining the key elements of KGP1, particularly on engaging external stakeholders in monitoring and evaluating teacher performance and increasing parental involvement in learning. In this mechanism, the Diagnostic SLA that was implemented as part of the KGP1 will be digitized into the upgraded KIAT App. Similar to KGP1, the Village Cadres will be trained to administer the Diagnostic SLA and share results with the stakeholders, this time at the beginning of the meeting where they will select the SA indicators, and also prior to the semi-annual evaluation meeting. Meanwhile, KGP2 Group B will not be implemented by an NGO facilitator. Rather, the government will identify which of the consolidated list of KGP1 SA indicators should be adopted by the school’s stakeholders. The district government will conduct socialization meetings, inviting school principals and village heads. The latter will lead socialization at the school level and revitalize the School Committee (SC), in line with the MoEC Ministerial Regulation 75/ 2016. The selection criteria for the SC was influenced by KGP1 UC. The role and responsibilities of the KGP2 Revitalized SC will be expanded to include the roles of the KGP1 UC. Unlike in the KGP1, the KGP2 Revitalized SC will be established by the School Principal Decree and its institutional arrangement will be under the school governance. KGP2 Group B therefore represents a more classical top-down government decision making and implementation approach that can be implemented strictly under the education system. This intervention group will be the easiest for a national scale-up since it involves an implementation mechanism that is highly standardized. To enforce engagement of external stakeholders, the results The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) of monthly evaluation and teacher presence verification will still need to be signed off by the Village Head and the School Committee Chair, before TKG based on teacher presence can be disbursed. Unlike KGP1 and KGP2 Group A, the KGP2 Group B will not include the Diagnostic SLA nor the semi- annual evaluation meeting. The two proposed KGP2 mechanisms may bring some valid concerns on the scalability of Group A, and on the effectiveness of Group B. The use of NGO facilitator for KGP2 Group A may bring up a question of scalability through government-led intervention. Lessons learned from implementation of Village Law in Indonesia indicates various challenges for government-managed community development facilitators. To address this issue, some community-driven and participatory development projects test mechanisms to engage with the private sector and NGOs. A recent Presidential Regulation 16/ 2018 enables the procurement of NGOs to conduct services for government works. Should KGP2 Group A find stronger impacts, this regulation allows government- led expansion with the support of NGO. On the other hand, the top-down mechanism of Group B may not be effective enough to engage external stakeholders in improving learning. Group B mirrors a typical pay-for-performance scheme that have been implemented in other developing countries and found to improve student learning outcomes (Barrera-Osoria & Raju, 2017; Duflo et al, 2012; Muralidharan, 2012; Muralidharan & Sundararaman, 2011; Glewwe et al, 2010). However, a purely top-down version may not be as effective as participatory decision making (Barr et al, 2012; Brinkerhoff & Wetterberg, 2013; Joshi, 2013; WB, 2004). Together, these studies raise an important question on how government-led education service delivery improvement can be made more participatory and effective. To this end, and different from previous studies, KGP2 Group B design inserts a required social accountability mechanism, where Village Head and School Committee Chair sign off on teacher presence records which became the basis of payment for the teacher’s TKG. Table. Comparison of CEM for KGP1, KGP2 Group A and KGP2 Group B KGP1 CEM KGP2 Group A KGP2 Group B with Facilitator CEM with Facilitator in CEM without key meetings (*) Facilitator Implemented NGO facilitators (14 NGO facilitators School principal by meetings), hand over to (maximum of 3 meetings), Village Cadre hand over to 3 Village Cadres Initial Phase Village socialization Village socialization* School socialization Meetings Three meetings (children, - - parents, teachers) The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) KGP1 CEM KGP2 Group A KGP2 Group B with Facilitator CEM with Facilitator in CEM without key meetings (*) Facilitator Service Agreement (bottom Service Agreement* Service Agreement up indicators) (selection of a (top down) consolidated list, informed by Diagnostic SLA) Setting up of User Setting up of User Revitalizing School Committee Committee* Committee Community score card - - evaluation matrix Implementation Monthly meeting to discuss Monthly meeting to Monthly meeting to SA and evaluate CSC discuss SA and evaluate discuss SA and CSC (with facilitator one evaluate CSC time only*) Evaluation Semi-annual meeting Semi-annual meeting - (informed by Diagnostic (informed by Diagnostic SLA) SLA) It should be noted that while all teachers in KGP2 Group A and Group B schools will be affected by the interventions, the TKG based on presence will only affect TKG-receiving teachers. Technical workshops will be conducted with MoEC to determine whether the formula for TKG based on presence need to be changed. During KGP1, the formula was developed based on government regulation for civil servants (Perka BKN 12/ 2016). Evaluation is based on a full day presence (no allowance cut), partial presence (cut by up to 1.5% daily), excused leaves (cut by 2%), and unexcused absences (cut by 5%). Teachers whose presence fall below 85% in a month do not receive their TKG at all. The project will support government-led implementation of the two intervention groups in 183 primary schools. In addition, the RETF will upgrade the KIAT App and MIS, with implementation support from the Bank’s Task Team. The upgrade aims to digitize the m onthly administration of teachers’ CSC scores and verify teacher presence, with all school-level clearance by principal and village-level approvals by the Village Head and UC/ SC to be completed through the KIAT App. The App will include a digitized version of the Diagnostic SLA for the Village Cadres and UCs in Group A to administer to randomly selected students. The upgraded MIS will compile village-level inputs from KIAT App and aggregate them at the district level, with web-based and phone-based dashboards for schools and district and national level governments to monitor progress, process TKG payment based on verified teacher presence, and analyze trends over time. The App will also provide a prognosis to inform TKG-recipient teachers of the amount of TKG due to them every month, based The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) on their verified attendance. Both the KIAT App and MIS will also integrate the complaint handling and redress mechanism, whereby school- and village-level stakeholders can register their complaints through the KIAT App and monitor the progress directly, while the MIS system will compile and manage the handling of the complaints, with automatic notifications to a higher-level government staff if the complaints are not resolved according to agreed procedure. Note to Task Teams: The following sections are system generated and can only be edited online in the Portal. . 4. PROJECT LOCATION AND SALIENT PHYSICAL CHARACTERISTICS RELEVANT TO THE SAFEGUARD ANALYSIS (IF KNOWN) The project covers up to the existing 203 primary schools under KGP1 and additional 183 schools as part of project expansion. The project will be implemented in the same five districts where KGP1 is currently being implemented, i.e. Sintang, Ketapang and Landak in West Kalimantan Province and Manggarai Barat and Manggarai Timur in Nusa Tenggara Timur. This project is part of a Technical Assistance (TA) provided to the MoEC and five districts. The project will not finance any physical investments, population displacement or land acquisition. All TA activities, recommendations and advice provided through the support from this project are not expected to generate environmental and social implications. 5. ENVIRONMENTAL AND SOCIAL SAFEGUARDS SPECIALISTS ON THE TEAM Vivianti Rambe, Environmental Specialist Krisnan Pitradjaja Isomartana, Environmental Specialist Fajar Argo Djati, Social Specialist SAFEGUARD_TABLE 6. SAFEGUARD POLICIES TRIGGERED Safeguard Policies Triggered Explanation The project is categorized as Category B and triggers OP 4.01 due to the triggering of the World Bank OP 4.10 on Indigenous Peoples. The project will not finance any civil works and instead focuses on providing Technical Assistance Environmental Assessment OP/BP 4.01 Yes (TA) for MoEC on the project scope expansion, training modules and capacity enhancement programs for school stakeholders as well as KIAT app and Management Information System (MIS) upgrades. The TA made available by the project is designed to provide the GoI with evidence-based The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) inputs on intervention designs, along with the tools to assess teacher performance and the mechanisms to do so within the school and government existing systems. Based on the World Bank Interim Guidelines on the Application of Safeguard Policies to Technical Assistance (TA) Activities in Bank-Financed Projects and Trust Funds Administered by the Bank January 2014, this is grouped as Type 1 (Building/ Strengthening Client Capacity). No standalone safeguard assessments nor development of safeguards instruments will be required under the project. However, some efforts to ensure meaningful engagement with parents and community representatives, accessible information for all including IPs, improvement in complaint handling and consultation will be undertaken through TORs review and regular project reports prior to and during implementation. Natural Habitats OP/BP 4.04 No Forests OP/BP 4.36 No Pest Management OP 4.09 No Physical Cultural Resources OP/BP 4.11 No The project covers up to the existing 203 primary schools under KGP1 and additional 183 schools as part of project expansion. The project will be implemented in the same five districts where KGP1 is currently being implemented. Since the target schools are often located in very remote areas, there is anticipated presence of communities with Indigenous Peoples’ criteria as per-OP 4.10. No adverse impacts on these communities are Indigenous Peoples OP/BP 4.10 Yes envisaged since the project is designed to enable community involvement in improving student learning and fostering teacher accountability. OP 4.10 is triggered due to understanding that the project will be implemented in areas where there is presence of Indigenous Peoples. The TA team/ project staff at Yayasan BaKTI will advocate to the national and district governments The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) such that regulations issued for the project will institute free, prior and informed consultations with stakeholders in project locations. In addition, Yayasan BaKTI will provide technical support and capacity development for district government officials so they can provide oversight to the target schools so meaningful engagement based on free, prior and informed consultations with parents and community representatives can be incorporated prior to and during project implementation. The project’s communication and engagement strategy will develop measures to ensure that information about the project is accessible for all, including Indigenous Peoples who may present different needs with regards to access to information and engagement approaches. The project’s Complaint Handling System (CHS) will also be enhanced to ensure accessibility of the system to these communities. Project progress reports submitted to the WB will provide explanation of how such engagement has been implemented, including constraints and remedial measures that will need to be addressed during project implementation by the target schools with support from the Grant Recipient. Involuntary Resettlement OP/BP 4.12 No Safety of Dams OP/BP 4.37 No Projects on International Waterways No OP/BP 7.50 Projects in Disputed Areas OP/BP 7.60 No KEY_POLICY_TABLE II. KEY SAFEGUARD POLICY ISSUES AND THEIR MANAGEMENT A. SUMMARY OF KEY SAFEGUARD ISSUES 1. Describe any safeguard issues and impacts associated with the Restructured project. Identify and describe any potential large scale, significant and/or irreversible impacts. In conjunction with the advice provided by RSA/ ESSA on April 19th, 2018, and reconfirmed on January 23rd, 2019, the project scope is assessed as a Category B due to the triggering of OP 4.10. The project will not finance any physical investments, nor cause physical displacement and livelihood impacts due to land acquisition and/ or access The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) restrictions. All TA activities, recommendations and advice provided through the support from KIAT Guru Phase 2 (KGP2) are not envisaged to generate environmentally and socially adverse impacts. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area. Taking stock of the lessons-learnt from KIAT Guru Phase 1 (KGP1), potential social risks are anticipated to be associated with: (a) complaints around teacher allowance payments (and deduction due to lack of attendance), (b) lack of stakeholders’ buy-in and understanding of the project’s objectives, (c) human resource constraints to ensure oversight, and (d) communication gaps between parents (through user committees or school committees) and teachers and principals (service providers) in deciding performance scores, which occasionally resulted in disputes. 3. Describe any potential alternatives (if relevant) considered to help avoid or minimize adverse impacts. The KGP2 will simplify information provided on the project's objectives during socialization meetings to be attended by representatives of the project's stakeholders, and made the information available in hard copies and through web- based knowledge hub for reference. In addition, KGP2 will improve its Management Information System (MIS) along with mobile-phone application (App) to provide teachers with prognosis of teacher allowance amount on a monthly basis, embed the Complaint Handling System (CHS) and enable two-way communications through the MIS and App. During KGP1, disputes on the teacher performance scores provided were caused by indicators that were not clearly defined, and as such, resulting in subjective interpretations. During KGP2, the indicators will be defined by the project, to ensure that they are measurable, and the stakeholders will be provided with guidelines on how the indicators should be evaluated, with the hope of reducing multiple interpretations. 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. The World Bank’s Safeguards Specialists will review the Project Operation Manuals (POM) and Terms of References (TORs) to ensure that proposed procedures and institutional capacities are adequate to address potential environmental and social safeguards risks and adhere to the World Bank’s safeguards policies. Prior to project implementation, Yayasan BaKTI will provide training to project staff and facilitators on relevant procedures to implement applicable World Bank’s safeguards, including free, prior and informed consultations, child protection, and Occupational, Health and Safety (OHS) where applicable. 5. Identify the key stakeholders and describe the mechanism for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The project will be implemented in the same five districts where KGP1 is currently being implemented, covering the existing 203 primary schools under KGP1 and additional 183 schools as part of project expansion. Key stakeholders include village governments, principals, teachers, parents, students, and community members surrounding these schools. Since the target schools are often located in very remote areas, there is an anticipated presence of communities with Indigenous Peoples’ criteria as per-OP 4.10. No adverse impacts on these communities are envisaged since the project is designed to enable community involvement in improving student learning and fostering teacher accountability. OP 4.10 is triggered due to understanding that the project will be implemented in areas where there is presence of Indigenous Peoples. The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) The TA team/ project staff at Yayasan BaKTI will advocate to the national and district governments such that regulations issued for the project will institute free, prior and informed consultations with stakeholders in project locations. In addition, Yayasan BaKTI will provide technical support and capacity development for district government officials so they can provide oversight to the target schools so meaningful engagement based on free, prior and informed consultations with parents and community representatives can be incorporated prior to and during project implementation. The project’s Complaint Handling System (CHS) will also be enhanced to ensure accessibility of the system to these communities. Project progress reports submitted to the WB will provide explanation of how such engagement has been implemented, including constraints and remedial measures that will need to be addressed during project implementation by the target schools with support from the Grant Recipient. DISCLOSURE_TABLE B. DISCLOSURE REQUIREMENTS ENV_TABLE Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank Date of submission for disclosure For Category ‘A’ projects, date of distributing the Executive Summary of the EA to the Executive Directors “In country� Disclosure INDIG ENOUS_TA BLE Indigenous Peoples Development Plan/Framework Date of receipt by the Bank Date of submission for disclosure “In country� Disclosure COMPLIANCE_TABLE C. COMPLIANCE MONITORING INDICATORS AT THE CORPORATE LEVEL EA_TABLE OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) report? NA IP_TABLE The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) OP/BP 4.10 - Indigenous Peoples Has a separate Indigenous Peoples Plan/Planning Framework (as appropriate) NA been prepared in consultation with affected Indigenous Peoples? PDI_TABLE The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the World Bank for NA disclosure? Have relevant documents been disclosed in-country in a public place in a form and language that are understandable and accessible to project-affected groups NA and local NGOs? ALL_TABLE All Safeguard Policies Have satisfactory calendar, budget and clear institutional responsibilities been NA prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included in the project NA cost? Does the Monitoring and Evaluation system of the project include the monitoring NA of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed with the borrower NA and the same been adequately reflected in the project legal documents? III. APPROVALS Dewi Susanti Task Team Leader(s) Javier Luque Approved By Safeguards Advisor Practice Manager/Manager Nina Bhatt 11-Feb-2019 . The World Bank Appraisal ISDS INDONESIA: IMPROVING TEACHER PERFORMANCE AND ACCOUNTABILITY (KIAT Guru) Phase 2 (P167216) Note to Task Teams: End of system generated content