Document of The World Bank FOR OFFICIAL USE ONLY Report No: PAD957 INTERNATIONAL DEVELOPMENT ASSOCIATION PROJECT APPRAISAL DOCUMENT ON A PROPOSED CREDIT IN THE AMOUNT OF SDR 202.4 MILLION (US$300 MILLION EQUIVALENT) TO THE PEOPLE’S REPUBLIC OF BANGLADESH FOR AN INCOME SUPPORT PROGRAM FOR THE POOREST PROJECT November 17, 2014 Social Protection and Labor Global Practice Bangladesh, Bhutan, Nepal Country Management Unit South Asia Region This document is being made publicly available prior to Board consideration. This does not imply a presumed outcome. This document may be updated following Board consideration and the updated document will be made publicly available in accordance with the Bank’s policy on Access to Information. CURRENCY EQUIVALENTS (Exchange Rate Effective October 30, 2014 Currency Unit = Bangladesh Taka (BDT) BDT 77.43 = US$1 US$1.48 = SDR 1 FISCAL YEAR July 1 – June 30 ABBREVIATIONS AND ACRONYMS ANC Antenatal care M&E Monitoring and Evaluation BBS Bangladesh Bureau of Statistics MDTF Multi Donor Trust Fund BDHS Bangladesh Demography and MIS Management Information System Health Survey BDT Bangladeshi Taka MoHFW Ministry of Health and Family Welfare BPD Bangladesh Poverty Database MoLGRD&C Ministry of Local Government, Rural Development & Cooperatives BPO Bangladesh Post Office MoPTIT Ministry of Posts, Telecommunications, and Information Technology CAG Comptroller & Auditor General MOU Memorandum of Understanding CAS Country Assistance Strategy NGO Non-Governmental Organization CC City Corporation NID National Identification CCT Conditional Cash Transfer NSPS National Social Protection Strategy CNCD Child Nutrition & Cognitive PCC Postal Cash Card Development DC Deputy Commissioner PD Project Director DDLG Deputy Director, Local PDO Project Development Objective Government DFID Department for International PIU Project Implementation Unit Development DGHS Directorate General of Health PMT Proxy Means Test Services DHIS District Health Information PMU Project Management Unit System DP Development Partners POS Point of Sales DPD Deputy Project Director PSC Project Steering Committee EGPP Employment Generation PSC Poverty Score Card Program for the Poorest FAPAD Foreign Aided Project Audit PSM Propensity Score Matching Directorate FFW Food For Work RSO Regional Statistics Officer ii FY Fiscal Year RSR Rapid Social Response G2P Government to Person SAFANSI South Asia food and Nutrition Security Initiative GAAP Governance & Accountability SFYP Sixth Five Year Plan Action Plan GDP Gross Domestic Product SID Statistics & Informatics Division GoB Government of Bangladesh SNC Safety Net Beneficiary Cell GR Gratuitous Relief SNSP Safety Net Systems for the Poorest GRO Grievance Redress Officer SPA Safety Net Program Assistant IBRD International Bank for SSN Social Safety Net Reconstruction and Development ICB International Competitive UHFWC United Health and Family Welfare Bidding Centres IDA International Development UNDB United Nations Development Association Business IE Impact Evaluation UNDP United Nations Development Programme IFPRI International Food Policy UNO Upazila Nirbahi Officer Research Institute IMF International Monetary Fund UP Union Parishad IPF Investment Project Financing USD United States Dollar IT Information Technology VGF Vulnerable Group Feeding KAP Knowledge, Attitude and WHO World Health Organization Practice KYC Know Your Customer LGD Local Government Division Regional Vice President: Philippe H. Le Houerou Country Director: Johannes C. M. Zutt Senior Global Practice Director: Arup Banerji Practice Manager: Pablo Gottret Task Team Leader: Iffath Sharif Co-Task Team Leader: Iftikhar Malik iii BANGLADESH Income Support Program for the Poorest Project TABLE OF CONTENTS Page I. STRATEGIC CONTEXT .................................................................................................1 A. Country Context ............................................................................................................ 1 B. Sectoral and Institutional Context................................................................................. 2 C. Higher Level Objectives to which the Project Contributes .......................................... 6 II. PROJECT DEVELOPMENT OBJECTIVES ................................................................7 A. PDO............................................................................................................................... 7 B. Project Beneficiaries ..................................................................................................... 7 C. PDO Indicators.............................................................................................................. 7 III. Project Description ............................................................................................................7 A. Project Components ...................................................................................................... 7 B. Project Financing ........................................................................................................ 10 C. Project Cost and Financing ......................................................................................... 10 D. Lessons Learned and Reflected in the Project Design ................................................ 11 IV. IMPLEMENTATION .....................................................................................................12 A. Institutional and Implementation Arrangements ........................................................ 12 B. Results Monitoring and Evaluation ............................................................................ 13 C. Sustainability............................................................................................................... 14 V. KEY RISKS AND MITIGATION MEASURES ..........................................................14 A. Risk Ratings Summary Table ..................................................................................... 14 B. Overall Risk Rating Explanation ................................................................................ 15 VI. APPRAISAL SUMMARY ..............................................................................................15 A. Economic and Financial Analysis ............................................................................... 15 B. Technical ..................................................................................................................... 16 C. Financial Management ................................................................................................ 16 D. Procurement ................................................................................................................ 17 E. Social (including Safeguards) ..................................................................................... 17 iv Annex 1: Results Framework and Monitoring .........................................................................18 Annex 2: Detailed Project Description .......................................................................................23 Annex 3: Implementation Arrangements ..................................................................................36 Annex 5: Implementation Support Plan ....................................................................................59 Annex 6: Economic and Financial Analysis ..............................................................................62 Annex 7: Governance Accountability and Action Plan ............................................................69 Annex 8: Proposed Impact Evaluation Design..........................................................................74 Annex 9: Proposed Project Locations ........................................................................................79 List of Figures Figure 1: FY13 Social Protection Expenditure (Crore BDT) Figure A2.1: Timing of the Human Brain Development Figure A3.1: Implementation arrangements Figure A3.2: Registration & enrolment process Figure A3.3: Compliance & Payment Fund Flow Figure A6.1: PMT and Per Capita Consumption List of Tables Table 1: Nutrition indicators by Wealth groups Table 2: Eligible Payments, Frequency and Amount Table 3: Project cost and IDA financing by component Table A2.1: Eligible Payments, Frequency and Amount Table A2.2: Topics to be discussed during CNCD sessions Table A2.3: Proposed project Locations Table A5.1: Implementation Support Table A5.2: Skills Mixed Required Table A6.1: Impact of Shombhob Pilot on Consumption Table A6.2: Impact of Shombhob Pilot on Nutrition Table A6.3: IRR and NPV of beneficiary earnings Table A6.4: Fiscal Impact of Shombhob List of Boxes Box A2.1: Characteristics of key safety net programs Box A2.2 Processes in the delivery of cash transfers . . . . v PAD DATA SHEET Bangladesh Income Support Program for the Poorest (P146520) PROJECT APPRAISAL DOCUMENT . SOUTH ASIA Report No.: PAD957 . Basic Information Project ID EA Category Team Leader P146520 C - Not Required Iffath Anwar Sharif Lending Instrument Fragile and/or Capacity Constraints [ ] Investment Project Financing Financial Intermediaries [ ] Series of Projects [ ] Project Implementation Start Date Project Implementation End Date 01-Apr-2015 31-Mar-2020 Expected Effectiveness Date Expected Closing Date 15-Mar-2015 30-Jun-2020 Joint IFC No Practice Senior Global Practice Country Director Regional Vice President Manager/Manager Director Pablo Gottret Arup Banerji Johannes C.M. Zutt Philippe H. Le Houerou . Borrower: Government of the People's Republic of Bangladesh Responsible Agency: Local Government Division Contact: Mr. Md. Akram al Hossain Title: Joint Secretary Telephone No.: 8801711894017 Email: akramalhossain@yahoo.com . Project Financing Data(in USD Million) [ ] Loan [ ] IDA Grant [ ] Guarantee [X] Credit [ ] Grant [ ] Other Total Project Cost: 303.37 Total Bank Financing: 300.00 Financing Gap: 0.00 . vi Financing Source Amount BORROWER/RECIPIENT 3.37 International Development Association (IDA) 300.00 Total 303.37 . Expected Disbursements (in USD Million) Fiscal Year 2015 2016 2017 2018 2019 2020 Annual 0.00 5.00 24.00 66.00 117.00 88.00 Cumulative 0.00 5.00 29.00 95.00 212.00 300.00 . Institutional Data Practice Area / Cross Cutting Solution Area Social Protection & Labor Cross Cutting Areas [ ] Climate Change [ ] Fragile, Conflict & Violence [x] Gender [ ] Jobs [ ] Public Private Partnership Sectors / Climate Change Sector (Maximum 5 and total % must equal 100) Major Sector Sector % Adaptation Mitigation Co-benefits % Co-benefits % Health and other social services Other social services 90 Public Administration, Law, and Public administration- 10 Justice Other social services Total 100 I certify that there is no Adaptation and Mitigation Climate Change Co-benefits information applicable to this project. . Themes Theme (Maximum 5 and total % must equal 100) Major theme Theme % Social protection and risk management Social safety nets 70 Human development Nutrition and food security 15 vii Human development Child health 15 Total 100 . Proposed Development Objective(s) The Project Development Objective is to provide income support to the poorest mothers in selected Upazilas, while (i) increasing the mothers’ use of child nutrition and cognitive development services, and (ii) enhancing local level government capacity to deliver safety nets. . Components Component Name Cost (USD Millions) Cash transfers for beneficiary mothers 267.00 Enhancing local government capacity 32.87 Monitoring and evaluation 3.50 . Compliance Policy Does the project depart from the CAS in content or in other significant Yes [ ] No [ X ] respects? . Does the project require any waivers of Bank policies? Yes [ ] No [ X ] Have these been approved by Bank management? Yes [ ] No [ X ] Is approval for any policy waiver sought from the Board? Yes [ ] No [ X ] Does the project meet the Regional criteria for readiness for implementation? Yes [ X ] No [ ] . Safeguard Policies Triggered by the Project Yes No Environmental Assessment OP/BP 4.01 X Natural Habitats OP/BP 4.04 X Forests OP/BP 4.36 X Pest Management OP 4.09 X Physical Cultural Resources OP/BP 4.11 X Indigenous Peoples OP/BP 4.10 X Involuntary Resettlement OP/BP 4.12 X Safety of Dams OP/BP 4.37 X Projects on International Waterways OP/BP 7.50 X Projects in Disputed Areas OP/BP 7.60 X . viii Legal Covenants Name Recurrent Due Date Frequency Program Operations Manual 15-Jun-2015 Description of Covenant The Government of Bangladesh, through the LGD, shall adopt an Operations Manual, in form and substance satisfactory to the Association, which shall set forth, inter alia, (i) the modalities for Cash Transfers and (ii) detailed arrangements and procedures for institutional coordination and day-to-day execution of the Program. Name Recurrent Due Date Frequency Interagency Coordination with 15-Jun-2015 Bangladesh Bureau of Statistics Description of Covenant The Government of Bangladesh, through LGD, shall enter into, and maintain throughout implementation of the Project, a Memorandum of Understanding, on terms and conditions acceptable to the Association, with the Bangladesh Bureau of Statistics, inter alia, setting out arrangements for the provision of access to lists of poor households based on the data from the Bangladesh Poverty Database. Name Recurrent Due Date Frequency Interagency Coordination with 15-Jun-2015 Directorate General of Health Services Description of Covenant The Government of Bangladesh, through LGD, shall enter into, and maintain throughout implementation of the Project, a Service Agreement, on terms and conditions acceptable to the Association, with the Directorate General of Health Services, inter alia, setting out arrangements for the sharing and management of Beneficiary data and the use of community clinics for the provision of services. Name Recurrent Due Date Frequency Interagency Coordination with Postal 15-Jun-2015 Directorate Description of Covenant The Government of Bangladesh, through LGD, shall enter into, and maintain throughout implementation of the Project, a Service Agreement, on terms and conditions acceptable to the Association, with the Postal Directorate setting out the modalities for electronic Cash Transfer payments to be made to Beneficiaries and acceptable cash transfer fees. Name Recurrent Due Date Frequency Procurement and fiduciary staffing 15-Sep-2015 Description of Covenant The Government of Bangladesh, through the LGD, shall recruit to the Project Management Unit one ix procurement specialist and two financial management specialists with qualifications and experience and under terms of reference acceptable to the Association. Name Recurrent Due Date Frequency Compliance with Governance and X CONTINUOUS Accountability Action Plan Description of Covenant The Government of Bangladesh, through LGD, shall carry out the Project in accordance with the Governance and Accountability Action Plan. Name Recurrent Due Date Frequency Compliance with Social Safeguards X CONTINUOUS Description of Covenant The Government of Bangladesh, through the LGD, shall carry out the Project in accordance with the Small Ethnic Communities Plan. . Conditions Source Of Fund Name Type IDA Program Operations Manual Disbursement Description of Condition No withdrawal shall be made under Category (1) for Cash Transfers unless and until the Recipient has adopted the Operations Manual, in form and substance satisfactory to the Association, which shall set forth, inter alia, (i) the modalities for Cash Transfers and (ii) detailed arrangements and procedures for institutional coordination and day-to-day execution of the Program. Team Composition Bank Staff Name Title Specialization Unit Iffath Anwar Sharif Lead Economist Team Lead GSPDR Iftikhar Malik Senior Social Protection Co-Task Team Leader GSPDR Specialist Bushra Binte Alam Senior Health Specialist Senior Health Specialist GHNDR Zahed H. Khan Senior Urban Specialist Senior Urban Specialist GURDR Pravesh Kumar Social Protection Social Protection GSPDR Specialist Specialist Aneeka Rahman Social Protection Social Protection GSPDR Economist Economist Ashiq Aziz Operations Analyst Operations Analyst GSPDR x Name Title Specialization Unit M. R. Ashish Joshi Consultant Consultant GSPDR Agha Alamdar Hussain Consultant Consultant GSPDR Salwa Khan Consultant Consultant GSPDR Celine Ferre Consultant Consultant GSPDR Nushin Subhan Consultant Consultant GSPDR Md. Abir Hasan Consultant Consultant GSPDR Mohammad Sayeed Consultant Consultant GENDR M. Akram ul Aziz Consultant Consultant GSPDR Md. Mahtab Alam Program Assistant Program Assistant SACBD Sandra X. Alborta Program Assistant Program Assistant GEDDR Mohammad Khalid Program Assistant Program Assistant GSPDR Khan Tanvir Hossain Senior Procurement Senior Procurement GGODR Specialist Specialist Mohammad Reaz Uddin Financial Management Financial Management GGODR Chowdhury Specialist Specialist Sabah Moyeen Social Development Social Development GURDR Specialist Specialist Barbara Weber Senior Operations Senior Operations GPSOS Officer Officer Junxue Chu Senior Finance Officer Senior Finance Officer CTRLN Satish Kumar Finance Officer Finance Officer CTRLN Shivakumar Roch Levesque Senior Counsel Senior Counsel LEGAM Shingira Samantha E T Consultant E T Consultant LEGES Masanzu xi I. STRATEGIC CONTEXT A. Country Context 1. Despite remarkable progress in the fight against poverty, reducing extreme poverty is a key development challenge for Bangladesh. Poverty fell from 48.9 percent in 2000 to 40 percent in 2005 to 31.5 percent in 2010. Coupled with this progress was a consistent advancement in well-being in terms of asset ownership, better quality homes, improved access to amenities, and increased caloric intake and educational attainments across all income groups. Nevertheless an estimated 6 million households (about 18 percent of the population) are extremely poor. Extreme poverty in Bangladesh is mainly a rural phenomenon: 60 percent of the poor in rural areas were also extremely poor. 1 2. To accelerate its poverty reduction rates Bangladesh needs to make better use of its social protection expenditures. The Government of Bangladesh (GoB) has set a target for a poverty rate of 14 percent by 2021. 2 Assuming population growth continues to decline at the same rate as during the 2000-2010 period, achieving this poverty target implies lifting approximately 15 million people out of poverty in the next 8 years. One of the areas where Bangladesh would need coordinated action to expedite poverty reduction is in the way it utilizes its social protection expenditures. 3 Annually Bangladesh spends over 2 percent of its GDP on social protection programs but the bulk of these resources are allocated to the non-poor. 3. If designed well, better targeted and efficiently implemented, social safety nets (SSNs) are able to have a significant impact on poverty. This was evidenced by a pilot project (P123629) titled Shombhob (which means possible in Bangla) that was funded by the World Bank’s Rapid Social Response Multi Donor Trust Fund and approved on August 25, 2011. Implemented by the Local Government Division (LGD) under the Ministry of Local Government, Rural Development and Cooperatives (MoLGRD&C) the project provided monthly cash transfers to poor mothers as long as they fulfilled the co-responsibility of: (i) attending monthly awareness sessions on nutrition; and (ii) regularly monitoring the growth of their children below three years of age 4. Transfers were accompanied by robust targeting, communication, payments, monitoring, and evaluation activities. Followed by a public information campaign, beneficiary mothers were selected using a Proxy Means Test Formula (PMTF) to ensure the participation of the poorest households. Payments were made electronically using Post Office debit cards and monitored by an automated Management Information System (MIS). Evaluation results 5 of Shombhob, funded by the South Asia Food and Nutrition Security Initiative, show that the targeting system based on PMTF worked well: beneficiary households had lower per capita consumption levels than those who applied but didn’t qualify based on the PMTF eligibility threshold. Regular cash transfers made directly to beneficiary mothers using these debit cards proved both transparent and efficient: 95 percent of 1 World Bank. 2013. “Bangladesh Poverty Assessment: Assessing a Decade of Progress in Reducing Poverty 2000- 2010,” Bangladesh Development Series No. 31. 2 See Bangladesh Vision 2021 Plan and the associated Perspective Plan 2010-2021. 3 Sharif, I. and D. Jolliffe. “Raising the game for pro-poor growth” in the Daily Star, May 1, 2014 4 The project also had an education co-responsibility targeted to families with children going to primary school. 5 Ferre, C. and I. Sharif. 2014. “Can Conditional Cash Transfers Improve Human Development Outcomes for Poor Children in Bangladesh? Evidence from a Pilot Project,” submitted to the World Bank policy research working paper series. 1 beneficiary mothers reported to have received their regular payments in full amounts without incurring any additional costs. Compared to a control group, beneficiaries of the Shombhob Pilot experienced a significant increase in monthly household food consumption of 11 percent. Moreover, the impact evaluation finds that food expenses on proteins – meat, eggs, dairy, fish and pulses – increased significantly for beneficiary households who attended the nutrition awareness sessions. The analysis also finds that the intervention had a significant impact on the incidence of wasting among children who were 10-22 months old when the Shombhob Pilot started, reducing the share of children with weight-for-height below 2 standard deviations from the WHO benchmark by 40 percent. Moreover, the intervention resulted in increased nutrition related knowledge of mothers regarding the importance of exclusive breastfeeding by 8 percent (Annex 6 provides a detailed description of these findings). Encouraged by these results and to further strengthen safety net delivery at the local level, the MoLGRD&C Government of Bangladesh requested for IDA support to scale up the Shombhob Pilot in other parts of the country. B. Sectoral and Institutional Context 4. Social protection spending in Bangladesh has been rising in recent years, and is countercyclical. The Government has provided an average of 12 percent of total annual public expenditures (about 1.8 percent of GDP) for social protection during 1996-2008. Since then the allocation was increased in response to the global food and energy price crises of 2007 to about 14 percent of the total budget over 2009-2014, and reached as high as 2.64 percent of GDP in FY11 following the 2010 global commodity price shock. These substantial allocations, and the FY15 allocation of 2.3 percent of the GDP, are partly aided by the increasing fiscal space created by steady growth rates of 6 percent on average in recent years. 5. Expenditures are skewed towards a few large programs that primarily address emergencies and seasonal shocks. Currently 22 Ministries implement over 100 programs with annual allocations that range from BDT 55 billion (US$714m) to BDT 0.01 billion (US$0.13m). The ten largest programs (shown in Figure 1) command 70 percent of the total budget, with the remaining allocation distributed among 18 medium sized programs (23 percent) and 67 very small ones (7 percent). Pension programs, including both formal and informal, constituted a third of the total budget in FY13, while the remainder was spent on safety net programs (SSNs) and various other community based organizations. The majority of large SSNs offer food based transfers, while the education stipend programs offer cash. The remaining cash based SSNs are spread thinly across numerous smaller programs for special groups, including widows, disabled children, minority groups, etc. 6. Poor targeting of safety net benefits, along with inadequate average transfer amounts at the beneficiary level, limit the potential of safety nets to reduce poverty. Social protection programs in Bangladesh at present cover only one-third of the poor population. The average transfer amount is about 11 percent of the total expenditures of poor households, much lower than the global median ranging from 18 to 27 percent. Effective targeting and efficient implementation could increase the coverage of poor households and make a larger dent on poverty using the existing social protection budget. For example, even if average transfer 2 amounts were unchanged, ensuring they reached the poorest households would reduce the poverty rate by 4.3 percentage points and lift nearly 5 million people out of poverty. 6 Figure 1. FY13 Social Protection Expenditures (Crore BDT) 7. The GoB has already taken a first step in the right direction by undertaking the development of a unified targeting system for SSNs. Using IDA support under the Safety Net Systems for the Poorest (SNSP) Project (IDA Cr. No. 5281-BD) the Statistics and Informatics Division (SID) is developing a PMT based database of poor households to allow SSNs target their beneficiaries more accurately. As has been done in many other countries, this method of targeting identifies key characteristics of the poor from household data and uses these to develop a household level “poverty scorecard” with which to identify poor households. Recent experience from pilot studies suggest adopting such a PMT formula-based targeting mechanism can substantially improve the current coverage of poor households. 7 8. Considerable overlap and fragmentation among SSNs are additional challenges that need to be addressed. The lack of coordination between the various SSNs results in inefficiencies and confusion among beneficiaries regarding their benefits. For example, despite working with the same target population, the Ministry of Women and Children Affairs (MoWCA) implements an unconditional maternity allowance as part of the Poor Lactating Mothers Program while the Ministry of Health & Family Welfare (MoHFW) offers Maternal Health Vouchers conditional on institutional births. Three different ministries run various education stipend programs. Similarly numerous public works programs are implemented by multiple ministries. There is overlap and fragmentation among programs within Ministries as well. For instance, the Ministry of Disaster Management and Relief (MoDMR) implements three similar workfare programs - Employment Generation Program for the Poorest (EGPP), Test Relief (TR) and Food for Works (FFW) - but utilizes different beneficiary lists and administrative processes leading to fragmentation, inefficiencies, and unmanageable workload on limited project implementation personnel. Through the SNSP Project, the Bank is helping to build common administration platforms at the program level, and thus help pave the way for their eventual consolidation to reduce overlap and fragmentation within the Ministry. 6 World Bank. 2013. “Bangladesh Poverty Assessment: Assessing a Decade of Progress in Reducing Poverty 2000- 2010,” Bangladesh Development Series No. 31 7 World Bank. 2014. “Developing a PMT based targeting system for Bangladesh.” Draft report. 3 9. Increased technical and financial resources at the local government level can help strengthen the delivery of safety net services and minimize fragmentation across programs. Local level governments or Union Parishads implement most SSNs on behalf of various line Ministries but suffer from weak administration capacity. They are responsible for preparing beneficiary lists and delivering the benefits, yet do not receive an administrative budget for carrying out these activities. Nor do the Ministries that implement various safety nets coordinate at the local level when developing their respective beneficiary lists through local government officials. Setting up common administrative platforms at the union level for safety net beneficiary identification, enrolment, payment and grievance redress will fill this critical gap in the implementation of SSNs and could potentially minimize fragmentation among SSNs across Ministries. The proposed project and the on-going SNSP Project, thus together offer a coordinated solution to the challenge of improving the implementation of SSNs in Bangladesh to accelerate poverty reduction. 10. Efficient implementation of SSNs also has the potential to help Bangladesh address other formidable human development challenges. Worldwide Conditional Cash Transfer (CCT) programs 8 have been used to reduce consumption poverty and improve human capital formation. 9 The accumulating evidence also suggests these programs have had a significant impact in improving maternal and child nutrition outcomes. 10 Ensuring adequate nutrition prenatally and in the first two years, and early childhood cognitive development can prevent devastating permanent effects on children’s intelligence and brain development. 11 For example, an intervention to help develop nutrition, and cognitive and socio-emotional skills among growth-stunted children in Jamaica increased their earnings capacity by 25 percent – enough for them to catch up with the earnings of their non-stunted counterparts. 12 Thus any strategy for strengthening the future workforce and their earning capability require investing in the environments of children during their early years. 13 The ability of SSNs to reach a large number of poor populations with income support along with an emphasis on child nutrition and cognitive development outcomes promises a potentially winning formula in the fight against both current and future poverty. Harnessing the potential of this type of SSNs thus represents a smart use of scarce government resources that are earmarked for fighting poverty in Bangladesh. 11. The prevalence of under-nutrition in Bangladesh is among the highest in the world. Whilst there has been significant progress in reducing the incidence of underweight children below 5 years (from 60 in 1990 to 36 percent in 2011), progress in reducing wasting and stunting 14 has been less encouraging. The annual rate of reduction in stunting from 2004 to 2011 was only 1.3 percentage points while the prevalence of wasting stagnated. Among countries with 8 CCTs in many countries are viewed as a form of a social contract between the state and beneficiaries, and the word “co-responsibility” (instead of condition) is used to reflect this notion. 9 Fiszbein et al. 2009. “Conditional Cash Transfers: Reducing Present and Future Poverty,” World Bank: DC 10 See Ruel et al. 2013. “Nutrition-sensitive interventions and programmes: how can they help to accelerate progress in improving maternal and child nutrition?” Lancet Series Volume 382, Issue 9891, Pages 536 - 551, 10 August 2013 for a detailed discussion 11 Hawley, T. 2000. “Starting Smart: How Early Experiences Affect Brain Development.” Zero to three Press 12 Gertler, P. et al. 2014. “Labor Market Returns to an Early Childhood Stimulation Intervention in Jamaica.” Science 30, vol 344 (6187): 998-1001 13 Nudsen et al. 2006. “Economic, Neurobiological and Behavioral Perspectives on Building America’s Future Workforce,” World Economics, July-September 2006 14 i.e. children do not have the required weight (wasting) and height (stunting) for age. 4 the highest prevalence of stunting, Bangladesh ranks 6th in the world. 15 The incidence of low birth weight in Bangladesh is also among the highest in the world at 22 percent, and maternal under nutrition is at about 24 percent. 16 The high prevalence of infectious disease poses an additional challenge for Bangladeshi children - the interaction between under nutrition and common infections creates a potentially harmful cycle of worsening illness and deteriorating nutritional status resulting in long term irreversible adverse impacts. 12. Although the problem of under nutrition affects the whole population in Bangladesh, the poor primarily bear its burden. All indicators in Table 1 show a negative wealth gradient. The difference between the prevalence of underweight among 0 to 60 months old in households in the lowest and the richest expenditure quintile is 29 percentage points. Poverty also interferes with the access to knowledge and services related to nutrition and proper food intake behavior. For example, both wealth and mother’s education are positively correlated with higher vaccination rates among children. 17 Poverty can also hamper school achievements: poor children in Bangladesh exhibit worse educational attainment compared to their non-poor counterparts. 18 Yet, none of the major SSNs focus on child nutrition and cognitive development. Table 1: Nutrition indicators by wealth groups Wealth Quintiles Indicators Q1 Q2 Q3 Q4 Q5 Stunting prevalence (%) 54 45 41 36 26 Underweight prevalence (%) 50 42 36 28 21 Wasting prevalence (%) 18 16 18 14 12 Women with low BMI (<18.5 kg/m2, %) 40 30 26 20 8 Women with high BMI (≥25 kg/m2, %) 5 7 11 20 37 Source: BDHS, 2011 13. The Bank is well placed to help the GoB improve the implementation of safety nets while promoting better child nutrition and cognitive development outcomes. The successful implementation of the Shombhob Pilot resulted in a strong Bank partnership with LGD and helped develop a tested mechanism of cash transfers linked to child Growth Monitoring and Promotion (GMP) interventions. The experience of the Shombhob Pilot suggest that when offered on a large scale in Bangladesh, the Shombhob interventions can complement existing nutrition services being offered under MoHFW’s universal National Nutrition Services (NNS) program by: (i) identifying the poorest pregnant women and mothers; and (ii) incentivizing them to regularly utilize services that are important for child nutrition and growth. As part of the national scale up of Shombhob, LGD has also requested to add interventions on mothers’ education on child cognitive development. Given its mandate to facilitate and coordinate a variety of public services locally under the Local Government Act of 2009, LGD is uniquely 15 UNICEF. 2013. “Improving Child Nutrition: The achievable imperative for global progress.” Unicef: New York 16 NIPORT. 2013. Bangladesh Demographic Health Survey 2011. 17 2011. NIPORT 18 See Chapter 2 in World Bank. 2013. “Bangladesh Poverty Assessment: Assessing a Decade of Progress in Reducing Poverty 2000-2010,” Bangladesh Development Series No. 31 for a detailed analysis. 5 placed to implement such a program in that it has an interface with all other line Ministries and departments at the local level (e.g. health, education, social services, etc.). 14. Additionally, through previous successful operations 19 and important analytical work 20 and the ongoing results-based SNSP Project, the Bank has established itself as a credible partner in bringing relevant international good practices in building sound social protection systems to Bangladesh. The proposed Income Support Program for the Poorest (ISPP) Project offers an additional strategic entry point to complement and leverage the Bank’s existing support for important policy reforms in social protection.21 It also complements the on-going: (i) Health Sector Development Program which supports the NNS as one if its strategic areas, and (ii) Third Primary Education Development Program which among other things, is promoting pre-primary education at the national level. C. Higher Level Objectives to which the Project Contributes 15. The proposed project will fulfill two of the main elements of Bangladesh’s poverty reduction strategy laid out in the Sixth Five Year Plan (SYFP): (i) to “improve poor households’ access to and quality of education, health and nutrition services,” and (ii) “strengthen the coordination, targeting and coverage of social protection programs.” The need to strengthen SSNs and to improve nutritional outcomes is also documented in the “Country Investment Plan: A roadmap towards investment in agriculture, food security and nutrition.” Further, the proposed ISPP project will be a critical platform to help inform and facilitate the implementation of the following important national strategies - National Nutrition Policy and the National Social Security Strategy – that are currently being finalized. 16. The proposed project will contribute to: (i) the World Bank Group’s twin goal of eliminating extreme poverty and boosting shared prosperity; and (ii) the Bank’s revised Country Assistance Strategy (CAS Progress Report no. 73983-BD) 22 for Bangladesh for FY 11-15 of strengthening social service delivery. Providing income support to the poorest women and helping to improve their children’s growth and development fulfills both immediate consumption needs and long term strategic needs of increasing the earnings ability of poor households. Further, these transfers are expected to change the traditional perception of women and children from being liabilities to “assets” for the household. Bio-metric enabled electronic payments solutions will improve the financial inclusion and literacy of poor women, and thereby have a transformational impact on their empowerment. The “door-step delivery” of awareness on child nutrition and growth has the potential to have a positive impact on nutrition indicators – somewhat in the same way that the “door-step delivery” of family planning services and information back in the 70s and 80s improved women’s decision making ability as well as maternal and child health outcomes. 19 The Employment Generation Program for the Poorest Project (P118701) and the Emergency Repatriation and Livelihood Restoration of Migrant Workers Project (P126263). 20 World Bank. 2013. “Bangladesh Poverty Assessment: Assessing a decade of remarkable progress, 2000-2010.” Bangladesh Development Series Report No. 31. World Bank: Dhaka 21 See World Bank. 2014. “Policy Options to Strengthen the Social Protection System,” for a description of these policy imperatives. 22 Discussed at the World Bank Board on January 14, 2014. 6 II. PROJECT DEVELOPMENT OBJECTIVES A. PDO 17. The Project Development Objective is to provide income support to the poorest mothers in selected Upazilas, while (i) increasing the mothers’ use of child nutrition and cognitive development services, and (ii) enhancing local level government capacity to deliver safety nets. B. Project Beneficiaries 18. The project beneficiaries would include pregnant women and mothers with young children below the age of 5 years from the poorest households. It is expected that the proposed project will directly benefit approximately 600,000 beneficiary mothers which would reach about 2.7 million people. Beneficiary mothers will receive cash benefits if they fulfill the following co- responsibilities linked to the growth and development of their young children: (i) use of GMP services, and (ii) attendance at child nutrition and cognitive development (CNCD) awareness sessions. Annex 2 provides details on the scope of these GMP and CNCD services. C. PDO Indicators Project Appraisal Document (PAD) 2013 19. The achievement of the PDO will be measured by the following indicators: • Number of ISPP beneficiaries registered to receive cash transfers • Proportion of ISPP beneficiary households in the bottom two expenditure quintiles • Proportion of ISPP beneficiaries receiving at least 70 percent of their maximum benefit • Number of Unions maintaining a single beneficiary registry for at least five SSNs 20. The correspondence of each indicator to the intermediate outcome indicators and the project components is explained in more detail in Annex 1. Both qualitative and quantitative evaluations will be used to assess the impact of the project on household consumption, birth weight of beneficiary children, dietary diversity, beneficiary children achieving weight-for- height, weight-for-age, and height for age goals, and proxy child cognitive development indicators such as beneficiary children achieving development milestones and transitioning from the proposed project and entering pre-primary or primary schools. III. PROJECT DESCRIPTION A. Project Components 21. To achieve the PDO the project will be implemented in 42 of the poorest Upazilas, 23 and cover about 600,000 mothers over a five year period (Annex 2 provides a list of the project Upazilas). The proposed project will support three components via an Investment Project Financing (IPF) amounting to approximately US$300 million for a period of five years (FY15- 20), and will be implemented by LGD of MoLGRD&C. The following briefly describes these components (details are provided in Annex 2). 23 Upazilas are rural administrative units within a District, while Unions are sub-Upazila level administrative areas. 7 22. Component 1: Cash transfers for beneficiary mothers (US$267 million). This component will finance quarterly cash transfers to eligible households. Eligibility will be determined by the following two characteristics: (i) household will have to belong to the bottom two expenditure quintiles, 24 and b) such households must have pregnant women and/or mothers of children below the age of 60 months. There would be four types of co-responsibilities depending on the household demographic composition (see Table 2 below). Cash transfers will be given conditional on utilizing the following services: (i) up to 4 antenatal care (ANC) visits by pregnant beneficiaries; (ii) monthly GMP of children from 0-24 months; (iii) quarterly GMP for children from 2 to 5 years of age; (iv) monthly attendance at CNCD awareness sessions by all eligible mothers. The incentive structure emphasizes the relative importance of GMP among 0 to 24 month old children, and that of CNCD awareness 25 among mothers for all children below 5. There is a natural exit mechanism whereby the maternal benefit will end once the mother gives birth, and the cash transfer linked to child growth and development will cease once the child reaches 5 five years of age. Further details regarding program rules including possible exceptions (e.g. in the case of motherless children) will be described in the program Operations Manual. Table 2. Eligible payments, frequency, and amount Name of Eligible Co-responsibility Benefit amount Payment Payment benefit beneficiary schedule condition ANC Pregnant Ensure 4 quarterly BDT 200 per visit completed No visit, no women antenatal care visit ANC visit* payment Monthly Mothers with Take child for BDT 500 per visit Quarterly Payment GMP children aged height and weight (total of BDT 1500 allowed if at 0-24 months check monthly in one quarter plus a least two visits bonus BDT 500 if have been all three visit are completed in completed in a three months** quarter) Quarterly Mothers with Take child for BDT 1000 Quarterly No visit, no GMP children aged height and weight payment 25-60 month check quarterly Monthly All beneficiary Attend child BDT 500 per visit Quarterly Payment CNCD women nutrition and (total of BDT 1500 allowed if at (pregnant development in one quarter least two visits women and education sessions irrespective of have been mothers) every month number of children completed in enrolled) three months** *GoB recommends upto 4 ANC visits. **Only BDT 1000 will be received if only two out of three visits are completed. Any less will result in suspension and possible termination of the benefits if the households do not comply even after the two successive warnings. Details will be laid out in the Operations Manual. 23. To remain consistent with Government’s family panning policy, each beneficiary mother will be entitled to benefit payments for only the first and second born child. This implies the average size of the monthly benefit would be between BDT 1200 and 1800, which would be 24 Priority will be on the poorest households determined by their poverty scorecard as assigned by the BPD. 25 While growth promotion and early childhood development interventions can cover a gamut of services, to ensure simplicity and account for capacity constraints, the package offered by the proposed project will include very basic but essential services. 8 around 15 - 23% of the estimated average monthly per capita expenditure of the target population who are expected to consume at around the lower national poverty line. 26 Evidence from similar CCT programs suggests limited labor disincentive impacts especially when the level of benefits is within 20 percent of household income. Thus the proposed benefit amount is adequate without creating an adverse impact on labor supply. 27 24. Component 2: Enhancing local level government capacity (US$32.87 million). This component would provide the necessary inputs to LGD to facilitate the implementation of the proposed cash transfers. This will include strengthening the capacity of: (i) Union Parishads (i.e. union level elected councils) to develop the beneficiary list based on the Bangladesh Poverty Database (BPD) being developed by SID, and supervise their enrolment into ISPP; (ii) Community Clinics (CCs) to deliver the ANC and GMP services, and the CNCD awareness sessions; and (iii) Union Post Offices (UPOs) to make electronic payments to beneficiaries using the Postal Cash Cards (PCCs) upon compliance with co-responsibilities. To facilitate the Union Parishad activities, a “Safety Net Cell” (SNC) will be established at the existing Union Parishad Offices, staffed by one Safety Net Program Assistant (SPA). An enrolment agency will be hired to support in managing the initial large volumes of enrolments in ISPP in the first two years of implementation. 25. The SNCs will also function as a safety net “one stop shop” for providing all citizens with information on these programs, their eligibility criteria, the benefit amounts, etc. The SPA will be responsible for facilitating this information, and for compiling the beneficiary lists (and their updates through new enrolments) of major SSNs that operate nationally (e.g. EGPP, FFW, TR, Vulnerable Group Feeding, Gratuitous Relief, Old Age Allowance, Widow Allowance, etc.) in addition to managing the ISPP beneficiary lists. Such local level coordination will allow SNCs to track SSN beneficiaries receiving benefits from different programs in each Union. This information can eventually feed into the central level beneficiary registry tracking system being developed by the Ministry of Finance (MoF) with support from DFID, and the MoDMR for its programs (FFW, EGPP, TR, VGF and GR) as part of the SNSP project. 26. To ensure regularity in service provision by the CCs that allow the fulfillment of beneficiary co-responsibility, and to avoid over-burdening the CC staff, one or more NGOs will be hired to support staff in each CC with delivering ANC and GMP services to ISPP beneficiaries. This NGO(s) however will be exclusively responsible for offering the CNCD awareness sessions. To support the BPO payments system, the component will procure the hardware and software needed to install a biometric-enabled system that links electronic payments to beneficiary compliance with their respective co-responsibilities. This IT-enabled operating system will allow for better coordination between the three sets of local institutions – the SNC, the CC, and the UPO. Once the payments platform is set up, it can be availed by other cash based SSNs to adopt similar electronic payments. All of these activities will be underpinned by an Operations Manual, as well as a MOU signed by LGD with the Bangladesh Bureau of Statistics (BBS) under SID, and a service agreement signed with the Directorate General of 26 Calculations are based on the 2010 national poverty line (adjusted for inflation). The benefit size is almost 2.5 to 3.5 times the average benefit offered by other SSNs. 27 Grosh, M. et al. 2008. “For Protection and Promotion: The Design and Implementation of Effective Safety Nets.” World Bank: Washington DC . 9 Health Services (DGHS) under the Ministry of Health & Family Welfare (MoHFW) and with the Postal Directorate/Bangladesh Post Office (BPO) under the Ministry of Posts, Telecommunications, and Information Technology (MoPTIT) respectively. 27. Component 3: Monitoring and evaluation (US$3.5 million) A robust monitoring and evaluation (M&E) framework will be critical to assess progress in achieving the project’s objectives, and the impact of cash transfers on household poverty and on CNCD outcomes. This component will thus provide the necessary inputs to help LGD monitor ISPP beneficiary selection, enrolment, compliance with co-responsibilities, payments, case management as well as any grievances or appeals. To facilitate these activities, this component will develop an automated Management Information System (MIS) by building on the existing Shombhob Pilot MIS. This MIS will be linked to the MIS set up by the DGHS to share data on service utilization by ISPP beneficiaries. In addition, an effort will be made to develop an interface with the SSNs MISs being built by BBS, MoF and MoDMR to allow central review of beneficiary information. 28. To ensure that the project activities are being carried out effectively, this component will also support third party monitoring which will cover: (i) an annual evaluation of the project cycle processes to assess administrative issues and constraints for a sample of locations; and (ii) bi- annual Knowledge, Attitude and Practice assessments on CDCD issues on a random sample of beneficiaries to track project outcomes. These assessments will help to assess and identify areas that require remedial measures and course correction, and thus will be used to inform necessary changes and updates needed to the ISPP Operations Manual. Additionally both qualitative and quantitative evaluations will be conducted through Trust Fund resources to assess the impact of the project activities on household poverty and CNCD outcomes based on household level surveys. B. Project Financing 29. The proposed operation would be financed by an IDA Credit of US$300 million through an Investment Project Financing (IPF) Credit under OP10.00. C. Project Cost and Financing 30. The total project cost is US$303.37 million out of which GoB contribution is of US$3.37 million (see Table 3 for a breakdown of the costs). 31. Component one will finance cash transfers to beneficiaries while component two will finance office space, contractual staff, hardware, individual consultant services, training, operational and maintenance costs required for the smooth flow of transfers and ANC, GMP and CNCD services to beneficiaries. Component three will finance the software and management information systems, and consultant services for monitoring and evaluation. Bank funds will flow into a Designated Account, and all three components will disburse using standard reimbursement procedures. GoB contribution will essentially finance government staff salary and honorarium and office rent. 10 Table 3. Project cost and IDA financing by component Project cost IDA Financing Project Components % Financing (US$ million) (US$ million) 1. Cash transfers for beneficiary households 267.0 267.0 100 2. Strengthening local level capacity & coordination 32.87 29.5 90 3. Monitoring and evaluation 3.5 3.5 100 Total Project Costs 303.37 300.0 98 Total GoB contribution 3.37 Total Financing Required 300.0 300.0 100 Document (PAD) 2013 D. Lessons Learned and Reflected in the Project Design 32. Three sets of lessons have informed the design of the proposed project. Lessons from the Shomhob Pilot highlight the importance of: (i) LGD’s supervisory mandate over elected local government institutions; (ii) using NGOs to provide implementation support at the local level due to varying capacity of CCs; (iii) close coordination between the LGD and other stakeholder agencies (e.g. P&TD and DGHS); (iv) a monitoring and evaluation system embedded in the project design to provide constant feedback for management on implementation; (v) regular independent assessments to allow for design or implementation modifications; and (vi) motivating Union Parishads to improve SSN service delivery. 33. Broader lessons have been drawn from other similar World Bank operations, as well as from the vast literature on CCT programs, 28 which suggest the following: (i) conditional cash transfers are more likely to be effective in strengthening human capital when supply-side constraints are addressed simultaneously; (ii) providing transfers to women ensures that the money is spent to benefit children, and that it has a positive impact on women’s empowerment; (iii) clear and transparent rules, and beneficiary awareness of them, help to ensure program credibility; and (iv) a system of control and accountability mechanism is important to provide timely and adequate information to management. 34. A third set of lessons is derived from global good practice in building an integrated comprehensive social protection system as laid out in the Bank’s Social Protection and Labor Strategy. 29 One key aspect includes synchronization among programs so that they are connected in terms data, monitoring, and policy objectives. The successful implementation of the proposed project would create Union level mechanisms to integrate existing SSNs through initially a common beneficiary registry, and over time facilitate the use of common administrative platforms for beneficiary identification, enrolment, payments and grievance. This could potentially pave the way for consolidating numerous cash based SSNs in Bangladesh into an integrated system to provide social protection to the poorest. This is how Oportunidades and Bolsa Familia evolved in Mexico and Brazil respectively, and became best global practice. 28 See Fizsbein, A and N. Schady. 2009. “Conditional Cash Transfers: Reducing Present and Future Poverty.” World Bank Policy Research report. World Bank: Washington D.C. 29 Programs are advised to be synchronized, measurable, affordable, responsive, transparent and accountable (SMART). See World Bank. 2012. “Building resilience and opportunity: The World Bank’s Social Protection and Labor Strategy 2012-2022” for more detail. 11 IV. IMPLEMENTATION A. Institutional and Implementation Arrangements 35. Fundamentally important to the successful implementation of ISPP is to have the appropriate institutional arrangements to: (i) identify eligible beneficiary mothers, enroll them into the program, and address their grievances; (ii) supervise and ensure the delivery of the required ANC and GMP visits, and CNCD sessions at the CCs; (iii) monitor beneficiary compliance with their respective co-responsibilities and ensure associated timely payments; and (iv) coordinate with Upazila level officials of other line Ministries that implement SSNs in the project locations. To achieve this LGD will forge partnerships with the following government agencies: (i) the BBS to determine the union-wise list of potential poor households; (ii) the DGHS to work with CCs to coordinate the ANC and GMP visits; and (iii) the BPO to facilitate biometric-enabled electronic payments. 36. A Project Management Unit (PMU) will be set up at LGD which will be led by a Project Director (PD), not below the rank of Joint Secretary. The PD will be assisted by a Deputy Project Director (DPD), to conduct day-to-day project management specifically linked to the administration of the cash transfers, and to oversee the coordination with partner agencies and various stakeholders at the District, Upazila and Union levels. The PMU will also comprise of specialists hired as consultants for the project period. These positions would include two Financial Management Specialists, one Procurement Specialist, one MIS Specialist, one M&E and Training Specialist, a Social Safety Net Implementation Specialist, a System Engineer, a Payments Specialist, along with support staff as needed. 37. The PMU will be advised and guided by a Project Steering Committee (PSC) chaired by the Secretary of LGD. This Committee will provide an oversight function to ensure that project activities are well coordinated across the various partner Ministries. Secretaries of these partner Ministries such as the MoHFW, MoPTIT, MoDMR, and SID will be members of the PSC, among others. A Project Implementation Committee (PIC), headed by the PD and consisting of other partner Ministries, will assist in the supervision of the project at all levels to ensure that it follows both Government and Bank rules and regulations during implementation. At the District level, the District Commissioner (DC) will be the focal point for providing overall supervision and guidance of the project activities, and will be assisted by the Deputy Director Local Government (DDLG). At the Upazila level, the Upazila Nirbahi Officer (UNO) will be the primary official responsible for all project related processes, and will be assisted by the Safety Net Program Supervisor (SPS) hired under the proposed project. At the Union level, the SPA will be hired on a contractual basis to manage the SNC situated at the Union Parishad office, and will work under the supervision of the UNO and SPS. At the Upazila level, the SPS will coordinate with BBS to collect the list of poor households determined by the BPD. An enrolment firm will be hired by LGD to conduct the enrolment process on a rolling basis but limited to this BPD list of eligible poor households. The same firm will conduct a public information and communication campaign (PICC) to reach out to poorest households requesting those with children below the age of 5 and/or pregnant mothers to enroll into ISPP. Both the list of eligible households and those registered in ISPP will be maintained by the SPA for each union. In addition, with the help of Union Parishad and UNO’s office, the SPA will help put together a 12 common beneficiary list of major SSNs operating in the Union. The SNC will essentially function as the Project Implementation Unit (PIU), and will mainly liase with the elected members of the Union Parishad but report to the UNO. 38. As part of the Service Agreement with DGHS, LGD will hire one or more NGOs to work with CCs to ensure the delivery ANC and GMP services, and provide any necessary equipment to facilitate and monitor the GMP and ANC services. The NGO(s) will be responsible for delivering the CNCD sessions which will be customized to cater to both the language/dialect and culture of local communities (e.g. tribal populations). As part of this agreement, access to the DGHS MIS will allow the exchange of beneficiary data between the two agencies. 39. The Service Agreement with the BPO will lay out the modality of the quarterly electronic payments to beneficiaries, as well as the scope of equipment required for the implementation of this biometric-enabled payments system using PCCs. Beneficiaries will be able to withdraw their transfers from the local UPOs, all of which will have Point of Sales (POS) machines with finger print scanners to facilitate the fast processing of payments. 30 Beneficiary compliance with co- responsibilities will be monitored using the same PCCs with the help of MIS. POS machines with finger print scanners will be made available at each service delivery point – SNC, CC, and with the NGO for CNCD sessions – to be used to verify attendance. The POS machines will be configured according to the type of co-responsibility to generate the respective payment. 40. SNCs will enroll all eligible households identified by the BPD as poor. Whist this provision reduces the scope for any discretion on the part of SPAs in determining the list of beneficiaries, there is always a scope for human error in compiling the beneficiary list. Thus developing transparent and practical mechanisms for grievance redress to address beneficiary appeals concerning targeting, payments, information updates, and/or the quality of services are important. The ISPP MIS will include a grievance redress module to be managed by Grievance Redress Officers (GROs) appointed at various levels who will address grievances as per the Operations Manual; and keep a record of the details of cases lodged, resolved cases, pending cases and actions taken. The UNO and the DC will be the Grievance Redress Officer (GRO) at the Upazila and District levels respectively. The PD will act as the GRO at the central level. B. Results Monitoring and Evaluation 41. A range of M&E tools will be employed in assessing LGD’s implementation performance, outputs, and outcomes. Project performance monitoring is expected to utilize the automated MIS in combination with independent assessments, including both third party monitoring and program impact evaluations. An appropriate amount of resources in Component three is earmarked for these activities, and are listed below: (a) Beneficiary data monitoring and compliance verification using the MIS (b) Internal audits of BPO payments by LGD 30 Evaluations of the payments system under the Shombhob Pilot Project suggest beneficiary mothers often forget their unique PIN to process payments, and the overall process can often be delayed. Using biometric data will help expedite this process while providing for a two-factor authentication system which is the global best practice. 13 (c) Third party monitoring to (i) conduct an annual evaluation of the project cycle processes to assess administrative issues and constraints for a sample of locations; and (ii) carry out bi-annual KAP assessments on a random sample of beneficiaries on a continual basis. (d) Focused group discussions with participants and non-participants to conduct a qualitative evaluation of project outcomes. In addition, Trust Fund resources will be used to finance panel household surveys on both program participants and non-participants to conduct a quantitative impact evaluation over a short and long term horizon. 42. The results from the above M&E activities will be triangulated to ensure that the Project objectives are on track. These activities are expected to offer sufficient oversight over the appropriate use of project funds, preclude the incidence of malpractice, and maintain good governance in project management. Some of these activities will also be regularly monitored as part of the Governance and Accountability Action Plan (GAAP) (see Annex 7). C. Sustainability Several factors underpin the sustainability of the proposed project. First, there is strong country ownership of the proposed project activities as evidenced by the support offered by the MoHFW during the implementation of the Shombhob Pilot, and for its scale up. Second, public expenditures for SSNs continue to receive priority by the MoF as shown by the consistent spending of about 2 percent of GDP since FY2008 till date. This emphasis is unlikely to diminish with any change in government. Third, there is an increased recognition among policy makers of the importance of improving the quality of SSN expenditures, as illustrated by the NSSS. The concrete recommendations of the NSSS include setting up a child-focused safety net as well as developing a single safety net beneficiary registry – both of which are being initiated by the proposed project. Fifth, the NSSS suggests the consolidation of the numerous SSNs into fewer outcome-based programs and to improve the pro-poor coverage of SSNs. The successful implementation of the proposed project thus will help position ISPP as a flagship SSN that is scaled up incrementally while non-performing programs are crowded out. V. KEY RISKS AND MITIGATION MEASURES A. Risk Ratings Summary Table Stakeholder Risk Moderate Implementing Agency Risk - Capacity Substantial - Governance Substantial Project Risk - Design Moderate - Social and Environmental Low - Program and Donor Low - Delivery Monitoring and Sustainability Substantial Overall Implementation Risk Substantial 14 B. Overall Risk Rating Explanation 43. The overall risk rating for the project is deemed substantial. This rating is driven largely by the high country level governance risk and the low capacity of the implementing agency. Leakage in safety net benefit amounts while not unique to Bangladesh is a formidable challenge. According to IFPRI estimates, the leakage in safety net food transfers at the beneficiary level can range between 2 and 13.6 percent. 31 Given this substantial in-built governance risk, an innovative design of the proposed project is critical. Experience from the implementation of the Shombhob Pilot suggests that the use of electronic cash payments and automated monitoring tools help to mitigate this risk. Thus the investment in the project MIS and payments system will be important mitigating measures for these risks. 44. Whilst LGD has gained some experience in implementing conditional cash transfers through the Shombhob Pilot, the larger scale of the proposed project suggest project activities may further stretch the existing low capacity of the implementing agency. Resources set aside for strengthened management and technology-enabled local level administration will mitigate some of this risk through improvements in beneficiary identification, benefit delivery and grievance mechanisms, and enhanced monitoring and evaluation of the programs. In addition the recruitment of NGO(s) to support implementation will help. However constant oversight by the Bank over these processes will be required. The regular monitoring of the GAAP, which has been jointly prepared with the counterparts, will assist the Bank team in that respect. 45. There is also the risk that improved coordination in safety net delivery by the proposed project will generate opposition from vested interest groups who currently benefit from poor implementation of SSNs. Mitigation measures therefore are an integral part of the project design in that they offer mechanisms to: (i) continue to highlight the important role Union Parishads play in safety net delivery by setting up the SNCs in Union Parishad offices; (ii) ensure beneficiary awareness of their benefits and co-responsibilities; and (iii) make biometric-enabled electronic payments linked to an automated MIS to preempt collusive behavior among local governments and other partner agencies such as NGOs, CCs, and UPOs. VI. APPRAISAL SUMMARY A. Economic and Financial Analysis 46. The project is expected to have (i) a short term impact on poverty; (ii) a medium term impact on selected nutrition indicators, and (iii) a longer term impact on human capital and earnings of beneficiary children. The results of the Shombhob Pilot suggest an estimated reduction of 4 percentage points in poverty headcount (from a rural average of 35 percent) in the project locations, and an improvement in selected nutrition outcomes. Global evidence suggests an improvement in child cognitive development outcomes through early childhood development interventions, leading to increased years of education and greater lifetime earnings. The services provided under the proposed project can thus be expected to bring about an improvement in beneficiary children’s ability to complete school, and thereby secure higher earnings in their 31 Ahmed, A., S. Rashid, M. Sharma and S. Zohir. 2003. “A Study on food aid leakage on Bangladesh” WFP/IFPRI Brief, Washington DC 15 adult life. Based on these assumptions, the cost benefit analysis suggests that the benefits expected from the proposed project outweigh the costs. At a 10 percent discount rate, the NPV of the project will be between US$17 million to US$459 million, with an IRR of about 10.5 – 16.5 percent, depending on the assumptions. These rates of return are consistent with other similar projects, and are conservative estimates since the impact of the cash transfers on consumption smoothing or reducing health expenditure costs are not estimated (see Annex 6 for a detailed analysis). B. Technical 47. The project is technically sound. In particular the introduction of the use of PMT based targeting, the automated MIS, electronic payments and grievance redress mechanisms are based on global good practice examples of CCT programs being implemented in a number of countries (e.g. Mexico, Brazil, Philippines, Pakistan). The design is being appropriately customized to local conditions based on the lessons from the Shombhob Pilot. The MIS and technology-enabled registration and payments system have a good balance between functionality and cost. By supporting the SNCs, the Project is expected to increase the effectiveness in safety net delivery to poor households, and initiating a SSN beneficiary tracking system. Strengthened CCs and UPOs are also able to serve local populations who are outside the scope of the proposed project. 48. Technical and financial inputs provided under the proposed project would also support on-going reforms in social protection. The successful implementation of the proposed project would strengthen safety net delivery at the Union level, while filling a gap in safety net programming. The proposed project, when fully implemented, would cost only about 1.5 percent of the total annual social protection expenditures or about 0.04 percent of GDP. C. Financial Management 49. A fiduciary assessment of LGD indicates a “substantial” risk in financial management. This risk is mainly driven by the large number of cash payments to be made to beneficiaries. While several risk-mitigating measures have been incorporated into the design of the cash transfer process, a number of additional measures will also be undertaken during implementation to improve overall financial management capacity (see Annex 3 and 7 for more details). 50. LGD would appoint two experienced consultants, with qualifications acceptable to the Bank, to coordinate financial management activities under the project. The consultants would support LGD in strengthening budgeting practices, internal controls, fund reconciliations, and other relevant financial functions. Annual external audits of all project components would be conducted by the Foreign Aided Project Audit Directorate (FAPAD), and would be supplemented by additional internal audits twice in the project term, to be conducted by a professional auditing firm. As part of regular monitoring and evaluation activities, third party validations of service delivery quality of ISPP would assess proper and timely receipt of cash transfers by beneficiaries. 51. Financing for all components will be disbursed to a Designated Account. For Component one, eligible expenditures include cash transfers to beneficiaries. For Components two and three, 16 eligible expenditures include payments for goods, works, non-consulting services, consultant services, training and operating costs. Disbursement would initially be made on an advance and replenishment based on regular statements of expenditure (SOEs). After one year of implementation, the Bank would review the quality of financial management performance and may convert the disbursement modality to one based on interim unaudited financial reports (IFRs) including a six-monthly forecast of fund requirements. These forecasts are expected to be produced via the program MIS. For Component one, based on the projected amount of benefit payments to enrolled beneficiaries, funds would be transferred to a dedicated account at the BPO, who would in turn make quarterly payments to individual beneficiary accounts in accordance with the payment list issued by LGD. D. Procurement 52. The fiduciary assessment of LGD also indicates a “substantial” risk in procurement administration. Risks are typical of those in other Government agencies in Bangladesh, and several standard mitigation measures are being applied during both the project preparation and implementation phase. These include strengthening overall procurement capacity, enhancing measures for technical evaluations, and improving transparency in the procurement process. 53. An initial procurement plan covering the entire period of the project will be agreed on during negotiations and the first update will be made immediately following project effectiveness. The procurement plan would subsequently be reviewed and updated on a semi- annual basis in consultation with the Bank. The Bank’s review of selected contracts would be determined on the basis of estimated value thresholds, which may be revised upwards as procurement performance improves. E. Social (including Safeguards) 54. A social assessment was carried out and the project has been classified as category C. However since indigenous people live in some of the project areas, OP 4.10 has been triggered for the project and a Small Ethnic Communities Plan has been prepared and disclosed on August 26, 2014. The purpose of the Plan is to ensure maximum access to the program by indigenous populations. The Plan was prepared on the basis of extensive consultation with indigenous communities and their feedback. Regular consultations will continue to be held with them in accordance with the Plan throughout implementation of the project. The PMU will prepare an annual report on compliance with social safeguards as required by the Bank.Nl Document (PAD) 2013 17 Annex 1: Results Framework and Monitoring BANGLADESH: Income Support Program for the Poorest Project (P146520) Results Framework Project Development Objectives PDO Statement The Project Development Objective is to provide income support to the poorest mothers in selected Upazilas, while (i) increasing the mothers’ use of child nutrition and cognitive development services, and (ii) enhancing local level government capacity to deliver safety nets. These results are at Project Level Project Development Objective Indicators Cumulative Target Values Baseline YR1 YR2 YR3 YR4 YR5 Indicator Name End Target (FY2015) (FY2016) (FY2017) (FY2018) (FY2019) (FY2020) Beneficiaries of Safety Nets programs 0.00 0.00 100000.00 325000.00 600000.00 600000.00 600000.00 (number) - (Core) Beneficiaries of Safety Nets programs - Conditional cash transfers (Number - Sub- 0.00 0.00 100000.00 325000.00 600000.00 600000.00 600000.00 Type: Breakdown) - (Core) Beneficiaries of Safety Nets programs – Female (Number - Sub-Type: Breakdown) - 0.00 0.00 95000.00 308750.00 570000.00 570000.00 570000.00 (Core) Proportion of ISPP beneficiary households in the bottom two expenditure quintiles 0.00 0.00 0.00 70.00 70.00 70.00 70.00 (Percentage) Proportion of ISPP beneficiaries receiving at least 70 percent of the maximum benefit 0.00 0.00 0.00 50.00 60.00 70.00 70.00 amount (Percentage) Number of Unions maintaining a single beneficiary registry of at least five safety net 0.00 0.00 0.00 25.00 50.00 100.00 100.00 programs (Number) 18 . Intermediate Results Indicators Cumulative Target Values Baseline YR1 YR2 YR3 YR4 YR5 Indicator Name End Target (FY2015) (FY2016) (FY2017) (FY2018) (FY2019) (FY2020) Proportion of ISPP beneficiary pregnant women and mothers who fulfill Child 0.00 0.00 0.00 50.00 60.00 70.00 70.00 Nutrition and Cognitive Development (CNCD) co-responsibility (Percentage) Proportion of ISPP beneficiary pregnant mothers who fulfill Ante-Natal Care co- 0.00 0.00 0.00 50.00 60.00 70.00 70.00 responsibility (Percentage) Proportion of ISPP beneficiary mothers who fulfill Growth Monitoring and Promotion co- 0.00 0.00 0.00 50.00 60.00 70.00 70.00 responsibility (Percentage) Proportion of implementing Unions/municipal wards addressing grievance cases 0.00 0.00 0.00 30.00 45.00 60.00 60.00 (Percentage) Periodic beneficiary spot check surveys conducted in sample of Unions/municipal 0.00 0.00 0.00 20.00 20.00 20.00 20.00 wards (Number) Process evaluation of project cycle conducted No No No No Yes No Yes (Yes/No) Impact evaluation of providing cash transfers on behavioural changes among beneficiary No No No Yes No Yes Yes population conducted (Yes/No) Dissemination of monitoring and evaluation reports on annual basis No No No Yes Yes Yes (Yes/No) 19 Indicator Description . Project Development Objective Indicators Data Source / Responsibility for Indicator Name Description (indicator definition etc.) Frequency Methodology Data Collection Beneficiaries of Safety Nets This indicator measures the number of Annual Administrative data from PMU programs (number) individual beneficiaries covered by safety MIS measuring the nets programs supported by the Bank. cumulative number of Safety nets programs intend to provide ISPP beneficiaries social assistance (kind or cash) to poor and vulnerable individuals or families, including those to help cope with consequences of economic or other shock. Beneficiaries of Safety Nets Follows the safety nets programs’ Annual Administrative data from PMU programs - Conditional cash classification used in SP Atlas. MIS measuring the transfers (number) cumulative number of ISPP beneficiaries Beneficiaries of Safety Nets This indicator measures female participation Annual Administrative data from PMU programs - Female (number) in SSN programs. It has the same definition MIS measuring the as the "Beneficiaries of Safety Nets cumulative number of programs" but applies only to female. This ISPP female beneficiaries indicator will yield a measure of coverage of SSN projects disaggregated by gender (in absolute numbers) Proportion of ISPP beneficiary This indicator measures the accuracy of Annual Baseline and endline PMU households in the bottom two beneficiary targeting. household surveys expenditure quintiles Administrative data from MIS Proportion of ISPP beneficiaries This indicator measures the extent of Annual Administrative data from PMU receiving at least 70 percent of utilization of services and beneficiary MIS the maximum benefit amount compliance. Number of Unions maintaining a This indicator measures the number of Annual Lists maintained at SNC PMU single beneficiary registry of at project unions SNCs where a single registry 20 least five safety net programs of beneficiaries is maintained for at least 5 safety net programs (including the ISPP). The programs which will be covered under the single registry are not specified so as to allow flexibility and will depend upon the specific programs operating in that union. . Intermediate Results Indicators Data Source / Responsibility for Indicator Name Description (indicator definition etc.) Frequency Methodology Data Collection Proportion of ISPP beneficiary No description provided. Semi-annual Administrative data from PMU pregnant women and mothers MIS who fulfill Child Nutrition and Cognitive Development (CNCD) co-responsibility Proportion of ISPP beneficiary Mothers utilizing ante-natal care services Semi-annual Administrative data from PMU pregnant mothers who fulfill offered by the Ministry of the Health and MIS Ante-Natal Care co- Family Welfare responsibility Proportion of ISPP beneficiary No description provided. Semi-annual Administrative data from PMU mothers who fulfill Growth MIS Monitoring and Promotion co- responsibility Proportion of implementing No description provided. Annual Administrative data from PMU Unions/municipal wards PMU addressing grievance cases Periodic beneficiary spot check This indicator measures the number of Semi-annual PMU PMU surveys conducted in sample of Unions/municipal wards where spot checks Unions/municipal wards have been conducted by the monitoring NGO. Process evaluation of project Process evaluation will be conducted during Once PMU PMU cycle conducted the mid-term of the project 21 Impact evaluation of providing Baseline and endline surveys to be Twice PMU PMU cash transfers on behavioural conducted in Year 2 and Year 4 changes among beneficiary population conducted Dissemination of monitoring and The PMU will publish M&E reports based Annual PMU PMU evaluation reports on annual on data generated from MIS basis 22 Annex 2: Detailed Project Description BANGLADESH: Income Support Program for the Poorest Project (P146520) 1. The proposed project includes the following three components: (i) Cash transfers for beneficiary mothers; (ii) Enhancing local government capacity; and (iii) Monitoring and evaluation. The first component finances cash payments to poorest mothers if they are pregnant and/or have children below the age of 60 months. To receive these cash transfers, mothers are required to fulfill certain co-responsibilities linked to the growth and development of their children. The second component provides the necessary inputs to LGD and the participating Upazilas to establish project implementation structures at the Union, Upazila, District and central level, while the objective of the third component is to help monitor implementation and assess progress in achieving project outcomes. 2. Component 1: Cash transfers for beneficiary mothers (US$267 million). The main purpose of cash transfers made under this component is to provide income support to poorest mothers to reduce their household level poverty, while incentivizing them to improve their use of services that are important for the nutrition and cognitive development of their young children. Global research suggests ensuring adequate nutrition prenatally and in the first two years after birth can prevent devastating permanent effects on intelligence and brain development, thereby improve the long run earnings potential of children. Rapid brain and physical development, social relationships, and environments work together to create phenomenal advances in children’s abilities during this time frame 32 (see Figure A2.1). Any medium to long term strategy for poverty reduction therefore requires investing in the socio-economic environments of poor children during their early childhood years. 33 Figure A2.1: Timing of the Human Brain Development 3. To harness this window of opportunity, this component will finance quarterly cash transfers to eligible mothers. Eligibility will be determined by the following two characteristics: (i) the beneficiary household will have to belong to the bottom two expenditure quintiles as 32 Hawley, T. 2000. “Starting Smart: How Early Experiences Affect Brain Development.” 33 Nudsen et al. 2006. “Economic, Neurobiological and Behavioral Perspectives on Building America’s Future Workforce,” World Economics, July-September 2006 23 identified by the BPD, 34 and b) such households must have pregnant women and/or mothers of children below the age of 60 months. There would be four types of co-responsibilities depending on the household demographic composition (see Table A2.1 below). Cash transfers will be given conditional on utilizing the following services: (i) up to 4 antenatal care visits by pregnant beneficiaries; (ii) monthly growth monitoring and promotion (GMP) of children from 0-24 months; (iii) quarterly GMP for children from 2 to 5 years of age; (iv) monthly attendance at child nutrition and development (CNCD) awareness sessions by all eligible beneficiary mothers. These CNCD sessions will essentially link GMP activities with essential early childhood development (ECD) information for mothers. The structure of the incentives is purposively designed to emphasize the importance of GMP among 0 to 24 month old children, and that of ECD awareness 35 among all children below 5. There is a natural exit mechanism whereby the maternal benefit ends once the mother gives birth, and ISPP benefit ceases once the child reaches 5 five years of age. It is expected that not all eligible households will fall under these simple categories. There may be cases of children who belong to eligible households but do not have a mother, or that two families are linked to one male household head. Further details regarding program rules including possible exceptions to cater to unique cases will be described in the ISPP Operations Manual. 4. The proposed project is mindful of the fact that the ISPP should not provide incentives to poor families to have additional children. Bangladesh has invested substantially since the 70s and 80s in intense grass roots campaigns and in the fielding nationwide family planning workers to bring down the Total Fertility Rate 36 of 6.3 in 1975 to almost replacement level of 2.3 in 2011. To remain consistent with the country’s family panning policy, ISPP will offer benefit payments to only the first and second born child. Such a policy also helps to prevent any potential gender bias in the household selection of the child to be taken for GMP and CNCD sessions. This implies the average size of the monthly transfer would be between BDT 1200-1800, which would be around 15 - 23% of the estimated average monthly per capita expenditure of the target population who are expected to consume at the lower national poverty line. 37 However the benefit size will be reviewed during the mid-term review of the proposed project to make any necessary inflation-adjustment to avoid the benefit from being inadequate over time. Evidence from CCT programs in other developing countries suggest limited labor disincentive impacts especially when the level of benefits is within 20 percent of household income. 38 Thus even if some upward adjustments have to be made to the benefit amount, there is sufficient room for the amount to increase without exceeding this “work disincentive threshold.” Moreover, recent macroeconomic trends suggest that inflation in Bangladesh has been relatively stable in recent years. 34 Emphasis will be on the poorest households determined by their poverty scorecard as assigned by the BPD and managed by BBS. 35 While growth promotion and early childhood development interventions can cover a gamut of services, to ensure simplicity and account for capacity constraints, the package offered by the proposed project will include very basic but essential services. 36 TFR refers to the number of births per women aged 15-49 years. 37 Based on the 2010 national poverty line (adjusted for inflation). The benefit size is almost 2.5 to 3.5 times the average benefit offered by other SSNs. 38 Grosh, M. et al. 2008. “For Protection and Promotion: The Design and Implementation of Effective Safety Nets.” World Bank: Washington DC . 24 Table A2.1: Eligible payments, frequency and amounts Eligible Co-responsibility Benefit amount Payment Payment beneficiary registered condition Pregnant women Ensure quarterly BDT 200 per visit Every time No visit, no antenatal care visit ANC visit is payment completed* All beneficiary Take child for height BDT 500 per visit (total Quarterly Payment allowed mothers with and weight check of BDT 1500 in one if at least two children aged 0- every month quarter plus a bonus visits have been 24 months BDT 500 if all three completed in visit are completed in a three months** quarter) All beneficiary Take child for height BDT 1000 Quarterly No visit, no mothers with and weight check payment children aged every 3 months 25-60 month All beneficiary Attend child BDT 500 per visit (total Quarterly Payment allowed women nutrition and of BDT 1500 in one if at least two (pregnant development quarter, irrespective of visits have been women and education sessions number of children completed in mothers) every month enrolled) three months** *GoB recommends at least 4 ANC visits. **Only BDT 1000 will be received if only two out of three visits are completed. Any less will result in suspension and possible termination of the benefits if the households do not comply even after the two successive warnings. Details will be laid out in the Operations Manual. 5. Table A2.1 describes the co-responsibilities for the three types of beneficiaries within the list of eligible beneficiaries. First, mothers (current or future) who are expecting their first or second child will have the incentive to complete all four ANCs visits that are recommended by the GoB as well as attend monthly sessions on CNCD issues. Meeting these co-responsibilities will reward the pregnant mother with BDT 500 per visit to the CNCD session plus an additional maximum of BDT 300 for completing the ANC visits. Second, mothers whose first or second child is below 24 months, will be expected to attend monthly GMP visits to measure the height and weight of the child and maintain the GM chart that will be given to her. Being able to understand the relative growth of her child with the help of this growth chart proved to be a very powerful motivational tool in the Shombhob Pilot: tracking the growth of their children both informed mothers of the health of their child and motivated them to take extra care when their weight decreased due to an illness. Relating the growth of their children with their nutrition in the nutrition awareness session in the Pilot also played an important role. Thus under the proposed project, the incentive for mothers of children below 24 months (which is the most critical window for child nutrition and growth) are the largest. In addition to BDT 500 for attending the CNCD session monthly, if mothers are able to maintain regular monthly GMP over one quarter, they will be entitled to an extra BDT 500. Thus mothers in this group with one child below 24 months will be able to collect a maximum of BDT 3500 in one quarter. Third, mother with children between 2 to 5 years, will be asked to come for quarterly GMP visits of their children but expected to attend monthly the CNCD sessions. This is the age category while child stimulation is important and accordingly the incentive for the latter co-responsibility is higher than GMP. The details regarding participation and payment rules including various exceptions 25 will be provided in the project Operations Manual. The following provides brief descriptions of the proposed basic set of services on CNCD which will be ensured by the proposed project. 6. ANC services: Currently community clinics offer basic antenatal care services. These services include measuring blood pressure and weight; detection of anaemia, jaundice, oedema, albumin in urine, sugar in urine; and counselling on birth planning and recognition of danger signs. Beneficiary pregnant mothers will be incentivized to seek at least four ANC visits from the CC with payments of BDT 200 per visit. Third party monitoring will be conducted on a regular basis to ensure these services are available in the project locations. 7. GMP services: All children under 24 months of age of beneficiary households will have their height and weight recorded every month and plotted on a growth chart according to age, while beneficiary children between 2 and 5 years of age will have their height and weight monitored quarterly. The mother will receive a copy of the GMP chart that they will bring along with their child to every GMP session which will be held at the Community Clinics. The same information will be stored in the ISPP MIS. The hired NGOs will ensure follow up with mothers to discuss the growth of their children to help them understand the overall health of their child. 8. CNCD sessions: These sessions will essentially focus on combining selected GP activities with early childhood development issues. To help mothers who are expected to have limited educational background, these sessions will introduce a single nutrition and a child cognitive development related topic each month. Flipcharts, posters and other media materials will be used to help reinforce key ideas and concepts. The sessions will provide general age specific nutrition information. Having one key topic each month will provide incentives for families to come back as well as make sure that they are not getting the same information each time. During these sessions, child cognitive development topics (some of which are illustrated in Table A2.2 below) will be presented in the form of scenarios to promote interaction. Discussions will be tailored to different groups of mothers/families. 9. As part of support to the overall health sector, the Bank-supported HSDP is helping to improve the availability of a broad range of services that are critical for maternal health and child nutrition outcomes. However recent analysis shows that there are inequalities in the utilization of health services between the rich and poor. For instance poorest households are 33 percentage points less likely than the richest households to use health facilities for treatment of common childhood illnesses. 39 Low utilization of nutrition-sensitive services offered at the CCs are has also been noted in the most recent evaluation of the National Nutrition Services (NNS) 40 – the main GoB instrument that is trying to improve nutrition outcomes in the country. By helping to strengthen the capacity of CCs, the proposed project will thus help to improve the utilization of basic services offered at the CCs particularly by the poorest mothers, thereby promoting the objectives of the HSDP, as well as strengthening CCs which is a flagship project of the GoB. 39 Niport. 2011. “Bangladesh Demographic and Health Survey 2011: Preliminary Report.” 40 World Bank. 2014. “What progress in the implementation of the National Nutrition Services (NNS) Program? Results of an Operational Assessment.” draft 26 Table A2.2: Topics to be discussed during CNCD sessions Audience Topic: Child Nutrition Specific items Pregnant/Expecting Feeding practices for infants Education regarding women and Mothers 0-6 months • need for exclusive breastfeeding up to 6 months of children 0-6 months • initiation of breastfeeding within half an hour of delivery • avoiding honey/water and other commonly given items to baby soon after birth • disadvantages of powder/cows milk/bottle feeding • maternal health care during pregnancy and breastfeeding Addressing issues and steps to take with barriers to breastfeeding such as: • when maternal milk flow is not adequate • in cases of maternal illness preventing breastfeeding such as mastitis Anticipatory guidance • Graduated approach to introduction of appropriate complementary feeding on completion of six months Pregnant/Expecting Anemia prevention and Education regarding women and Mothers adequate nutrition for • Need for intake of adequate calories by pregnant of children 0-6 expecting/breastfeeding women months, mothers • Signs of anemia and need for intake of increased husbands/other adult family members iron containing foods and supplementation if needed • Need for decreased workload to avoid risk of preterm labor and other complications Key decision makers Appropriate feeding for infants Building awareness and education for the need to such as fathers, 0-6 months exclusive breastfeeding and points mentioned above. mother-in law, father in law Mothers/caregivers of Immunizations and early new Education regarding well baby care such as children 0-6 born care • proper bathing-drying-wrapping practices, • appropriate hygiene practices including hand washing • immunizations • need for vitamin A supplementation for mothers and children Key decision makers Health issues and early new Education and awareness building for new born care such as fathers, mother born care topics above, importance of immunizations and in law, father in law appropriate steps for managing common childhood conditions. Mothers/caregivers/ Continuation of breastfeeding Encouraging continuation of breastfeeding based on household members IYCF recommendations for infants 7-23 Support for possible barriers such as mom going to 27 Audience Topic: Child Nutrition Specific items months work/pregnant. Complementary foods Steps to introduce complementary food/weaning introduction foods so that infants are • fed properly • given adequate quantities • fed in a timely fashion • safe practices are used • getting fed appropriate minimum number of times per day according to age and breastfeeding status Dietary diversity Education and awareness building on what IYCF entails (e.g. what types of food to feed and how often): • dairy: milk other than breastmilk, cheese or yogurt or other milk products; • foods made from grains, roots, and tubers, including porridge and fortified baby food from grains; • vitamin A-rich fruits and vegetables; • other fruits and vegetables; • eggs; • meat, poultry, fish, and shellfish (and organ meats); • legumes and nuts; • foods made with oil, fat, butter Education on appropriate amounts based on child’s age and needs. Education on how families can use their limited resources such as vegetable patch, pond, hen coop to improve dietary diversity. Education on the importance of using iodized salt and the importance of fortified foods (when available and affordable) Mothers/caregivers/ Need based supplementation Learning how to recognize that a child is malnourished household members and complications that can arise as a result of that. for infants 7-23 *Severely malnourished Education regarding how to increase calories using months who are children will be determined by • high calorie foods that are easily accessible/ severely growth indicators (Ht and wt affordable malnourished* <<3rd percentile for age) or • use of supplement sachets designed principally for dropping two percentile lines children 6 – 24 months of age . 60 single-dose over 2 months. sachets for each severely malnourished child, consumed over a 60 to 120 day period (no more than one sachet a day should be used for a child) Mothers/caregivers of Health issues related to nutrition Education regarding steps to take when a child has a children 0-23 months • diarrheal illness • URI/pneumonia • Fever Increasing awareness of problems that can arise if infants are not getting adequate nutrition and steps to 28 Audience Topic: Child Nutrition Specific items prevent • anemia • night blindness Community Leaders, Advocacy related activities for Education and building support for the need for religious leader infant feeding practices and exclusive breastfeeding for infants 0-6 months, general health, support for openness to learning from health workers, need for change immunizations etc Audience Topic: Child Development Specific items Pregnant/Expecting Bond building with new born Education regarding mothers and Mothers infants • Using breastfeeding time for building bonds with of children 0-6 baby months, • Making eye contact, holding baby and talking/singing to baby to stimulate the newborn • Using rattles/colorful objects for visual stimulation Mothers/care givers of Developing motor skills in Education regarding when and how children develop children 6 mo to 5 children their gross and fine motor skills and ways to enhance years them with the use of simple household items. • Holding up to stand • Providing age appropriate items (foods, pencils, crayons) to allow children to develop their hand eye coordination Mothers/caregivers of Developing cognitive skills in Education regarding the use of household items and children 6 mo to 5 children simple toys to enhance memory and analytical skills in yeas children. • Picture books to engage caregiver and child together for learning • Memory games • Building toys Mothers/caregivers of Developing social and language Education regarding the importance of talking , children 6 mo to 5 skills in children singing, story telling from a young age to develop yeas language in children. Awareness on maternal depression Mothers/caregivers, Parenting/disciplining children Importance of consistency and boundaries community leaders Pros and cons of corporal punishment Listening of children/understanding their emotions and viewpoints. Mothers/caregivers, Protection against injury • Education regarding environmental hazards for all community leaders ages • Sleeping arrangements for infants • Fall risk reduction • Supervision • Drowning risk reduction • Fire/burn risk reduction 29 10. Proposed locations. The proposed project will be located in 42 of the poorest rural Upazilas with a total poor population of over 1.6 million households. The selection of these areas was based on the following technical criteria: (i) Upazila level poverty rate of 40 percent or higher (2010 BBS Poverty Map), and (ii) the probability of under-nutrition among 50 percent of children below the age of five of more than 70% (WFP/BBS Report on Local Estimation of Poverty and Malnutrition in Bangladesh 2004). These locations are also contiguous to each other which would make monitoring of project implementation easier and efficient. Table A2.3 provides a summary list of these proposed locations while a detailed list is provided in Annex 9. A supply side assessment of these services was conducted in the proposed locations to ascertain the availability of these services. The assessment found that while most of the Union Parishad Complexes are well established, not all CCs are well-equipped to deliver the necessary ANC and GMP services. This finding is also consistent with the results of the 2014 Operational Assessment of the NNS. The proposed project therefore have made provision to provide additional inputs to CCs where needed - such as procuring GMP equipment and ANC related medical instruments, as well as secure the services of a NGO(s) to provide additional implementation support. Table A2.3: Proposed project locations Poor Upazila Sl. Division District Upazila Population^ Population+ Unions 1 Dhaka Jamalpur 7 2,384,810 1,218,170 68 2 Dhaka Mymensingh 12 5,313,163 2,679,825 146 3 Dhaka Sherpur 5 1,412,601 684,231 52 4 Rangpur Gaibandha 7 2,471,681 1,186,765 82 5 Rangpur Kurigram 9 2,150,974 1,369,315 72 6 Rangpur Lalmonirhat Hatibandha* 242,814 92,474 12 7 Rangpur Nilphamari Jaldhaka* 354,287 154,264 11 *These locations have been selected as they had previously been covered by the CCT pilot project. This would help build on the implementation capacity already in place as well as provide continued cash assistance to beneficiary families. ^ as per Population & Housing Census 2011. + calculated on the basis of Bangladesh Poverty Map 2010 11. Component 2: Enhancing local level government capacity (US$32.87 million). This component would provide the necessary inputs to LGD to facilitate the implementation of the proposed cash transfers. This will include strengthening the capacity of: (i) Union Parishads to facilitate beneficiary identification, enrolment, appeals, as well as administer grievances and case management; (ii) CCs to deliver the ANC and GMP services, and the CNCD awareness sessions with the help of NGOs; and (iii) union Post Offices to make electronic payments to beneficiaries using the Postal Cash Cards (PCCs) upon compliance with co-responsibilities. The Union Parishad Act of 1998 (amended in 2009) currently mandates Union Parishads to determine the list of safety net beneficiaries as per program eligibility criteria as well as the delivery of benefits. However surveys show that targeting criteria for some programs are not always applied, and these beneficiary lists become subjective and vulnerable to political capture. In some cases indicators used to identify the poor are difficult if not impossible to observe and verify. Programs are often fragmented, administered by multiple ministries, and have considerable overlap. Multiple and ineffective targeting systems, combined with the large number of intermediaries in the system, increase targeting errors. Studies show that a more objective targeting system that 30 improves the beneficiary identification can help reduce targeting errors. 41 This is the main rationale for the development of the Bangladesh Poverty Database (BPD) by BBS. Coupled with this targeting system, an effective local level administration system that helps to systematically enroll safety net beneficiaries, verify and monitor their claims and payments will make safety net delivery more transparent and effective. To ensure such a systematic implementation of Shombhob, this component will help to set up a “Safety Net Cell” (SNC) within existing Union Parishad Offices, staffed by one Safety Net Program Assistant (SPA). An enrolment agency will be hired to help manage the initial large volumes of enrolments in ISPP in the first two years of implementation. The SNC will mainly liase with the elected members of the Union Parishad and will report to the local level administration officials namely the Upazila Nirbahi Office (UNO). Training of the relevant government officials to implement a grievance redress system through the office of the UNO and District Commissioner (DC) via the SNC will also be financed. A large portion of GoB contribution will finance these capacity development costs. Box A2.1: Characteristics of key safety net programs Public works programs: Food For Work and Test Relief distribute food grains (rice and wheat) as wage payment to both poor male and female workers. The Rural Employment Opportunity for Public Asset (REOPA) program provides cash wages and training for income-generation activities to participating female beneficiaries. In 2008, the Government of Bangladesh introduced the Employment Generation for Hard Core Poor (later known as EGPP) which also provided cash wages. All these programs require participants to do physical work for building and maintaining rural infrastructure. They are generally self-targeted because the poor are typically the only people willing to take on onerous, low-paying jobs requiring manual labor, though the performance varies by program. Training programs: The Vulnerable Group Development (VGD) program exclusively targets poor women and provides a monthly food ration for 24 months. Although it was introduced as a relief program in the mid-1970s, it has evolved over time to integrate food security with development objectives. The development package includes training on income-generating activities; awareness-raising for social, legal, health, and nutrition issues; and basic literacy and innumeracy. Beneficiaries of VGD programs are selected by the Government administrative structures. Education programs: The Food for Education (FFE) program, established in early 90s, distributed monthly food grain rations to poor households if they sent their children to primary schools. Due to governance concerns FFE was terminated in 2002 and has been replaced by the cash-based Primary Education Stipend program (PESP). The School Feeding (SF) program distributes micronutrient-fortified energy biscuits to primary school children. Bangladesh also pioneered conditional cash transfers targeted at girls enrolled in secondary schools through the Female Secondary School Assistance Program (FSSAP). The program was redesigned in 2008 and renamed the Secondary Education Access and Quality Enhance Program, and now includes boys from poor families as well. Relief programs: These programs are designed as a mechanism for mitigating the consequences of disasters like floods, cyclones, and other natural calamities. Currently, there are only two such programs: Vulnerable Group Feeding (VGF) and Gratuitous Relief (GR) programs. Unlike other programs, these programs have no pre-set criteria or conditionality for participation. They are relief programs that try to help the poor cope during times of natural disaster and smooth their consumption. VGF also provides one time transfers to poor households during festivals. Cash Assistance Programs for disadvantaged groups: These programs are essentially unconditional cash transfers and include the Old-Age Allowance Scheme; Allowance for Widowed, Deserted, and Destitute Women; Honorarium Program for Insolvent Freedom Fighters; Fund for Housing for the Distressed; Fund for Rehabilitation of Acid Burnt Women and Physically Handicapped; and Allowance for the Distressed and Disabled Persons. 41 According Sharif, I. (2009) “Building a Targeting System for Bangladesh based on Proxy Means Testing,” SP Discussion Paper No. 0914, The World Bank. 31 12. Given the legal mandate of Union Parishads to support the implementation of all SSNs, the SNCs will function as a safety net “one stop shop” for providing citizens with information on these programs, their eligibility criteria, etc. (Box A2.1 illustrates the main types of SSNs operating at the national level). The SPA will be responsible for facilitating this information, and for compiling the beneficiary lists (and their updates through new enrolments) major SSNs that operate nationally (e.g. EGPP, FFW, TR, Vulnerable Group Feeding, Gratuitous Relief, Old Age Allowance, Widow Allowance, etc.) in addition to managing the ISPP beneficiary lists. Such local level coordination will allow SNCs to track SSN beneficiaries receiving benefits from different programs in each Union. This information can eventually feed into the central level beneficiary registry tracking system being developed by the Ministry of Finance (MoF) with support from DFID, and the MoDMR for its programs (FFW, EGPP, TR, VGF and GR) as part of the SNSP project. The SNC over time would then have the potential to function as the common administrative platform (e.g. targeting, enrolment, complaints, appeals and case management) for all SSNs at the local level (see Box A2.2 for details). 13. One of the key factors for the success of CCTs is to ensure that the supply side is well- established and can meet the demand for increased services incentivized by the cash transfers. This implies that the staff in the CCs in the project locations will need to ensure regular service provision as well as handle a much larger volume of users. Thus to ensure ISPP beneficiaries are able to fulfill their co-responsibility, and to avoid over-burdening the CC staff, a NGO will be hired to extend ANC services and GMP services to ISPP beneficiaries when required as a back up to the CC. This NGO will also be responsible for offering the awareness sessions on CNCD. Working with government health workers is nothing new for NGOs in Bangladesh. The National Nutrition program (NNP) that preceded the NNS, in fact was totally implemented by NGOs. One of the recommendations made by the recent draft Operational Assessment of NNS includes the use of NGOs to provide reinforcements to CCs so that the capacity of the health workers can be strengthened as well as a greater outreach and coverage of the population can be achieved. 14. Transparency in payments is fundamental to ensuring that safety net beneficiaries are receiving their full entitlements. To support the BPO payments system for Shombhob beneficiaries, the component will help procure the hardware and software needed to install a biometric-enabled system that links electronic payments with beneficiary unique identity and compliance with their respective co-responsibilities. This will be made possible by collecting beneficiary biometric data (e.g. 10 finger prints) at the time of enrolment and issue smart PCCs. These cards will be used at POS machines with finger print scanners for both registering attendance at GMP and CNCD sessions, and when receiving ANC services at the CCs. Every time attendance is registered to fulfil beneficiary co-responsibilities, the associated cash payment will be automatically uploaded to the beneficiary PCC. Thus the same PCCs will also be used to withdraw payments at the Union Post Offices (UPOs). Thus this IT-enabled system will allow for better coordination between the three sets of community institutions – the SNC, the CC, and the UPOs – while simplifying participation in ISPP by poor often illiterate mothers. Once this G2P payments platform is set up, it can be availed by other cash based SSNs if they can also adopt similar electronic payments. The coordination between these three local entities will be supervised by the UNO (as per the rules of business) who will be assisted by a Safety Net Program Supervisor (SPS). The SPS will liaise with the Bangladesh Bureau of Statistics (BBS) to determine the beneficiary lists from the Bangladesh Poverty Database (BPD); (ii) the 32 Bangladesh Post Office (BPO). All of these activities will be underpinned by an Operations Manual, as well as MOUs signed by LGD with BBS, and Service Agreements signed with the DGHS and BPO. Box A2.2: Processes in the delivery of cash transfers Targeting is the first – and a one-time – process which would be split in several stages. First, there would be a public information campaign to alert potential beneficiaries about the program. In parallel, SPAs would receive training on how to identify potential beneficiaries (the “extreme poor”) based on the BPD list. Second, the list of “eligible poor households” will be determined. Enrolment is the second – and a one-time – process entailing formal registration of selected households in ISPP to become beneficiaries, i.e. those households that include pregnant women and/or mothers with children below the age of five. This process will: verify household information; orient beneficiary mothers on program rules; identify children who are eligible for difference co-responsibilities. Further enrolment sessions will be held if additional beneficiaries can be absorbed by the CCT program. Payment is a recurring process which will commence after enrolment as per a fixed annual schedule for the entire duration of the ISPP. Payments would be made on a quarterly basis. The first payment would be made in full to work as an incentive for beneficiary mothers (other household representatives would be entertained in cases where the children’s mother is deceased). The payment amount due would be generated by the MIS based on the number of children in the household and compliance information – penalties would be applied as described in the Operational Manual. Compliance (Verification) is a recurring process which checks whether ISPP co-responsibilities are being met (for the entire duration of the project), in order to prepare payment lists for beneficiaries and identify problems. The compliance process involves the data collection on attendance at ANC and GMP visits at CCs and attendance at CNDC sessions via the POS machines. Every time a beneficiary mother attends one of these sessions, she will have to swipe her PCC and register her attendance using her finger print. Case Management is an ongoing process during the payment-compliance cycle which seeks to track changes in beneficiary household information. Changes which the ISPP will need to be constantly apprised on include: increase in number of children or household members (births and adoptions); reduction in number of children or household members (deaths or transfers); change of address; household moving outside the Union; change of household representative collecting payment; etc. Grievances regarding payments may arise when the household has complied with its co-responsibilities, but there is an incorrect deduction in the payment receipt. Such mistakes may occur due to improper data entry into the MIS or even due to more extreme situations such as fraud committed by program stakeholders. Complaints regarding quality of services may include: delays in service; general misbehavior by program staff, refusal to accept formal complaints; fee charging for free services; allegations of bias in determination of program eligibility; among others. Prescribed complaint forms will be made available at the SNCs. Completed forms must be submitted to the SPA, who will issue applicants with a stamped receipt confirming that the form has been received. SNC staff will then make an inventory of the complaints received, on a fortnightly basis, and enter the information into the MIS. In the case of valid complaints pertaining to payments, the office of the UNO will make the correction in the payment amount and inform the banks to release the adjusted amount with the next payment. Appeals. After the identification and poverty verification stages using the BPD are complete, the list of eligible households is published. Households that feel they have been mistakenly or unfairly excluded as potential beneficiaries and believe they meet the eligibility criteria can submit an appeal to the SNC using prescribed forms clearly stating the reasons for appealing. 15. A Grievance Redress System (GRS) will address beneficiary complaints concerning targeting, payments, information updates, and complaints on quality of service. The ISPP MIS will include a grievance redress module, which will be managed by Grievance Redress Officers (GROs) who will help keep a record of these grievances, and monitor the details of cases lodged, 33 resolved cases, pending cases and action taken. Tracking of these grievances also provide additional insight on the challenges associated with implementation. A feedback loop that includes informing the complainant about the action taken on their complaints, and feeding this information into the implementation of the program, will be a key aspect of the GRS. The proposed ISPP will need the help of the UNO and the DC who will be the GROs at the Upazila and District levels respectively, while the PD will act as the GRO at the central level. 16. To support the G2P payments system, the component will help procure the hardware and services of the BPO to facilitate and monitor beneficiary cash payments, and link them electronically to compliance with beneficiary co-responsibilities. Training of the relevant government officials to implement a grievance redress system through the office of the UNO and District Commissioner (DC) will also be financed. This component will also finance any other inputs required to implement the conditional cash transfers. This will involve procuring POS machines with finger print scanners for beneficiary compliance monitoring – i.e. attendance at GMP, ANC and CNCD session. Specifically the component will finance the following outputs: a) ISPP Operations Manual, b) Common SSN beneficiary registry, c) Biometric enabled ISPP beneficiary enrolment system, d) Grievance redressal mechanisms to track complaints regarding targeting errors and payment irregularities, e) Training of staff (CCs, SNC, UPO) to implement cash transfers and manage beneficiary compliance, f) Provision of operational support services to the Project Management Unit, g) Transport facilities for monitoring of project activities, h) Hardware support for a platform for the payment of Cash Transfers to Beneficiaries and for community clinics, i) Retention of the services of firms and non-governmental organizations to provide support for the implementation of the Project. 17. Component 3: Monitoring and evaluation (US$3.5 million). A robust monitoring and evaluation (M&E) framework will be critical to assess progress in achieving the project’s objectives, and the impact of cash transfers on household poverty and on nutrition and child cognitive outcomes. This component will thus provide the necessary inputs to LGD to monitor beneficiary selection, enrolment, compliance with co-responsibilities, payments, case management as well as any grievances or appeals. To facilitate these activities, this component will develop an automated Management Information System (MIS) by building on the existing Shombhob Pilot MIS. Modules for beneficiary enrolment, compliance, payments, and grievances will be developed. This MIS will be linked to the MIS set up by the DGHS to share data on service utilization by ISPP beneficiaries. In addition, an effort will be made to develop an interface with the MISs being built by BBS, MoF and MoDMR to allow central review of beneficiary information. 18. To ensure that the project activities are being carried out effectively, this component will also support third party monitoring which will cover: (i) an annual evaluation of the project cycle processes to assess administrative issues and constraints for a sample of locations; and (ii) bi- 34 annual knowledge, attitude and practice (KAP) assessments on a random sample of beneficiaries to track project outcomes. The annual process evaluation will help assess and identify areas that require remedial measures and course correction, and thus will be used to inform necessary changes and updates needed to the Operations Manual. To track the extent to which beneficiaries are improving their knowledge about nutrition and child cognitive development and actually changing behavior, beneficiary surveys will be conducted twice a year. A random sample of ISPP beneficiaries will be interviewed 20 randomly selected unions. These interviews will also assess beneficiary satisfaction with the overall implementation of ISPP. Additionally both qualitative and quantitative evaluations will be conducted to assess the impact of the project activities on household poverty and CNCD outcomes based on household level surveys financed by Trust Fund resources. Thus the component will help to finance the following outputs: a) A MIS system that allows for the monitoring of beneficiaries (and is linked with the DGHS and BBS MIS) b) Process evaluations c) Bi-annual assessments of beneficiary knowledge, attitude and practices (KAP) on CNCD d) Qualitative evaluation based on focused group discussions 35 Annex 3: Implementation Arrangements BANGLADESH: Income Support Program for the Poorest Project (P146520) Project Institutional and Implementation Arrangements Overview 1. The proposed project will set up an income support program for the poorest mothers linked to their utilization of basic CNCD services, while enhancing the capacity of local level government institutions in the delivery of SSNs. Fundamentally important to the success of these conditional cash transfers is the need to have the appropriate institutional and implementation arrangements to: (i) identify eligible beneficiaries for ISPP, enroll them into the program, and address their grievances and/or appeals; (ii) supervise and ensure the delivery of the required ANC services, and GMP and CNCD sessions at the CCs; (iii) monitor beneficiary compliance with their respective co-responsibilities and ensure associated timely payments; and (iv) coordinate with Upazila level officials of other line Ministries that implement SSNs in the project locations. This set up will require LGD to forge partnerships with the following government agencies: (i) the BBS to determine the list of potential poor households in each union; (ii) the DGHS to work with CCs to coordinate the ANC visits and GMP sessions, and facilitate the CNCD awareness sessions; and (iii) the BPO to facilitate biometric-enabled electronic payments. In addition LGD will be recruiting one or more NGOs for conducting the CNCD workshop and sessions, as well as supporting the CCs in ensuring ANC visits and GMP sessions. The need to coordinate with the above stakeholders at the local level make the LGD - given its mandate to facilitate and coordinate service delivery by all line ministries - well placed to implement the proposed project. 2. A Project Steering Committee (PSC) chaired by the Secretary, LGD, will advise and guide the implementation process. The PSC is expected to include representatives from any ministry, division, department or agency, which it finds useful in coordinating and determining strategy. This Committee will provide an oversight function to ensure that project activities follow the appropriate parameters and are well coordinated. Specifically, the PSC will be responsible for the following: (a) providing policy advice and operational guidance particularly in relation to strengthening local level safety net administration; (b) reviewing financial and physical progress; (c) resolving any implementation problems and addressing grievances; (d) overseeing integration of results and findings from activities into operational processes; (e) providing any other necessary directions for effective implementation. 3. A Project Implementation Committee (PIC) chaired by the Project Director, will assist in the supervision of the project. The PIC is expected to include representatives from BBS, DGHS, and BPO, as well as from any ministry, division, department or agency, which it finds useful in coordinating project implementation and monitoring issues. This Committee will ensure that project implementation follows both Government and Bank rules and regulations. Specifically, the PIC will be responsible for the following: (a) supervising the implementation team; (b) providing advice for timely implementation of scheduled activities; (c) monitoring and evaluating implementation progress and suggesting necessary course corrections; (d) reviewing the performance of project personnel and quality of deliverables; (e) resolving issues and 36 conflicts that may emerge during implementation; (f) facilitating coordination and convergence with other line ministries/divisions/departments/agencies; (g) keeping the PSC apprised on overall performance and other key issues relating to the project. 4. The project implementation will be led by a Project Director (PD), not below the rank of Joint Secretary, to ensure smooth implementation and supervision of the project by the PMU set up at the LGD. The PD will be assisted by a Deputy Project Directors (DPD), to conduct day-to- day project management specifically linked to the administration of the cash transfers, and oversee the activities focused on the coordination with the stakeholders at the local level. The PMU will also comprise of specialists hired as consultants for the project period. These positions would include two Financial Management Specialists, one Procurement Specialist, one MIS Specialist, one M&E & Training Specialist, a Social Safety Net Implementation Specialist, a Systems Engineer, a Payments Specialist, , along with support staff as needed. Key positions and technical services are outlined in the table A3.1 below: Table A3.1: Key positions and technical services to be hired FUNCTION POSITIONS SERVICE PROVISIONS (AGENCIES) Senior • Project Director - Management • Deputy Project Director • Procurement Specialist* Administration & • Financial Management • Internal Audit * Finance Specialists* Program • Public Information & • Social Safety Net Specialist* Management & Communication Campaign; Training Training • Payment Specialist* & Enrolment Support * • CNCD Services * • M&E and Training • MIS (development / implementation Monitoring & Specialist* / training) * Evaluation • MIS Specialist* • Process Evaluation * • Systems Engineer* * Project-funded individual consultants and consulting firms 5. At the district level, the Deputy Commissioner (DC) will be the focal point for the overall coordination and guidance of the project activities, and will be supported by the Deputy Director Local Government (DDLG). The existing District level Coordination Committees headed by the respective DC will act as the core institutional structure at this administrative level to support implementation and supervision. At the Upazila level, the Upazila Nirbahi Officer (UNO) will be the primary official responsible for all project related processes. The existing Upazila level Coordination Committees headed by the respective UNO will act as the core institutional structure at this administrative level to support implementation and supervision. Both these District and Upazila level Coordination Committees will include relevant officials representing the partner agencies – BBS, DGHS and BPO. At the union level, a Safety Net Cell (SNC) will be set up at the existing Union Parishad Complex, staffed by a Safety Net Program Assistant (SPA), to facilitate implementation at the local level. These SNCs would be supported by project 37 financing and would thus report to the PMU at the LGD, and support all administrative functions of the ISPP, i.e. beneficiary enrolment; compliance monitoring; payment; appeals and grievance redress. With the added implementation capacity at the local level, SNCs would function as a “one stop shop” to enlist beneficiaries in other safety nets, thereby helping to put together a single beneficiary register at their respective union levels. Figure A3.1 below provides an overview of the implementation arrangements. Figure A3.1: Implementation arrangements Public Information and Communication Campaign 6. A targeted Public Information and Communications Campaign (PICC) will be developed and carried out to provide all stakeholders relevant information on ISPP. At the District and Upazila levels, the strategy will revolve around the promotion of transparency, and the development of an understanding of the program, seeking the trust of opinion leaders and civil society. Print and electronic media at each level will be used to disseminate these messages. Following the PICC, the SPA would work with the Union Parishad Chairman and the members of the Parishad for mobilization and outreach activities so that communities are aware of the enrolment event. It is critical to involve these elected members of the Union Parishad in this outreach activity in order to motivate them and secure their support for ISPP. Given that they are 38 no longer involved in determining the list of beneficiaries, nor in delivering these benefits, finding a way to still involve them in the implementation will minimize any opposition to ISPP. 7. At the union level, the PICC will be implemented by the SNC in close consultation with members of the Union Parishads. The focus will be on providing information regarding eligibility criteria, enrolment processes, household co-responsibilities, payment systems, grievance redress mechanisms, etc. and will rely on local and traditional communication mechanisms such as posters, brochures, banners, along with newspapers, radio and television. The involvement of Upazila level local government officials such as the Upazila Chairman and Vice Chairman will also help in disseminating key messages, as well as help mitigate any opposition to the program. The PICC will be developed by an external agency as was done for the Shombhob Pilot, and the processes and guidelines for implementation will be incorporated into the ISPP Operations Manual. Beneficiary Enrolment 8. SNCs will be responsible for the enrolment of ISPP beneficiaries under the supervision of the UNO’s office. The Safety Net Program Supervisor (SPS) hired by the Project will sit in the UNO’s office and will coordinate with Upazila level BBS staff to obtain the list of poor households in their respective Upazilas, generate a list of potential beneficiaries for the ISPP, and share them with the respective SNCs. The SPAs will then be instructed to organize the enrolment of ISPP beneficiaries based on whether eligible households have pregnant mothers and/or children below the age of 5. The SPA would also work with the SPS and UNO to obtain the beneficiary lists of other SSNs in the Union, and put together a common registry of SSN beneficiaries. Once developed, this common registry will be updated by the SNC by conducting further enrollment of beneficiaries in the respective SSNs. 9. Beneficiary enrolment of eligible beneficiaries is expected to be carried out on rolling basis. However, the PICC will be launched ahead of the first enrolment event to inform eligible beneficiaries about the registration and enrolment dates, locations and the required documentation. During enrolment, eligible pregnant women will be required to provide a valid pregnancy test report and mothers enrolling with children will be required to provide valid birth certificates or immunization records. Failure to provide correct evidence of eligibility, or provision of misinformation, may lead to cancellation of enrolment or termination of their benefits. A Know Your Customer (KYC) form will be filled out during enrolment to fulfil the BPO’s documentary requirements for postal cash card issue. Along with the identification details captured through the KYC form, biometric information (i.e. fingerprints) will also be collected. Since initially there will a large number of enrolments, the firm that developed the PICC will also be hired to support the SNC in conducting the enrolment activities. During program implementation, this firm will support the SNC in: (a) conducting the PICC on program eligibility, beneficiary registration and enrolment process; (b) facilitating enrolment by ensuring completion of KYC forms for beneficiaries and collecting biometric information; and (c) providing training and technical support to the SPA. 10. Beneficiary enrolment will be managed via the program MIS so that relevant information can be recorded in real time (depending on internet connectivity). The PMU will review and 39 approve the list of enrolled beneficiaries for each location and forward the relevant information to the BPO to print the PCCs. The PMU will subsequently deliver the cards and a copy of the final beneficiary list to the concerned UNO. The UNO will in turn instruct the SPS to deliver the cards to the SNC who would be responsible for distribution to the beneficiaries. Biometric POS machines would verify beneficiary fingerprint information to record card receipt, as well as to activate the cards for use. Figure A3.2: Enrolment & Cash Card Distribution process Compliance and Payment 11. Attendance at monthly child GMP and CNCD sessions will be verified using biometric- enabled POS machines and beneficiaries’ smart PCCs. Beneficiaries will be required to swipe their cards and register their fingerprint at the beginning and at the end of the monthly interventions so as to enable the PMU to monitor compliance with program co-responsibilities at the household level. 12. Benefits will be calculated upon evaluation of compliance data for each household, and disbursed on a quarterly basis. Payments will be collected using the postal cash cards from 40 UPOs. These post office locations will use biometric-enabled POS machines to verify the identity of a beneficiary. Based on the volume of needs in specific unions or wards, the BPO may also establish a mobile payment option also using a POS machine. The local post office will prepare a payment schedule to be prominently displayed at the Union Parishad notice board, SNC office as well as its own local branch, to inform beneficiaries of the time and locations its mobile unit. 13. A Service Agreement between LGD and BPO will be signed to ensure adequate standards of service for the G2P payment process. Responsibilities for the BPO, among others, will include: (i) printing postal cash cards according to the list of enrolled beneficiaries received from the PMU; (ii) transferring appropriate amounts to beneficiary accounts as per PMU instructions, (iii) remitting any balance amount not transferred to any beneficiary account within the specified timeframe to an account designated by PMU; and (iv) preparing and sharing a summary of all transfers made or otherwise returned, and forwarding all transaction documents to the PMU. LGD’s responsibilities, among others, will include: (i) remitting the cost of opening beneficiary accounts and delivery of the postal cash cards; (ii) transferring total amounts to be deposited to the BPO within a stipulated timeframe; and (iii) remitting an agreed service charge on the basis of disbursement details submitted by the BPO. Detailed terms of the Service Agreement will be agreed upon prior to project implementation, and included in the Operations Manual. Figure A3.3: Compliance & Payment Fund Flow 14. The PMU will also sign a Service Agreement with the Director General of Health Services (DGHS) on the use of its District Health Information System (DHIS) for registration, 41 enrolment, case records, compliance monitoring, grievance redress, among others, as well as for the use of the premises of CCs and relying on the CC staff for providing ANC and GMP services. The PMU will engage a MIS firm to develop a customized system to access and draw information from various existing modules of the DHIS, as well as to develop a module to link the ISPP MIS with other MISs being developed by the MoF and MoDMR. Detailed terms of the MoU will be agreed upon prior to project implementation, and included in the Operations Manual. See Figure A3.3 for summary of the processes to be followed to link compliance with co-responsibilities with quarterly payment. Grievance Redress and Appeals 15. ISPP will enroll all eligible households identified by the BPD as poor. Whist this provision reduces the scope for any discretion on the part of SPAs in determining the list of beneficiaries, there is always a scope for human error in compiling the beneficiary list. Thus developing transparent and practical mechanisms for grievance redress to address beneficiary appeals concerning targeting, payments, information updates, and complaints on quality of service are important. The ISPP MIS will include a grievance redress module to be administered by the SPA who will help keep a record of these grievances, and monitor the details of cases lodged, resolved cases, pending cases and actions taken while the Grievance Redress Officers (GROs) at various levels will resolve these grievances. 16. The PMU will develop the mechanisms for grievance redress for beneficiary complaints concerning targeting, payment, service quality, etc. This process would be incorporated in the MIS to maintain adequate records for cases, and would be used by Grievance Redress Officers (GROs) to monitor the status of resolution. The UNO and the DC would function as GROs, at their respective administrative level, while the PD would function as the GRO at the central level. At each level, there will be a Grievance Redress Register for complaints to be logged and applicants to be provided with a receipt and/or transaction number. Should beneficiaries fail to receive a solution within established service standards (to be defined in the Operations Manual) they may pursue their case before an appellate authority. The DC of respective district will be the appellate authority for Upazila level complaints, while the PD of the project will be the appellate authority for District level complaints. Service Provision through NGOs 17. Given the considerable efforts needed during the initial phases of the ISPP program implementation, and the comparative advantage of specialized agencies and/or NGOs, support from such external sources in effective service delivery is of critical importance. Accordingly, as part of the Service Agreement with DGHS, LGD will hire one or more NGOs to work with CCs to improve their capacity to deliver ANC and GMP services, as well as to deliver the CNCD sessions to the beneficiary mothers. These tasks will involve: (i) conducting outreach activities to bring beneficiary mothers to the Community Clinics; (ii) supporting the CC staff to conduct GMP and ANC activities; (iii) providing height and weight measuring equipment, and any ANC related equipment in CCs where there is a shortage; (iii) designing, printing and disseminating training booklets for mothers; (iv) training project personnel and other stakeholders on relevant issues; and (v) managing individual beneficiary cases. The NGO(s) will also customize and 42 deliver the CNCD sessions to cater to both the language/dialect and culture of local communities, including small ethnic communities. Details of the assignment will be provided in the terms of reference to be developed by the PMU. 18. A second agency will be hired to: (i) design tools for monitoring of compliance with program conditions, and for knowledge, attitude and practice (KAP) assessments of beneficiaries, and (ii) conduct process assessments. This will also serve as a third party quality check on the services provided by the first agency and provide feedback on any necessary course corrections. Details of the assignment will be provided in the terms of reference to be developed by the PMU. Fiduciary (Procurement & Financial Management) Fiduciary Capacity 19. Based on the assessment of LGD’s fiduciary capacity, the fiduciary risk of the project is substantial. As with other government institutions in Bangladesh, LGD is not immune to systemic issues affecting procurement efficiency and performance. LGD will require adequately skilled staff to manage procurement, as well as additional training and on international competitive bidding (ICB) procedures following the Bank’s Guidelines. Internal control, documentation, information dissemination, contract administration including delivery follow up, payments, complaints handling, etc. also need to be strengthened. Several measures will need to be introduced to minimize procurement risks during project implementation. LGD does not have an integrated financial management system. Each project and revenue budget unit is currently segmented and ring-fenced. The accounting system is cash-based, follows single-entry bookkeeping, and does not include a statement of assets and liabilities. In terms of reporting, interim financial reports (IFRs) to monitor budget use and annual financial statements to show overall financial position, are not currently produced. Although LGD has gained some experience by working with the Association there is insufficient capacity for financial management functions of the project. These capacity issues were noted in assessments of other IDA financed projects, which included unacceptability of IFRs due to inaccurate reporting of financial figures and delayed settlement of issues raised in annual audits. Several measures need to be introduced to minimize financial management risks during project implementation. There are no outstanding audit reports with LGD on any of the other current Bank financed projects. Planning and Budgeting 20. Planning: A draft procurement plan covering all major procurement will be prepared for the entire duration of the project before appraisal. This plan will be agreed upon between the Borrower and the Bank during negotiations and be made available on the Bank’s external website. The procurement plan will be updated by LGD, at least annually, to reflect actual implementation needs in consultation with the Bank. 21. Budgeting: A budget will be maintained for the entire term of the project, and detailed budgets for each fiscal year will also be produced to provide a framework for financial management purposes. The annual budget will be prepared on the basis of the procurement plan 43 and any other relevant annual work plans. These budgets will be monitored periodically to ensure actual expenditures are in line with the budgets, and to provide input for necessary revisions. The project budget will be included in LGD’s overall budget. Internal Control 22. Filing and Record-Keeping: LGD will preserve all procurement records and documents in accordance with provisions of the Public Procurement Act 2006 (PPA 2006). These records must be made readily available on request for audit/investigation/review by Government and that Bank. The PMU will retain copies of supporting documents for all project transactions, and originals will be maintained by the Finance Wing at LGD. All project related documents must be filed separately to facilitate internal and external audits, as well as reviews by the Bank. 23. Controls: The project will use dedicated software to account for project transactions and all transactions must follow Government review and approval procedures. Such controls have been reviewed and found satisfactory. Signatories for the bank account for project financing must include the PD and one DPD to facilitate transaction, who would also act as custodians of the checkbooks for this account. The Financial Management Specialist will be responsible for reconciliation of the project bank account on a monthly basis, and any irregularities must be addressed in a timely manner. 24. Internal Audit: Internal audits must be carried out by a professional auditing firm twice in the life of the project. The first audit will be due by the end of the second year of implementation. The subsequent audit will be carried out one year prior to the project closing date. In each case, the project must submit the internal audit reports to the Bank within fifteen days from the receipt of the report. The terms of reference for the internal audits (detailed out in the Operations Manual) would be prepared by the Financial Management Specialist and must be submitted to the Bank for concurrence. Governance and Oversight Arrangements 25. External Audit: The Foreign Aided Projects Audit Directorate (FAPAD) of the Comptroller & Auditor General’s (CAG) would conduct an audit of the project’s annual financial statements within six months from the end of the fiscal year. The PD will be responsible be responsible for audit follow-up and taking remedial actions. Meetings to resolve audit objections must be held within three months of the receipt of the external audit report from FAPAD. 26. Project Audit Committee: In order to ensure that the observations and recommendations from the internal and external audits are reviewed and adequately followed-up on, a project audit committee (PAC) will be constituted. The Joint Secretary LGD, will chair the PAC, and membership would include a Deputy Secretary/Senior Assistant Secretary (audit), the PD, and the Financial Management Specialist would serve as the secretary. 44 27. Procurement Complaints: The PMU must establish a system to manage complaints, including a database for recording, monitoring, and following up on all procurement activities. The Bank must be notified of any complaints to ensure transparency in the resolution process. Procurement Considerations in the Fiduciary Assessment 28. Total procurement of goods and consultant services under the project will be around US$17.5 million, out of which goods of US$3.25 million, and consulting services of individuals and firms of about US$12.70 million. Procurement would be carried out in accordance with the World Bank’s “Guidelines: Procurement of Goods, Works, and Non-Consulting Services under IBRD Loans and IDA Credits & Grants” dated January 2011 (Procurement Guidelines) and “Guidelines: Selection and Employment of Consultants under IBRD Loans and IDA Credits & Grants by World Bank Borrowers” dated January 2011 (Consultant Guidelines), as well as the specific provisions stipulated in the Financing Agreement. A General Procurement Notice (GPN), for all major procurement to be financed by the proposed project, will be published in the Bank’s external website and United Nations Development Business (UNDB). 29. Procurement of Goods and Works: Except as otherwise agreed in the procurement plan, procurement of goods and works would follow ICB procedures. Procurement of goods and works having an estimated value less than the ceiling stipulated in the procurement plan may follow National Competitive Bidding (NCB) and National Shopping (NS) procedures. Direct Contracting (DC) may be allowed under special circumstances with prior approval of the Bank. NCB contracting would be carried out under the Bank’s Procurement Guidelines, following procedures for the Open Tendering Method (OTM) of the Public Procurement Act, 2006 (PPA 2006) (including first amendment to the PPA, 2009) and the Public Procurement Rules, 2008 (as amended in 2009), using standard bidding documents satisfactory to the Bank. For the purpose of NCB contracting the following shall apply: (a) post-bidding negotiations shall not be allowed with the lowest evaluated or any other bidder; (b) bids should be submitted and opened in public in one location immediately after the deadline for submission; (c) lottery in the award of contracts shall not be allowed; (d) bidders’ qualification/experience requirements shall be mandatory; (e) bids shall not be invited on the basis of percentage above or below the estimated cost and contract award shall be based on the lowest evaluated bid price of compliant bid from eligible and qualified bidder; and (f) single-stage two-envelope procurement shall not be allowed. 30. Procurement of Non-Consulting Services: Except as otherwise agreed in the procurement plan, procurement of non-consulting services would follow ICB procedures. Procurement of non-consulting services having an estimated value less than the ceiling stipulated in the procurement plan may follow NCB procedures. 31. Selection and Employment of Consultants: The following methods will apply for selection of consultants: Quality and Cost-Based Selection (QCBS), Quality-Based selection (QBS), Fixed Budget Selection (FBS), Consultants’ Qualification (CQ), Least-Cost Selection (LCS), and Single-Source Selection (SSS). Single Source Selection (Consultants) may be allowed under special circumstances with prior approval of the Bank. Shortlists of consultants for services estimated to cost less than US$500,000 equivalent per contract may be composed 45 entirely of national consultants. The procurement plan will specify the circumstances and threshold under which specific methods will be applicable. 32. Staffing: LGD shall nominate a procurement focal point for the project. The appointed focal points will take necessary training, both on the Bank’s Guidelines as well as on the PPA and PPR. The focal points will support LGD in day-to-day procurement follow-up and preparation of periodic procurement reporting. In addition, LGD would have to hire a Procurement Specialist as part of the PMU. The Procurement Specialist must be a qualified professional with adequate knowledge of the Government and World Bank systems, and will be a mandatory member of all evaluation committees for procurement under the project. The consultant selection process must be prioritized so that the position is filled from project effectiveness. 33. Webpage for procurement information: All information pertaining to bidding and procurement above the specified thresholds, as per PPR, must be published on the Central Procurement Technical Unit (CPTU) website. In addition, LGD will publish procurement information on its own website. This information must include: invitations to bid, bid documents and RFPs (wherever applicable); latest information on procurement plan/contracts; status of evaluations once completed; contract award information; and information covering the poor performance of contractors, suppliers and consultants, including a list of debarred firms. The website would be accessible to all bidders and interested persons equally and free of charge. 34. Procurement Risk Mitigation Plan (PRMP): These periodically produced plans must be submitted to the Bank and include updates on the following measures: i. Alert bidders in pre-bid meeting: LGD through a notification will alert bidders during pre- bid meeting on consequences of corrupt practices (fraud and corruption, collusion, coercion, etc.). The alert notice, among others, will include that if bidders are found to have adopted such practices, there may be remedial actions including debarment from bidding processes in conformity with the Bank’s Guidelines. For national competitive bidding, national bidders debarred, if any, under the PPA will not be able to participate. In addition, in the pre-bid meeting, the bidders will be clarified for preparation of bids correctly. ii. Alert internal officers/staff: LGD will issue alert letter(s) notifying on the fraud and corruption indicators and the possible consequences of corrupt and similar behavior in procurement practices and action to be taken against the official staff if they are involved in such practices. Moreover, LGD will highlight that, in case of noncompliance or material deviation from IDA’s Procurement Guidelines, IDA may take remedial actions (i.e., withdrawal of funds, declaration of mis-procurement) for concerned contracts. iii. Multiple Dropping: Bids may not be submitted in more than one location for any procurement. iv. Bid Opening Committee (BOC) & Bid Evaluation Committee (BEC): A formally structured BOC will be constituted for each contract package. The BEC will have at least five members with two experts from outside the procuring entity with proven track record of 46 experience in procurement; depending on the type of procurement such experts shall be either from public offices and/or from professional bodies/individuals of known probity. Formation of such BEC shall be in conformity with the Bank’s Guidelines and be acceptable to the Bank. Individual consultants and/or representatives of the consulting firm may participate as members of the BEC. v. Bid Opening Minutes: During the same day of bid opening, photocopies of the Bid Opening Minutes (BOM) with readout bid prices of participating bidders will be submitted by BEC for circulation to all concerned. For prior review packages, such BOM will be shared with IDA. vi. Low competition among bidders and high price of bids: The case(s) of low competition (not solely based on number of bidders) in ICB and NCB cases, coupled with high-priced bids will be inquired into and further reviewed by LGD. The review and decision in this regard would be in the context of qualification criteria, the contract size (too small or too large), location and accessibility of the site, capacity of the contractors, etc. vii. Measures to reduce coercive practices: Upon receiving allegations of coercive practices resulting in low competition, LGD will look into the matter and take appropriate measures. For prior review contracts, observations of LGD will be shared with IDA, along with the evaluation reports. LGD may seek assistance from law enforcing agencies to provide adequate security for bidders during bid submission. For ICB contracts, provision for bid submission through international/national courier services will be allowed and confirmation of the receipt of the bid will be informed to the bidders through e-mail. viii. Rebidding: LGD will inquire into the matter, record and highlight the grounds of rebidding (i.e. corruption or similar, high bid prices etc.) along with recommended actions to be taken. For prior review of cases, all such detailed reports will be sent to IDA. ix. Publication of award of contract: LGD will publish contract award information within two weeks of contract award on its own, as well as UNDB Online and CPTU websites. The following information must be included: contract package number, advertisement date, number of bid documents sold, number of bids submitted along with names of bidders, bid prices as read out at bid opening, name and evaluated price of each bid, number of responsive bids along with name of bidder, name of bidders whose bids were rejected and brief reasons for rejection of bids, name of the winning bidder and the price it offered, proposed completion of date of contract, as well as a brief description of the contract awarded. 35. Prior Review of Procurement Decisions: IDA prior review of procurement decisions will be governed by Appendix 1 of the Bank’s Guidelines. For each contract to be financed by the Credit, the monetary threshold for prior review and post review will be identified in the Procurement Plan. During the first 18 months of the project, IDA will carry out prior review of the following contracts (to be updated based on the procurement performance of LGD): (a) all contracts for goods and non-consulting services following international competitive bidding (ICB) and direct contracting (DC) procedures irrespective of estimated cost; (b) all contracts for 47 goods and non-consulting services following national competitive bidding (NCB) procedures estimated to cost US$1,000,000 or above; (c) all contracts for consultant services following single source selection (SSS) procedures irrespective of estimated cost; (d) all contracts for firms estimated to cost US$500,000 or above; and (e) all contracts for individuals estimated to cost US$200,000 or above. In addition, all terms of reference for consultants will be subject to the Bank’s review, irrespective of the prior review status of the contract. Financial Management Considerations in the Fiduciary Assessment 36. Staffing: Given the financial management capacity and weaknesses of the internal control environment, LGD would have to hire two Financial Management Specialists as part of the PMU. The Financial Management Specialists must be qualified professional accountants with adequate knowledge of project financial management requirements of the Government and World Bank, and with a proven experience in working with computerized accounting systems. The consultant selection process must be prioritized so that the positions are filled from project effectiveness. The Financial Management Specialists will report to the PD and be assisted by qualified Accounts Officers and Accountants in order to carry out day to day activities. 37. Fund Flow: A separate Designated Account must be opened by LGD, in the form of a Convertible Taka Special Account (CONTASA) in a commercial bank acceptable to the Bank. This Designated Account would be used solely for the purpose of financing all components of the project. Disbursement to the Designated Account will initially be SOE-based, i.e. on the basis of advances and replenishments. After one year of implementation, the Bank would review the quality of financial management performance and may convert the disbursement modality to one based on interim unaudited financial reports (IFRs) including a six-monthly forecast of fund requirements. For Component 1 specifically, the BPO must maintain a dedicated account to which LGD will transfer funds for payments to beneficiaries, based on payment lists generated by the program MIS. The BPO must reconcile this account on a monthly basis to assess whether there are any pending amounts to be transferred to beneficiary accounts. 38. Accounting & Reporting: The PMU will be responsible for preparing all monthly, quarterly and annual financial reports, and ensure consistency with the Government’s project accounting manual. IFRs must be prepared and submitted to the association with forty-five days from the end of each calendar quarter. The formats of the IFRs will be agreed with the Borrower during negotiations. The project will report on the cash transferred to beneficiaries (under Component 1) and expenditures by the PMU (under Components 2 and 3). Funds at the BPO account for onward transfer to beneficiaries will be treated as advances and not expenditure. Accordingly, the IFRs will need to be supported by an actual cash transfer statement from the BPO. IFRs are expected to be prepared directly from the computerized accounting system and not from manual ledgers and cashbooks. 39. Third Party Assessment of Program Benefit Delivery: The agency to be hired by the project for monitoring compliance and conducting assessments of beneficiaries would also review whether beneficiaries have actually received their due cash allowances on time and report any irregularities to the PMU. 48 Environmental and Social (including Safeguards) Environment Environmental impacts are not envisaged under the project. Social 40. The proposed project will be implemented in areas where small ethnic communities (SECs) live as confirmed by a Social Assessment that was carried out in May/June 2014. Specifically, Mymensingh and Jamalpur districts are home to Garo and Khoitrio populations. The Garo community has their own language, but for the most part, both populations are mixed with mainstream Bengali communities and their regular medium of communication is Bangla. 41. OP 4.10 has been triggered for the project and a Small Ethnic Communities Plan (SECP) has been prepared to ensure maximum access to the program by tribal populations and disclosed on August 26, 2014. The Plan was prepared on the basis of extensive consultation with tribal people and community leaders. Project activities will not have any adverse social impacts on tribal people or other social groups. Rather, the proposed project is expected to provide benefits to beneficiaries though better maternal and child health care by improving their access to basic child nutrition and development services through participation in the program. 42. The primary principle of the plan is to lay out the necessary actions for awareness raising, mobilization and training campaigns that will need to be carried out in a manner tailored to the needs of the SECs in the relevant locations such that the statutory rights and privileges and customs and norms are not hampered or disturbed. 43. The following steps will be taken to ensure maximum coverage and dissemination of project information as laid out in the Tribal Peoples Plan: Disclosure of Information, Public Awareness and Access to Information (i) At the national level, the Project Management Unit will procure the services of a firm/agency to design, develop and implement a public information campaign which will cover program objectives, eligibility criteria, benefits and grievance mechanisms. The firm/agency will be responsible for adopting and incorporating all the elements of the Tribal Peoples Plan for all project areas where the screening conducted by the SNC and coordinated by the UNO/Safety Net Program Supervisor (SPS) shows the presence of SECs. (ii) The PMU will sensitize and encourage SNCs to actively disclose the information to Tribal Peoples in a culturally sensitive manner and using appropriate tools. Training on the implementation of the Plan will be provided for UNOs, SPS, SPAs and UP members by the PMU under the supervision of World Bank safeguards specialists. 49 Registration and Enrolment (i) Regular consultations will be held with SECs in accordance with the Plan throughout implementation of the project and particularly prior to the registration and enrolment phase. This will include union and upazila level workshops with tribal leaders, community organizations, journalists, school teachers, and cultural activities to raise awareness of the program. In remote villages and SEC-concentrated areas (or areas with only SEC population), tribal leaders will be utilized for better communication with local language and participatory approach. Grievance redress (i) The proposed project will ensure that indigenous peoples are aware of and have easy access to grievance redress mechanisms at the local level. There will be a grievance redress system for the whole project, details of which will be laid out in the project operations manual. In the interest of minimizing duplication and confusing beneficiaries, the same system will be applicable to tribal populations. Monitoring and Reporting (i) A bi-annual review on a random sample of unions will be carried out by a firm/NGO that will be responsible for conducting spot checks and beneficiary assessments. Their scope of work will also include review of SECP implementation. This will highlight coverage of tribal mothers and children and the awareness raising activities conducted for ensuring participation and inclusion of poor tribal households. 44. The PMU will prepare and submit an annual report to the World Bank on tribal beneficiary coverage of the project and activities related to implementation of the Plan. Monitoring and evaluation 45. Project performance monitoring is expected to utilize the automated MIS program in combination with independent assessments, including both third party monitoring and a program impact evaluation. While the MIS and third party monitoring will help to track progress in project implementation, the impact evaluation aims to establish the effects of the conditional cash transfers on a number of outcomes, such as child nutritional status and school readiness. An appropriate amount of resources in Component three is earmarked for this exercise. The following range of M&E tools will be employed in assessing LGD’s implementation performance, outputs, and outcomes. (a) Beneficiary data monitoring and compliance verification. The project’s monitoring system would be established and administered by the PMU through a comprehensive Management Information System (MIS) that would monitor the project’s physical and financial progress during implementation. The system would produce timely reports and would track achievement of project performance indicators included in the Results Framework (Annex I). It would also keep the program beneficiary database updated, 50 verify beneficiary compliance with agreed co-responsibilities, track beneficiary payments, and produce reports to help management monitor key project indicators. (b) Internal Audits of BPO payments: A sample review of payments made to beneficiary accounts will be conducted on a bi-annual basis by firm contracted out by the PMU. (c) Third party monitoring. A third party agency will be recruited to: (i) conduct an annual evaluation of the project cycle processes to assess administrative issues and constraints for a sample of locations; and (ii) carry out KAP assessments on a random sample of beneficiaries on a bi-annual basis. These are important mechanisms to both inform and motivate tailoring project (a) design to better meet the needs of the beneficiaries, and (b) processes to improve administration and management of project personnel. Additionally the Bank will carry out independent Union level regular spot checks to validate that program implementation is being carried out as per the program Operations Manuals, and assess whether program benefits are reaching the intended beneficiaries, including any minority and/or indigenous population groups. These successive spot checks will also assess the progress in the harmonization of SSN implementation at the local level. (d) Beneficiary Surveys. In order to assess the quality of implementation, beneficiary surveys will be conducted to develop a feedback loop to assess beneficiary satisfaction with the services offered under the ISPP. These surveys will also include process related questions to help validate findings of the third party assessments and other impact evaluations. (e) Quantitative evaluation. To assess the project’s impact on beneficiary poverty, a rigorous impact evaluation will be conducted using Trust Fund resources based using panel household surveys. The survey data will be used to estimate impact measures such as the net change in beneficiary consumption expenditure, dietary quality, and nutrition and child development indicators over both the short and long term. The outputs of the short term evaluation would be used to improve the program design, including the targeting mechanism and the efforts to improve nutrition and education outcomes of participants, for a potential scaling up the intervention to other regions of Bangladesh. While the long term evaluation will be geared towards contributing to the learning agenda on the effectiveness of the proposed interventions on child nutrition and cognitive development. (f) Qualitative evaluation. Focused group discussions with participants and non-participants to conduct a qualitative evaluation of the project outcomes. This will involve conducting beneficiary satisfaction surveys. 46. The triangulation of the results from the above M&E tools will help to ensure that the Project objectives are being met. The implementation arrangements and the set of M&E activities discussed above are expected to facilitate effective and appropriate use of the funds for the project, preclude the incidence of malpractice and maintain good governance in the management and implementation of project activities. Thus, some of these activities will also be 51 regularly monitored as part of the Governance and Accountability Action Plan (GAAP) designed to reflect the specific responsibilities of the implementing agencies (see Annex 7). The Role of Partners 47. There are numerous Development partners (DPs) who have shown keen interest in supporting safety net programs implemented by GoB, including in the development of the NSSS. DFID is currently engaged in a concerted effort to work with multiple DPs, including the Bank, to better coordinate support to the Government to improve the SSN implementation, as well as their impact on nutrition indicators. Specifically DFID is providing technical assistance to the Ministry of Finance to improve the tracking of beneficiaries at the central level. The activities in the proposed operation will inform this important discourse and allow for greater donor harmonization on key policy issues as well as support the GoB to make the SPS operational. UNDP is planning to support GoB in the implementation of the National Social Security Strategy, and has sought to collaborate with the Bank to help expand the use of the common administrative platforms for beneficiary targeting, enrolment, payments and grievance redress system as per the design of these platforms proposed by this project. 48. Discussions are on-going with DFID regarding their support to the proposed operation as well as providing financial support to conduct some of the M & E activities. While DFID has expressed interest, the timeframe under which the proposed project is being processed means that DFID is not able to commit any co-financing at this stage. However, it is very likely that DFID will be able to partner with the Bank team to support some of the project evaluation activities. 52 53 54 55 56 57 58 Annex 5: Implementation Support Plan BANGLADESH: Income Support Program for the Poorest Project (P146520) Strategy and Approach for Implementation Support 1. The Implementation Support Plan (ISP) lays out the support required for implementation of the mitigation measures of the risks identified in the ORAF and Systematic Operations Risk- Rating Tool (SORT) in the following areas: (a) technical design and institutional capacity; (b) fiduciary, and (c) social safeguards. The design of the project contains safeguards against each of the risks and the ISP is designed to review and ensure that those safeguards are effective and to reinforce them where necessary. 2. Implementation activities under the project are based at the union level and will require adequate support in terms of personnel and resources. The project will put in place additional staff and resources through the Project Management Unit at LGD as well as in the union level Project Implementation Units to ensure compliance with and achievement of project objectives. In addition, an Operations Manual will be developed to provide clear definitions of rules and guidelines on program operation and the roles and responsibilities at all levels of implementation. 3. On fiduciary activities, supervision of financial management will include reviews of the operational status and capability of financial management systems; quality of financial reports; reconciliation of financial data; capacity of FM staff; review of audit reports and follow up on implementation of recommendations. The MIS will be a large procurement under the project for which the Bank will support LGD through provision of technical and procurement expertise, specifically in the development of technical specifications, drafting bid documents, detailed guidance on the Bank’s procurement guidelines and monitoring procurement progress against the detailed project procurement plan. 4. The project has been classified as Category C and triggers Indigenous Peoples OP/BP 4.10. A Small Ethnic Communities (SEC) Plan has been prepared for the project and will apply to all project areas where there is identified presence of tribal people. The SEC Plan has been reviewed by the Bank team and updating of and reporting on the Plan will be regularly monitored by the Bank safeguards team. Implementation Support Plan 5. The Bank’s supervision team will include the Task Team Leader and the country-based team, including fiduciary, procurement and safeguards staff. Implementation support missions will be conducted up to three times a year. Specific technical support will be provided in the following areas: (a) Technical design and institutional capacity: In addition to the country-based operational support team, the Bank task team will also include an Institutional Development Specialist, a MIS/IT Specialist, a Child Nutrition and Development Specialist, and an Impact Evaluation 59 Specialist. The Institutional Development Specialist will support the Local Government Division in the development of the Operations Manual, which will clearly lay out the process and procedures entailed in implementation, including beneficiary targeting, enrolment, compliance, payments and grievance redress. The Institutional Development Specialist will also guide and support LGD in developing the Terms of Reference for contracting the NGOs for services related to GMP and delivery of nutrition and child development sessions. The Impact Evaluation Specialist will supervise the activities geared towards the evaluation of the proposed project. The MIS/IT Specialist will support LGD in developing the specifications of the MIS and will work with procurement staff to ensure bidding documents have been appropriately designed. As part of the regular monitoring and evaluation under the project, LGD will contract the services of a NGO to monitor compliance with program conditions and conduct Knowledge, Attitude and Practice assessments of beneficiaries on a sample basis throughout the year. The Child Nutrition and Development Specialist will support LGD in developing the Terms of Reference for contracting this NGO and reviewing the tools which will be employed for the assessments. (b) Fiduciary: The project will require intensive procurement and financial management supervision support during the first year of set up. The Bank task team will include a dedicated Financial Management Specialist who will be responsible for guiding and supporting the implementing agency in developing the Memorandum of Understanding between LGD and the Bangladesh Post Office, which will define the necessary controls at each level of financial transaction and manage timely reconciliation of funds from LGD to BPO to project beneficiaries. During implementation, the Bank will review (i) the project Interim Unaudited Financial Reports and audited financial statements, including the budget execution report, together with the management letters, and (ii) the project’s FM and disbursement arrangements to ensure compliance with the agreed requirements. The Bank’s regular implementation review procedures in addition to implementation of sound FM monitoring measures by the FM Specialist appointed by LGD are deemed to be appropriate and sufficient measures for the project. In terms of procurement, in addition to prior review of selected contracts, the Bank will carry out a procurement post review of contracts below the prior review threshold. This review will be carried out on a sample of about ten to twenty percent of contracts on an annual basis depending upon the procurement risk. Training will be provided by the Bank’s financial management and procurement specialists and the team will also help LGD strengthen its fiduciary and procurement capacity through the placement of dedicated specialists under the project. Formal supervision of financial management will be carried at least twice a year and procurement supervision will be conducted out on a timely basis as and when required by the client. 60 (c) Social safeguards: The Bank safeguards team will review compliance with the Small Ethnic Communities Plan at least once a year following the registration and enrolment process of beneficiaries and highlight any issues and possible solutions to the task team. 6. Tables A5.1 and A5.2 present the main focus of implementation support over the life of the project: Table A5.1: Implementation Support Resource Time Focus Skills Required Estimate 0-18 months Preparation of Operations Institutional Development Manual Specialist Development of bidding Institutional Development documents/TOR for Specialist procurement of NGO services Pediatric Specialist Development of MIS MIS/IT Specialist specifications and bidding documents Development of MIS MOU with Bangladesh Post Financial Management Specialist Office 19-60 months Overall quality of Task team implementation FM, Procurement & Safeguards staff Institutional Development Specialist MIS/IT Specialist Pediatric Specialist Table A5.2: Skills Mix Required Skills Required Staff Weeks Number of Trips Task management (TTL) 20 staff weeks/year At least 3 Task management 20 staff weeks/year Field based Task management 20 staff weeks/year Field based Institutional Development Specialist 15 staff weeks/year As required MIS/IT Specialist 8 staff weeks/year As required Pediatric Specialist 6 staff weeks/year Once a year FM Specialist 8 staff weeks/year Field based Procurement Specialist 6 staff weeks/year Field based Social Specialist 4 staff weeks/year Field based 61 Annex 6: Economic and Financial Analysis BANGLADESH: Income Support Program for the Poorest Project (P146520) 1. The proposed project aims to benefit the poorest households through setting up an innovative conditional cash transfer (CCT) program at the local level. This will be through linking cash transfers to the utilization of specific services by pregnant women and mothers, while harmonizing local level safety net administration. There is a large body of literature that suggest that, if implemented well, CCTs are appropriate demand side interventions that can have a significant positive impact on both poverty and human development outcomes. 42 2. CCTs have resulted in sizeable reductions in poverty among recipients, especially when the transfers have been adequate, well targeted, and structured in a way that they do not offer disincentives towards productive employment. Because CCTs provide a steady income, they have helped protect poor households from the effects of unemployment, catastrophic illness, and other sudden income shocks. When transfers have been made to women, their bargaining power within the household increased. Similarly, CCTs linked to early childhood development have also shown to have had a positive impact on child cognitive development. Providing a combination of cash, information and gender targeting in Nicaragua facilitated investments by parents that resulted in improved cognitive development. 43 Children with low levels of cognitive development before they enter school have shown to have lower school achievement and earn lower wages. 44 Data on Jamaican children living in underprivileged areas show that early psychosocial stimulation and nutritional interventions increased lifetime earnings by 42 percent by the time the beneficiaries reach the age of 22. 45 3. Thus we expect the proposed project with its interventions of cash transfers targeted to poor households with young children conditional on fulfilling nutrition sensitive household co- responsibilities to have (i) a short term impact on poverty; (ii) a medium term impact on child nutrition indicators; and (iii) a longer term impact on human capital and earnings of the beneficiary children. Using the experience of the Shombhob pilot project, the following analysis illustrates pathways through which these outcomes are expected to be achieved under the proposed project. In addition a financial analysis is conducted to assess the fiscal impact of the proposed project. A. Impact on poverty 4. The Shombhob Pilot provided bi-monthly cash transfers to mothers of very poor households. Two types of transfers were provided depending on the household demographic 42 Fiszbein, A., N. Schady, F.H.G. Ferreira, M. Grosh, N. Keleher, P. Olinto, and E. Skoufias, 2009. “Conditional Cash Transfers: Reducing Present and Future Poverty,” World Bank Policy Research Report, Number 47603. 43 Macours, K., N. Schady, and R. Vakis, 2012. “Cash Transfers, Behavioral Changes, and Cognitive Development in Early Childhood: Evidence from a Randomized Experiment,” American Economic Journal: Applied Economics, American Economic Association, vol. 4(2), pages 247-73, April. 44 Case, A., and C. Paxson. 2008. “Stature and Status: Height, Ability, and Labor Market Outcomes.” Journal of Political Economy 116(3): 499-532. 45 Gertler, P., J. J. Heckman, R. Pinto, A. Zanolini, C. Vermeerch, S. Walker, S. Chang-Lopez, and S. Grantham-McGregor, (2013). “Labor Market Return to Early Childhood Stimulation: a 20-year Follow-up to an Experimental Intervention in Jamaica.” World Bank Policy Research Working Paper No. 6529, The World Bank, Washington D.C. 62 composition and location: (i) a “nutrition” allowance of BDT400 (US$5) for those with children aged 0 to 36 months provided that they attended monthly GMP and nutrition counseling sessions; and (ii) an “education” transfer of BDT400 (US$5) for those families with children going to primary school provided that the children attended 80 percent of classes. To evaluate the impact of the intervention, a baseline and an endline survey was fielded over a two year period which included 13 months of transfers made from the Pilot. 46 The results suggest that on average, Shombhob pilot beneficiaries received a transfer of BDT542 per household per month – or BDT70 per capita per month. The impact of this transfer was almost entirely passed on to food expenses: Shombhob pilot participants spent about BDT340 per month more on food than the control group a year after Shombhob pilot started. The difference is quite substantial, even after controlling for the fact that food expenses had gone up by BDT250 for both the treatment and control group between the baseline and the endline. Given that total food consumption prior to the program was BDT 3,168 in the families that were about to become beneficiaries, BDT340 represents an increase of 11 percent. Moreover, food expenses on proteins – meat, eggs, dairy, fish and pulses – increased significantly for Shombhob pilot recipients, and even more so for households receiving the nutrition awareness sessions (see Table A6.1). Table A6.1: Impact of Shombhob pilot on consumption Proteins Per Househol Food HH receiving nutrition HH receiving education capita d transfers transfer Impact of Shombhob 70.3* 378.8* 337.0*** 174.2*** 118.0** pilot (δ) (39.3) (215.8) (107.3) (46.4) (54.5) - - - -65.0* -83.1** (T-C) at baseline (β) 85.7*** 477.0*** 205.7*** (28.5) (156.5) (77.8) (33.5) (39.7) Trend for non recipients 32.2 52.6 96.1 150.4*** 163.7*** (γ) (30.3) (166.5) (82.8) (35.6) (45.1) 1665.1* Constant 715.6 1970.6* 764.2* 527.3* ** (395.2) (2168.9) (1078.6) (400.2) (294.4) Controls Yes Yes Yes Yes Yes R2 0.2 0.4 0.4 0.3 0.2 Df 2,330 2,330 2,330 1,636 1,458 Number Obs. 2,376 2,376 2,376 1,680 1,502 Significance levels: * p<0.10, ** p<0.05, *** p<0.01.Controls include: household head characteristics in terms of age and education; household size; housing characteristics; asset ownership; access to remittances. Proteins include meat, eggs, dairy, fish and pulses. 5. Assuming that the proposed project has a similar impact on consumption as Shombhob pilot, and assuming it is rolled out to the entire countryside (rural areas only), and that all poor households with a child in age of receiving the transfer benefit from the cash transfer, then beneficiaries should see their per capita consumption increased by BDT70 every month. Using HIES 2010 data, and simulating new income for the poorest, one finds that the headcount ratio 46 See Ferre, C. and Sharif, I. 2014. “Can Conditional Cash Transfers Improve Human Development Outcomes of Poor Children in Bangladesh? Evidence from a Pilot Intervention,” World Bank Policy Research Working Paper Series No. 7077, for more detailed description of the impact of the Pilot. 63 for rural areas would go down from 35.1 percent to 30.8 percent. Given that the proposed project offers a larger monthly transfer (BDT500 instead of BDT400 per beneficiary), it is reasonable to assume that an estimated reduction of 4 percentage points in the rural poverty headcount is a lower bound of what could be achieved with the roll-out. B. Impact on nutrition indicators 6. Evidence from Shombhob pilot project shows that mothers’ knowledge about best breastfeeding practices improved, the proportion of wasted children was curbed, and dietary diversity was improved (although not significantly). Mothers’ knowledge about best breastfeeding practices improved significantly in Shombhob households: 6.3 percentage points more mothers know that they should breastfeed their child exclusively until he reaches the age of 6 months. Given that initially 83.1 percent of the mothers knew about best breastfeeding practices, that represents an increase of 8 percent. Food diversification 47 among children 6 months and above improved but not significantly. In addition, wasting – or insufficient weight- for-height – saw significant improvement among the youngest cohort of children aged 1 year at the start of the program: wasting was reduced by 12.5 percentage points, which is a reduction of about 40 percent of wasted children in this age group. Table A6.2 provides details of these impact results. Table A6.2: Impact of Shombhob pilot on nutrition knowledge Dietary Stunting Under Wasting (10-22 about diversity (6+ weight months when infant months) enrolled) feeding Impact of 0.063* 0.031 0.034 0.046 0.125* Shombhob (0.03) (0.05) (0.05) (0.05) (0.07) (T-C) at -0.015 -0.023 0.103** baseline (0.04) (0.04) (0.05) Trend for non 0.060 -0.083** -0.079 recipients (γ) (0.04) (0.04) (0.05) Constant -0.222 -0.001 0.120 (0.43) (0.42) (0.37) Controls Yes Yes Yes R2 0.117 0.052 0.036 0.093 Df 1,536 1,594 606 Number Obs. 1,538 1,318 1,580 1,638 648 Significance levels: * p<0.10, ** p<0.05, *** p<0.01.Controls include: household head gender, age, education, household size, housing characteristics, asset ownership, remittances. C. Impact on early childhood cognitive development and earnings ability 7. Global evidence suggests that early childhood development interventions result in improved cognitive development, which in turn increase children’s probability of attending and finishing school, which in turn leads to greater lifetime earnings in the long term. For instance, 47 I.e. more than four out of 7 food groups recommended by Infant and Young Child Feeding Practices (IYFP). 64 every additional year that a mother attends CNCD workshops is likely to be associated with 0.05 standard deviations better child cognitive development, on average. 48 This estimate is lower than most estimates obtained for developing countries in Latin American (0.05 on average and 0.18 for the poorest children in Ecuador, 49 0.23 in Argentina 50). Following for over 20 years a cohort of children in Jamaica who received an ECD intervention, research show that the intervention increased earnings over the entire tenure in labor market. 51 Average monthly lifetime earnings were 49 percent higher for all jobs and 60 percent higher when considering only non-temporary full time jobs. D. Cost Benefit Analysis 8. The simple cost benefit analysis compares the discounted stream of expected benefits to the discounted stream of project costs. To do this, we assume that given the interventions under the proposed project, the cash transfers have an impact in beneficiary children’s ability to complete school, and thereby secure an ability to earn higher wages in their adult life. We combine existing evidence on the impact of similar intervention with information on the consumption levels of poor households, demographic composition of households, and returns to education from the HIES 2010. For instance, the HIES 20101 shows that that 20 percent of households have only one child and 70 percent have more than one child in the family. We assume this distribution of children for the beneficiary households as well. A discount rate of 10 percent is assumed. The analysis is conducted as follows: 9. The total costs are constructed in the following way: • nb :the proposed project is assumed to provide transfers for 4 years covering 100,000 beneficiaries in the second year, 325,000 in the third, 600,000 in the fourth and final year. • maxt: beneficiary families can be grouped into 3 categories to determine their cash transfers: o Group 1 (families with pregnant mothers only): BDT 500 o Group 2 (families with pregnant mother and one child): BDT 1,200 o Group 3 (families two children): BDT 1800 • admin: to estimate the cost per beneficiary, administrative costs are assumed to be 10 percent of the transfer amount for all registered individuals. • compliance: 70 percent of the beneficiary population is expected to comply on average over the course of the project. Total Costs = nb * (12 * maxt * compliance + admin) 10. To estimate the private benefits to increased educational attainment, we estimate the 48 Macours, K., N. Schady, and R. Vakis, 2012. “Cash Transfers, Behavioral Changes, and Cognitive Development in Early Childhood: Evidence from a Randomized Experiment,” American Economic Journal: Applied Economics, American Economic Association, vol. 4(2), pages 247-73, April. 49 Paxson, C., and N. Schady, 2010. “Does Money Matter? The Effects of Cash Transfers on Child Health and Development in Rural Ecuador,” Economic Development and Cultural Change 59(1): 187-230. 50 Berlinski, S., S. Galiani, and M. Manacorda, 2008. “Giving Children a Better Start in Life: Preschool Attendance and School- Age Profiles.” Journal of Public Economics 92(5-6):1416-40. 51 Gertler, P., J. Heckman, R. Pinteo, A., Zanolini, C. Vermeerche, S. Walkerd, S. Chang-Lopez, and S. Grantham-McGregor, 2013. “Labor Market Returns to Early Childhood Stimulation: a 20-year Follow-up to an Experimental Intervention in Jamaica,” World Bank Policy Research Working Paper No. 6529. 65 number of mothers who will enroll in the program, the educational attainment of their children and finally the impact those increased years of schooling will have on their lifetime income stream. The motivation here is that increasing school attainment has an impact on individual productivity, which in turn will lead to more access to better paid jobs and therefore higher lifetime earnings. 11. The total benefits are constructed the following way: • redu : we assume that an increased year of educational attainment has a 15, 17 or 19 percent impact on annual earnings. This is consistent with the analysis presented in the 2013 Bangladesh Poverty Assessment Report, which suggest incomes increase for people who completed 5 to 10 years of schooling to be about 18 percent. This rate increases to 63 percent for those who completed above 10 years of schooling. Note that we use the lower end of the possible increase in earnings because we assume that beneficiary children on average increase their school attainment within 10 years given that the average years of schooling is 6.6 years of schooling. • incedu: the net impact on enrolment, repetition and dropouts is assumed to result in an increase in schooling of 0.5 year - derived from the trends in increase in years of education among the poor. 52 • pccons: the average GDP per capita is about US$1000 per year. • Estimations based on different growth scenarios are presented with associated NPV and ERR (zero growth, 1%, 3%, and 5% growth) Total Benefits = nb * redu * incedu * pccons* compliance 12. The estimates of Internal Rate of Return (IRR) and Net Present Value (NPV) are computed assuming that participants work from the age of 18 to 60, so IRR and NPV are calculated on a 60-year frame. These estimates are presented in Table A6.3 below: Table A6.3: IRR and NPV of beneficiary earnings over a lifetime Rate of return 15% 17% 19% Growth rate 1% 3% 5% 1% 3% 5% 1% 3% 5% IRR (%) 10.5% 12.9% 15.3% 11.1% 13.5% 16.0% 11.6% 14.1% 16.5% NPV (US$ Million) 17 128 334 37 163 397 57 198 459 13. The results suggest that the schooling benefits expected from the proposed project alone outweigh the costs in all three cases. At a 10 percent discount rate, the NPV of the project will be between US$17 million to US$459 million, with an IRR of about 10.5 – 16.5 percent, depending on the assumptions. However, the interventions are expected to possibly reduce health costs during the beneficiaries’ lifetime. Increased earnings are also expected to reduce beneficiaries’ dependency on social transfers and increase tax contributions. Finally, experience in Latin America suggests that ECD also reduces violence and criminality among recipients, which in 52 These estimates are in line with Gertler et al. (2013) who show that the ECD intervention increased education in the treatment group by about half a year of schooling, in a target population where the average number of years of education was already 11 years. 66 turn has a positive externality at the local level. Thus it is reasonable to consider the expected outcomes of the proposed project presented in Table A6.4 as lower bound impacts. 14. The IRR calculated for this project is within the range of acceptable estimates obtained from other similar projects. For example, Paes de Barros (1999) found that the IRR for the internal rate of return from an additional year of preschool for 6 year old is between 12.5 and 15 percent depending on factors such as parents’ schooling, race, geographic location. Similarly, World Bank (2007) estimated IRRs for ECD programs (namely the Perry Preschool, Abecedarian Project, Chicago Child–Parent Centers, and Elmira Prenatal) and found that estimates ranged from 7 to 16 percent per annum. E. Impact on fiscal sustainability 15. The proposed project is also expected to improve coordination among local government institutions to help implement safety nets in a more coordinated fashion. This would be achieved through the use of a common list of poor households generated by the BBS (based on a PMT method), and over time develop common beneficiary lists, and common administrative platforms for beneficiary enrolment, payments and grievance redress mechanisms. This could potentially pave the way for consolidating numerous cash based SSNs in Bangladesh (e.g. old age allowances, widow allowances, school stipends, school feeding program, etc.) into an integrated system to provide social protection to the poorest. This is how Oportunidades and Bolsa Familia evolved in Mexico and Brazil respectively, and became best global practice. 16. Evaluations of the Shombhob pilot show that a PMT based targeting methodology is able to target the poor well. The eligibility requirement to participate in the Shombhob pilot was to have a PMT score that is lower than 660 in Jaldhaka. According to Figure A6.1 below most Shombhob pilot beneficiaries had PMT scores below the 660 threshold, while non-beneficiary households had PMT scores above 660. Moreover, when the control group is divided between those who applied and were rejected from the program on the basis of their PMT score, and those who did not apply at all, we find that the latter group had a flatter distribution with more individuals in the upper part of the distribution. The data seems to suggest that the targeting system worked well: the project was able to reasonably identify poorer households. 17. Simulation analysis also shows that improving the administration and improving the targeting of five of the largest SSNs (EGPP, GR, TR, FFW and VGF) (as is currently being done under the SNSP project) using the PMT has the potential to reduce the rural poverty headcount rate from 34.6% to around 34.1% by allocating the existing budget more efficiently. This translates to lifting an additional half million individuals out of poverty. Alternatively the analysis shows that, holding the poverty headcount constant, PMT based targeting would allow these five major programs to collectively achieve their existing poverty reduction impact with 45 per cent fewer funds. This would equate to a savings of between BDT 8 and 20 billion, or US$100 to 250 million per year. Thus improving the performance of more programs in terms of their targeting and payments systems at the local are likely to bring about significant savings in the government budget annually. Thus despite costing about 2% of the annual SSN budget, the proposed project will essentially be leveraging the reform of vast amounts of public expenditures by modernizing SSN implementation. 67 18. Currently the GoB spends 2.4 percent of its GDP or about USD 3 billion annually on over 100 SSNs. Based on GDP and public expenditure using the most recent IMF findings projections, the proposed project when fully implemented would cost about 1.5 percent of the total safety net expenditures or about 0.04 percent of GDP. This includes all management overhead and initial start-up costs (which are one-time cost with no long term fiscal impact) when fully implemented in the project areas by 2020. Table A6.4 below shows the details. 19. The recently drafted National Social Security Strategy recommends the consolidation of the numerous SSNs into fewer outcome-based programs and to improve their pro-poor coverage while phasing out those programs that are not performing well. The successful implementation of the proposed project thus will help position ISPP as a flagship SSN that is scaled up incrementally. Such has been the experience of the well performing flagship EGPP SSN which the Bank has been supporting since 2011. Table A6.4: Fiscal Impact of Shombhob (Amounts in Actual Projected BDT billion) FY 11 FY 12 FY 13 FY 14 FY 15* FY 16 FY 17 FY 18 FY 19 FY 20 Nominal GDP 8,952 9,280 10,392 12,240 13,992 15,344 16,960 18,696 20,664 22,760 ** Public 1,278 1,501 1,752 2,225 2,292 2,581 2,906 3,273 3,685 4,150 Expenditure Safety Net 209 226 231 271 308 340 375 414 456 504 Expenditure ISPP Project - - - - 0 1 1 7 8 8 Expenditure Public Expenditure 14.28% 16.17% 16.86% 18.18% 16.38% 16.82% 17.14% 17.50% 17.83% 18.23% as % of GDP Safety Net Expenditure 16.35% 15.08% 13.18% 12.16% 13.43% 13.16% 12.90% 12.64% 12.38% 12.13% as % of Public Expenditures ISPP Project Expenditure - - - - 0.00% 0.16% 0.17% 1.64% 1.84% 1.51% as % of Safety Net Expenditure *Provisional. **Source: GDP Projections are based on IMF Country Report June 2014 while expenditure projections are based on their average growth rate between FY11-FY14. 68 Annex 7: Governance Accountability and Action Plan BANGLADESH: Income Support Program for the Poorest Project (P146520) 1. The Governance and Accountability Action Plan (GAAP) for the proposed project outlines a set of risks which may compromise good governance of the project and proposes a set of mitigating actions to minimize the impact of such risks and promote accountability in project implementation. The GAAP has been designed based on issues associated with implementation arrangements outlined in Annex 3. These risks are categorized into the following four areas: (1) procurement; (2) financial management; (3) implementation capacity (local level); and (4) CCT program administration. 2. The first two areas pertain to project management issues at the central level and are drawn from an integrated fiduciary assessment of LGD, as well as lessons learned from other Bank financed projects implemented by the same agency. These risks primarily revolve around the lack of overall capacity for procurement and financial management functions, which extend to weaknesses in technical evaluation, transparency, internal controls, audit capacity, and fund flows. Such risks are largely to be mitigated by standard measures applied to investment financing projects. 3. The latter two areas pertain to implementation issues in terms of staffing and competency at the local level as well as those typically inherent in the proposed ISPP program administration. Measures to address implementation capacity issues include the provision of human resources with adequate training, as well as the development of an Operational Manual for the ISPP program, which is a crucial step in preparing the program for rollout. In terms of the program administration itself, a number of tasks will be outsourced to consulting firms to provide technical support to LGD and local government institutions both for service delivery and monitoring functions. Overall program administration will be largely supported by an automated MIS to ensure personal data pertaining to program beneficiaries and all financial transactions can be managed in a secure and efficient manner. 4. The GAAP will be agreed during Negotiations and monitored throughout the period of project implementation. Reporting on actions taken as per GAAP provisions will comprise part of the Project Reports to be submitted on a regular basis by LGD. Modifications may be made during the course of implementation based on changes to the governance environment, and such changes would be incorporated in the GAAP with the Bank’s concurrence. 69 Governance and Accountability Action Plan Issues / Risks Actions / Features Timeline Early Warning Indicators Project Management: Procurement Lack of capacity for Appointment of Procurement By Project Delays in procurement functions Focal Points negotiations; appointment; ongoing delays in refilling vacancy Appointment of Procurement 1 month from Delays in Specialist Project consultant effectiveness; selection process; ongoing delays in refilling vacancy Preparation of detailed Ongoing - procurement schedule for major procurement Lack of capacity for technical Mandatory membership of the Ongoing Non-inclusion of evaluation PFP and the Procurement focal point and/or Specialist in evaluation specialist committees. Engagement of relevant technical Ongoing Non-inclusion of experts in drafting specifications technical experts and terms of reference and inclusion in the concerned evaluation committee. Use of an agreed checklist of flags Ongoing Failure to identify indicating collusive practices for collusive practices all procurement Lack of adequate transparency in Establishment of procurement 1 month from Unavailability of procurement information on LGD website Project webpage on LGD (accessible to public free of effectiveness; website charge) ongoing Establishment of a system to 1 month from Delays in manage complaints (including Project notifications to the database for recording, effectiveness; Bank monitoring, and following up on ongoing all procurement activities); Bank to be notified of any complaints 70 Issues / Risks Actions / Features Timeline Early Warning Indicators Project Management: Financial Management Lack of capacity for financial Appointment of two Financial 1 month from Delays in management functions Management Specialists. One to Project consultant oversee withdrawal processes effectiveness; selection process; while the other person supervises ongoing delays in refilling the cash transfer accounts vacancy Preparation of annual budget and Ongoing - monthly adjustments against planned expenditures Weak internal controls Copies of all transaction Ongoing - documentation to be retained by PMU and originals retained by Finance Wing, LGD Use of dedicated software to Ongoing account for project transactions and report generation. Lack of adequate audit capacity Two internal audits conducted by End of second Delays in audit firm (with TOR acceptable year; 12 months appointment of to the Bank) before closing date audit firm Annual external audits by FAPAD 6 months after end - of each FY Lack of adequate follow-up of Establishment of Project Audit 6 months after end Delays in internal and external audit Committee of first FY appointment of findings and recommendations PAC; delays in resolution of audit issues Fund flow from LGD to BPO BPO to maintain dedicated As per terms of Delays in account for ISPP program benefit MOU between submission of transfers; monthly reconciliation LGD and BPO; reconciliation reports to be submitted to LGD ongoing reports Implementation Capacity (Local Level) Human resource and technical Appointment of Safety Net Ongoing Delays in constraints Program Assistant and provision advertising for of financial and technical relevant positions; resources (i.e. computers and other delays in initiating equipment, internet connectivity, the procurement of etc.) in selected locations (union office equipment and ward levels) 71 Issues / Risks Actions / Features Timeline Early Warning Indicators Lack of adequate guidance on Development of an Operations 3 months from Delays in drafting program operations Manual (OM) to outline program Project of OM processes, rules, roles and effectiveness responsibilities Insufficient technical capacity Extensive training for Safety Net 12 months from Delays in selection for administrative functions Program Assistants on Project of training firm implementation of the OM effectiveness Lack of dedicated grievance Appointments and extensive 12 months from Delays in redress points training of grievance redress Project orientation officers (from among existing effectiveness workshops with Government staff at various DCs and UNOs administrative sub-units) CCT Program Administration Targeting: location and Selection of locations on the basis Before Project Delay in beneficiary selection may not be of the latest Bangladesh Poverty Negotiations; finalization of based on objective criteria Map and nutrition indicators additional areas locations and relating to poverty and welfare during Project slippages from criteria tenure program rollout work plan Outreach: needs to be systematic Agency (third party) to be 9 months from Delay in to ensure selected beneficiaries contracted to conduct public Project procurement of are aware of responsibilities information campaign aimed at effectiveness agency; slippages during enrolment process potential beneficiaries to ensure from program full information availability at the rollout work plan local level Enrolment: registration may be Abovementioned agency would 9 months from Delay in onerous with ineffective identity provide enrolment support; Project procurement of verification procedures; postal enrolment process to be conducted effectiveness agency; slippages cash cards may not be using biometric verification cross- from program distributed to the correct checked against National IDs; rollout work plan beneficiaries SPA and UNO to distribute postal cash cards Service Delivery: lack of NGO (third party) to be contracted 9 months from Delay in adequately skilled personnel to for module development and Project procurement of provide advisory services and service delivery effectiveness agency; delay in monitor relevant progress development of relevant modules 72 Issues / Risks Actions / Features Timeline Early Warning Indicators Monitoring Compliance with Agency (third party) to be 9 months from Delay in Co-Responsibilities: beneficiary contracted to monitor service Project procurement of attendance of advisory sessions delivery effectiveness agency may not be adequately documented and progress reporting may be delayed Payment: ineffective link Program MIS to calculate benefits 9 months from Delay in between compliance verification based on compliance Project development and and payment generation; effectiveness operationalization withdrawal of funds by of MIS linked to unintended persons DHIS Delay in Service Agreement signing w/ BPO; Delay in procurement of POS machines Use of biometric-enabled POS Ongoing Delay in Service machines for payment delivery Agreement confirmation; payment through signing w/ BPO; postal cash cards Delay in procurement of POS machines Extensive beneficiary training on Ongoing Delay in use of postal cash cards procurement of agency; slippages from program rollout work plan Case Management: information Development of standardized 6 months from Delay in updates or grievance redress processes for case management as Project development and process may be onerous and part of OM; dedicated modules effectiveness; 12 operationalization unsystematic for MIS months from of MIS linked to Project DHIS effectiveness 73 Annex 8: Proposed Impact Evaluation Design BANGLADESH: Income Support Program for the Poorest Project (P146520) 1. This Annex describes the different steps related to the design of the quantitative evaluation that will be put in place in order to measure the impact of the proposed project. The project, which is to be implemented in 27 of the poorest rural upazilas and two urban municipalities, will provide cash payments to households in the bottom expenditure quintile as determined by the Poverty Score Card, (PSC) or through a proxy means test (PMT). Households with children ages 0 to 60 months will receive a payment conditional upon mothers attending counseling and knowledge sharing sessions. Households with pregnant women will receive a payment conditional upon future mothers’ ANC visits. Women will be the recipients of the cash transfers, deposited in their BPO accounts. In addition to the regular monitoring and evaluation exercise, a quantitative impact evaluation of the project will be done in order to (i) establish a set of benchmarks in targeting effectiveness and beneficiary selection, as well as (ii) assess the impact of the CCT on human capital, especially nutrition and early childhood development (ECD) outcomes. Technical Approach 2. The impact evaluation (IE) will select a random sample of households, half of which benefit from the program (treatment) and the other half being similar to beneficiary households but not enrolled in the program (control). Both sets of households – treatment and control – will be surveyed immediately prior to the implementation of the proposed project (baseline survey) and at completion (endline survey). The same set of households will be surveyed upon implementation and upon completion. It is expected that between 5 and 10 percent of households will disappear between the two rounds (attrition estimates taken from the Shombhob pilot IE). The same set of outcome indicators will be collected at baseline and endline: the difference in progress between endline and baseline, between treatment and control will give an estimate of the impact of the programs on this selected set of outcomes. Treatment and Control Groups 3. If the Poverty Score Card is available at the time of the project start, households with young children or pregnant mothers will be able to participate in the program based on their poverty status. If the PSC is not available on time, eligibility will be based on the same PMT used to determine poverty with the PSC, but administered upon application (similar to the Shombhob pilot). Control households may be identified using two different methodologies: - Regression Discontinuity Design. Firstly, the control group could consist of non-poor households located in the same upazillas as those where the project is implemented. Control households would include those close to the PSC eligibility threshold (when the PSC is available), or those whose PMT score is just above the eligibility threshold (in case a PMT is administered to all applying households). - Propensity Score Matching. Secondly, the control group could consist of poor households (according to the PSC if available or those with low PMT if not available) located in upazillas similar to those where the program is implemented but not receiving 74 the program. A Propensity Score Matching technique would then be used to determine the potential control upazilas. Potential Identification Strategies 4. Similarly, two identification strategies may be used to determine the impact of the proposed project. - Regression Discontinuity Design. If the treatment and control groups are located within the same upazilas, then a combination of difference-in-differences and regression discontinuity design around the eligibility threshold could be used. This identification strategy is similar to that used in the IE of the Shombhob pilot project IE. - Propensity Score Matching. If the control group consists of poor households located in non-beneficiary upazilas similar to those implementing the project, a difference-in- differences using PSM could be used. Sampling Design 5. The final sample of treatment and control households will consist of a total of about 5,000 households located in a random selection of upazilas. Once the sampled upazilas are identified, a census of the local households will be conducted, collecting information on household composition (identifying which households are potential beneficiaries of the program) and poverty status. If the PSC is available, non-poor households only will be administered an additional questionnaire to determine the PSC score of each households. If the PSC is not available, all households will be administered a questionnaire to determine their poverty score. These questionnaires will be administered over a short and long intervals to capture both short terms and long term impacts of the intervention. - Regression Discontinuity Design. A random sample of about 2,500 poor households will then be selected to form the treatment group, and a random sample of about 2,500 non-poor households close to the eligibility threshold will be identified to form the control group. - Propensity Score Matching. A random sample of about 2,500 poor households in Shombhob upazilas will then be selected to form the treatment group, and a random sample of about 2,500 poor households in non-Shombhob upazilas will form the control group. Summary of IE methodology Scenario 1 Scenario 2 Status of Poverty PSC available PSC not available PSC available PSC not available Score Card Database Treatment Poor according to Poor according to Poor according to Poor according to PSC PMT administered PSC PMT administered upon application upon application Control Non-poor, i.e. just Non-poor, i.e. just Poor according to Poor according to above the PSC above the PMT PSC in non- PSC in non- eligibility eligibility beneficiary beneficiary threshold threshold upazilas similar to upazilas similar to Shombhob upazilas Shombhob upazilas Identification DiD with regression discontinuity design DiD with PSM at the upazila level 75 Indicators to be measured 6. The proposed IE aims at identifying the impact of Shomhob on two sets of indicators: (i) household consumption, and (ii) knowledge, attitude and practices related to nutrition and early childhood development (ECD) outcomes. Consumption Indicators Nutrition/ECD Indicators Total household consumption Z-scores Per capita consumption KAP score Protein consumption Primary school enrolment Dietary diversity Questionnaires - Consumption 7. The household questionnaire will include a full-length questionnaire on consumption patterns. Indicators on household consumption, per capita consumption, superior foods (such as proteins) consumption, and dietary diversity will be computed. - Nutrition and ECD 8. All participating children will be weighted and measured, in order to compute In addition, the individual questionnaire will include questions on knowledge, attitudes and practices of young mothers and pregnant women. There will be four focus areas for the questions: • Breastfeeding • Dietary diversity • Child cognitive development • Child safety and monitoring - Knowledge, Attitude and Practice (KAP) 9. The KAP questions involve a 5 point Likert scale (see table below). Each section has a total of 10 points. The interviewer will collect some basic information on the following three groups: - Is the respondent pregnant now - Is the respondent with a child 6 months or less - Is the respondent with a child of any other age 76 Likert scale to evaluate Knowledge, Attitude and Practice Knowledge Answer Max Score What is the duration for exclusive 6 months 1 breastfeeding for a new born child Name three types of food that are needed Any 3 of: 3 to keep your child healthy Meat pulses lentils vegetables fruits fish milk eggs oil/ghee Name 2 symptoms that shows a woman Any 2 of 2 does not have enough iron in her blood Headache dizziness tiredness irritable sleepy difficulty working What are the three main causes of death Acute respiratory infections/pneumonia 3 among children under 5 diarrhea and injuries/drowning Name one activity that can be done with Any 1 of: 1 your child to help with their brain Reading books singing storytelling playing development with puzzles or games showing things and saying their names Attitudes Answer Score Breastfeeding is good for my baby Likert scale (1 for strongly agree, then 0.8 1 then 0.6 and so on) Strongly agree - somewhat agree -neutral - somewhat disagree - strongly disagree Breastfeeding is inconvenient for me Likert scale (reverse values) 1 A young woman has to take care of her Likert sca1e 1 nutrition/ eat healthy foods even before she gets pregnant ANC visits before my delivery can help Likert scale 1 identify any problems I might have related to my delivery ANC visits are not needed if the mom is Likert scale 1 not having any obvious problems. Giving my children different types of Likert scale 1 foods is better than giving lots of only one or two types of foods It is possible for my family to have a wide Likert scale 1 variety of foods without spending too much extra money I can help my child’s brain development Likert scale 1 by singing and reading I can read books using pictures even if I Likert scale 1 don’t know how to read Children swimming without adult Likert scare (reverse values) 1 supervision is safe most of the time 77 Practices Answer Score How many times did you have food made Greater or = 1 1 from legumes or nuts in the past day How many times did you have dairy Greater or =1 1 products such as milk yogurt and cheese in the past day How many times did you have vitamin A Greater or = 1 1 rich foods such as pawpaw carrots and mango How many times did you have iron rich Greater or = 1 1 foods such as leafy green vegetables, meats, pumpkin and chickpeas How many times did you have any other Greater or = 1 1 fruits or vegetables How many times did you eat any eggs Greater or = 1 1 How many days did you have 3 meals a 1 day = 0.25 1 day in the past 4 days (can be adjusted – I 2 days = 0.5 used 4 to keep the values simple) 3 days = 0.75 4 days = 1 How many times did you go to the ANC Greater or = 1 1 clinic during your pregnancy How often are your children playing in Likert scale 1 water without any adults nearby How often did you read with your child in Greater or = 1 1 the past 3 days 78 Annex 9: Proposed Project Locations BANGLADESH: Income Support Program for the Poorest Project (P146520) Poor Population Probability of 50% Poverty Population (Poverty Rate x Sl. Division Zila Upazila Unions Children under 5 Rate (Adjusted) Population being Underweight (Adjusted)) 1 Dhaka Jamalpur Bakshiganj 7 50.39% 227,327 114,555 57.08% 2 Dhaka Jamalpur Dewanganj 8 58.51% 268,517 157,105 92.08% 3 Dhaka Jamalpur Islampur 12 54.99% 310,328 170,641 98.15% 4 Dhaka Jamalpur Jamalpur Sadar 15 49.76% 640,539 318,756 97.61% 5 Dhaka Jamalpur Madarganj 7 55.45% 274,105 151,992 98.21% 6 Dhaka Jamalpur Melandaha 11 47.22% 325,550 153,733 91.63% 7 Dhaka Jamalpur Sarishabari 8 44.73% 338,444 151,389 96.42% 8 Dhaka Mymensingh Bhaluka 11 31.08% 447,296 139,031 98.43% 9 Dhaka Mymensingh Dhobaura 7 58.20% 203,759 118,581 99.98% 10 Dhaka Mymensingh Fulbaria 13 52.63% 466,010 245,282 99.99% 11 Dhaka Mymensingh Gaffargaon 15 43.92% 447,574 196,588 99.76% 12 Dhaka Mymensingh Gauripur 10 50.63% 335,702 169,960 87.59% 13 Dhaka Mymensingh Haluaghat 12 50.33% 301,093 151,526 99.46% 14 Dhaka Mymensingh Ishwarganj 11 55.97% 391,078 218,879 99.91% 15 Dhaka Mymensingh Muktagachha 10 43.35% 431,984 187,262 99.50% 16 Dhaka Mymensingh Mymensingh Sadar 13 52.28% 809,324 423,133 99.55% 17 Dhaka Mymensingh Nandail 12 60.66% 418,539 253,896 100.00% 18 Dhaka Mymensingh Phulpur 20 58.80% 625,001 367,472 96.78% 19 Dhaka Mymensingh Trishal 12 47.78% 435,803 208,215 99.36% 20 Dhaka Sherpur Jhenaigati 7 36.91% 166,563 61,481 26.29% 21 Dhaka Sherpur Nakla 9 46.76% 197,373 92,297 50.74% 22 Dhaka Sherpur Nalitabari 12 41.76% 261,305 109,133 57.34% 23 Dhaka Sherpur Sherpur Sadar 14 55.82% 517,495 288,869 99.68% 24 Dhaka Sherpur Sreebardi 10 49.08% 269,865 132,451 95.65% 25 Rangpur Gaibandha Fulchhari 7 58.06% 171,633 99,656 78.28% 26 Rangpur Gaibandha Gaibandha Sadar 13 44.76% 454,940 203,653 98.61% 27 Rangpur Gaibandha Gobindaganj 17 45.39% 534,809 242,771 79.90% 28 Rangpur Gaibandha Palashbari 9 44.75% 254,154 113,736 84.62% 29 Rangpur Gaibandha Sadullapur 11 50.99% 298,379 152,149 99.92% 30 Rangpur Gaibandha Saghata 10 52.75% 278,037 146,676 88.26% 31 Rangpur Gaibandha Sundarganj 15 47.55% 479,729 228,124 99.66% 32 Rangpur Kurigram Bhurungamari 10 65.14% 240,416 156,615 63.60% 33 Rangpur Kurigram Char Rajibpur 3 68.82% 76,201 52,443 34.94% 34 Rangpur Kurigram Chilmari 6 61.07% 127,632 77,949 51.62% 35 Rangpur Kurigram Kurigram Sadar 8 57.99% 325,412 188,692 58.77% 36 Rangpur Kurigram Nageshwari 14 64.96% 410,143 266,443 68.43% 37 Rangpur Kurigram Phulbari 6 68.48% 166,373 113,940 22.54% 38 Rangpur Kurigram Rajarhat 7 67.69% 189,958 128,578 31.38% 39 Rangpur Kurigram Raumari 5 57.01% 203,949 116,266 48.61% 40 Rangpur Kurigram Ulipur 13 65.32% 410,890 268,388 83.40% 41 Rangpur Lalmonirhat Hatibandha 12 38.08% 242,814 92,474 8.58% 42 Rangpur Nilphamari Jaldhaka 11 43.54% 354,287 154,264 77.80% 79