Comparison Chart: USAID's PVS for Contractors Provides Benefits Not Afforded to NGOs

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Date: 
September 4, 2009

If USAID implements a Partner Vetting System (PVS) that applies to both foreign assistance programs (NGOs) and acquisition (contractors), to the extent possible, the PVS should be the same for both. However, the proposed rule for contractors provides several benefits not available to NGOs in the foreign assistance rule. 

See a chart comparing the PVS for NGOs and contractors.
 

Key differences between the two final rules:
 

  • Risk assessment: The proposed rule for contractors limits application of PVS to situations where USAID has conducted a risk assessment and determined there is a need for enhanced vetting. In contrast, PVS is imposed on all NGOs, regardless of risk. No justification for this difference has been offered, and we do not believe there is one. To be consistent and fair, the risk assessment provision should apply to NGOs as well, regardless of the final structure of the vetting system. 
  • Minimizing impact: In the proposed contractor rule USAID appropriately states that its goal is a rule that "minimizes the impact on our programs and contractors while still protecting against the possibility that USAID funds could benefit terrorist groups." USAID has not stated this as a goal for its rule for NGOs, despite substantial comments attesting to the negative impact PVS would have on them. Fairness requires USAID to have a consistent standard, which should be the higher one afforded contractors. 
  • Appeals process: The proposed appeal/reconsideration process for contractors is more specific than the process USAID has provided for NGOs. For example, the seven day time for contractors to appeal and the requirement that USAID provide a decision within seven days is more reasonable than the open ended times provided for NGOs. Delays can cause serious problems for program implementation and should be avoided. The contractor rule provides another opportunity not given NGOs: to resubmit the form with additional information prior to a decision on whether or not it passes vetting. Both NGOs and contractors should have this opportunity.