Emergency Justification Memo -- COVID-19 Performance Monitoring

MEMORANDUM
DATE:

11/23/2022

TO:

Michael McManus, USAID Desk Officer Office of Information and Regulatory
Affairs Office of Management and Budget (0MB)

FROM:

Beth Tritter, Director, COVID-19 Response Team, Bureau for Global Health at
the U.S. Agency for International Development (USAID)

SUBJECT:

Justification for Emergency Processing

Summary
USAID is seeking emergency consideration of its Information Collection Review that aims to
require a subset of contractors and NGOs receiving USAID funds for COVID-19 global health
programming to collect and report performance data on a regular basis through USAID’s
web-based Development Information Solution (DIS). USAID cannot reasonably comply with the
normal clearance procedures under the Paperwork Reduction Act because they would delay the
Agency's efforts to monitor activities that further the Administration’s Initiative for Global
Vaccine Access–thus hindering USAID’s ability to save lives, preserve livelihoods, and mitigate
risks to critical infrastructure around the world.
Background
The United States is committed to ending the acute phase of the COVID-19 pandemic, both at
home and abroad, and has been instrumental in the global response to fight the virus. The
emergence of COVID-19 hotspots and variants, including Omicron and its sub-lineages,
underscores the importance of this global fight. Vaccinating the world is the best way to prevent
future variants that could threaten the health of Americans and undermine our economic
recovery.
As part of the U.S. Government’s commitment to global frontline efforts to get shots into arms
and save lives around the world, USAID Administrator Samantha Power announced the U.S.
Government’s Initiative for Global Vaccine Access, or Global VAX for short. This initiative
expands assistance and enhances interagency and international coordination to identify and
overcome vaccine access barriers and save lives now, with a specific emphasis on scaling up and
sustaining vaccination support in sub-Saharan Africa. Global VAX brings together a
whole-of-government effort, through which the United States has already committed more than
$1.3 billion for vaccine readiness.

As the U.S. Government coordinating Agency for executing the Initiative for Global Vaccine
Access (Global VAX), USAID and its implementing partners (IPs) are at the frontlines of
delivering shots into arms and saving lives. As the coordinating agency, USAID leads
interagency reporting and analysis on progress on this important effort. With widespread
availability of vaccines since mid-2021, global vaccination rates have soared, but many countries
remain stalled at low rates, particularly among populations at greatest risk of severe disease and
death.
This important effort–countering stalled progress to vaccinate the world–requires close
coordination across a range of actors and careful tracking of performance indicators for adaptive
management, strategic decision-making, and accountability. USAID IPs play a vital role in the
collection and reporting of performance indicators that facilitate adaptive management and
strategic planning, and ensure that COVID-19 response activities are continually aligned with the
Agency and Administration’s primary objectives. Tracking these metrics and timebound targets
allow the Agency to systematically monitor and respond to changes in an ever-evolving crisis–in
Washington and overseas–including the COVID-19 Task Force (CTF), Technical Bureaus,
Regional Bureaus, and field-based Missions.
Proposed Information Collection Activity and Justification
At present, USAID relies on IPs to voluntarily report these data. While many IPs have
voluntarily provided rich performance data, reporting rates remain low and limit our ability to
comprehensively assess progress and inform decision- making. Incomplete data impedes USAID
efforts to use performance data for adaptive management, strategic resource allocations, or to
provide an accurate picture of our achievements to key USG and non-governmental stakeholders.
Moreover, it compromises efforts to aggregate USAID implementing partner data with that
collected by Interagency partners as required by USAID’s role as the Global VAX reporting and
analysis lead. The current system of voluntary reporting is not fit-for-purpose under USAID’s
lead Global VAX role.
Accordingly, USAID requests emergency OMB approval to conduct this essential information
collection activity on a mandatory basis utilizing the web-based Development Information
Solution (DIS) platform. Emergency approval is being sought under 5 C.F.R. § 1320.13(a)(2)
which allows for emergency processing of collections of information in instances where an
agency cannot reasonably comply with the normal clearance procedures because (ii) an
unanticipated event – the COVID-19 pandemic – has occurred and (iii) normal procedures would
likely prevent or disrupt the timely collection of this information or cause a deadline to be
missed.

The information collected would not only guide how USAID implements the Administration’s
COVID-19 response strategy, but also feed into key evaluations, promote Agency-wide learning,
and inform future pandemic planning. USAID cannot reasonably comply with the normal
clearance procedures under the PRA because, given the programmatic timeline of Global VAX
activities, they would derail the Agency's efforts to collect this critical information.
● Current voluntary reporting is inadequate. Since the beginning of the pandemic,
USAID has relied on partners to voluntarily report COVID-19 global health indicators.
While many IPs submit rich and informative data, it is incomplete. An analysis for this
ICR found a historic reporting rate of under 70 percent for a subset of partners that have
received Global VAX funding since January 2022 and also received earlier ARPA funds,
leaving tens of millions of dollars of assistance without reported results. Given the
composition of recipients of recent o Global VAX funds–with proportionally more money
going to bilateral mechanisms, which have lower reporting rates–we may expect lower
reporting rates in key Global VAX countries in 2023. USAID has devoted significant
resources to encourage IPs to report voluntarily, but these voluntary efforts have proven
insufficient to boost reporting to acceptable levels. An expedited review will allow us to
quickly increase reporting rates on GVAX efforts in FY2023–including in the countries in
which USAID is making its most significant investments to boost vaccinations and
advance the U.S. COVID-19 Global Response and Recovery Framework.
● New interagency responsibilities for GVAX reporting and analysis. In the first quarter
of 2022, USAID was designated as the lead agency for coordinating Global VAX
implementation and reporting interagency progress. Fulfilling this responsibility requires
USAID to regularly collect complete COVID-19 performance information from its own
IPs through a centralized reporting system, and to collect data from interagency partners
such as the CDC and State Department. USAID rapidly developed a COVID-19 health
module in the web-based Development Information Solution (DIS) for IPs to enter
COVID-19 results. DIS is a web-based, Agency-wide portfolio management system
designed to meet the need for high-quality, readily available data by integrating program
funding, awards, contract information and development results into a single platform.
Full roll-out of the DIS across the Agency is included in an ongoing rule-making process,
a decision on which is not expected until mid-2023 at the earliest–much too late to inform
the evolving COVID response. As of June, 2022, USAID has trained most GVAX IPs in
using the DIS, and a number of partners have begun voluntarily submitting C19 health
data through the system. The centralized, streamlined reporting through DIS will
significantly improve adaptive management and reporting–if complete data are

submitted. Given low reporting rates detailed above, this will only happen if USAID can
require reporting from its Global VAX IPs.
● Funding timeline. More than $250 million of Global VAX funding was obligated in
September, 2022. These funds will enable USAID to intensify its efforts to boost
vaccination rates in countries with a significant Global VAX investment, and will be used
to pay for the cost of data collection proposed herein. The standard ICR process will not
be complete before those funds are obligated or before a significant portion of them are
spent. The obligation and programmatic times require an expedited review that will allow
USAID to incorporate those costs into obligations and capture performance results from
its 2023 Global VAX programming.
The Paperwork Reduction Act of 1995 requires that agencies obtain OMB approval before
requesting most types of information from the public ("information collections" include forms,
interviews, and record keeping). USAID seeks emergency approval of information collection
associated with this performance monitoring effort. USAID cannot reasonably comply with the
normal clearance procedures under the PRA because complying would delay the Agency's
efforts to monitor ongoing activities designed to advance the Administration’s global vaccination
goals. This request meets the standard for emergency processing as the COVID-19 crisis is an
unanticipated event with ongoing risks to lives, livelihoods, and critical systems worldwide.
Failure to collect and analyze performance data on the COVID-19 response would hobble the
Agency’s ability to engage in accountable programming, provide proper oversight for more than
half a billion dollars of resources, and wholly undermine efforts to facilitate operational tracking
and continuous learning.The Agency will issue a Federal Register Notice notifying the public of
this request, and will provide 1 week for public comment.

SIGNED BY:
Beth Corinne

Digitally signed by Beth
Corinne TRITTER (affiliate)

_________________________
TRITTER (affiliate) Date: 2022.11.23 14:24:58
-05'00'

Beth Tritter
Director
COVID-19 Response Team, Bureau for Global Health
U.S. Agency for International Development
11/23/2022