MONROVIA –April 14, 2022: The Ministry of Health has informed the public that it has the investigation report issued by the Global Fund’s Office of Inspector General (OIG) on April 8, 2022. The Ministry is analyzing the report to inform action(s) to be instituted by the Ministry.
It is important activities to note the that the OIG investigation was triggered by the Ministry when irregular in one of its programs, The National Aids Control Program (NACP) was discovered by the internal audit unit of the Ministry in 2020 after which the Ministry’s alerted the Global Fund which triggered the OIG investigation in keeping with the Grant Agreement.

The ministry says the period under review in keeping with the Global Fund grant management and procedure, The fiduciary responsibilities such as procurement, Financial Management (including co-signing of checks, Local Purchase Orders, and Vouchers), Internal Audit and External Audit functions were all being jointly executed by many international firms with the following responsibilities:

Cardno International Development, An American base financial management firm was contracted by Global fund as its Fiscal Agent (FA) and was stationed at the MOH with the fiduciary responsibility of reviewing all procurement and financial transactions as well as providing pre-audit and post-audit functions on global fund transactions. If the LFA is dissatisfied with a particular transaction or transaction, it doesn’t get processed until it’s corrected and signed on by the FA. The FA has the right to also declare a transaction as illegible even after it has occurred. Cardno served the Ministry in this capacity from 2015 to 2021 and has now been replaced by GFA Consulting Group another Internal Financial and Procurement management firm as of January 2022.

Swiss Centre for International Health has also been under contract by the Global Fund as the Local Fund Agent (LFA). The LFA oversees quarterly reviewing and certification of all quarterly transactions submitted to the Global Fund along with their supporting documents. They also provide assurances of all quarterly reports submitted to the Global Fund on a periodic basis. The LFA performed post-audit of all transactions on a quarterly basis and report to Global any irregularities. The LFA has the right to also declare expenditures stated in the quarterly report as illegible after it has reviewed the transactions. In which case, the MOH will have to reimburse the Global Fund for such expenditures deemed illegible. Since 2015 the Swiss Center for International Health has played the role of Local Fund Agent.

The Moore Stevens International Auditing Firm based in the UK was hired by the Global for the period of the OIG report, as is expected, the International Auditors provided assurances of all transactions carried out by the Ministry during the period 2015-2020. These very transactions which were reviewed by the FA and LFA were also authenticated by the external auditors through the provision of an Unqualified Opinion (Clean Opinion). The Moore Stevens five years contract has ended and has been replaced by Ernst & Young, another international Auditing firm that is currently conducting an Audit of the Global transactions for the fiscal year ended December 31, 2021.

The ministry further stated that they believe the vigorous system of check and balance the Global Fund Grant management system has in place at the Ministry of health along with our robust Financial Management System and many years of managing grants we can safely say it’s impossible to engage in massive corruption without being detected over a long time as it has been portrayed by the OIG report. OIG’s findings declared an aggregate expenditure summing up to US$990,000 (Nine Hundred and Ninety Thousand United States dollars) non-compliant and recommended restitution. The Ministry believes restituting this amount is unfair and firmly disagrees with some of the reasonings behind the OIG’s conclusion. We however concede that some amount must be restituted depending on the circumstances. For example, the draft OIG report shows that some people received money as daily subsistence allowances (DSAs) for a given number of days but spent fewer days on the field. Those who fall in this category are among the persons being investigated. Stipulation to restitute the DSAs for the number of days not accounted for will certainly form a part of the recommendations of the investigation.

The following were the finding as mentioned in the final report issued by the OIG on April 8, 2022.

Staff of the National AIDS Control Program were accused of conducting fraudulent procurements of vehicle repairs and advertising services.

No assurance could be provided over program delivery in 75% of MoH field activities that we reviewed.

The MoH overcharged for daily subsistence allowances and misused grant funds by providing incorrect allowances and catering expenses.

The MOH used global Fund grant to pay taxes to the Government of Liberia

The Ministry has established a committee to carry out detailed reviews of the report and to further investigate allegations contained in count one the report. The internal investigation committee will determine the level of wrongdoings and recommend actions against those accused, depending on the levels of culpability.

Such actions range from suspension to restitution of funds and possible prosecution. Meanwhile, the Ministry and the Global Fund’s Geneva-based Project Team—also accused in the report of inadequate oversight—are collaborating to put in place more robust measures to avoid the reoccurrence of the disreputable activities reported in the findings. The Ministry suspended the NACP’s Deputy Procurement Manager for Finance and Administration in 2020 based on the initial internal audit finding which triggered the OIG investigation. Further appropriate actions are expected to be taken after receipt of OIG report and the MOH investigation team report.

The Ministry is cognizant of its duty to discharge its duties in line with established guiding principles and in line with commitments made to execute grants pursuant to agreed procedures and guidelines.

Based on our initial reading of the report and other prior communications with the Global Fund, we are compelled to strongly disagree with count two that no assurance was provided in 75% of the field activities that were reviewed. The ministry has provided the OIG and Global fund with all supporting documentation to justify all the reviewed field activities not only during the OIG investigation but also during the previous review.

Most of the transactions referenced in the report concerning the mother Peer activities carried out by NACP’s Staff involve payment of DSA to staff responsible for the disbursement of funds to the beneficiaries as well as payment to the beneficiaries themselves. To claim that this program doesn’t exist, and payments made to these Mothers for the entire grant period are deemed illegible is grossly unfair to the people of Liberia not only considering that most of the Mothers are still alive and the Global has agreed with MOH to continuously pay them on the monthly basis but also the fact that OIG was unable to visit Liberia to physically interact with the beneficiaries apparently due to Covid 19.

Meanwhile, MOH maintained that this program has existed, funds were disbursed to the beneficiaries and is still being disbursed to them but using as agreed with the Global Fund, mobile money transfer mechanism rather than cash disbursement s being implemented since early 2021.

Count three of the OIG’s findings also charged that the Ministry paid overcharged DSA—totaling US$204,769.43 (two hundred and four thousand seven hundred sixty-nine United States dollars forty-three cents). The Ministry strongly disagrees with this finding. As you are aware, each GFATM grant is signed with a fixed budget—that has a stated DSA rate and assumption therefor—but the OIG disregarded the approved rates and declared the above amount noncompliant because, according to the OIG, the DSA rates were inconsistent with GOL local Travel Ordinance Rate. Thus, the OIG’s interpretation of the Grant Agreement regarding DSA is in dissonance with those of the Ministry. The OIG posits that, though the grant currency is in USD, the Ministry should have converted all DSA amounts to Liberian dollar before disbursing to staff travelling to the field even though the GMFTM doesn’t maintain a Liberian Dollar Bank Account

The last count in the findings also charged that PR applied import taxes on petroleum products of ($160,00). The Ministry agrees that taxes were applied on petroleum products, but the Ministry has no control over taxes. As a non-tax paying agency, the Ministry can only apply for tax waiver for items specifically consigned to the Ministry. This is not the case with petroleum products that are imported by select venders; however, we are engaging relevant government agencies to derive mechanisms through which petroleum products procured with GFATM money can be tax free—we wrote the Liberia Revenue Authority (LRA) in October 2020 and made specific request for tax waiver on fuel procure with GFATM money but did not get feedback from the LRA.

The Ministry assures the public that appropriate actions will be taken against those culpable of committing fraud. Corrective actions will also be taken to ensure that procedural errors such as issuing of tax-exempt documentation does not occur going forward.

The Ministry however wishes to inform the public that averments contained in the OIG report are allegations and not a guilty verdict against any employee of the Ministry. Our country’s legal system commands investigations that are consistent with due process of law. That is why an internal probe into the OIG finding has been commissioned.

It can be recalled on Wednesday, April 14, 2022, Frontpage Africa reported that renowned international health body The Global Fund released a damaging report on the Ministry of Health, unearthing alleged acts of corruption amounting to nearly US$1M.
The Global Fund is a partnership designed to accelerate the end of AIDS, tuberculosis and malaria as epidemics. As an international organization, the group mobilizes and invests more than US$4 billion a year to support programs run by local experts in more than 100 countries.
In a report released by the Office of the its Inspector General on April 8, 2022, the group pointed out alleged conflict of interest, procurement fraud, overcharging for services rendered, concealing improper payment of fuel taxes, systemic fraud, and misappropriation, among others.

The OIG is responsible to safeguard Global Fund’s assets, investments, reputation and sustainability by ensuring that it takes the right action to end the epidemics of AIDS, tuberculosis and malaria.
Through audits, investigations and advisory work, it promotes good practice, enhances risk management and reports fully and transparently on abuse.
Genesis of probe
It can be recalled that in January 2020, the OIG received reports of suspected fraud and other wrongdoing at the National AIDS Control Program (NACP), a Global Fund grant implementer under the Ministry of Health.
In response, the OIG opened an investigation, undertaking a field mission to Liberia in November 2020. The OIG also obtained digital copies of payment vouchers and other records and verified vendors.

Due to pandemic-related travel restrictions, the OIG conducted interviews with MoH staff by videoconference. During the investigation, the Global Fund’s Liberia Country Team and the MoH reported additional suspicions of fraudulent documents identified by the Fiscal Agent. The scope of the OIG’s investigation was expanded to include a review of these documents.
The OIG reviewed the expenditures for goods and services for which irregularities were reported, as well as a sample of additional expenditures. 347 MoH payment vouchers totaling US$2 million fell within the scope of the investigation.
Findings
In its findings, GF pointed out that US$0.52 million in grant funds were wasted or misused for the Mother-to-Mother Peer Program and travel-related costs.
The report disclosed that the program was a component of the prevention of mother-to-child transmission of HIV module under the HIV/TB grant.
It quoted the MoH as saying that the program was an essential component for early infant diagnosis, which had been identified as a key program activity in Liberia.
As a result, Global Fund invested US$0.25 million towards incentive payments to mother peers, who were required to provide MoH with reports on mothers they had enrolled into the program, and the infants that had been tested.
The report unearthed that between January 2020 and April 2020, MoH spent US$27,032 in Daily Subsistence Allowances (DSA) and fuel to deliver incentive payments to mother peers, or to have them sign contracts.

“The OIG found that there was no reasonable assurance that these activities took place. Depending on the period, our review highlighted that between 92-100% of the dates allegedly provided by the mother peers for the receipts of their incentive payments fell outside of the dates of travel reported by MoH staff. In 50% of cases, MoH attendance records showed that staffs were at headquarters during dates of the alleged travel”.
It noted that separate travel cost claims for the same activity to the same counties, were made by both NACP and PCU staff, while vouchers for fuel either did not contain vehicle logs confirming the travel or showed that the fuel coupons were delivered during or after the alleged travel.
“MoH incentive distribution lists showed that between 2018 and 2020, 232 mother peers were enrolled. MoH could not however provide the OIG with contracts for all mother peers. We found that some mother peers who did have a contract were not included in the incentive distribution lists, and vice-versa. We compared the signatures of 122 mother peers on identification documents, contracts and DSA distribution lists, and found inconsistencies between signatures in 92% of cases”.
It indicated that though Mother peer reports were a contractual condition for incentive payments, the NACP could only provide the OIG with a very small number of reports, which were inadequate.
“They included data inconsistencies, as well as reports from mother peers who were not part of the Global Fund-financed program. Some mother peers listed each other as clients, and the reports showed that only a small number of infants had actually been tested for HIV. The OIG was unable to determine whether the reports were fraudulent or whether they contained data errors that should have been identified by MoH. MoH could not provide evidence that it reviewed or used any of the reports. NACP’s Program Manager misrepresented the authenticity of program documentation, claiming it was used by NACP in 2018 and 2019 despite it only being created in 2021”.
Other travel-related costs
The report further pointed out that GF reviewed 47 payment vouchers for DSA totaling US$0.35 million and found that MoH overcharged the Global Fund by approximately 44%, or US$0.15 million, by applying incorrect US$ exchange rates which inflated the amounts.
Given the number of payments for travel-related costs, the report maintained that the total amount of overcharge was likely even higher.
“The Global Fund requires that when meals are provided, the DSA amount should be reduced accordingly. MoH however told OIG that its practice was to provide both catering and full DSA. We reviewed payment vouchers for 12 activities and found that MoH overcharged the Global Fund US$90,638 by providing meals and full DSA”.

Non-compliance with policies, insufficient controls
It disclosed that there was also a non-compliance with policies, insufficient controls and a lack of oversight which led to no assurance over program delivery in 75% of cases reviewed, totaling US$0.4 million.
According to the report, the OIG reviewed payment vouchers, supplier invoices, per-diem distribution lists, attendance records, activity reports and vehicle logs for program activities carried out by the National AIDS Control Program (NACP) and the National Malaria Control Program (NMCP), totaling US$0.54 million.
It emphasized that in 75% of expenditures for field activities, the OIG found fraud and in 90% of these expenditures there was no reasonable assurance that the activities took place as reported or even at all. “The majority of the remaining 25% of expenditures did not comply with MoH or Global Fund policies and/or there was no reasonable assurance that the program activity took place”.
The report named some of the prohibited practices and unsupported expenditures as the Roll-out of 2019/2020 National Operational Plan.
It recalled that in June 2019, a cheque for US$23,535 was made payable to a Program Coordination Unit (PCU) accountant to cover Daily Subsistence Allowances (DSA), transportation reimbursement, catering, and hall rental for five meetings in five counties to roll out the 2019/2020 National Operational Plan.
The report disclosed that the OIG review of the payment and supporting documents found multiple red flags, including identical phone numbers and taxpayer identification numbers for supplier bidders, and the same names listed in attendance registers for the same day in different areas, adding that, “all attendance registers contained entries apparently written by the same hand”.
Quality Control review of Health Facilities
The report pointed out that in October 2020, the Global Fund approved MoH’s request for US$14,650 for three teams to conduct a Diagnostic Quality Assurance and Quality Control review of health facilities.
According to GPS trackers installed on the vehicles, one of the three teams travelled for only 6 of the 15 days claimed, and to 2 of the 4 counties they reported visiting.
In the counties to which the team did travel, the report added that, the team did not travel to at least five health facilities which they reported visiting.
“The second team only travelled for 8 of the 21 days they reported, and did not travel to at least 3 health facilities they reported visiting. A review of the third team’s travel revealed its members were eligible for 2.5 days of DSA, as opposed to the 17 days they claimed”.
Maintenance and training for GeneXpert machines and chemistry analyzers
The report uncovered that in March 2020, the NACP spent US$11,420 for DSA and fuel to conduct maintenance and training for GeneXpert machines and chemistry analyzers.
According to the report, the same NACP staff members were recorded as attending different events on the same dates.
“NACP attendance logs showed that staff members allegedly participating in the activities were actually present at the NACP office. Vehicle logs and activity reports were fabricated: for example, one activity report included photocopied sections of another. NACP acknowledged that the activities did not take place, and MoH financial records stated that the expenditures had been voided and the funds reimbursed. However, MoH bank account records revealed no such reimbursement”.

Roll-out of 2018/2019 National Operational Plan

The report further recalled that in June 2018, a cheque for US$14,740 was issued to a PCU accountant for a meeting to “consolidate, validate and print” the 2018/2019 national operational plan.

It noted that the quotation for event venue and catering and the receipt for payment were both dated for the first day of the meeting.
“DSA was provided to 45 people, 24 of whom signed attendance registers for less than the number of meeting days. Attendance registers appeared to have been falsified and included 11 people who did not receive DSA. Three people signed the register twice on the same day, and one director was listed on 8 April 2022 Geneva Switzerland Page 8 of 18 the attendance register as a driver. There was no budget for fuel, and no vehicle logs supporting travel. There was also no activity report to justify the expenditure”.
Financial Management System training
The report stated that in September 2018, US$35,320 was paid to a PCU accountant to also conduct a refresher, in-person training event on its financial management system, but there was no evidence that three quotations were received for catering and hall rental, and venue invoices were identical to the amount budgeted.
It claimed that 34% of DSA recipients did not attend the training for the number of days they received DSA and the attendance registers appeared fabricated, including signatures of individuals who had not received DSA as well as signatures of individuals twice on the same day.
It noted that some NACP staff requested and received DSA from NACP for the training, despite also having received DSA from the PCU accountant.

“In January 2019, US$47,800 was paid to a PCU accountant for an additional in-person financial management system training event. The activity report indicated that the activity was held over 10 days, but there were attendance registers for 11 days. 68% of DSA recipients did not attend the training for the number of days they received DSA. Attendance registers included signatures of people who did not receive DSA, and individuals who signed the register twice on the same day. There was no evidence that three quotations were sought or received for the supplier of the training”.

The report maintained that the budget referenced a 12-day activity, and the amount invoiced by the supplier for 11 days was identical to the amount budgeted.
“Despite representing to the OIG that all supporting documents had been reviewed, validated and retained, no records could be produced for the OIG to review.
It added that the Ministry of Health allegedly concealed improper payments of fuel taxes of at least US$0.16 million.
According to the group, the MOH controls, policies and oversight were either insufficient or overridden, while Fiscal Agent oversight was ineffective, and its personnel engaged in conflicts of interest and misappropriation of grant funds.
The group pointed out that there was systemic fraud and misappropriation by staff of the Ministry of Health (MoH), a Principal Recipient for Global Fund grants in Liberia.
“Our investigation found non-compliant expenditures and/or various types of wrongdoing in 91% of the expenditures reviewed. Non-compliant expenditures totaled US$1.1 million, of which we recommend recovery of US$0.99 million. Staff of the National AIDS Control Program conducted fraudulent procurements of both vehicle repairs and advertising services, for which there is no reasonable assurance of delivery”.

“No assurance could be provided over program delivery in 75% of MoH field activities that we reviewed. The MoH also overcharged the Global Fund for daily subsistence allowances and misused grant funds by providing incorrect allowances and catering expenses”.
The report emphasized that Global Fund’s US$0.25 million investment into the mother peer program for early infant diagnosis produced a small number of inadequate reports that were not used.
Contrary to Grant Regulations, the report divulged that, the MoH used grant funds to pay taxes on fuel, and knowingly misrepresented the grants’ tax- exempt status to the Global Fund.
“MoH controls, policies, and oversight to mitigate fraud and misappropriation were either insufficient or did not exist. Where they existed, they were overridden. The Global Fund has implemented several internal controls to address this issue, and further controls will be implemented as a result of this investigation”.

Fiscal Agent linked

The report stated that Global Fund’s Fiscal Agent became aware of the wrongdoing identified in this investigation in 2015 but continued to approve MoH expenditures and did not adequately mitigate the risk of fraud.
“The Fiscal Agent also engaged in conflicts of interest and misappropriation, including accepting grant funds for DSA and fuel coupons for activities that did not take place. A new Fiscal Agent was appointed in 2022”.
It maintained that the Global Fund Secretariat was aware of fraud red flags and other wrongdoing in MoH-managed grants from 2015, but did not report the matters at issue in this investigation to the Office of the Inspector General.
The report disclosed that during the time of the OIG’s investigation, the Principal Recipient was known as the Ministry of Health and Social Welfare (now known as the Ministry of Health).
It noted that the OIG reviewed the expenditures for goods and services for which irregularities were reported, as well as a sample of additional expenditures.
Since 2004, Global Fund has signed grants of US$309 million and disbursed over US$248 million to the post-conflict Liberia, which has been classified by the World Bank as a low income country. The nation, which has suffered over a decade of civil war and a major Ebola outbreak have caused major loss of life and socio-economic disruption.
The Ministry of Health is the Principal Recipient for the HIV/TB and Malaria grants.
The HIV/AIDS program is implemented by the National Aids Control Program, and the malaria program by the National Malaria Control Program. A Program Coordination Unit within MoH is responsible for monitoring program implementation, ensuring compliance with Global Fund policies and guidelines, and managing grant funds.
Between 1 January 2018 and 30 June 2021, MoH expenditures for the HIV/TB grant totaled US$25.8 million. Between 1 July 2018 and 30 June 2021, expenditures for the Malaria grant totalled US$22.0 million. The Global Fund has invested heavily to strengthen MoH’s financial management capacity.
In 2014, a Fiscal Agent, Cardno Emerging Markets USA Ltd., was put in place to provide additional fiduciary controls.
After OIG’s 2019 Audit of Global Fund Grants in Liberia found that Fiscal Agent oversight was inadequate, a new Fiscal Agent Team Leader was assigned in 2020.
In 2017, the MoH issued new policy regulations for transactions under Global Fund grants. The regulations increased the national programs’ transaction spending limit to US$10,000, with the Fiscal Agent only reviewing national program expenditures after they had been made.
In 2019, the MoH assigned Compliance Officers to the national programs to review program expenditures against financial and procurement policies. Expenditures by the national programs were also reviewed by the Program Coordination Unit (PCU).
Responses
In its report, Global Funded recalled that on 10 November 2021, the OIG provided MoH and the Fiscal Agent with a copy of the Letter of Findings, which represented the full record of relevant facts and findings as they related to them.
It stated that the two organizations were afforded an opportunity to provide comments and supporting documents on the findings and conclusions.
The Fiscal Agent provided its response on 3 December 2021, while the MoH responded on 5 December 2021.
Following the release of the report’s findings, the MoH convened an Investigation Committee headed by the Office of the General Counsel.
The ministry had previously removed NACP’s Finance Manager from his position, and OIG’s report will be used by the Committee as a basis for its investigation to assist the MoH in its decisions against persons found liable or culpable for the fraud and misappropriation identified in this report.
The Investigation Committee’s findings in relation to MoH could result in suspension, restitution, dismissal, or possible criminal prosecution.
However, the Committee’s findings will not impact OIG’s investigation findings or the subsequent actions taken by the Global Fund as a consequence of OIG’s investigation findings”.
In its report, the Fiscal Agent Cardno disagreed with OIG’s conclusions regarding conflict of interest on the part of the former Fiscal Agent team.
According to GF, Cardno was not aware that the former Fiscal Agent’s in-country team members received DSA and fuel from the PR but noted that the former Fiscal Agent’s budget had not anticipated the level of travel required for the Fiscal Agent’s attendance at MoH field activities.
The report added that Cardno noted that even if reimbursed by the Global Fund, the reimbursement would have come from the grant budget.
“Cardno responded that the financial management system training events in which Fiscal Agent staff participated took place but relied on the MoH to provide related evidence. OIG concluded that these activities did not take place as described. Cardno agreed that it was poor judgment to have the Fiscal Agent intern participate in the distribution of mother-peer incentive payments, which OIG concluded did not take place as described. However, Cardno disagreed that the hiring of the intern constituted a conflict of interest. Fiscal Agents are bound by the Global Fund’s Policy on Conflict of Interest. The Fiscal Agent’s acceptance of funds from the Principal Recipient, and the hiring of an intern with close connections with the MoH constituted a conflict of interest as defined by Global Fund’s policy”.