United States Government Accountability Office Report to Congressional Committees HUMAN December 2018 TRAFFICKING State and USAID Should Improve Their Monitoring of International Counter- trafficking Projects GAO-19-77 December 2018 HUMAN TRAFFICKING State and USAID Should Improve Their Monitoring of International Counter-trafficking Projects Highlights of GAO-19-77, a report to congressional committees Why GAO Did This Study What GAO Found Human trafficking is a pervasive The Departments of State (State), Labor (DOL), and the U.S. Agency for problem throughout the world. Victims International Development (USAID)—through agreements with implementing are often held against their will in partners—managed 120 international counter-trafficking in person projects slave-like conditions. during fiscal year 2017. The National Defense Authorization GAO reviewed a selection of 54 counter-trafficking projects (37 State, 3 DOL, Act for Fiscal Year 2017 includes a and 14 USAID), and found that DOL and USAID had fully documented their provision for GAO to report on the monitoring activities, while State had not. All three agencies used similar tools to programs conducted by specific monitor the performance of their projects, such as monitoring plans, performance agencies, including State, DOL, and indicators and targets, progress reports, and site visits. GAO found, however, USAID, that address trafficking in that State did not fully document its monitoring activities for 16 of its 37 projects persons. Among other objectives, this report (1) identifies the recent projects (43 percent). GAO found that State did not have the monitoring plans or in international counter-trafficking in complete progress reports for one-third of its projects and often lacked targets for persons that key U.S. agencies have performance indicators in its final progress reports. State officials said they had awarded to implementing partners; not required targets for each performance indicator for the projects GAO and, for selected projects, assesses reviewed, or had not set targets due to limited resources in prior years. State has the extent to which key agencies have taken steps to improve its monitoring efforts, including issuing a November 2017 (2) documented their monitoring policy that requires targets to be set for each performance indicator and activities and (3) ensured the reliability developing an automated data system that would require targets to be recorded. of project performance information. However, because the pilot data system allows targets to be recorded as “to be determined” and does not have controls to ensure entry of actual targets, it is GAO reviewed State, DOL, and USAID uncertain whether performance targets will be regularly recorded. Without full project documents and interviewed agency officials. GAO reviewed documentation of monitoring activities and established performance targets, monitoring documents for 54 of the 57 State has limited ability to assess project performance, including project projects that were active from the efficiency or effectiveness. beginning of fiscal year 2016 through the end of fiscal year 2017. Of these GAO reviewed the reliability of project performance information for 5 of the 54 54 projects, GAO selected a counter-trafficking projects (2 State, 1 DOL, and 2 USAID) and found that State nongeneralizable sample of 5 projects, and USAID used inconsistent and incomplete performance information, while based primarily on largest total award DOL used consistent and complete information. For example, some quarterly amounts, for review of the reliability of indicator results in State and USAID progress reports were inconsistent with project performance information. annual total results, and narrative explanations for significant deviations from performance targets were sometimes not present in quarterly reports. According What GAO Recommends to agency officials, performance information from these projects is regularly used GAO is making four recommendations not only for direct project oversight but also for internal and external reporting, to State and one recommendation to program decisions, and lessons learned. GAO found that State’s and USAID’s USAID, including that both agencies processes lack sufficient controls to ensure the reliability of project performance establish additional controls to improve information, but did not find inadequate controls in DOL’s process. For example, the consistency and completeness of neither State nor USAID consistently used automated checks on indicator results project performance information, and to ensure consistency and completeness of performance indicator result that State maintain monitoring activity calculations. In contrast, DOL used automated checks as part of its process. documentation and establish targets Without implementing controls to ensure that performance information is for each performance indicator. State consistent and complete, State and USAID officials cannot fully or accurately and USAID concur with GAO’s understand what projects are, or are not, achieving, and how their efforts might recommendations. be improved. View GAO-19-77. For more information, contact Jennifer Grover at (202) 512-7141 or groverj@gao.gov. United States Government Accountability Office Contents Letter 1 Background 6 During Fiscal Year 2017, State, DOL, and USAID Managed 120 Counter-Trafficking in Persons Projects 13 DOL and USAID Fully Documented Their Monitoring Activities for All Selected Projects, but State Did Not Fully Document Its Activities for 16 of 37 Selected Projects 18 State and USAID Do Not Have Sufficient Controls to Ensure the Reliability of Project Information, while DOL Had Consistent and Complete Performance Information in the Project We Reviewed 26 State Does Not Have a Process to Ensure that All Performance Indicators are Useful, while USAID and DOL Have Established Processes to Regularly Review the Usefulness of Indicators 35 Conclusions 38 Recommendations for Executive Action 39 Agency Comments and Our Evaluation 39 Appendix I Objectives, Scope, and Methodology 44 Appendix II Three Key U.S. Agencies’ Counter-trafficking in Persons Projects, Active in Fiscal Year 2017 54 Appendix III State Documentation for Its Performance Monitoring Activities for 37 Counter-Trafficking in Persons Projects 64 Appendix IV Comments from the Department of State 67 Appendix V Comments from the U.S. Agency for International Development 70 Appendix VI GAO Contact and Staff Acknowledgments 77 Page i GAO-19-77 Human Trafficking Related GAO Products 78 Tables Table 1: Summary of Departments of State (State) and Labor (DOL), and U.S. Agency for International Development (USAID) Counter-trafficking in Persons Projects Active during Fiscal Year 2017, as Identified by Agency Officials 14 Table 2: GAO Summary of Logic Model Example from Department of State’s Office to Monitor and Combat Trafficking in Persons 19 Table 3: Extent to Which Department of State Documented Performance Monitoring Activities for 37 Selected Counter-Trafficking in Persons Projects 22 Table 4: Departments of State (State) and Labor (DOL), and U.S. Agency for International Development (USAID) Counter- trafficking in Persons Projects Active during Fiscal Year 2017, as Identified by Agency Officials 54 Table 5: Extent to Which Department of State Documented Performance Monitoring Activities for 37 Selected Counter-Trafficking in Persons Projects 65 Figure Figure 1: Examples of Trafficking in Persons Victims in the Department of State’s Trafficking in Persons Report June 2018 8 Page ii GAO-19-77 Human Trafficking Abbreviations ADS Automated Directives System CPI common performance indicators DIS Development Information Solution DOD Department of Defense DOL Department of Labor DRG Center Center of Excellence on Democracy, Human Rights and Governance DRL Bureau of Democracy, Human Rights, and Labor FAPD Federal Assistance Policy Directive FinCEN Financial Crimes Enforcement Network GPD-42 Grants Policy Directive Number 42 ILAB Bureau of International Labor Affairs MPG Management Procedures and Guidelines OCFT Office of Child Labor, Forced Labor, and Human Trafficking OFAC Office of Foreign Assets Control PITF President’s Interagency Task Force to Monitor and Combat Trafficking in Persons SAMS-D State Assistance Management System - Domestic State Department of State TFFC Office of Terrorist Financing and Financial Crimes TFI Office of Terrorism and Financial Intelligence TIP Office Office to Monitor and Combat Trafficking in Persons Treasury Department of the Treasury USAID United States Agency for International Development This is a work of the U.S. government and is not subject to copyright protection in the United States. The published product may be reproduced and distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. Page iii GAO-19-77 Human Trafficking Letter 441 G St. N.W. Washington, DC 20548 December 4, 2018 Congressional Committees Trafficking in persons, or human trafficking, is a longstanding and pervasive problem throughout the world, as traffickers buy, sell, and transport victims across national boundaries. 1 Victims are often held against their will in slave-like conditions or forced to work in the commercial sex trade, garment factories, fishing boats, agriculture, domestic service, and other types of servitude. In addition to inflicting grave damage upon its victims, trafficking in persons is a multi-billion dollar industry that undermines government authority, distorts markets, fuels organized criminal groups and gangs, enriches transnational criminals and terrorists, and imposes social and public health costs. The Department of State (State) noted in its June 2018 Trafficking in Persons Report that terrorist organizations also use trafficking in persons to recruit adherents and finance their operations. 2 Congress enacted the Trafficking Victims Protection Act of 2000 to combat trafficking in persons, 3 and has reauthorized this act four times. 4 The act, as amended, defines severe forms of trafficking in persons as (1) sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act is under age 18; or (2) the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion, for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery. 5 According to the International Labor Organization, in 2016, there were an estimated 24.9 million people in forced labor, including 4.8 million people 1 The terms “human trafficking” and “trafficking in persons” are often used interchangeably. In this report, we use the term “trafficking in persons,” as referred to in U.S. law, except where source documents use the term “human trafficking.” 2 U.S. Department of State, Trafficking in Persons Report (June 2018). 3 Enacted as Division A of the Victims of Trafficking and Violence Protection Act of 2000. Pub. L. No. 106-386, Div. A, 114 Stat. 1464, 1466-91. 4 Trafficking Victims Protection Reauthorization Act of 2003, Pub. L. No. 108-193, 117 Stat. 2875; Trafficking Victims Protection Reauthorization Act of 2005, Pub. L. No. 109- 164, 119 Stat. 3558 (Jan. 10, 2006); William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008, Pub. L. No. 110-457, 122 Stat. 5044; Violence Against Women Reauthorization Act of 2013, Pub. L. No. 113-4, Title XII, 127 Stat. 54,136-160. 5 22 U.S.C. § 7102. Page 1 GAO-19-77 Human Trafficking in forced sexual exploitation. However, as we previously reported, estimates of the number of trafficking victims are often questionable due to data and methodological weaknesses. 6 The National Defense Authorization Act for Fiscal Year 2017 includes a provision for GAO to report on the programs conducted by the Department of State (State), the Department of Labor (DOL), the United States Agency for International Development (USAID), the Department of Defense (DOD), and the Department of the Treasury (Treasury) that address human trafficking and modern slavery, including a detailed analysis of the effectiveness of such programs in limiting human trafficking and modern slavery. 7 Three of these agencies—State, DOL, and USAID—have programs that design and award counter-trafficking projects to implementing partners, through contracts, grants, or cooperative agreements. 8 These agencies then oversee and monitor these projects. Since DOD and Treasury officials did not identify these types of projects as part of their counter-trafficking in persons efforts, we provide background information on their efforts but do not cover these agencies in our reporting objectives. This report (1) identifies the recent projects in international counter-trafficking in persons that key U.S. agencies have awarded to implementing partners, and for selected projects, assesses the extent to which key agencies have (2) documented their monitoring activities, (3) ensured the reliability of the performance information they use in monitoring projects, and (4) reviewed the usefulness of the performance indicators they use in monitoring projects. To address these objectives, we reviewed relevant agency documents and interviewed agency officials. To report on agencies’ programs, we asked knowledgeable officials at State, DOL, USAID, DOD, and Treasury to identify their projects that (1) had an international focus; (2) were delivered by implementing partners to external recipients, such as trafficking victims or host governments, as project beneficiaries; and (3) 6 See GAO, Human Trafficking: Better Data, Strategy, and Reporting Needed to Enhance U.S. Antitrafficking Efforts Abroad, GAO-06-825 (Washington, D.C.: July 18, 2006). 7 See Pub. L. No. 114-328, Div. A, Title XII, § 1298(h), 130 Stat. 2000, 2563 (2016). 8 For the purposes of our review, implementing partners include contractors, grantees, and recipients of cooperative agreements. Page 2 GAO-19-77 Human Trafficking addressed trafficking in persons, modern slavery, 9 or forced labor. 10 Because State, DOL, and USAID managed such projects, we focus on them as the three key agencies for the purposes of our reporting objectives. According to officials from these three agencies, the projects they identified range from those with counter-trafficking in persons as a primary goal, to those in which this goal was integrated as part of the agency’s activities. 11 We used the lists of projects that these agencies provided to report the relevant counter-trafficking projects that agencies 9 According to the Department of State, “trafficking in persons,” “human trafficking,” and “modern slavery” are used as umbrella terms to refer to both sex trafficking and compelled labor. Agency officials we met with also commented that modern slavery is not defined in law, and often used interchangeably with the term “trafficking in persons” or “human trafficking.” 10 To address the mandate, we gathered information about agencies’ programs and projects. In past GAO reports, we noted that the Glossary of Terms Used in the Federal Budget Process defines “program” as “generally, an organized set of activities toward a common purpose or goal that an agency undertakes or proposes to carry out its responsibilities.” This definition acknowledges that because the term program has many uses in practice, it does not have a well-defined, standard meaning in the legislative process. It is used to describe an agency’s mission, functions, activities, services, projects, and processes. Our report focuses on, and therefore uses the term, “projects,” to refer to counter-trafficking in persons interventions funded by key agencies through awards made to implementing partners, though some agencies may sometimes refer to what we term “projects” as “programs.” 11 The agencies used different approaches to identify relevant projects. State’s projects are those with a primary goal of counter-trafficking in persons. DOL’s list of projects includes those that either solely focused on forced labor or trafficking in persons, or included a substantial component on either of those issues. DOL’s projects also include those in which reducing child labor was the primary goal, but for which there was a substantial component focused on forced labor or trafficking. In addition to including projects with a primary goal of counter-trafficking in persons, USAID included projects that do not have counter-trafficking in persons as a primary goal. According to USAID officials, USAID’s counter-trafficking in persons integration is part of USAID’s counter-trafficking in persons policy, and that excluding integrated projects that do not have a primary goal of counter- trafficking in persons, but incorporate a counter-trafficking component, would present an incomplete picture and would leave out a set of projects that reflect USAID’s holistic approach to addressing trafficking in persons. According to DOD officials, DOD’s only relevant program is its trafficking in persons awareness training provided to its staff, which is not internationally focused nor delivered to external recipients as projects. Treasury officials informed us that Treasury does not have specific programs on countering- trafficking in persons to report. As such, our reporting objectives do not cover DOD or Treasury. Page 3 GAO-19-77 Human Trafficking awarded to implementing partners to carry out the projects. 12 For our first objective, we determined the projects that were active during fiscal year 2017, including those which began, were ongoing, or ended during fiscal year 2017, and interviewed agency officials to confirm project information. To analyze the effectiveness of agencies’ programs in limiting human trafficking and modern slavery, we assessed the key agencies’ monitoring efforts for a subset of the projects. We identified State’s, DOL’s, and USAID’s projects that started before or during October 2015, which corresponded to the first quarter of fiscal year 2016, and were active through September 30, 2017, which corresponded to the fourth and last quarter of fiscal year 2017. 13 This resulted in a selection of 54 projects— 37 from State, 3 from DOL, and 14 from USAID—for our review. 14 To assess the extent to which State, DOL, and USAID documented their monitoring activities for selected projects, we reviewed documentation of key monitoring activities as specified in agency policy or the project award 12 Funding amounts for the counter-trafficking in persons projects were provided by each agency in response to our request for funding information. However, the agencies used different methods for collecting and reporting the funding data, which limited our ability to combine funding information across agencies. State’s reported funding consists of total award amounts for projects that focused on counter-trafficking in persons. DOL also reported total award amounts for projects that focused on counter-trafficking in persons, and estimated award amounts for the counter-trafficking in persons component of the total award amounts for projects that did not focus on counter-trafficking in persons. USAID’s reported funding consists of total award amounts for counter-trafficking in persons standalone projects, in which the sole focus of the project was to combat trafficking in persons. However, for USAID’s integrated projects in which counter-trafficking in persons efforts make up a component of the overall project, USAID reported on the commitment of its funds specifically for counter-trafficking in persons activities, which consist of obligated amounts plus committed amounts. 13 For our reporting objectives to assess the extent to which agencies have documented their monitoring activities, ensured the reliability of the performance information, and reviewed the usefulness of the performance indicators they use for that monitoring, we reviewed projects based on the information contained in an initial list of projects that agencies provided. USAID subsequently provided an updated list of projects that slightly affected the count of projects that we report in our objective to identify projects, but we did not revise the scope of projects we reviewed for other objectives. 14 We identified a total of 57 State, DOL, and USAID projects that started before or during October 2015 and were active through September 30, 2017. Out of these 57 projects, we excluded 3 projects from our selection for various reasons. We excluded one DOL project because DOL identified the project as being a research project for which certain agency performance monitoring requirements (e.g., indicators, targets) are not applicable. We also excluded two USAID projects because USAID identified each project as including several projects with various start and end dates, thus making it difficult to determine their time frames for inclusion in our report. Page 4 GAO-19-77 Human Trafficking agreements, including (1) the monitoring plan for each project, (2) evidence of performance indicators and targets for each project, 15 (3) fiscal year 2017 progress reports for each project, (4) final progress reports for the projects that ended by December 2017, and (5) evidence of the agency’s site visits for each project. Additionally, we interviewed knowledgeable monitoring officials from each agency to understand agencies’ monitoring process and application of monitoring requirements for counter-trafficking in persons projects. To assess the extent to which key agencies ensured the reliability of the performance information, as well as the extent to which they reviewed the usefulness of the performance indicators they use to monitor selected international counter-trafficking in persons projects, we selected for review a nongeneralizable sample of 5 projects—2 State projects, 1 DOL project, and 2 USAID projects—out of the 54 counter-trafficking in persons projects identified by agencies that started before or during October 2015 and were active through fiscal year 2017. We based our selection of these projects primarily on the largest total award amounts. 16 For these five selected projects, we collected 2 years of progress reports and other documents to assess the quantitative and qualitative performance information. We assessed whether quarterly or semi-annual indicator totals were consistent with annual and cumulative totals where these were reported. Using this quantitative information, we judgmentally selected indicators for inclusion in agency interviews where it appeared likely that numerical errors had occurred or there appeared to be significant project events, such as large over- or under-performance or the elimination of the indicator. We interviewed agency officials, including managers of each of the 5 projects, about the consistency and completeness of monitoring information in these projects for about 60 indicators identified through our analysis, as well as to determine whether our findings for these selected projects reflected general agency policies and procedures, and to understand the processes and systems agencies 15 For State and USAID projects that ended by December 2017 and therefore had final progress reports, we reviewed those reports to determine whether State and USAID had documented indicators and targets for their projects. Because DOL’s projects were ongoing at the time of our request, we reviewed the second semi-annual report for fiscal year 2017 for each project to determine whether DOL had documented indicators and targets for its projects. 16 Total award amount of the project may include components that are not focused on counter-trafficking in persons effort. Page 5 GAO-19-77 Human Trafficking use to review indicators. 17 We assessed the completeness and consistency of project performance data that State, DOL, and USAID use to monitor projects as part of our data reliability assessment. We found State and USAID data to be unreliable in the projects we reviewed. We discuss the implications of these unreliable data for State and USAID’s project management and reporting in our findings and recommendations. We found the performance data that DOL used were consistent and complete for the project we reviewed. While we examined indicator and narrative information for consistency and completeness, we did not verify the accuracy of performance information. See appendix I for more details on our scope and methodology. We conducted this performance audit from October 2017 to December 2018 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. Human trafficking exploits individuals and often involves transnational Background criminal organizations, violations of labor and immigration codes, and government corruption. Many forms of trafficking—including sex trafficking and labor trafficking—can take place anywhere in the world and occur without crossing country boundaries. As discussed in State’s annual Trafficking in Persons Report, trafficking victims include, for example, Asian and African women and men who migrate to the Persian Gulf region for domestic labor but then suffer both labor trafficking and sexual abuse in the homes of their employers. Some victims are children. For example, Pakistani children as young as 5 years are sold or kidnapped into forced labor to work in brick kilns, some of which are owned by government officials. Other victims are subjected to sexual exploitation. In some cases, women and girls have been bought and sold 17 While we reviewed all available indicator data as part of our process that led to selecting about 60 indicators for which we requested additional information, we did not attempt to count the total number of indicators. In the five projects we reviewed, there were varying practices for labeling and categorizing indicators, leading to ambiguity in counting indicators, such as whether a reported figure is a disaggregation of an indicator or, itself, an indicator; and whether an indicator had been discontinued or was not reported for a given reporting period. Further, the number of indicators for a given project sometimes varied from quarter to quarter. Page 6 GAO-19-77 Human Trafficking as sex slaves by members of the Islamic State. In other cases, adult men and women have been forced to engage in commercial sex, and children induced to do the same. Individuals, including men, are exploited in forced labor in a variety of industries. Burmese men, for example, have been forced to labor 20 hours a day, 7 days a week on fishing boats in Thailand. See figure 1 for examples of victims of trafficking in persons. Page 7 GAO-19-77 Human Trafficking Figure 1: Examples of Trafficking in Persons Victims in the Department of State’s Trafficking in Persons Report June 2018 Page 8 GAO-19-77 Human Trafficking Among other U.S. agencies involved in counter-trafficking in persons, State, DOL, USAID, DOD, and Treasury have various roles and responsibilities related to international counter-trafficking in persons, including some internationally-focused programs and activities that do not involve awards made to implementing partners, as follows: • State. State leads the global engagement of the United States, and supports the coordination of efforts across the U.S government in counter-trafficking in persons. State’s Office to Monitor and Combat Trafficking in Persons (TIP Office), established pursuant to the Trafficking Victims Protection Act of 2000, is responsible for bilateral and multilateral diplomacy, targeted foreign assistance, and public engagement on trafficking in persons. The office also prepares and issues an annual Trafficking in Persons Report that assesses the counter-trafficking efforts of governments and assigns them tier rankings. 18 Furthermore, the TIP Office develops annual regional programming strategies, awards projects to implementing partners and oversees the project award process, and provides technical assistance to implementing partners. Other parts of State, including regional bureaus that cover geographic regions and functional bureaus that cover global issues such as human rights, are also responsible for work related to combating trafficking in persons. 19 • DOL. Within DOL, the Bureau of International Labor Affairs’ (ILAB) Office of Child Labor, Forced Labor, and Human Trafficking (OCFT) conducts research, publishes reports, and administers projects awarded to implementing partners on international child labor, forced 18 For more information on State’s Trafficking in Persons Report, see GAO, Human Trafficking: State Has Made Improvements in Its Annual Report but Does Not Explicitly Explain Certain Tier Rankings or Changes, GAO-17-56 (Washington, D.C.: December 5, 2016). 19 In addition to the projects that State awarded to implementing partners, State officials also reported two other programs related to counter-trafficking in persons during fiscal year 2017. According to State officials, the Intermittent Legal Advisor for Trafficking in Persons Proposal for Malaysia and Cambodia is an interagency agreement between U.S. Department of Justice’s Office of Overseas Prosecutorial Development, Assistance and Training with State TIP Office, in which the Department of Justice’s office would work with the Government of Malaysia and of the Royal Government of Cambodia to strengthen the justice sector to effectively prosecute traffickers, protect victims, and prevent trafficking throughout the two countries. In addition, State’s Bureau of Educational and Cultural Affairs managed the International Visitor Leadership Program in which the bureau brought 143 foreign leaders with responsibilities related to combating trafficking in persons to the United States in 2017. Through such exchanges, foreign participants examined the global problem of trafficking in persons, and explored effective practices in prevention, including the prosecution of and enforcement against traffickers. Page 9 GAO-19-77 Human Trafficking labor, and trafficking in persons. ILAB’s reports include the annual Findings on the Worst Forms of Child Labor report, which assesses the efforts of approximately 140 countries and territories to eliminate the worst forms of child labor in the areas of laws and regulations, institutional mechanisms for coordinating and enforcement, and government policies and programs. ILAB also reports on the List of Goods Produced by Child Labor or Forced Labor showing goods and their source countries which ILAB has reason to believe are produced by child labor or forced labor in violation of international standards. • USAID. USAID administers projects awarded to implementing partners that address counter-trafficking in persons, including increased investments in conflict and crisis areas, and integrating such projects into broader development projects. USAID field missions manage the majority of these counter-trafficking activities through projects that address trafficking challenges specific to the field mission’s region or country. USAID’s Center of Excellence on Democracy, Human Rights and Governance (DRG Center) in Washington, D.C. is responsible for oversight of USAID’s counter- trafficking policy. The DRG Center is responsible for coordinating and reporting on USAID-wide counter-trafficking in persons efforts; oversees the implementation of USAID’s counter-trafficking in persons policy in collaboration with regional bureaus and country missions; works with regional bureaus and country missions to gather counter- trafficking best practices and lessons learned; provides technical assistance and training to field and Washington-based staff on designing, managing, and monitoring and evaluating trafficking in persons projects; and conducts and manages research and learning activities related to combating trafficking in persons to collect data to inform the design of field projects. 20 • DOD. DOD’s Combating Trafficking in Persons Program Management Office, under the Under Secretary of Defense for Personnel and Readiness in the Defense Human Resources Activity, develops trafficking awareness and training material for all DOD components. On December 16, 2002, the President signed National Security 20 In addition to the projects that USAID awarded to implementing partners, USAID officials also reported that during fiscal year 2017, USAID’s Office of Innovation and Development Alliances, Local Sustainability Division, implemented the Peace Corps Small Project Assistance (SPA) Program that relates to combating trafficking in persons. Small Project Assistance is a multi-sector program that aims to build the capacity of host country individuals, organizations, and communities to meet their own development needs and priorities. Funds provided to the Peace Corps go toward supporting small community grants that are awarded to Peace Corps volunteers to implement. Page 10 GAO-19-77 Human Trafficking Presidential Directive 22, which declared the United States had a zero tolerance policy for trafficking in persons. 21 The Combating Trafficking in Persons Program Management Office is responsible for overseeing, developing, and providing the tools necessary for implementing National Security Directive 22 within DOD. 22 The office has developed several different training programs, designed to provide an overview of trafficking in persons (including signs of trafficking, key policies and procedures, and reporting procedures), as well as awareness materials for distribution to DOD components and defense contractors overseas. • Treasury. Treasury has activities, but not specific programs, that may support wider U.S. efforts to address counter-trafficking in persons, according to Treasury officials. Pursuant to its mandate, components of Treasury’s Office of Terrorism and Financial Intelligence (TFI), including Financial Crimes Enforcement Network (FinCEN), Office of Terrorist Financing and Financial Crimes (TFFC), and Office of Foreign Assets Control (OFAC) work on addressing illicit finance 21 The Directive states, “Departments and agencies shall ensure that all of the appropriate offices within their jurisdiction are fully training to carry out their responsibilities to combat trafficking.… Agencies shall review their internal structures, personnel requirements, capabilities, information systems, professional education programs, training procedures, legislative authorities, and budgets to accommodate the provisions of this Directive.” 22 For more information on DOD’s and other agencies oversight of contractors’ use of foreign workers, see GAO, Human Trafficking: Oversight of Contractors’ Use of Foreign Workers in High-Risk Environments Needs to Be Strengthened, GAO-15-102 (Washington, D.C.: November 18, 2014). Page 11 GAO-19-77 Human Trafficking activities that support the wider goal of combating global trafficking in persons. 23 Pursuant to the Trafficking Victims Protection Act of 2000, the President established the President’s Interagency Task Force to Monitor and Combat Trafficking in Persons (PITF), which is a cabinet-level entity that consists of agencies across the federal government responsible for coordinating implementation of the Trafficking Victims Protection Act of 2000, among other activities. 24 It is chaired by the Secretary of State; State, DOL, USAID, DOD, and Treasury are all PITF agencies. 25 In addition, the Trafficking Victims Protection Act, as amended in 2003, established the Senior Policy Operating Group, which consists of senior officials designated as representatives of the PITF agencies. 23 For example, FinCEN is the lead anti-money laundering and countering the financing of terrorism supervisor and regulator for the United States. TFFC focuses on policy development and coordination on combatting illicit finance globally. OFAC administers sanctions programs that target, among many other actors, transnational criminal organizations that are often involved in human trafficking and individuals and organizations involved in the recruitment and use of child soldiers. In 2014, FinCEN issued an advisory note to financial institutions on human trafficking, including descriptions of indicators and red flags for use in identifying this kind of activity. According to Treasury officials, in 2017, FinCEN and other foreign financial intelligence units launched a project within the Egmont Group of Financial Intelligence Units, an intergovernmental body, to analyze information related to human trafficking. The human trafficking project team applies new approaches, processes, and tools for enhanced bilateral information sharing to produce actionable information and disrupt financial movement related to human trafficking. The project focuses on producing results on both a jurisdictional and global level. The scope of the Egmont human trafficking project consists of three major objectives: strengthening knowledge; identifying and disrupting financial flows; and supporting the Financial Action Task Force, an intergovernmental body, and the Financial Action Task Force-style Regional Bodies projects. Moreover, TFI contributed to a report on Financial Flows Associated with Human Trafficking, published in August 2018 by the Financial Action Task Force, according to Treasury officials. 24 Pub. L. No. 106-386, § 105. 25 Other PITF members are the Departments of Agriculture, Education, Health and Human Services, Homeland Security, Interior, Justice, and Transportation; as well as the Office of Management and Budget, the Office of the U.S. Trade Representative, the Office of the Director of National Intelligence, the National Security Council, the Domestic Policy Council, the Federal Bureau of Investigation, and the U.S. Equal Employment Opportunity Commission. Page 12 GAO-19-77 Human Trafficking State, DOL, and USAID managed 120 projects in counter-trafficking in During Fiscal Year persons carried out by implementing partners during fiscal year 2017, 2017, State, DOL, according to information provided by officials with these agencies. These projects, as identified by agency officials, ranged from those focused on and USAID Managed counter-trafficking in persons, to those in which counter-trafficking in 120 Counter- persons was integrated into but was not the primary goal of the project. 26 At these agencies, project officers work with the implementing partner on Trafficking in Persons the administration and technical guidance of the project, such as Projects reviewing progress reports. 27 Table 1 shows a summary of these agencies’ project information; appendix II provides more detailed information on all 120 projects. 26 Funding amounts for the counter-trafficking in persons projects were provided by each agency in response to our request for funding information. However, the agencies used different methods for collecting and reporting the funding data, which limited our ability to combine funding information across agencies. State’s reported funding consists of total award amounts for projects that focused on counter-trafficking in persons. DOL also reported total award amounts for projects that focused on counter-trafficking in persons, and estimated award amounts for the counter-trafficking in persons component of the total award amounts for projects that did not focus on counter-trafficking in persons. USAID’s reported funding consists of total award amounts for counter-trafficking in persons standalone projects, in which the sole focus of the project was to combat trafficking in persons. However, for USAID’s integrated projects in which counter-trafficking in persons efforts make up a component of the overall project, USAID reported on the commitment of its funds specifically for counter-trafficking in persons activities, which consists of obligated amounts plus committed amount. 27 We use the term “project officer” to include various job titles for this position, including State TIP Office’s Project Officers, Program Advisor, and Grants Officer Representative; State DRL’s Grants Officer Representative; DOL’s Project Officers or Grant Officer’s Representatives; and USAID’s Contracting Officer’s Representatives or Agreement Officer’s Representatives. Page 13 GAO-19-77 Human Trafficking Table 1: Summary of Departments of State (State) and Labor (DOL), and U.S. Agency for International Development (USAID) Counter-trafficking in Persons Projects Active during Fiscal Year 2017, as Identified by Agency Officials Responsible Total Number of Projects Locations of Projects Agency/Office State (total) 79 (see details below) State/TIP Office 75 • 11 global projects • 11 regional projects that cover Africa, Asia, Balkans, Caribbean, and South America • 53 projects that cover 41 different countries State/DRL 4 • 4 projects that cover 3 different countries DOL/ILAB/OCFT 6 • 3 global projects • 3 projects that cover 5 different countries USAID/DRG and 35 • 2 regional projects covering 5 countries in South and Southeast Asia overseas missions and 5 countries in Central Asia • 33 DRG and field-managed bilateral projects that cover 22 different countries Total (all agencies) 120 (see details above) Legend: State/TIP Office = State’s Office to Monitor and Combat Trafficking in Persons; State/DRL = State’s Bureau of Democracy, Human Rights, and Labor; DOL/ILAB/OCFT = DOL’s Bureau of International Labor Affairs’ Office of Child Labor, Forced Labor, and Human Trafficking; USAID/DRG = USAID’s Center of Excellence on Democracy, Human Rights and Governance. Source: GAO analysis of the information provided by the Departments of State and Labor, and the U.S. Agency for International Development officials. | GAO-19-77 Note: Projects in the table, as identified by agency officials, ranged from those focused on counter- trafficking in persons, to those in which counter-trafficking in persons was integrated into but was not the primary goal of the project. During fiscal year 2017, State managed 79 counter-trafficking projects, from those focused on individual countries, to regional and global ones that covered several countries, with a total award amount of approximately $62 million, according to information provided by State officials. State TIP Office managed 75 projects with total awarded amount of around $57 million. Award amounts per project ranged from approximately $150,000 to $2.55 million. For example, • State TIP Office had 11 global projects totaling about $10 million and 6 regional projects in Africa amounting to about $4 million. • State TIP Office had two projects in Ghana that received the highest amount of awards, approximately $2.5 million for each project. • State TIP Office had four projects in India amounting to around $3 million, and four in Thailand totaling around $2.35 million. Page 14 GAO-19-77 Human Trafficking In addition to State TIP Office’s projects, State’s Bureau of Democracy, Human Rights, and Labor (DRL) managed four counter-trafficking projects with a reported total award amount of about $5 million, with two projects in Mauritania making up around 70 percent of DRL’s total awarded amount. DOL’s ILAB/OCFT managed six projects in fiscal year 2017 with a total award amount of approximately $31 million, according to DOL officials. These projects ranged from one scheduled to last for 5 years with an awarded amount of about $1 million, to one scheduled to last for about 4 years with an awarded amount of about $14 million. Three of DOL’s projects were global projects, while two others focused on two countries each and one project focused on one country. USAID’s projects during fiscal year 2017 consisted of 2 regional projects in Asia, and 33 individual projects in 22 different countries. Some of these USAID-identified projects were integrated projects with a broader development focus that includes USAID programmatic objectives other than counter-trafficking in persons. 28 According to information provided by USAID officials, the award amount for all counter-trafficking in persons projects active in fiscal year 2017, including all integrated projects and standalone projects with a sole focus on combatting trafficking in persons, totaled around $296 million; and USAID’s committed funding to these projects’ activities related to counter-trafficking in persons was about $79 million as of September 2018. 29 During fiscal year 2017, USAID focused on a few countries where the agency awarded multiple counter-trafficking projects, such as four projects in Nepal and four projects in Burma. According to officials, State, DOL, and USAID generally design projects to align with the “3Ps approach”—prevention, protection, and prosecution— and to consider trends and recommendations identified in agency reports on foreign governments’ counter-trafficking efforts. According to State’s 28 For example, USAID identified a development project that supported the government of Ghana to rebuild the marine fisheries sector through the adoption of responsible fishing practices. According to USAID officials, because there is documented forced child labor in the fisheries sector in Ghana, an activity to combat child labor and trafficking was integrated into this broader fisheries project, but the majority of this project’s total award amount of $24 million was not focused on counter-trafficking in persons efforts. 29 According to USAID officials, USAID’s commitment of funds is an administrative reservation of the funds in anticipation of an obligation. USAID reported its committed funding to date for counter-trafficking in persons activities that consists of its obligated amounts plus committed amounts. Page 15 GAO-19-77 Human Trafficking publicly available information, the “3Ps” approach serves as the fundamental counter-trafficking in persons framework used around the world, and the U.S. government follows this approach to 1. prevent trafficking in persons through public awareness, outreach, education, and advocacy campaigns; 2. protect and assist victims by providing shelters as well as health, psychological, legal, and vocational services; and 3. investigate and prosecute trafficking in persons crimes by providing training and technical assistance for law enforcement officials, such as police, prosecutors, and judges. State’s publicly available information on the 3Ps noted that prevention, protection, and prosecution efforts are closely intertwined. Prosecution, for example, can function as a deterrent, potentially preventing the occurrence of human trafficking. Likewise, protection can empower those who have been exploited so that they are not victimized again once they re-enter society. A victim-centered prosecution that enables a survivor to participate in the prosecution is integral to protection efforts. In addition to the “3Ps,” a “4th P”—for partnership—serves as a complementary means to achieve progress across the “3Ps” and enlist all segments of society in the fight against human trafficking, according to State’s publicly available information. Addressing the partnerships element, USAID’s counter-trafficking policy seeks to increase coordination across a broad range of national, regional, and global stakeholders from civil society, government, the private sector, labor unions, media, and faith-based organizations. Examples of individual counter-trafficking in persons projects that agencies awarded to implementing partners include the following. • Short-term Assistance to Victims of Trafficking. One project offered assistance on an emergency basis that could include shelter; food and other basic necessities; counseling; medical services; legal services; travel documentation; safe transport arrangements for return, reintegration, or for participation in criminal justice proceedings; family tracing; and resettlement arrangements. • Education, Empowerment, and Awareness Efforts for Girls. One project provided services to decrease the incidence of sex trafficking, child labor trafficking, domestic violence, early marriage, unsafe early Page 16 GAO-19-77 Human Trafficking migration, and sexual abuse, through education, empowerment, and awareness for girls, their families, and their communities. The scope of services includes enrolling girls in schools, paying for their education, and motivating them to stay in school and stay safe, while indirectly supporting other girls, parents, and key stakeholders for community-level protection. • Specialized Services. One project contributed specialized services for victims of trafficking and individuals at risk and capacity building for first responders. The scope of services includes offering timely information and raising awareness on trafficking risks to victims and populations at risk of being trafficked; ensuring that first responders are equipped to identify and respond to human trafficking, as well as furnishing emergency referrals for trafficking victims; and providing crisis-specific interventions for affected and at-risk individuals. • Reintegration and Prevention of Recruitment. One project supported efforts to reintegrate children rescued from illegal armed groups that forcibly recruit children and to prevent future recruitment. This project supported host government entities to provide physical, psychological, social, and economic assistance to disengaged children and adolescents. The project also supported the reception of, and assistance to, children in temporary transitional centers, and assisted in preparation for their reincorporation and social inclusion into their families and communities. • Assistance to Strengthen Host Government Capacity. One project provided assistance to investigate and prosecute suspected trafficking cases, improve the identification and referral of trafficking victims, introduce common and improved standards of care and assistance for victims of trafficking, and raise awareness of the crime. • Technical Assistance to Develop and Implement Laws and Policies. One project provided assistance to bring laws and policies into alignment with international labor standards, including on forced labor. The project will also create an occupational safety and health management system, and establish effective labor market information systems and employment services Page 17 GAO-19-77 Human Trafficking DOL and USAID Fully Documented Their Monitoring Activities for All Selected Projects, but State Did Not Fully Document Its Activities for 16 of 37 Selected Projects State, DOL, and USAID Monitoring is the collecting of data to determine whether a project is being Use Similar Tools to implemented as intended and the tracking of progress through preselected performance indicators during the life of a project. State, Monitor Performance of DOL, and USAID use a number of similar tools—according to their Their Counter-Trafficking current policies, guidance, and agency officials—to monitor the in Persons Projects performance of their counter-trafficking in persons projects, including monitoring plans, indicators and targets, periodic progress reports, and final progress reports. The agencies also conduct site visits, but their policies vary on whether site visits are required for every project during implementation. • Monitoring plan. The monitoring plan—according to monitoring policies of the three agencies—documents, among other things, all of the indicators and targets for the project as well as data collection frequency for each indicator. In addition, according to State TIP Office officials, the monitoring plan’s indicators and targets for TIP Office- managed counter-trafficking in persons projects are to be organized in a logic model, which is a visual representation that shows the linkages among the project’s goals, objectives, activities, outputs, and outcomes (see table 2). 30 The logic model is intended to show relationships between what the project will do and what changes it expects to achieve. 30 State TIP Office officials also informed us that the TIP Office organizes the monitoring plan’s common performance indicators (CPI) and targets in a CPI reporting template. We did not include the CPI reporting template in our review of the extent to which agencies documented their monitoring activities because, according to TIP Office officials, older projects that were awarded prior to fiscal year 2018 might not have used the template. Page 18 GAO-19-77 Human Trafficking Table 2: GAO Summary of Logic Model Example from Department of State’s Office to Monitor and Combat Trafficking in Persons PROJECT GOAL: To develop and strengthen the national criminal justice system’s response to trafficking in persons (TIP) and ensure access to justice and fair treatment for all victims of TIP. Objective 1: To increase the number of TIP cases identified, investigated, and prosecuted by criminal justice practitioners in XX country (region, etc.). Activity 1: Develop a training manual with tools that address core elements of a victim-centered criminal justice response to combat human trafficking that is structured around national laws and case files. Output 1.1: Output indicator 1.1: Outcome 1.1: Outcome indicator 1.1: Tailored training manual with Training manual and tools Training manual and tools # of government tools developed developed (Target: manual & appropriately and effectively institutions/structures that tools in 2 languages) utilized by government appropriately and effectively stakeholders utilize manual/tools (Target: 4 ministries, 8 state-level police units, 30 district-level court systems) Activity 2: Conduct multidisciplinary week-long trainings on victim-centered investigations and prosecutions. Output 1.2: Output indicator 1.2: Outcome 1.2: Outcome indicator 1.2: Trainings conducted on victim- # of week-long trainings (Target: Trained criminal justice 1.2.1 # of investigations by centered investigations and 10) practitioners identify, trained law enforcement officials prosecutions # of criminal justice practitioners investigate, and prosecute TIP (Target: 50) trained (Target: 150) crimes 1.2.2# of prosecutions by trained prosecutors (Target: 40) 1.2.3 # of convictions by trained prosecutors (Target: 10) Source: GAO summary of logic model example from Department of State’s Office to Monitor and Combat Trafficking in Persons. | GAO-19-77 • Indicators and Targets. Performance indicators—according to monitoring policies of the three agencies—are used to monitor progress and measure actual results compared to expected results. Targets are to be set for each performance indicator to indicate the expected results over the course of each period of performance. According to agency officials, the monitoring plan documents indicators and targets to be tracked and reported on through periodic progress reports to assess whether the project is likely to achieve the Page 19 GAO-19-77 Human Trafficking desired results. 31 GAO has also found that a key attribute of effective performance measures is having a measurable target. • Periodic progress reports. The reporting templates for the three agencies show that periodic progress reports—which are submitted at established intervals during the project’s implementation—compare actual to planned performance and indicate the progress made in accomplishing the goals and objectives of the project, including reporting on progress toward the monitoring plan’s indicator targets. • Final progress report. The final progress report—according to monitoring policies of the agencies or agency officials—is a stand- alone report that provides a summary of the progress and achievements made during the life of the project. • Site Visits. The three agencies policies vary on whether site visits are required for every project during implementation. 32 For example, State’s policy notes that site visits may be conducted to review and evaluate recipient records, accomplishments, organizational procedures, and financial control systems, as well as to conduct interviews and provide technical assistance as necessary. In 2015, the State TIP Office established a goal to conduct at least one site visit during the life time of every project. While site visits during a project’s implementation are not required under DOL’s policy, DOL officials explained that they use site visits when deemed necessary to supplement information from other forms of oversight. USAID’s policy requires that a site visit be conducted for every project during implementation to provide activity oversight, inspect implementation progress and deliverables, verify monitoring data, and learn from activity implementation. In addition to these monitoring tools, State, USAID, and DOL officials told us that they rely on frequent communication with implementing partners as part of their monitoring process. Overall, monitoring is intended to help 31 For example, the semi-annual or final progress reports we reviewed for State, DOL, and USAID projects showed indicators such as (1) number of beneficiaries who received medical care (including mental-health care) from a healthcare professional; (2) number of trained trafficking survivors and at-risk women placed in jobs; and (3) number of forced labor complaints sent from workers’ organizations to the Ministry of Labor and Employment. 32 We did not include pre-award site visits in the scope of our review. According to the State TIP Office’s current policy, new grantees who have never received funding from the TIP Office usually receive a pre-award site visit. Page 20 GAO-19-77 Human Trafficking agencies determine whether the project is meeting its goals, update and adjust interventions and activities as needed, and ensure that funds are used responsibly. DOL and USAID Fully We found, based on our review of 54 selected counter-trafficking in Documented Their persons projects (37 State, 3 DOL, and 14 USAID), that DOL and USAID had fully documented their performance monitoring activities, while State Monitoring Activities for did not fully document its activities for 16 of 37 (43 percent) of the projects Selected Projects, while we reviewed with project start dates between fiscal years 2011 to 2016. 33 State Did Not DOL’s documented monitoring activities included the monitoring plan for each project as well as fiscal year 2017 semi-annual progress reports, including indicators and targets. 34 USAID’s documented monitoring activities included the monitoring plan for each project; fiscal year 2017 progress reports at the reporting frequency specified in the agreements for each project; the final progress report, including indicators and targets, for the three projects that ended as of December 2017; and evidence that at least one site visit was conducted during each project’s implementation. Overall, the three agencies reported having conducted at least one site visit during the life time of the project for 47 of 54 (87 percent) of the selected projects. 35 As shown in table 3, State did not fully document its monitoring activities (monitoring plan; fiscal year 2017 quarterly progress reports; and final progress report, including indicators and targets, for projects that ended 33 We identified all of State’s, DOL’s, and USAID’s projects that started before or during October 2015, which corresponded to the first quarter of fiscal year 2016, and were active through September 30, 2017, which corresponded to the fourth and last quarter of fiscal year 2017. This produced a list of a total of 57 State, DOL, and USAID projects. Out of these 57 projects, we excluded 3 projects from our selection for various reasons. We excluded one DOL project because DOL identified the project as being a research project for which certain agency performance monitoring requirements (e.g., indicators, targets) are not applicable. We also excluded two USAID projects because USAID identified each project as including several projects with various start and end dates, thus making it difficult to determine their time frames for inclusion in our report. 34 Because DOL’s projects were ongoing at the time of our request, we reviewed the second semi-annual progress report for each project to confirm DOL had documented indicators and targets. 35 Specifically, DOL reported having conducted at least one site visit for all 3 of its projects; USAID reported having conducted at least one site visit for all 14 of its projects; and State reported having conducted at least one site visit for 30 of its 37 projects. Page 21 GAO-19-77 Human Trafficking as of December 2017) for 16 of the 37 selected projects we reviewed. 36 Specifically, State did not have nine monitoring plans, five complete progress reports, or targets for each indicator in six of seven final progress reports for projects that ended as of December 2017. 37 (See appendix III for detailed information on each of the 37 projects.) Table 3: Extent to Which Department of State Documented Performance Monitoring Activities for 37 Selected Counter- Trafficking in Persons Projects Monitoring Q1 FY17 Q2 FY17 Q3 FY17 Q4 FY17 Final Indicators plan progress progress progress progress progress and targets in report report report report report at end final progress a a of project report Fully documented 28 34 37 36 36 7 1 Partially 0 3 0 0 1 0 6 Documented Not documented 9 0 0 1 0 0 0 Legend: Q = quarter; FY = fiscal year. Source: GAO analysis of Department of State (State) documents. | GAO-19-77 Notes: State projects we reviewed all started between fiscal years 2011 to 2016. State did not fully document its monitoring activities (monitoring plan; fiscal year 2017 quarterly progress reports; and final progress report, including indicators and targets, for projects that ended as of December 2017) for 16 of the 37 selected projects we reviewed. The combined count for “partially documented” and “not documented” will not add to 16 due to certain projects appearing across categories. a We reviewed the final progress reports for the 7 of 37 projects that ended as of December 2017. (The remaining 30 projects continued after December 2017.) 36 The combined count for “partially documented” and “not documented” will not add to 16 due to certain projects appearing across categories. 37 Our prior work emphasizes key attributes of effective performance measures, such as measurable targets. See GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002), p. 45, for a description of how we developed the attributes of effective performance goals and measures, and GAO, Defense Health Care Reform: Additional Implementation Details Would Increase Transparency of DOD’s Plans and Enhance Accountability, GAO-14-49 (Washington, D.C.: Nov. 6, 2013), p. 17, for a description of why the baseline measure was added as an attribute of effective performance measures. See also GPRA Performance Reports, GAO/GGD-96-66R (Washington, D.C.: Feb. 14, 1996); Missile Defense: Opportunity to Refocus on Strengthening Acquisition Management, GAO-13-432 (Washington, D.C.: Apr. 26, 2013); Performance Measurement and Evaluation: Definitions and Relationships, GAO-11-646SP (Washington, D.C.: May 2011); and Agency Performance Plans: Examples of Practices That Can Improve Usefulness to Decisionmakers, GAO/GGD/AIMD-99-69 (Washington, D.C.: Feb. 26, 1999). Page 22 GAO-19-77 Human Trafficking • For the nine projects for which the monitoring plan was not documented, the State TIP Office indicated that it was unable to locate these documents or they were not completed because the projects were finalized when the TIP Office was beginning to institute the monitoring plan requirement. 38 Although TIP Office officials told us that the TIP Office piloted and began to phase in the monitoring plan requirement over the course of 2014 and early 2015, eight of the nine projects without monitoring plans started in September or October 2015. 39 We found that each of the nine projects had a logic model used to report progress in the fiscal year 2017 quarterly progress reports we reviewed, which would have provided TIP Office officials a basis for monitoring project performance at that point. However, federal standards for internal control call for agency management to design monitoring activities so that all transactions are completely and accurately recorded and so that management can evaluate project results. 40 Specifically, internal controls specify that monitoring should be ongoing throughout the life of the project, which is consistent with State’s current policy that generally requires completion of the monitoring plan prior to award. Without timely documentation of the monitoring plans at the start of the project, TIP Office officials may not be able to ensure that projects are achieving their goals, as intended, from the beginning of project operations. • For the three projects for which the quarterly progress report for the first quarter of fiscal year 2017 had been partially completed, the State TIP Office indicated that the implementing partners began to use the TIP Office’s quarterly reporting template for subsequent reports after TIP Office officials instructed the implementing partner to do so. For the one project where the quarterly progress report was not completed for the third quarter of fiscal year 2017, or partially 38 State TIP Office officials also informed us that documents were lost in the database changeover to State Assistance Management System Domestic in January 2018 and that some of the monitoring plans may have been among the documents that were lost. 39 In March 2015, State had issued a new policy specifying that it is the responsibility of the grants officer and grants officer representative to develop a monitoring plan that is appropriate for the award, and that all grants officers must ensure that a copy of the monitoring plan and all revisions/updates are kept in the official award file. In October 2017, State issued a new policy explicitly excluding from the requirement voluntary and assessed contributions, and property grants where the property is turned over immediately and permanently to the recipient. 40 GAO, Standards for Internal Control in the Federal Government, GAO-14-704G (Washington, D.C.: Sept. 2014), and Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: Nov. 1999). Page 23 GAO-19-77 Human Trafficking completed for the fourth quarter of fiscal year 2017, the project officer provided possible reasons why the documents were not in the project’s file, including that the implementing partner lacked the capacity to design a logic model. The project ended December 31, 2017. Federal standards for internal control call for agency management to design monitoring activities, such as performance reporting, so that all transactions are completely and accurately recorded, and project results can be continuously evaluated. 41 As previously discussed, performance progress reports should compare actual to planned performance and indicate the progress made in accomplishing the goals and objectives of the project. Therefore, the TIP Office may lack information needed to assess project performance if it does not have access to complete monitoring documentation. • For the six projects for which targets were not fully documented in the final progress reports, 42 we found that targets were lacking for 110 of 253 (43 percent) of indicators across the six final progress reports. 43 Our prior work on performance measurement identified 10 key attributes of performance measures—such as having a measurable target—that GAO has found are key to successfully measuring a project’s performance. 44 For example, our prior work has shown that numerical targets or other measurable values facilitate future assessments of whether overall goals and objectives are achieved because comparisons can be easily made between projected performance and actual results. 45 State TIP Office officials explained 41 See GAO-14-704G and GAO/AIMD-00-21.3.1. 42 The final progress reports provide information on output and outcome indicators. According to the State TIP Office’s logic model proposal template, output indicators provide a means to measure the products, goods, and services which result from an activity, program, or policy (e.g., number of training manuals and tools developed). Outcome indicators provide a means to measure the extent to which an activity, project, program, or policy achieves its objectives (e.g., number of government institutions/structures that utilize manual/tools to train others). For the total number of indicators lacking targets across the six final progress reports, we excluded from the count any disaggregated indicators or indicators for which the target could be inferred, such as when the target could be inferred as being a value of “1.” 43 The number of indicators lacking targets across the six final progress reports ranged from 2 to 50. 44 See GAO-03-143, GAO-14-49, GAO-13-432, GAO-11-646SP, and GAO/GGD/AIMD-99-69. 45 See GAO-03-143. Page 24 GAO-19-77 Human Trafficking that the final progress reports we reviewed lacked targets because the TIP Office had not required targets for each indicator for the projects we reviewed that started in fiscal years 2011 to 2016. State TIP Office officials also said that project officers may not have set targets due to limited resources in previous years. A lack of actual targets limits the TIP Office’s ability to assess project performance, including effectiveness, and determine if implementation is on track or if any timely corrections or adjustments may be needed to improve project efficiency or effectiveness. According to State TIP Office officials, the TIP Office has taken steps to improve its documentation of monitoring activities, such as instituting a monitoring plan requirement; increasing staff, including hiring a monitoring and evaluation specialist; and developing standard templates for implementing partners to use for reporting. Moreover, in November 2017, State established a new policy asserting that, building on the logic model or project charter, bureaus and independent offices must set targets for each performance indicator to indicate the expected change over the course of each period of performance. It further notes that bureaus and independent offices should maintain documentation of project design, including the logic model. Additionally, State TIP Office officials said that State is developing a department-wide automated information management system (State Assistance Management System - Domestic, or SAMS-D) that officials expect to standardize entry of performance information and, under the new system targets, must be recorded for each indicator. State TIP Office officials have worked to pilot- test SAMS-D to provide feedback on the system, including suggestions to improve the completeness of data collection, according to TIP Office officials. Despite these efforts, the TIP Office’s documentation of all monitoring activities, and implementation of its November 2017 requirement to set targets for all performance indicators, is uncertain. For example, even though the TIP Office informed us that it began to institute a monitoring plan requirement over the course of 2014 and early 2015, as previously noted, eight projects we reviewed that started in September or October 2015 did not have monitoring plans. In addition, according to State officials, in SAMS-D, targets could be recorded as “to be determined” and there are no controls in place to ensure that “to be determined” entries are replaced with actual targets. State officials said that SAMS-D has the capability to implement controls to alert users to update “to be determined” targets, but pilot users of SAMS-D, which include the TIP Office, have not provided feedback for this capability so far. Furthermore, Page 25 GAO-19-77 Human Trafficking State TIP Office officials informed us that the TIP Office cannot require all implementing partners to set targets, but that the TIP Office aspires to update relevant targets regularly in the future and would encourage implementing partners to update target values when appropriate. 46 Without controls to ensure full documentation of monitoring activities and established performance targets, State is limited in its ability to assess project performance, including project efficiency or effectiveness. In our review of selected indicators in two State TIP Office and two State and USAID Do USAID projects, we found that State and USAID used inconsistent and Not Have Sufficient incomplete performance information to monitor these projects. We found that State TIP Office and USAID do not have sufficient controls in place to Controls to Ensure ensure that the performance information they use is reliable. In contrast, the Reliability of we found that DOL had consistent and complete performance information in a project we reviewed, and we identified no controls in DOL’s process Project Information, that were insufficient for assuring the reliability of this information. while DOL Had Consistent and Complete Performance Information in the Project We Reviewed 46 According to TIP Office officials, the TIP Office cannot require targets for projects using grants as an award agreement instrument. Page 26 GAO-19-77 Human Trafficking State and USAID Projects For selected indicators in two State TIP Office and two USAID projects, We Reviewed Showed we found numerous errors or omissions in progress reports we reviewed, which resulted in inconsistent and incomplete performance information Inconsistent and agencies used to monitor these projects. 47 Specifically, we found Incomplete Performance examples of inconsistent information, which included many instances in Information which quarterly indicator totals differed from annual or cumulative totals reported separately on the same projects, and numbers reported in narrative information that differed from numbers reported as indicator values. In addition, we found examples of incomplete information, including narrative elements that were missing in whole or in part. 48 Inconsistent Performance Information. We found numerous instances in which quarterly totals differed from annual or cumulative totals reported separately on the same projects. When these errors occurred, it was not possible to independently determine project performance based on report information. For example, • For one State TIP Office project, reported cumulative progress overstated quarterly progress for at least 11 indicators (3 of which by 25 percent or more) and understated quarterly progress for at least 5 indicators (once by 25 percent or more). For example, for the indicator “number of standardized reintegration protocols/guidelines/tools developed (case forms, family assessment, etc.,)” State’s cumulative performance report as of the 4th quarter of fiscal year 2017 indicated that two tools had been developed, whereas quarterly reports showed that only one had been developed. • For one USAID project, the indicator “number of assisted communes allocating and accessing funds for trafficking in persons prevention activities” showed that annual results were 60, while quarterly report 47 We selected for review a nongeneralizable sample of 5 projects—2 State projects, 1 DOL project, and 2 USAID projects—out of the 54 projects that started before or during October 2015 and were active through fiscal year 2017. While projects we selected were identified by the relevant agency as being counter-trafficking in persons projects, not all indicators for these projects were explicitly related to counter-trafficking in persons. In order to fully analyze the monitoring of counter-trafficking in persons related projects, and because many activities in these projects may be inter-related, we reviewed all types of indicators among our selection of indicators within a selected project. 48 While we were able to examine indicator and narrative information for consistency and completeness in order to assess its reliability, we did not verify the accuracy of the reported information. Page 27 GAO-19-77 Human Trafficking data combined showed that the number was 6, which USAID officials confirmed was the correct figure. 49 • For another USAID project, the indicator, “number of food security private enterprises (for profit), producers organizations, water users associations, women’s groups, trade and business associations, and community-based organizations receiving U.S. government assistance” showed an annual result of one, while quarterly totals combined showed a total of three, which USAID officials confirmed was the correct figure. For the projects we reviewed, implementing partners produced narrative descriptions of progress made to accompany indicator results. We found cases in which numbers reported in narrative information were not consistent with numbers reported as indicator values. For example, for the State TIP Office indicator “number of criminal justice practitioners trained” for one project, indicator results for two quarters differed from results presented in the corresponding narrative during fiscal years 2016 to 2017. State officials found that the narrative information was correct for one of these inconsistencies and the indicator result was correct for the other. In addition, for one USAID indicator—number of public awareness tools on trafficking in persons developed and disseminated—the narrative report for one quarter described distributions that added up to 21,765 products, while the reported quantitative indicator total was 21,482. USAID officials confirmed that 21,765 was the correct figure. 50 Incomplete Performance Information. Additionally, some quarterly reports had narrative elements that were incomplete in whole or in part, which made independent interpretation of project performance difficult or impossible. • The implementing partner in one State TIP Office project copied and pasted significant portions of narrative information in quarterly reports for 2 years and, according to State TIP Office officials, did not fulfill a request by State TIP Office to include only current quarterly information in formal quarterly reports because it was focused on 49 USAID officials said that, although 60 communes had an allocated budget for counter- trafficking in persons activities, only 6 had actually spent the budgeted money. 50 According to USAID officials, the implementing partner for this project subsequently took steps to reduce manual entry errors for its indicators, including developing its own database system to store information from subcontractors and perform calculations automatically. Page 28 GAO-19-77 Human Trafficking other activities. For nearly the entire period, the implementing partner indicated that it was “following up” with government entities in three countries to set up counter-trafficking in persons training for government officials, but no indication was made in formal quarterly reports about the results of any of these follow-up activities. 51 • For one State TIP Office project, the indicator “number of children receiving care, whose cases are reported to the police” had no narrative information or incomplete narrative information provided for three of the four quarters in which activity occurred during our period of review (comprising almost 90 percent of reported performance under this indicator). • For a USAID project, the implementing partner reported a combined performance number of approximately 200 from the first through third quarters of fiscal year 2017 for the indicator “number of members of producer organizations and community based organizations receiving U.S. government assistance.” However, annual performance for fiscal year 2017 was reported as nearly 1,700 organizations. USAID officials explained that this difference was the result of the implementing partner’s misinterpretation of the indicator’s definition when producing the quarterly reports, but the annual report narrative did not explain this correction. • Additionally, for USAID’s indicator on the “number of public awareness tools on trafficking in persons developed and disseminated,” no narrative information in the quarterly or annual reports explained how the last quarter of fiscal year 2016 performance approximately doubled from that of the previous quarter. Narrative information in the annual report described performance for the year only in general terms and did not clarify this significant change. In addition to direct project oversight, State TIP Office and USAID officials stated that performance information from progress reports that the agencies use to monitor counter-trafficking in persons projects is regularly used for internal and external reporting, program decisions, and lessons learned. For example, according to officials, this information is used by senior agency officials to inform their decision-making, in reports such as the Attorney General’s Annual Report to Congress and Assessment of 51 State TIP Office officials said that they were aware of the current status of this project because of emails and telephone calls that were not part of the formal quarterly reporting process. Page 29 GAO-19-77 Human Trafficking U.S. Government Activities to Combat Trafficking in Persons, and to fulfil other requests from Congress. Neither State TIP Office Neither State TIP Office nor USAID has sufficient controls to ensure nor USAID Has Sufficient consistent and complete performance information, and both face challenges to data reliability stemming from information reported in non- Controls to Ensure the standard formats, implementing partners with limited capacities to report Reliability of Performance performance information, and the time-consuming nature of reviewing Information reported information. 52 Federal internal control standards state that management should obtain data from reliable internal and external sources. 53 According to these standards, reliable internal and external sources should provide data that are reasonably free from error and bias and faithfully represent what they purport to represent; and management should evaluate both internal and external sources of data for reliability. Without implementing additional controls to ensure that performance information are consistent and complete, State and USAID officials may not fully or accurately understand what projects are, or are not, achieving and, therefore, how their efforts could be altered as needed. Further, reports that are prepared or program decisions that are made using the TIP Office monitoring reports could be based on inconsistent or incomplete information that does not accurately present project results. State Lacks Adequate Controls State TIP Office currently receives performance information using to Ensure the Reliability of documents submitted by implementing partners, although this information Performance Information is not compiled into a single data system and is not in a standardized format. While State provides suggested templates for reporting information, officials said that they cannot require implementing organizations to use these templates and we found that implementing partners provided information in varying formats. According to State TIP Office officials, project officers perform manual reviews of quantitative information in monitoring reports but have insufficient time to carry out detailed reviews of data reliability for all indicators. State TIP Office project officers also stated that the process of comparing narrative information to indicator information was time 52 According to State TIP Office officials, State TIP Office cannot require a specific reporting format from its grantees, including international organizations, due to the Paperwork Reduction Act. 53 See GAO-14-704G. Page 30 GAO-19-77 Human Trafficking consuming and difficult. According to these officials, the quality of the information in progress reports also depends on the priorities and resources—which can be limited—of the implementing partner. In addition to reviewing progress reports, State project officers we spoke to said that they rely on site visits and frequent, less formal communication as part of their oversight process. Project officers for the State TIP Office projects we reviewed stated that they did not always examine performance trends over time or review consistency in reported cumulative totals—which should be the sums of the previous and current quarters’ reported results—with quarterly totals, for reasons including the difficulty in assembling quarterly information in this manner and resource limitations. State TIP Office officials noted that they are aware of data quality problems in counter-trafficking in persons monitoring reports. State is developing SAMS-D, a system that officials expect to standardize entry of information from common performance indicators and logic models, according to State officials. These officials stated that if SAMS-D is deployed, State TIP Office could find it easier to analyze and revise logic models that implementing partners submit, as well as examine performance indicator results over time, since standardized data would be available in a centralized location. According to State officials, SAMS-D could be programmed with automatic checks or alerts under conditions defined by the TIP Office and the database programmer. For example, the system could require that fields be filled out in particular formats or provide an alert if performance under a certain indicator has significantly deviated from prior quarters or the indicator’s target. State TIP Office officials said they were uncertain whether SAMS-D would become operational in 2019, as currently planned. According to officials, State TIP Office has participated in planning and pilot activities for SAMS- D, including testing monitoring tools with implementing partners. According to these officials, additional work is needed to develop rules and controls necessary to operationalize SAMS-D to meet the TIP Office’s particular needs and ensure improved data. Another challenge to implementation of SAMS-D, according to these officials, is that some implementing partners are unable to maintain consistent internet connections necessary to upload information, impeding full roll-out of the system, and an alternative upload mechanism does not yet exist. Page 31 GAO-19-77 Human Trafficking USAID Lacks Adequate According to USAID officials, overseas missions currently set many of Controls to Ensure the their own policies and procedures for data quality oversight. 54 For the two Reliability of Performance projects we reviewed, USAID relied on implementing partners to manage Information information, while it reviewed this information in addition to conducting site visits and communicating with implementing partners on a regular basis to monitor the projects. USAID officials attributed errors in the project reports we reviewed to factors including implementing partners’ errors in manual computation and misunderstandings of indicator definitions. According to USAID officials, data quality errors due to factors such as transcription errors can also occur in the performance information USAID uses to monitor counter-trafficking in persons projects. USAID project officers for the projects we reviewed said that they regularly conducted manual analysis of information received from implementing partners, but USAID and implementing partners are often pressed for time during the quarterly reporting cycle. According to these project officers, some of the errors GAO found had already been identified by USAID implementing partners during their annual review process and corrected in the annual reports we reviewed. For example, for the USAID indicator “value of new private sector investments in select value chains,” quarterly totals overstated corrected annual results by more than $120,000—approximately $170,000 instead of approximately $50,000. USAID officials said that they and the implementing partner had identified that the implementing partner was incorrectly including additional, unrelated data when producing its quarterly totals and while the annual total had been corrected to approximately $50,000, the annual report did not indicate that this error had occurred in the quarterly reports. USAID officials noted that the quality of the information in the progress reports also depends on the experience and capacity—which can be limited—of the implementing partner. 55 According to USAID officials, USAID is currently building the Development Information Solution (DIS), an agency-wide information system that would provide USAID’s operating units (such as headquarters 54 According to USAID officials, USAID has centrally established a data-quality assessment process, which requires that all data collected externally have a data-quality assessment within the 1st year of collecting data and every 3 years thereafter. 55 USAID officials said that, for one of the projects GAO reviewed, USAID uses a third- party monitoring project to work with local organizations to improve their collection and analysis of data, which these officials said is a major challenge to building local capacity in USAID’s partners. Page 32 GAO-19-77 Human Trafficking bureaus or field missions) with a tool to better collect, track, and analyze information to improve how they manage their projects and overall strategies. Implementing partners would be able to access the DIS via a portal where they would directly enter project information and upload reports and supporting information, according to this official. In addition, this information would better inform USAID’s decision-making at the operating unit level and agency level. A USAID official explained that USAID developed DIS partly as a result of USAID senior management’s concern about the lack of one corporate system to collect data in a timely fashion and improve efficiency. A USAID official responsible for managing DIS informed us that the business case for DIS was approved in fiscal year 2016. Developers have regularly solicited input from across the agency, according to this official, and a pilot with six missions is expected to begin in November 2018. This official explained that USAID plans to have DIS operational by the end of 2019, but DIS’s timeframe has been accelerated by a year, to 2019 from 2020, which may create programming and budget challenges, and unexpected challenges may also arise during the pilot process as mission needs for DIS are more fully assessed. USAID is currently developing training, deployment, and communications plans to prepare the agency for implementing DIS, according to officials. DOL Had Consistent and We reviewed selected indicators and targets information in one DOL Complete Performance project and identified no significant consistency or completeness issues beyond early project stages. For example, for the indicator “number of Information for the countries that ratify the International Labor Organization Protocol on Selected Project and We Forced Labor,” the October 2016 report contained no reported value for Identified No Controls this indicator, while the subsequent report (April 2017) updated this figure Insufficient to Ensure the to indicate a value of “4” for October 2016. DOL officials explained that a Reliability of Performance data reporting form had not yet been developed as of October 2016, but indicator performance was discussed in the October 2016 narrative and Information added to the data reporting form when it was developed. While DOL does not require that a project progress report discuss every indicator associated with an activity in the performance report narrative, according to officials, we found that explanations were present for every significant Page 33 GAO-19-77 Human Trafficking performance-related event that we identified for the fiscal year 2016 and fiscal year 2017 period. 56 We did not identify any controls in DOL’s process that were insufficient to ensure the reliability of performance monitoring information. DOL officials said that they use a system of spreadsheets with automated calculations and validation checks that are intended to standardize information submission and assure consistency and completeness of submitted information. These officials said that the project’s Comprehensive Monitoring and Evaluation Plan defines rules for how information for indicators is to be collected and how indicators are to be computed from this information. According to these officials, DOL develops a customized indicator reporting form for each project in conjunction with implementing partners, which implementing partners complete as part of their regular reporting requirements. According to these officials, these spreadsheets contain formula checks to mitigate the risk of implementing partners making undisclosed changes to indicator results and array information in a standardized manner across reporting periods. Officials also commented that for internal reporting purposes, such as the Government Performance and Results Act, project officers can extract information from indicator templates in a manner that is not overly burdensome. According to officials, DOL is developing an enhancement to existing tools, expected in late 2019, which will provide a traceable way to send and receive reports from grant recipients; timestamps when reports are sent, received, and accepted; and tracking of performance monitoring communications between DOL and implementing partners. They plan to continue to use a spreadsheet-based system for tracking indicator information. 56 While we examined indicator and narrative information for consistency and completeness in order to assess its reliability, we did not verify the accuracy of the reported information. Page 34 GAO-19-77 Human Trafficking State Does Not Have a Process to Ensure that All Performance Indicators are Useful, while USAID and DOL Have Established Processes to Regularly Review the Usefulness of Indicators State TIP Office Does Not State TIP Office does not have a process to regularly review the number Have a Process to Review and content of indicators for counter-trafficking in persons projects to ensure that these indicators are useful and that collecting and reviewing All Indicators to Ensure information for them is not overly burdensome. State TIP Office officials Their Usefulness acknowledged there are too many indicators for many counter-trafficking in persons projects. Project officers have the discretion to revise indicators if the scope of the project is not altered, according to State officials. In addition, according to these officials, changes that alter the project scope are possible with the consent of the implementing partner. However, State TIP Office project officers do not formally indicate which indicators they have determined are most useful and informed us that they have insufficient time and resources to do so as projects progress. One official who focuses on monitoring issues stated that, ideally, there should be three to five indicators per activity, and efforts have been made to reduce the number of indicators in some projects. For example, in one of the State TIP Office projects we reviewed—which was designed prior to the hiring of this official—had more than 230 indicators across 20 activities as of the first quarter of fiscal year 2017, which had been reduced to about 150 by the fourth quarter of fiscal year 2017. Our review of two State TIP Office projects showed that indicators did not change in some situations even when the project officer considered the indicator to have become less relevant. State project officers explained that, instead of only relying on indicator information, they regularly spoke with implementing partners for an understanding of what performance level to expect. While acknowledging errors in the numerical information Page 35 GAO-19-77 Human Trafficking for some indicators, project officers for the two projects we reviewed said that they sometimes overlooked reviews of all reported indicators in the quarterly progress reports because they consider some indicators to be less useful or unimportant and not needed for monitoring purposes, and burdensome to review in depth. These officials said that project officers focus on the indicators that they consider to be most important for project oversight or congressional requests. State TIP Office officials said that logic models, which include indicators, have improved significantly in recent years (including improvements to the suggested logic model template and the glossary of definitions), partly due to hiring additional monitoring staff, but that State has found the analysis of logic models to be difficult because of the absence of centralized and standardized information and a lack of staff capacity. In addition, project officers stated that they often rely on implementing partners for suggestions with regard to changing indicators. However, according to State officials, these implementing partners may be reluctant to bring up challenges they encounter out of concern that doing so may damage their relationship with State. State’s Program Design and Performance Management Toolkit, rolled-out in 2017, states that indicators can be costly to collect and manage and should therefore be “useful,” which includes having a clear utility for learning, tracking, informing decisions, or addressing ongoing program needs. This policy further states that indicators should also be “adequate,” which includes having only as many indicators in overall monitoring plan as are necessary and feasible to track key progress and results, inform decisions, conduct internal learning, and meet any external communication or reporting requirements. Further, federal internal control standards state that management should establish and operate monitoring activities, and, after doing so, may determine how often it is necessary to change the design of the internal control system as conditions change to effectively address objectives. 57 Without a process to ensure that the number and content of counter-trafficking in persons project indicators are reviewed and modified as needed, project monitoring may be less efficient and effective as implementing partners and State TIP Office staff spend time collecting and reviewing indicator information that is not useful for project monitoring and management. 57 See GAO-14-704G. Page 36 GAO-19-77 Human Trafficking DOL and USAID Have DOL and USAID had processes in place to regularly review indicators for Established Processes to the projects we selected. DOL officials told us that project officers work with subject-matter experts to review the relevance of indicators in each Regularly Review the semi-annual reporting period. These officials also stated that grantees are Usefulness of Indicators required to review their monitoring and evaluation plan annually, which includes the project’s indicators, and to provide the most recent work plan with each semi-annual report. According to DOL officials, while not a DOL requirement, the project we reviewed incorporated a work plan for each component of the project defining when important activities were planned under each output indicator. We found that DOL and the implementing partner made regular changes to these project plans in response to changing conditions. These plans were consistently included in the monitoring documents and most elements were discussed in the associated narrative text. USAID conducts its project oversight primarily out of its overseas missions, according to USAID officials. 58 According to USAID officials associated with the projects we reviewed, these officials should review the project’s indicators annually, as well as when they determine a review is needed, such as when projects have changes in planned activities. USAID officials stated that this annual review process may be explicitly required in some agreements. According to these officials, missions or other operating units are required to manage and update reference sheets for indicators, which officials said are intended to define each indicator and the information to be collected to measure each indicator. Changes to these reference sheets are tracked, according to these officials. Projects we reviewed showed evidence of regular changes to indicators and associated targets. We spoke to project officers about several specific changes that we had identified. For many of these changes, the project officers provided information about their work with implementing partners to appropriately adjust program goals and expectations, such as adapting the project indicators and targets to unexpected or changing conditions. 58 According to officials, USAID/Washington also reviews indicator data that is submitted in the Performance Plan Report, which is an annual data call to all operating units that implement foreign assistance funds. According to these officials, the Performance Plan Report process informs dialogue between USAID/Washington and overseas missions intended to ensure that there is appropriate oversight and understanding of counter- trafficking in persons programming. Page 37 GAO-19-77 Human Trafficking Given the grave suffering of victims and damaging effects on society that Conclusions trafficking in persons imposes, and the U.S. government’s reliance on implementing partners to carry out its counter-trafficking projects, performance monitoring is important to ensure that the United States funds projects that are effective, efficient, and achieve their intended counter-trafficking goals. In fiscal year 2017, State, DOL, and USAID managed 120 counter-trafficking projects and monitored the performance of the projects. However, weaknesses in State’s and USAID’s monitoring processes limit their ability to collect reliable performance information and assess project performance. First, we found that the State TIP Office did not fully document its monitoring activities for many of the projects we reviewed that started in between fiscal years 2011 to 2016. Monitoring the implementation of projects and fully documenting the results of such monitoring are key management controls to help ensure that project recipients use federal funds appropriately and effectively. The State TIP Office was also not setting targets for some project indicators, which may have limited the TIP Office’s ability to determine if implementation was on track or if corrections needed to be made. Furthermore, we found that the State TIP Office and USAID used project performance information reported by the implementing partners—used for internal and external reporting purposes—that was not always consistent or complete, and did not have sufficient controls to ensure the reliability of performance information. Finally, to ensure effective and efficient monitoring, projects need to establish a reasonable number of indicators and update them as needed. However, we found that the State TIP Office does not regularly evaluate and revise all of its indicators for counter-trafficking in persons projects, which can have large numbers of indicators. As a result, the State TIP Office may be using information to monitor project performance that that is less useful and relevant for understanding project progress, and requires more resources and time for the implementing partners to produce and agency officials to review. State TIP Office officials noted that the TIP Office has taken steps to improve its monitoring process, and State and USAID officials explained that State and USAID are developing information management systems that may increase the quality and usefulness of the monitoring information they use. However, these systems are not fully designed or operational and their capabilities are not yet known. Thus, the potential of these systems to strengthen the ability of State and USAID to collect reliable performance information and assess their efforts to combat the serious problem of global trafficking in persons is unclear. State and USAID could benefit from making additional improvements to ensure their projects are Page 38 GAO-19-77 Human Trafficking being implemented as intended and achieving project goals to prevent trafficking in persons, protect victims, and prosecute trafficking crimes. We are making a total of five recommendations, including four to State Recommendations for and one to USAID. Specifically: Executive Action The Secretary of State should ensure that the Director of the TIP Office establishes targets for each performance indicator. (Recommendation 1) The Secretary of State should ensure that the Director of the TIP Office maintains documentation of all required monitoring activities, including monitoring plans, progress reports, and performance targets. (Recommendation 2) The Secretary of State should ensure that the Director of the TIP Office establishes additional controls to improve the consistency and completeness of performance information that the TIP Office uses to monitor counter-trafficking in persons projects. (Recommendation 3) The Secretary of State should ensure that the Director of the TIP Office establishes a process to review and update performance indicators, with the participation of implementing partners, to ensure that project monitoring remains efficient and effective. (Recommendation 4) The Administrator of USAID should establish additional controls to improve the consistency and completeness of performance information that USAID uses to monitor counter-trafficking in persons projects. (Recommendation 5) We provided a draft of this report to State, DOL, USAID, DOD, and the Agency Comments Treasury for review and comments. In State’s and USAID’s letters, and Our Evaluation reproduced in appendixes IV and V, respectively, both agencies concurred with our recommendations and described their planned actions to address the recommendations. In addition, State’s letter indicated that our draft report did not fully recognize the investment State has made, and the changes underway, to improve the TIP Office’s performance measurement and ensure complete and consistent documentation. State cited additional dedicated financial and personnel resources for monitoring and evaluation added over the past two years. We acknowledge and report on these positive steps, including the hiring of a monitoring and evaluation specialist and other TIP Office staff, in our Page 39 GAO-19-77 Human Trafficking report. USAID’s letter included other comments that we have responded to in appendix V. Furthermore, State, DOL, USAID, and the Treasury provided technical comments, which we incorporated as appropriate. DOD had no comments. We are sending copies of this report to the appropriate congressional committees; the Secretaries of State, Labor, Defense, and Treasury; and the Administrator of USAID. In addition, the report is available at no charge on the GAO website at http://www.gao.gov. If you or your staff members have any questions about this report, please contact me at (202) 512-7141, or groverj@gao.gov. Contact points for our Office of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made major contributions to this report are listed in appendix VI. Jennifer Grover Director, International Affairs and Trade Page 40 GAO-19-77 Human Trafficking List of Committees The Honorable James M. Inhofe Chairman The Honorable Jack Reed Ranking Member Committee on Armed Services United States Senate The Honorable Bob Corker Chairman The Honorable Bob Menendez Ranking Member Committee on Foreign Relations United States Senate The Honorable Richard Shelby Chairman The Honorable Dick Durbin Ranking Member Subcommittee on Defense Committee on Appropriations United States Senate The Honorable James Lankford Chairman The Honorable Christopher Coons Ranking Member Subcommittee on Financial Services and General Government Committee on Appropriations United States Senate The Honorable Roy Blunt Chairman The Honorable Patty Murray Ranking Member Subcommittee on Labor, Health and Human Services, Education, and Related Agencies Committee on Appropriations United States Senate Page 41 GAO-19-77 Human Trafficking The Honorable Lindsey Graham Chairman The Honorable Patrick Leahy Ranking Member Subcommittee on State, Foreign Operations, and Related Programs Committee on Appropriations United States Senate The Honorable Mac Thornberry Chairman The Honorable Adam Smith Ranking Member Committee on Armed Services House of Representatives The Honorable Ed Royce Chairman The Honorable Eliot Engel Ranking Member Committee on Foreign Affairs House of Representatives The Honorable Kay Granger Chairwoman The Honorable Pete Visclosky Ranking Member Subcommittee on Defense Committee on Appropriations House of Representatives The Honorable Tom Graves Chairman The Honorable Mike Quigley Ranking Member Subcommittee on Financial Services and General Government Committee on Appropriations House of Representatives Page 42 GAO-19-77 Human Trafficking The Honorable Tom Cole Chairman The Honorable Rosa DeLauro Ranking Member Subcommittee on Labor, Health and Human Services, Education, and Related Agencies Committee on Appropriations House of Representatives The Honorable Hal Rogers Chairman The Honorable Nita Lowey Ranking Member Subcommittee on State, Foreign Operations, and Related Programs Committee on Appropriations House of Representatives Page 43 GAO-19-77 Human Trafficking Appendix I: Objectives, Scope, and Appendix I: Objectives, Scope, and Methodology Methodology The National Defense Authorization Act for Fiscal Year 2017 includes a provision for GAO to report on the programs conducted by the Department of State (State), the Department of Labor (DOL), the United States Agency for International Development (USAID), the Department of Defense (DOD), and the Department of the Treasury (Treasury) that address human trafficking and modern slavery, including a detailed analysis of the effectiveness of such programs in limiting human trafficking and modern slavery. 1 Three of these agencies—State, DOL, and USAID—have programs that design and award counter-trafficking projects to implementing partners, through contracts, grants, or cooperative agreements. 2 These agencies then oversee and monitor these projects. Since DOD and Treasury officials did not identify these types of projects as part of their counter-trafficking in persons efforts, we provided background information on their efforts but did not cover these agencies in our reporting objectives. This report (1) identifies the recent projects in international counter-trafficking in persons that key U.S. agencies have awarded to implementing partners, and for selected projects, assesses the extent to which key agencies have (2) documented their monitoring activities, (3) ensured the reliability of the performance information they use in monitoring projects, and (4) reviewed the usefulness of the performance indicators they use in monitoring projects. To address these objectives, we reviewed relevant agency documents and interviewed agency officials. To report on agencies’ programs, we asked knowledgeable officials at State, DOL, USAID, DOD, and Treasury to identify their projects that (1) had an international focus; (2) were delivered by implementing partners to external recipients, such as trafficking victims or host governments, as project beneficiaries; and (3) addressed trafficking in persons, 1 See Pub. L. No. 114-328, Div. A, Title XII, § 1298(h), 130 Stat. 2000, 2563 (2016). 2 For the purposes of our review, implementing partners include contractors, grantees, and recipients of cooperative agreements. Page 44 GAO-19-77 Human Trafficking Appendix I: Objectives, Scope, and Methodology modern slavery, 3 or forced labor. 4 Because State, DOL, and USAID managed such projects, we focus on them as the three key agencies for the purposes of our reporting objectives. According to officials from these three agencies, the projects they identified range from those with counter- trafficking in persons as a primary goal, to those in which this goal was integrated as part of each agency’s activities. 5 We used the lists of projects that these agencies provided to report the relevant counter- trafficking projects that agencies awarded to implementing partners to 3 According to the Department of State, “trafficking in persons,” “human trafficking,” and “modern slavery” are used as umbrella terms to refer to both sex trafficking and compelled labor. Agency officials we met with also commented that modern slavery is not defined in law, and often used interchangeably with the term “trafficking in persons” or “human trafficking.” 4 To address the mandate, we gathered information about agencies’ programs and projects. In past GAO reports, we noted that the Glossary of Terms Used in the Federal Budget Process defines “program” as “generally, an organized set of activities toward a common purpose or goal that an agency undertakes or proposes to carry out its responsibilities.” This definition acknowledges that because the term program has many uses in practice, it does not have a well-defined, standard meaning in the legislative process. It is used to describe an agency’s mission, functions, activities, services, projects, and processes. Our report focuses on, and therefore uses the term, “projects,” to refer to counter-trafficking in persons interventions funded by key agencies through awards made to implementing partners, though some agencies may sometimes refer to what we term “projects” as “programs.” 5 The agencies used different approaches to identify relevant projects. State’s projects are those with a primary goal of counter-trafficking in persons. DOL’s list of projects includes those that either solely focused on forced labor or trafficking in persons, or included a substantial component on either of those issues. DOL’s projects also include those in which reducing child labor was the primary goal, but for which there was a substantial component focused on forced labor or trafficking. In addition to including projects with a primary goal of counter-trafficking in persons, USAID included projects that do not have counter-trafficking in persons as a primary goal. According to USAID officials, USAID’s counter-trafficking in persons integration is part of USAID’s counter-trafficking in persons policy, and that excluding integrated projects that do not have a primary goal of counter- trafficking in persons, but incorporate a counter-trafficking component, would present an incomplete picture and would leave out a set of projects that reflect USAID’s holistic approach to addressing trafficking in persons. According to DOD officials, DOD’s only relevant program is its trafficking in persons awareness training provided to its staff, which is not internationally focused or delivered to external recipients as projects. Treasury officials informed us that Treasury does not have specific programs on countering- trafficking in persons to report. As such, our reporting objectives do not cover DOD or Treasury. Page 45 GAO-19-77 Human Trafficking Appendix I: Objectives, Scope, and Methodology carry out the projects. 6 For our first objective, we determined the projects that were active during fiscal year 2017, including those which began, were ongoing, or ended during fiscal year 2017, and interviewed agency officials to confirm project information. To analyze the effectiveness of agencies’ programs in limiting human trafficking and modern slavery, we assessed the key agencies’ monitoring efforts for selected projects by examining the extent to which agencies have documented their monitoring activities, ensured the reliability of the performance information, and reviewed the usefulness of the performance indicators they use in monitoring projects. To assess the extent to which State, DOL, and USAID documented their monitoring activities for selected counter-trafficking in persons projects, we reviewed these agencies’ monitoring policies and related guidance as well as the full agreements for the projects to identify specific required monitoring activities. The policies and related guidance included State’s Grants Policy Directive Number 42 (GPD-42) related to monitoring assistance awards; 7 Federal Assistance Policy Directive (FAPD), 8 which according to a State official superseded State’s grants policy directives, including GPD-42; Federal Assistance Directive, 9 which superseded the 6 Funding amounts for the counter-trafficking in persons projects were provided by each agency in response to our request for funding information. However, the agencies used different methods for collecting and reporting the funding data, which limited our ability to combine funding information across agencies. State’s reported funding consists of total award amounts for projects that focused on counter-trafficking in persons. DOL also reported total award amounts for projects that focused on counter-trafficking in persons, and estimated award amounts for the counter-trafficking in persons component of the total award amounts for projects that did not focus on counter-trafficking in persons. USAID’s reported funding consists of total award amounts for counter-trafficking in persons standalone projects, in which the sole focus of the project was to combat trafficking in persons. However, for USAID’s integrated projects in which counter-trafficking in persons efforts make up a component of the overall project, USAID reported on the commitment of its funds specifically for counter-trafficking in persons activities, which consists of obligated amounts plus committed amount. 7 Department of State, Bureau of Administration, Office of the Procurement Executive, Grants Policy Directive Number 42 (Aug. 30, 2010). 8 Department of State, Office of the Procurement Executive, U.S. Department of State Federal Assistance Policy Directive (Mar. 13, 2015), and U.S. Department of State Federal Assistance Policy Directive (Jan. 14, 2016). 9 Department of State, Office of the Procurement Executive, Federal Assistance Division, Federal Assistance Directive, version 1.0 (May 20, 2017), and Federal Assistance Directive, version 2.0 (Oct. 1, 2017). Page 46 GAO-19-77 Human Trafficking Appendix I: Objectives, Scope, and Methodology FAPD; Program Design and Performance Management Toolkit; 10 and Program and Project Design, Monitoring, and Evaluation Policy. 11 We also reviewed State’s Office to Monitor and Combat Trafficking in Persons standard operating procedures. 12 For DOL, we reviewed its Management Procedures and Guidelines (MPG) 13 as well as the Comprehensive Monitoring and Evaluation Plan Guidance Document 14 referenced in the fiscal year 2017 MPG. For USAID, we reviewed—from its Automated Directives System or ADS—Chapter 203 on Assessing and Learning 15 and Chapter 201 on Program Cycle Operational Policy, 16 which according to USAID officials superseded Chapter 203. Once we determined what tools the agencies use to monitor their counter-trafficking in persons projects, we sought documentation of those tools to determine whether agencies were implementing those tools. To assess the agencies’ monitoring efforts, we identified all of State’s, DOL’s, and USAID’s projects that started before or during October 2015, which corresponds to the first quarter of fiscal year 2016, and were active through September 30, 2017, which corresponds to the fourth and last 10 Department of State, Program Design and Performance Management Toolkit (Sept. 2016). 11 Department of State, Department of State Program and Project Design, Monitoring, and Evaluation Policy (Nov. 2017). 12 Department of State, Office to Monitor and Combat Trafficking in Persons, International Programs Team Manual (updated Apr. 2018). 13 Department of Labor, Bureau of International Labor Affairs, Office of Child Labor, Forced Labor and Human Trafficking, Management Procedures and Guidelines for USDOL-ILO Cooperative Agreements: FY2012 Projects awarded to ILO Programme for the Elimination of Child Labour, Management Procedures and Guidelines for Cooperative Agreements 2014; Management Procedures and Guidelines for USDOL-ILO Cooperative Agreements: FY2015 Projects awarded to the ILO; and Management Procedures and Guidelines for Cooperative Agreements Fiscal Year 2017 (Dec. 19, 2017). 14 Department of Labor, Bureau of International Labor Affairs, Office of Child Labor, Forced Labor and Human Trafficking, Resources for Developing an OCFT Comprehensive Monitoring & Evaluation Plan (CMEP) (Feb. 13, 2018). 15 United States Agency for International Development, ADS Chapter 203 Assessing and Learning (revised Nov. 2, 2017). 16 United States Agency for International Development, ADS Chapter 201 Program Cycle Operational Policy (revised Oct. 5, 2017). Page 47 GAO-19-77 Human Trafficking Appendix I: Objectives, Scope, and Methodology quarter of fiscal year 2017. 17 This produced a list of a total of 57 State, DOL, and USAID projects. Out of these 57 projects, we excluded 3 projects from our selection for various reasons. We excluded one DOL project because DOL identified the project as being a research project for which certain agency performance monitoring requirements (e.g., indicators, targets) are not applicable. We also excluded two USAID projects because USAID identified each project as including several projects with various start and end dates, thus making it difficult to determine their time frames for inclusion in our report. This resulted in a selection of 54 projects—37 from State, 3 from DOL, and 14 from USAID. We reviewed documentation of key monitoring activities as specified in agency policy or the project award agreements to determine the extent to which the agencies had full documentation of key monitoring activities. We also applied federal standards for internal control, which call for agency management to design monitoring activities so that all transactions are completely and accurately recorded, 18 and GAO’s key attributes of effective performance measures, specifically the attribute of 17 For our reporting objectives to assess the extent to which agencies have documented their monitoring activities, ensured the reliability of the performance information, and reviewed the usefulness of the performance indicators they use for that monitoring, we reviewed projects based on the information contained in an initial list of projects that agencies provided. USAID subsequently provided an updated list of projects that slightly affected the count of projects that we report in our objective to identify projects, but we did not revise the scope of projects we reviewed for other objectives. 18 GAO, Standards for Internal Control in the Federal Government, GAO-14-704G (Washington, D.C.: Sept. 2014), and Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: Nov. 1999). Page 48 GAO-19-77 Human Trafficking Appendix I: Objectives, Scope, and Methodology having a numerical target. 19 We made our determinations of the extent to which agencies had full documentation of key monitoring activities, as follows: • State (37 projects 20). To determine whether State had fully documented its monitoring activities, we reviewed the monitoring plan for each project; fiscal year 2017 quarterly progress reports for each project; and the final progress report, including indicators and targets, for the seven projects that ended as of December 2017. • We determined that State had “fully documented” the monitoring plan, if State provided a monitoring plan worksheet for the project. If State did not provide a monitoring plan worksheet for the project, we determined the monitoring plan was “not documented.” • For each quarterly progress report for fiscal year 2017 as well as the final progress report for projects that ended as of December 2017, we determined that State had “fully documented” the report, if the report included both a qualitative and quantitative summary of progress. For the State TIP Office projects we reviewed, the qualitative summary of progress is captured in a narrative and the quantitative summary of progress is captured in the logic model. For the State DRL project we reviewed, the qualitative summary of 19 Our prior work on performance measurement identified 10 key attributes of performance measures—such as having a measurable target—that GAO has found are key to successfully measuring a project’s performance. For example, our prior work has shown that numerical targets or other measurable values facilitate future assessments of whether overall goals and objectives are achieved because comparisons can be easily made between projected performance and actual results. See GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002), p. 45, for a description of how we developed the attributes of effective performance goals and measures. See GAO, Defense Health Care Reform: Additional Implementation Details Would Increase Transparency of DOD’s Plans and Enhance Accountability, GAO-14-49 (Washington, D.C.: Nov. 6, 2013), p. 17, for a description of why the baseline measure was added as an attribute of effective performance measures. See also GPRA Performance Reports, GAO/GGD-96-66R (Washington, D.C.: Feb. 14, 1996); Missile Defense: Opportunity to Refocus on Strengthening Acquisition Management, GAO-13-432 (Washington, D.C.: Apr. 26, 2013); Performance Measurement and Evaluation: Definitions and Relationships, GAO-11-646SP (Washington, D.C.: May 2011); and Agency Performance Plans: Examples of Practices That Can Improve Usefulness to Decisionmakers, GAO/GGD/AIMD-99-69 (Washington, D.C.: Feb. 26, 1999). 20 Of the 37 projects, 36 are managed by State’s Office to Monitor and Combat Trafficking in Persons (TIP Office) and the remaining project is managed by State’s Bureau of Democracy, Labor, and Human Rights (DRL). We did not find any instances of “partially documented” or “not documented” monitoring activities for the DRL project. Page 49 GAO-19-77 Human Trafficking Appendix I: Objectives, Scope, and Methodology progress is captured in a narrative and the quantitative summary of progress is captured in the monitoring plan. If either component—narrative or quantitative summary—was not documented, we determined that the report was “partially documented.” If both components were not documented, we determined that the report was “not documented.” • We determined that State had “fully documented” indicators and targets for projects that ended as of December 2017, if the final progress report for the project included indicators as well as targets for each indicator. 21 If the final progress report included indicators but did not specify targets for each indicator, we determined that indicators and targets were “partially documented.” 22 If the final progress report did not include indicators and targets, we determined that indicators and targets were “not documented.” (We did not find any instances of “not documented.”) • DOL (3 projects). To determine whether DOL had full documentation of its monitoring activities, we reviewed the monitoring plan as well as fiscal year 2017 semi-annual progress reports for each project. Because DOL’s three projects were ongoing as of December 2017, we reviewed the second semi-annual progress report for fiscal year 2017 to determine whether DOL had “fully documented” indicators and targets for each project. Overall, we determined that DOL had “fully documented” (1) the monitoring plan for each project, if the monitoring plan documented the performance metrics and data collection frequency for the project; (2) each fiscal year 2017 semi- annual progress report for the project, if the report included a qualitative and quantitative summary of progress for the period of performance; and (3) indicators and targets for the project, if the second semi-annual progress report included indicators as well as targets for each applicable indicator. 21 The final progress reports provide information on output and outcome indicators. According to the State TIP Office’s logic model proposal template, output indicators provide a means to measure the products, goods, and services which result from an activity, program, or policy (e.g., number of training manuals and tools developed). Outcome indicators provide a means to measure the extent to which an activity, project, program, or policy achieves its objectives (e.g., number of government institutions/structures that utilize manual/tools to train others). 22 For indicators lacking targets, we excluded from the count any disaggregated indicators or indicators for which the target could be inferred, such as when the target could be inferred as being a value of “1.” Page 50 GAO-19-77 Human Trafficking Appendix I: Objectives, Scope, and Methodology • USAID (14 projects). To determine whether USAID had full documentation of its monitoring activities, we reviewed the monitoring plan for each project; fiscal year 2017 progress reports at the reporting frequency specified in the agreements for each project; and the final progress report, including indicators and targets, for the three projects that ended as of December 2017. We also reviewed evidence of site visits conducted during the life time of the projects. Overall, we determined that USAID had “fully documented” (1) the monitoring plan for each project, if the monitoring plan documented performance metrics for the project; (2) the periodic progress reports for fiscal year 2017 as well as the final progress report for projects that ended as of December 2017, if the report included a qualitative and quantitative summary of progress for the period of performance; and (3) indicators and targets for the three projects that ended as of December 2017, if the final progress report included indicators as well as targets for each applicable indicator. We determined that USAID “fully documented” a project’s site visit, if USAID provided evidence of having conducted at least one site visit during the life time of the project. Additionally, we interviewed knowledgeable monitoring officials from each agency to understand agencies’ monitoring process and application of monitoring requirements for counter-trafficking in persons projects. Because State and DOL officials also identified site visits as a key tool they use to monitor their counter-trafficking in persons projects, we reviewed evidence of site visits conducted during the life time of the projects to report on these efforts. 23 We also interviewed State TIP Office officials to discuss instances in which the agency did not have full documentation of key monitoring activities. To assess the extent to which key agencies have ensured the reliability of the performance information they use to monitor selected projects, we selected for review a nongeneralizable sample of 5 projects—2 State projects, 1 DOL project, and 2 USAID projects—out of the 54 counter- trafficking in persons projects identified by agencies that started before or during October 2015 and were active through fiscal year 2017. We based 23 We did not include pre-award site visits in the scope of our review. According to the State TIP Office’s current policy, new grantees who have never received funding from the TIP Office usually receive a pre-award site visit. Page 51 GAO-19-77 Human Trafficking Appendix I: Objectives, Scope, and Methodology our selection of these projects primarily on largest total award amounts. 24 For these selected projects, we obtained 2 years of progress reports and other documents to assess the quantitative and qualitative performance information. We developed a standardized template to capture all quarterly or semi-annual indicator performance information reported for each of these projects and assessed whether quarterly or semi-annual totals were consistent with annual and cumulative totals where these were reported. Using this quantitative information, we judgmentally selected indicators for inclusion in agency interviews where it appeared likely that numerical errors had occurred or there appeared to be significant project events, such as large over- or under-performance or the elimination of the indicator. We interviewed agency officials, including managers of these five projects, about the consistency and completeness of monitoring information in these projects for about 60 indicators identified through our analysis. 25 Additionally, we questioned these officials about performance report narrative information describing project activities that, in our judgement, appeared to be incomplete or inconsistent with respect to indicator results. We also used these interviews to determine whether our findings for these selected projects reflected general agency policies and procedures. We assessed the completeness and consistency of project performance data that State, DOL, and USAID use to monitor projects as part of our data reliability assessment. We found State and USAID data to be unreliable in the projects we reviewed. We discuss the implications of these unreliable data for State and USAID’s project management and reporting in our findings and recommendations. We found the performance data that DOL used were consistent and complete for the project we reviewed. While we examined indicator data and narrative information for consistency and completeness, we did not verify the accuracy of performance information. 24 Within a given agency’s portfolio, we chose not to select a second project if it was being implemented in the same locale as the first project. We instead selected the next largest project. Total award amount of the project may include components that are not focused on counter-trafficking in persons effort. 25 While we reviewed all reported indicator data as part of our process that led to selecting about 60 indicators for which we requested additional information, we did not attempt to count the total number of indicators. In the five projects we reviewed, there were varying practices for labeling and categorizing indicators, leading to ambiguity in counting indicators, such as whether a reported figure is a disaggregation of an indicator or, itself, an indicator; and whether an indicator had been discontinued or was not reported for a given reporting period. Further, the number of indicators for a given project sometimes varied from quarter to quarter. Page 52 GAO-19-77 Human Trafficking Appendix I: Objectives, Scope, and Methodology To assess the extent to which key agencies have reviewed the usefulness of the performance indicators they use to monitor selected projects, we used the same nongeneralizable sample of five projects— two State projects, one DOL project, and two USAID projects. We interviewed agency officials, including managers of these five projects, about processes and systems they use to review the usefulness of indicators on an ongoing basis, such as when conditions in the project activity region change or if the agency and implementing partner learn that certain project activities are less effective than expected. We identified examples of indicators that had apparently been discontinued, as well as continued indicators that showed minimal progress, and we asked these officials to explain what had or had not been discontinued. We also used these interviews to determine whether our findings for these selected projects reflected general agency policies and procedures. We conducted this performance audit from October 2017 to December 2018 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. Page 53 GAO-19-77 Human Trafficking Appendix II: Three Key U.S. Agencies’ Appendix II: Three Key U.S. Agencies’ Counter-trafficking in Persons Projects, Active in Fiscal Year 2017 Counter-trafficking in Persons Projects, Active in Fiscal Year 2017 The Departments of State (State) and Labor (DOL), and U.S. Agency for International Development (USAID) managed 120 projects in counter- trafficking in persons carried out by implementing partners during fiscal year 2017, according to information provided by officials with these agencies. The three agencies used different approaches to identify relevant projects. For example, State reported projects with a primary goal of counter-trafficking in persons, while DOL and USAID included projects that may not have counter-trafficking in persons as a primary goal. Table 4 lists these agencies’ reported project information for projects that were active during fiscal year 2017. Table 4: Departments of State (State) and Labor (DOL), and U.S. Agency for International Development (USAID) Counter- trafficking in Persons Projects Active during Fiscal Year 2017, as Identified by Agency Officials Agency Project name Location(s) of project Start date of End date of Funding a project project amount (month and (month and (in dollars) year) year) State/ Support for United Nations Office on Drugs and Global 9/2011 4/2018 1,410,000 TIP Crime’s (UNODC) normative work on the Office implementation and interpretation of the UN Protocol to Prevent, Suppress, and Punish Trafficking in Persons State/ Global Database for Human Trafficking Cases Global 10/2013 3/2018 1,025,000 TIP Office State/ Counter-Trafficking Training and Technical Global 10/2013 3/2018 1,000,000 TIP Assistance (T&TA): A Global Rapid Response Office Project State/ Strengthening National and Regional Capacity Global 10/2013 6/2018 2,094,792 TIP in the Criminal Justice Response to Trafficking Office in Persons State/ Providing comprehensive support to victims of Sierra Leone 10/2013 9/2018 1,200,000 TIP trafficking in Sierra Leone Office State/ Enhance Government and Civil Society Bhutan 10/2013 9/2018 750,000 TIP Responses to Counter Trafficking in Persons in Office Bhutan State/ Providing comprehensive support to victims of Democratic Republic of 10/2014 11/2017 1,000,000 TIP trafficking in South Kivu and educating key Congo Office stakeholders on Trafficking in Persons (TIP). State/ Strengthening coordination to respond to TIP Mozambique 10/2014 12/2017 750,000 TIP and ensure justice and protection for victims of Office trafficking in Mozambique Page 54 GAO-19-77 Human Trafficking Appendix II: Three Key U.S. Agencies’ Counter-trafficking in Persons Projects, Active in Fiscal Year 2017 Agency Project name Location(s) of project Start date of End date of Funding a project project amount (month and (month and (in dollars) year) year) State/ Building a National Non-Governmental Burma 10/2014 12/2017 700,000 TIP Organization (NGO) Network to Combat Office Trafficking, Especially in Conflict and Ceasefire Areas in Myanmar State/ Integrated Services for Human Trafficking Peru 10/2014 12/2017 700,000 TIP Victims in Peru Office State/ Best Practices in Global Data Collection on Global 10/2014 3/2018 500,000 TIP Trafficking in Persons: The Science (and Art) of Office Understanding Trafficking in Persons State/ Supporting the Enactment of Anti-Trafficking Tunisia 10/2014 9/2018 700,000 TIP Legislation and National Action Plan in Tunisia, Office as well as Strengthening the National Capacities on Identification and Assistance to Victims of Trafficking State/ A cloud-based case data capture, management Global: Burma, Cambodia, 10/2014 9/2018 650,000 TIP and analysis platform for anti-trafficking NGOs Hong Kong, Indonesia, Office across different countries in Asia for Laos, Malaysia, the standardization of TIP data collection and for Philippines, Thailand, data research Vietnam, Bangladesh, India, Nepal, Ghana, Kenya, Uganda State/ Safe and Sound Vietnam 10/2014 9/2018 600,000 TIP Office State/ International Organization for Migration’s (IOM) Global 10/2014 12/2018 600,000 TIP Human Trafficking Information Exchange: A Office Reliable Foundation for Effective Anti- Trafficking Policies State/ Strengthening the criminal justice response to Somalia 10/2014 3/2018 750,000 TIP trafficking in persons through legislative Office assistance and capacity building in Somalia State/ Protect, Shelter and Heal: Victim-Centered Africa regional: Nigeria, 4/2015 12/2017 750,000 TIP Technical Assistance for Sub-Saharan African Swaziland Office Governments and Civil Society State/ Strengthening Uruguay’s efforts to effectively Uruguay 4/2015 3/2018 470,000 TIP combat TIP at the local level Office State/ Trafficking in Persons-Legal Assistance Africa regional: 4/2015 6/2018 750,000 TIP Program (TIP-LAP) Mozambique, Rwanda, Office Togo, Madagascar, Mauritius Page 55 GAO-19-77 Human Trafficking Appendix II: Three Key U.S. Agencies’ Counter-trafficking in Persons Projects, Active in Fiscal Year 2017 Agency Project name Location(s) of project Start date of End date of Funding a project project amount (month and (month and (in dollars) year) year) State/ Growing up Free: An Effective Response to Ghana 9/2015 9/2019 2,550,000 TIP Child Trafficking in Ghana Office State/ United States Conference of Catholic Bishops’ East Asia and the Pacific 10/2015 12/2017 500,000 TIP Migration and Refugee Services Regional Office (USCCB/MRS) Project to Combat Global Maritime Human Trafficking State/ Establishment of data collection systems in Africa regional: Malawi, 10/2015 12/2017 400,000 TIP Southern African Development Community Mozambique, Seychelles, Office (SADC) member states Zimbabwe, South Africa, Lesotho, Swaziland State/ Strengthening coordination to respond to TIP Namibia 10/2015 9/2018 750,000 TIP and ensure justice and protection for victims of Office trafficking in Namibia State/ Combating Human Trafficking in Bangladesh Bangladesh 10/2015 9/2018 750,000 TIP through the Promotion of Safe Migration and Office Protection State/ Combating human trafficking by strengthening India 10/2015 9/2018 750,000 TIP law enforcement responses, facilitating Office interstate police cooperation, building capacities of victim support systems, enhancing multi sectoral partnerships State/ Technical Assistance to the Government of Kyrgyzstan 10/2015 9/2018 750,000 TIP Kyrgyzstan to Strengthen the Legal and Office Operational Framework on Combating Trafficking in Persons State/ New Law on the Books: women Judges Haiti 10/2015 9/2018 750,000 TIP Provide Leadership on Trafficking in Haiti Office State/ Strengthening the capacity of the Mexican Mexico 10/2015 9/2018 750,000 TIP government to conduct victim-centered Office investigations and prosecutions of TIP cases and to enhance victims’ protection systems State/ Burma Anti-Trafficking in Persons project Burma 10/2015 9/2018 700,000 TIP Office State/ Protecting Victims of Human Trafficking Timor-Leste 10/2015 9/2018 600,000 TIP through Enhanced Partnership, Identification Office and Referral State/ Improving the Capacity of Philippines Law Philippines 10/2015 9/2018 500,000 TIP Enforcement, Judicial System and Social Office Services in Combating Human Trafficking Page 56 GAO-19-77 Human Trafficking Appendix II: Three Key U.S. Agencies’ Counter-trafficking in Persons Projects, Active in Fiscal Year 2017 Agency Project name Location(s) of project Start date of End date of Funding a project project amount (month and (month and (in dollars) year) year) State/ Strengthening the National Action Plan on TIP Turkmenistan 10/2015 9/2018 500,000 TIP in Turkmenistan to Ensure Coordinated Office Assistance and a Victim-centered Approach State/ Strengthening the Institutional Capacity of Caribbean Regional- 10/2015 9/2018 500,000 TIP Criminal Justice Actors in the Caribbean to Antigua and Barbuda, Office Counter Trafficking in Persons Using a Victim Belize, Jamaica, Trinidad Centered Approach and Tobago State/ Assisting the Government of Ghana to Combat Ghana 10/2015 9/2019 2,540,000 TIP Child Trafficking Office State/ Emergency Direct Assistance for Victims of Global 10/2015 9/2018 750,000 TIP Trafficking Office State/ Strengthening the national criminal justice Djibouti 10/2015 3/2018 500,000 TIP system’s response to trafficking in persons in Office Djibouti State/ Enhancing National Counter-Trafficking Efforts Malaysia 1/2016 12/2017 400,000 TIP in Malaysia Office State/ A Shelter and Repatriation Services for Laos 1/2016 12/2018 930,000 TIP Survivors of Human Trafficking in Vientiane, Office Lao People’s Democratic Republic State/ Bangladesh: Combating Labor Trafficking Bangladesh 4/2016 3/2018 500,000 TIP through Awareness Raising and Enhancing Office Victim Protection State/ Providing Assistance & Support to Victims of Thailand 4/2016 3/2019 600,000 TIP Human Trafficking in Thailand’s Fishing Office Industry State/ Urban Light: Expanding Victim-Services for Thailand 6/2016 11/2018 250,000 TIP Males Who Are Victims of Trafficking and Office Exploitation in Northern Thailand State/ UNODC Country Programme for Pakistan-Illicit Pakistan 9/2016 8/2019 750,000 TIP Trafficking and Border Management Sub- Office Programme State/ IMPACT TIP-TAN Tanzania 10/2016 9/2018 750,000 TIP Office State/ GLOT59 Global Programme Against Trafficking Global 10/2016 9/2018 750,000 TIP in Persons: Strengthening the Implementation Office of a Comprehensive Response to Trafficking in Persons in Selected Countries Page 57 GAO-19-77 Human Trafficking Appendix II: Three Key U.S. Agencies’ Counter-trafficking in Persons Projects, Active in Fiscal Year 2017 Agency Project name Location(s) of project Start date of End date of Funding a project project amount (month and (month and (in dollars) year) year) State/ Establishment of data collection systems in Africa Regional: Angola, 10/2016 9/2018 500,000 TIP Angola, Botswana and Namibia Botswana, Namibia Office State/ Unraveling the Net: Human Trafficking in the Indonesia 10/2016 9/2018 500,000 TIP Indonesian Fishing Industry Office State/ Strengthening Governmental Efforts to Combat Egypt 10/2016 9/2018 400,000 TIP Human Trafficking through Increased Office Prosecution and Enhanced Victim Protection in Egypt (SETIP) State/ Establishment of a national data collection Tanzania 10/2016 9/2018 150,000 TIP system in Tanzania Office State/ Strengthening institutional capacity to Mali 10/2016 3/2019 750,000 TIP coordinate national anti-trafficking response Office including the identification, protection of victims, investigation and prosecution of trafficking offenders in Mali State/ Strengthening Counter-Trafficking Efforts for Indonesia 10/2016 9/2019 829,964 TIP Improved Human Security in Indonesia Office State/ Strengthened Capacities for Improved Madagascar 10/2016 9/2019 750,000 TIP Coordination, Protection, and Prosecution on Office TIP in Madagascar State/ International Criminal Police Organization Global 10/2016 9/2019 750,000 TIP (INTERPOL) Project to Combat Human Office Trafficking via Rapid Response Technical Assistance and Training (T&TA) State/ Counter-Trafficking Training and Technical Global 10/2016 9/2019 750,000 TIP Assistance (T&TA): A Global Rapid Response Office Project State/ Strengthening Capacities of Civil Society in Morocco 10/2016 9/2019 722,000 TIP Morocco to Identify and Provide Services to Office Victims of Trafficking in Persons State/ Strengthening and Sustaining Tanzania’s Tanzania 10/2016 9/2019 600,000 TIP Response to Trafficking in Persons, Ensuring Office Access to Justice and Fair Treatment for TIP Victims State/ Improving the Judiciary’s Capacity to Fight Lebanon 12/2016 3/2018 400,000 TIP Human Trafficking in Lebanon Office Page 58 GAO-19-77 Human Trafficking Appendix II: Three Key U.S. Agencies’ Counter-trafficking in Persons Projects, Active in Fiscal Year 2017 Agency Project name Location(s) of project Start date of End date of Funding a project project amount (month and (month and (in dollars) year) year) State/ Strengthening Investigation of Trafficking in Jordan 12/2016 11/2018 750,000 TIP Persons Cases & Services for Victims in Office Jordan State/ Improving national capacities to fight trafficking Burkina Faso 12/2016 11/2018 715,000 TIP in persons by enhancing prosecution of Office traffickers, identification and protection of victims of trafficking in Burkina Faso State/ Engaging Indigenous Women to Prevent and Bolivia 12/2016 11/2018 635,000 TIP Counter Trafficking in Persons Office State/ Enhancing National and Local Capacities for Ethiopia 12/2016 11/2018 500,000 TIP the Prevention of Trafficking in Persons and Office Protection of Victims of Trafficking and Vulnerable Returnees in Ethiopia State/ Capacity-building of the INTERPOL Regional Africa Regional 12/2016 11/2019 750,000 TIP Bureau for Southern Africa to support Southern Office African Regional Police Chiefs Cooperation Organization (SARPCCO) member states in victim-centered investigations and prosecution of trafficking in persons cases State/ Strengthening Guyana’s capacity to effectively Guyana 12/2016 11/2019 750,000 TIP combat TIP and assist victims of trafficking Office State/ Training and Technical Assistance to Ensure Lake Chad Basin: Nigeria 1/2017 12/2018 750,000 TIP Comprehensive Services for Victims of and Cameroon Office Trafficking in the Lake Chad Basin State/ Enhancing Counter Trafficking in Crisis in the Balkans Regional 2/2017 7/2018 750,000 TIP Western Balkans (Albania, Bosnia and Office Herzegovina, Macedonia, Kosovo, Montenegro, Serbia) State/ Ending impunity for traffickers in the Thai Thailand 2/2017 1/2019 1,000,000 TIP fishing industry Office State/ Reduce the vulnerability and level of labor India 2/2017 1/2019 750,000 TIP exploitation and trafficking of local and inter- Office state migrant workers in the brick kiln and agriculture industry in Chhattisgarh, Uttar Pradesh and Punjab. State/ Innovation in Analytics, Technology and Thailand 2/2017 1/2019 500,000 TIP Partnerships to Eliminate Slavery in Thai Office Supply Chains Page 59 GAO-19-77 Human Trafficking Appendix II: Three Key U.S. Agencies’ Counter-trafficking in Persons Projects, Active in Fiscal Year 2017 Agency Project name Location(s) of project Start date of End date of Funding a project project amount (month and (month and (in dollars) year) year) State/ Activating the Bonded Labor System Abolition India 2/2017 1/2020 750,000 TIP (BLSA) Act Office State/ Combating TIP through Victim-Centered India 2/2017 1/2020 735,000 TIP Approaches in India Office State/ Improving Victim-Centered Investigations and Mongolia 4/2017 3/2019 750,000 TIP Prosecutions of TIP Cases in Mongolia Office State/ Enhancing Availability and Accessibility of Ukraine 4/2017 3/2019 750,000 TIP Services for (Potential) Victims of Trafficking, Office Especially Children in Ukraine State/ SEA Fisheries Project (Strengthened Burma, Brunei, Cambodia, 4/2017 3/2020 1,500,000 TIP Coordination to Combat Trafficking in Fisheries Indonesia, Laos, Malaysia, Office in Southeast Asia) Philippines, Singapore, Thailand, and Vietnam State/ Fostering a South American (SA) Network for South American Regional 5/2017 12/2018 750,000 TIP Knowledge Management (KM) on TIP Office Investigations and Prosecutions State/ Capacity Enhancement for institutionalized South Africa 6/2017 5/2020 500,000 TIP victim centered investigations and prosecutions Office of Trafficking in Persons (TIP) Cases in South Africa State/ Supporting Availability and Access to Iraq 8/2017 4/2019 690,630 TIP Specialized Services for Victims of Trafficking Office and Individuals At Risk State/ Strengthening Civil Society in Mauritania Mauritania 9/2014 2/2019 1,927,622 DRL State/ Aar Sunu Khaleyi (“Protect Our Children”) Senegal 8/2016 9/2018 693,069 DRL State/ Freedom, Rights and Justice: Combating Mauritania 8/2016 6/2019 1,675,594 DRL Descent-based Slavery in Mauritania State/ Combatting Hereditary Slavery and Forced Mali 9/2016 3/2018 693,069 DRL Child Labor in Mali DOL/ Consolidating and Disseminating Efforts to Brazil, Peru 12/2012 12/2018 6,800,000 ILAB/ Combat Forced Labor in Brazil and Peru OCFT Page 60 GAO-19-77 Human Trafficking Appendix II: Three Key U.S. Agencies’ Counter-trafficking in Persons Projects, Active in Fiscal Year 2017 Agency Project name Location(s) of project Start date of End date of Funding a project project amount (month and (month and (in dollars) year) year) DOL/ Randomized controlled trial impact evaluations Nepal, China 12/2014 12/2019 999,993 ILAB/ examining the effects of mass media campaigns on norms and behaviors related to OCFT vulnerability to forced labor and the worst forms of child labor in Nepal and China DOL/ Support for the Implementation of the Decent Uzbekistan 12/2014 12/2018 6,000,000 ILAB/ Work Country Programme in Uzbekistan OCFT DOL/ From Protocol to Practice: A Bridge to Global Global; priority in 9/2015 9/2019 14,395,138 ILAB/ Action on Forced Labor (The Bridge Project) Malaysia, Mauritania, Nepal, Niger, and Peru; OCFT limited activities in Thailand, the Dominican Republic, and Paraguay DOL/ Monitoring and Evaluation (M&E) Toolkit: Global 9/2016 8/2018 1,000,000 ILAB/ OCFT Sector-Specific Interventions and Cross- Cutting Themes OCFT DOL/ Measurement, Awareness-Raising, and Policy Global 12/2016 12/2020 1,500,000 ILAB/ Engagement (MAP 16) Project on Child Labor and Forced Labor in Support of Sustainable OCFT Development Goal Target 8.7 USAID Ushindi Democratic Republic of 7/2010 7/2017 783,000 Congo USAID Counter Trafficking in persons Program (CTIP) Nepal 7/2010 6/2017 10,177,548 USAID Reintegration for Trafficking Survivors Project Uzbekistan 3/2011 12/2017 1,279,683 USAID Livelihoods and Food Security Trust Fund Burma 9/2012 12/2019 661,500 (LIFT) USAID The Sajhedari Bikaas Partnership for Local Nepal 12/2012 5/2018 743,922 Development USAID The Association of Southeast Asian Nations Indonesia 9/2013 9/2018 214,000 (ASEAN)-US Partnership for Good Governance, Equitable and Sustainable Development and Security (PROGRESS) USAID Counter-trafficking in Persons-Belarus (IOM) Belarus 9/2013 9/2020 1,910,036 USAID Promoting Rule of Law Program (CTIP Burma 10/2013 9/2018 770,000 Component) USAID Philippine-American Fund Philippines 6/2014 9/2018 2,527,468 USAID Sustainable Fisheries Management Project Ghana 10/2014 10/2019 623,862 USAID Bangladesh Counter Trafficking-in-Persons Bangladesh 10/2014 11/2020 5,520,000 Program (BC/TIP) USAID Supply Unchained/International Labor Rights Thailand 6/2015 9/2017 150,000 Forum (ILRF) Page 61 GAO-19-77 Human Trafficking Appendix II: Three Key U.S. Agencies’ Counter-trafficking in Persons Projects, Active in Fiscal Year 2017 Agency Project name Location(s) of project Start date of End date of Funding a project project amount (month and (month and (in dollars) year) year) USAID Criminal Justice System Strengthening Project Dominican Republic 6/2015 6/2020 100,000 USAID Cambodia Countering Trafficking in Persons Cambodia 8/2015 9/2019 8,500,000 (CTIP) Program USAID Counter-trafficking in Persons - Azerbaijan Azberbaijan 9/2015 9/2018 600,000 (IOM) USAID Positive Life Alternatives for Egyptian Youth At- Egypt 9/2015 12/2018 2,071,465 Risk of Irregular Migration USAID Supply Unchained/GoodWeave India 10/2015 9/2017 250,000 USAID Reintegration and Prevention of Recruitment Colombia 10/2015 10/2018 1,800,000 USAID Dignity and Rights (IOM) Kazakhstan, Kyrgyzstan, 10/2015 9/2020 4,300,592 Tajikistan, Turkmenistan, Uzbekistan. USAID USAID Mali Justice Project Mali 12/2015 12/2018 100,000 USAID Combatting Human Trafficking in Afghanistan Afghanistan 1/2016 1/2019 7,098,717 (CTIP) USAID Youth and Gender Justice Project Guatemala 5/2016 2/2021 2,250,000 USAID Impact Evaluation for USAID/Cambodia Cambodia 6/2016 1/2020 684,972 Counter-Trafficking in Persons Activity USAID Stop Girl Trafficking Nepal 7/2016 7/2019 1,500,000 USAID The IOMX Campaign for the Prevention of Bangladesh 9/2016 9/2018 200,000 Human Trafficking and Exploitation Asia Pacific Region Phase II (For USAID/Regional Development Mission for Asia (RDMA)). IOM X Bangladesh Roadshow (For USAID/Bangladesh) USAID Migrant and Refugee Human Rights Project Macedonia 9/2016 3/2018 673,301 (Macedonian Young Lawyers Association) USAID USAID Asia CTIP Asia-Pacific region 12/2016 12/2021 10,524,278 USAID Improving knowledge, enforcement and Rwanda 1/2017 1/2019 1,360,000 coordination in counter-trafficking USAID Growing in Peace Project Guatemala 3/2017 3/2019 69,646 USAID Hamro Samman Nepal 7/2017 7/2022 2,765,270 USAID Reducing Vulnerabilities to Human Trafficking Burma 8/2017 12/2018 650,000 USAID Enabling Communities and Stakeholders to Burma 9/2017 1/2019 350,000 Proactively Address Forced Labour USAID Municipal Partnerships for Violence Prevention Dominican Republic 9/2017 9/2019 100,000 in Central America and the Dominican Republic Page 62 GAO-19-77 Human Trafficking Appendix II: Three Key U.S. Agencies’ Counter-trafficking in Persons Projects, Active in Fiscal Year 2017 Agency Project name Location(s) of project Start date of End date of Funding a project project amount (month and (month and (in dollars) year) year) USAID USAID Thailand CTIP Thailand 9/2017 9/2022 6,487,799 USAID USAID Laos CTIP Laos 9/2017 9/2022 1,500,001 Legend: State/TIP Office = State’s Office to Monitor and Combat Trafficking in Persons; State/DRL = State’s Bureau of Democracy, Human Rights, and Labor; DOL/ILAB/OCFT = DOL’s Bureau of International Labor Affairs’ Office of Child Labor, Forced Labor, and Human Trafficking; USAID/DRG = USAID’s Center of Excellence on Democracy, Human Rights and Governance. Source: GAO analysis of the information provided by the Departments of State and Labor, and the U.S. Agency for International Development. | GAO-19-77 a Funding amounts for the counter-trafficking in persons projects were provided by each agency in response to our request for funding information. However, the agencies used different methods for collecting and reporting the funding data, which limited our ability to combine funding information across agencies. State’s reported funding consists of total award amounts for projects that focused on counter-trafficking in persons. DOL also reported total award amounts for projects that focused on counter-trafficking in persons, and estimated award amounts for the counter-trafficking in persons component of the total award amounts for projects that did not focus on counter-trafficking in persons. USAID’s reported funding consists of total award amounts for counter-trafficking in persons standalone projects, in which the sole focus of the project was to combat trafficking in persons. However, for USAID’s integrated projects in which counter-trafficking in persons efforts make up a component of the overall project, USAID reported on the commitment of its funds specifically for counter-trafficking in persons activities, which consists of obligated amounts plus committed amount. Page 63 GAO-19-77 Human Trafficking Appendix III: State Documentation for Its Appendix III: State Documentation for Its Performance Monitoring Activities for 37 Counter-Trafficking in Persons Projects Performance Monitoring Activities for 37 Counter-Trafficking in Persons Projects The Department of State (State) did not fully document its monitoring activities (monitoring plan; fiscal year 2017 quarterly progress reports; and final progress report, including indicators and targets, for projects that ended as of December 2017) for 16 of the 37 selected projects we reviewed with start dates between fiscal years 2011 to 2016. 1 (See table 5.) For example, State’s Office to Monitor and Combat Trafficking in Persons did not have monitoring plans for nine projects or targets for each indicator in six of seven final progress reports for projects that ended as of December 2017. 2 1 Federal standards for internal control call for agency management to design monitoring activities so that all transactions are completely and accurately recorded. See GAO, Standards for Internal Control in the Federal Government, GAO-14-704G (Washington, D.C.: Sept. 2014), and Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: Nov. 1999). 2 Our prior work on performance measurement identified 10 key attributes of performance measures—such as having a measurable target—that GAO has found are key to successfully measuring a project’s performance. For example, our prior work has shown that numerical targets or other measurable values facilitate future assessments of whether overall goals and objectives are achieved because comparisons can be easily made between projected performance and actual results. See GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002), p. 45, for a description of how we developed the attributes of effective performance goals and measures. See GAO, Defense Health Care Reform: Additional Implementation Details Would Increase Transparency of DOD’s Plans and Enhance Accountability, GAO-14-49 (Washington, D.C.: Nov. 6, 2013), p. 17, for a description of why the baseline measure was added as an attribute of effective performance measures. See also GPRA Performance Reports, GAO/GGD-96-66R (Washington, D.C.: Feb. 14, 1996); Missile Defense: Opportunity to Refocus on Strengthening Acquisition Management, GAO-13-432 (Washington, D.C.: Apr. 26, 2013); Performance Measurement and Evaluation: Definitions and Relationships, GAO-11-646SP (Washington, D.C.: May 2011); and Agency Performance Plans: Examples of Practices That Can Improve Usefulness to Decisionmakers, GAO/GGD/AIMD-99-69 (Washington, D.C.: Feb. 26, 1999). Page 64 GAO-19-77 Human Trafficking Appendix III: State Documentation for Its Performance Monitoring Activities for 37 Counter-Trafficking in Persons Projects Table 5: Extent to Which Department of State Documented Performance Monitoring Activities for 37 Selected Counter- Trafficking in Persons Projects Monitoring Q1 FY17 Q2 FY17 Q3 FY17 Q4 FY17 Final Indicators and plan progress progress progress progress progress targets in final report report report report report at end progress a a of project report Project #1 ● ● ● ● ● ● ● Project #2 ● ● ● ● ● n/a n/a Project #3 ● ● ● ● ● n/a n/a Project #4 ● ● ● ● ● n/a n/a Project #5 ● ● ● ● ● n/a n/a Project #6 ● ● ● ● ● n/a n/a Project #7 ● ● ● ● ● n/a n/a Project #8 ● ● ● ● ● n/a n/a Project #9 ● ● ● ● ● n/a n/a Project #10 ● ● ● ● ● n/a n/a Project #11 ● ● ● ● ● n/a n/a Project #12 ● ● ● ● ● n/a n/a Project #13 ● ● ● ● ● n/a n/a Project #14 ● ● ● ● ● n/a n/a Project #15 ● ● ● ● ● n/a n/a Project #16 ● ● ● ● ● n/a n/a Project #17 ● ● ● ● ● n/a n/a Project #18 ● ● ● ● ● n/a n/a Project #19 ● ● ● ● ● n/a n/a Project #20 ● ● ● ● ● n/a n/a Project #21 ● ● ● ● ● n/a n/a Project #22 ○ ● ● ● ● n/a n/a Project #23 ○ ● ● ● ● n/a n/a Project #24 ○ ● ● ● ● n/a n/a Project #25 ○ ● ● ● ● n/a n/a Project #26 ○ ● ● ● ● n/a n/a Project #27 ○ ● ● ● ● n/a n/a Project #28 ○ ● ● ● ● n/a n/a Project #29 ○ ● ● ● ● n/a n/a Project #30 ○ ● ● ● ● n/a n/a Project #31 ● ◒ ● ● ● n/a n/a Project #32 ● ◒ ● ● ● ● ◒ Project #33 ● ◒ ● ○ ◒ ● ◒ Page 65 GAO-19-77 Human Trafficking Appendix III: State Documentation for Its Performance Monitoring Activities for 37 Counter-Trafficking in Persons Projects Monitoring Q1 FY17 Q2 FY17 Q3 FY17 Q4 FY17 Final Indicators and plan progress progress progress progress progress targets in final report report report report report at end progress a a of project report Project #34 ● ● ● ● ● ● ◒ Project #35 ● ● ● ● ● ● ◒ Project #36 ● ● ● ● ● ● ◒ Project #37 ● ● ● ● ● ● ◒ Legend: Q = quarter; FY = fiscal year; n/a = not applicable because project was ongoing as of December 2017. ● = fully documented, ◒ = partially documented, ○ = not documented. Source: GAO analysis of Department of State (State) documents. | GAO-19-77 a We reviewed the final progress reports for the 7 of 37 projects that ended as of December 2017. (The remaining 30 projects continued after December 2017.) Page 66 GAO-19-77 Human Trafficking Appendix IV: Comments from the Appendix IV: Comments from the Department of State Department of State Page 67 GAO-19-77 Human Trafficking Appendix IV: Comments from the Department of State Page 68 GAO-19-77 Human Trafficking Appendix IV: Comments from the Department of State Page 69 GAO-19-77 Human Trafficking Appendix V: Comments from the U.S. Appendix V: Comments from the U.S. Agency for International Development Agency for International Development Note: GAO comments supplementing those in the report text appear at the end of this appendix. Page 70 GAO-19-77 Human Trafficking Appendix V: Comments from the U.S. Agency for International Development Page 71 GAO-19-77 Human Trafficking Appendix V: Comments from the U.S. Agency for International Development Page 72 GAO-19-77 Human Trafficking Appendix V: Comments from the U.S. Agency for International Development See comment 1. See comment 2. See comment 3. See comment 4. Page 73 GAO-19-77 Human Trafficking Appendix V: Comments from the U.S. Agency for International Development Page 74 GAO-19-77 Human Trafficking Appendix V: Comments from the U.S. Agency for International Development 1. USAID commented that it does not believe that our draft report GAO Comments reflected the existing controls the USAID mission in Ghana shared with us, and that the mission had furnished us with a file that, according to USAID, contained correct information for all indicators and their results from the time the activity began until our audit. While the mission provided us with a spreadsheet, this document included only annual performance totals for several years without accompanying quarterly totals, or quarterly or annual narrative information. We focused our analysis on the quarterly and annual performance reports to understand the extent to which USAID was ensuring the consistency and completeness of performance information, including associated narratives, underlying its aggregate and higher-level performance reports. We reported on inconsistent or incomplete performance information only after discussing and substantiating the specific errors we identified with USAID officials. Further, we recognize USAID’s efforts to address errors that the agency identified prior to our review and we provide an example of such efforts in the report. 2. We have incorporated USAID’s comment. Our report no longer characterizes USAID’s regular activity monitoring and conversations with implementing partners as “informal.” 3. USAID noted that our report does not discuss how the USAID mission in Ghana uses its third-party monitoring project—Monitoring, Evaluation and Technical Support Services (METSS)—to work with local organizations to improve their collection and analysis of data. We have added a reference to USAID’s third-party monitoring project to the report where we discussed limited capacity of local partners as a cause of data reliability issues. 4. USAID commented that one of the Ghana counter-trafficking in persons indicators we examined in the integrated project (“value of new private sector investments in selected value-chains”), was not related to trafficking in persons and, therefore, was not directly related to the focus of our audit. As discussed in the Objectives, Scope, and Methodology section of our report (see app. I), we selected projects, including the integrated project in Ghana, based on a list of counter- trafficking in persons projects provided by USAID. Because the same operational policy that sets the monitoring and evaluation standards Page 75 GAO-19-77 Human Trafficking Appendix V: Comments from the U.S. Agency for International Development for the agency applied to all indicators within a given project, 1 we examined available quarterly or semi-annual indicator data for all reported indicators in selected projects to determine the completeness and consistency of the data. We then conducted interviews with agency officials to discuss instances in which we identified potentially incomplete and inconsistent performance information, as well as whether our findings about the management of performance information for these selected projects reflected general agency policies and procedures. 1 United States Agency for International Development, ADS Chapter 201 Program Cycle Operational Policy (revised Oct. 5, 2017). Page 76 GAO-19-77 Human Trafficking Appendix VI: GAO Contact and Staff Appendix VI: GAO Contact and Staff Acknowledgments Acknowledgments Jennifer Grover, (202) 512-7141, or groverj@gao.gov GAO Contact In addition to the contact named above, Leslie Holen (Assistant Director), Staff Victoria Lin (Analyst-in-Charge), Esther Toledo, and Andrew Kurtzman Acknowledgments made key contributions to this report. The team benefited from the expert advice and assistance of Neil Doherty, Justin Fisher, Benjamin Licht, Grace Lui, and Aldo Salerno. Page 77 GAO-19-77 Human Trafficking Related GAO Products Related GAO Products Human Trafficking: State Has Made Improvements in Its Annual Report but Does Not Explicitly Explain Certain Tier Rankings or Changes, GAO-17-56 (Washington, D.C.: December 5, 2016). Human Trafficking: Oversight of Contractors’ Use of Foreign Workers in High-Risk Environments Needs to Be Strengthened. GAO-15-102 (Washington, D.C.: November 18, 2014). Human Trafficking: Monitoring and Evaluation of International Projects Are Limited, but Experts Suggest Improvements. GAO-07-1034 (Washington, D.C.: July 26, 2007). Human Trafficking: Better Data, Strategy, and Reporting Needed to Enhance U.S. Antitrafficking Efforts Abroad. GAO-06-825 (Washington, D.C.: July 18, 2006). (102348) Page 78 GAO-19-77 Human Trafficking The Government Accountability Office, the audit, evaluation, and investigative GAO’s Mission arm of Congress, exists to support Congress in meeting its constitutional responsibilities and to help improve the performance and accountability of the federal government for the American people. GAO examines the use of public funds; evaluates federal programs and policies; and provides analyses, recommendations, and other assistance to help Congress make informed oversight, policy, and funding decisions. GAO’s commitment to good government is reflected in its core values of accountability, integrity, and reliability. 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