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Document of The World Bank Report No: ICR2453 IMPLEMENTATION COMPLETION AND RESULTS REPORT (IDA-H5770) ON A GRANT IN THE AMOUNT OF SDR 2 MILLION (US$3 MILLION EQUIVALENT) TO THE UNION OF THE COMOROS FOR A ECONOMIC GOVERNANCE REFORM SUPPORT GRANT July 17, 2012 Poverty Reduction and Economic Management 1 Country Department AFCS4 Africa Region Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized
Transcript
Page 1: World Bank Document...ii (Exchange Rate Effective as of May 1st, 2012) Currency Unit = Comorian Franc (KMF) Euro 1.00 = KMF 492 AfDB African Development Bank CREF Economic and Financial

Document of The World Bank

Report No: ICR2453

IMPLEMENTATION COMPLETION AND RESULTS REPORT

(IDA-H5770)

ON A

GRANT

IN THE AMOUNT OF SDR 2 MILLION

(US$3 MILLION EQUIVALENT)

TO

THE UNION OF THE COMOROS

FOR A

ECONOMIC GOVERNANCE REFORM SUPPORT GRANT

July 17, 2012

Poverty Reduction and Economic Management 1

Country Department AFCS4

Africa Region

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ii

(Exchange Rate Effective as of May 1st, 2012)

Currency Unit = Comorian Franc (KMF)

Euro 1.00 = KMF 492

AfDB African Development Bank

CREF Economic and Financial Reforms Unit

DGCF Direction Générale du Contrôle Financier

DGTCP Direction Générale du Trésor et de la Comptabilité Publique

DPO Development Policy Operation

ECF Extended Credit Facility

EGRSG Economic Governance Reform Support Grant

EGTA Economic Governance Technical Assistance Project

EPCA Emergency Post-Conflict Assistance

EU European Union

GDP Gross Domestic Product

GISE Integrated civil service and wage management software

HACS High Authority of Civil Service

HIPC Highly Indebted Poor Countries

ICRR Implementation Completion and Results Report

IDA International Development Association

IDF Institutional Development Facility

IMF International Monetary Fund

ISN Interim Strategy Note

LICUS Low Income Countries Under Stress

LOFE Loi sur les Opérations Financières de l’État

MDRI Multilateral Debt Relief Initiative

MOF Ministère des Finances (Ministry of Finance)

PDO Project Development Objective

PEFA Public Expenditure and Financial Accountability

PFM Public Financial Management

PRGSP Poverty Reduction and Growth Strategy Paper

SDR Special Drawing Rights

TOFE Tableau des Opérations Financières de l’État

Vice President:

Country Director:

Sector Director:

Sector Manager:

Task Team Leader:

Makhtar Diop (AFRVP)

Haleh Bridi (AFCS4)

Marcelo Giugale (AFTPM)

John Panzer (AFTP1)

Noro Aina Andriamihaja (AFTP1)

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iii

UNION OF THE COMOROS

IMPLEMENTATION COMPLETION AND RESULT REPORT ON

THE ECONOMIC GOVERNANCE REFORM SUPPORT GRANT

CONTENTS

Data Sheet

A. Basic Information

B. Key Dates

C. Ratings Summary

D. Sector and Theme Codes

E. Bank Staff

F. Results Framework Analysis

G. Ratings of Program Performance in ISRs

H. Restructuring

A. Basic Information ...................................................................................................... iv B. Key Dates .................................................................................................................. iv

C. Ratings Summary ...................................................................................................... iv D. Sector and Theme Codes ............................................................................................ v

E. Bank Staff ................................................................................................................... v F. Results Framework Analysis ..................................................................................... vi

G. Ratings of Program Performance in ISRs ............................................................... viii H. Restructuring (if any) .............................................................................................. viii 1. Program Context, Development Objectives and Design ........................................ 1

2. Key Factors Affecting Implementation and Outcomes .......................................... 5 3. Assessment of Outcomes ...................................................................................... 11

4. Assessment of Risk to Development Outcome ..................................................... 14

5. Assessment of Bank and Borrower Performance ................................................. 15 6. Lessons Learned.................................................................................................... 16

7. Comments on Issues Raised by Borrower/Implementing Agencies/Partners....... 17 Annex 1: Bank Lending and Implementation Support/Supervision Processes ............ 18 Annex 2: Beneficiary Survey Results (if any) .............................................................. 19

Annex 3: Stakeholder Workshop Report and Results (if any) ...................................... 20

Annex 4: Summary of Borrower’s ICR and/or Comments on Draft ICR .................... 21

Annex 5: Comments of Cofinanciers and Other Partners/Stakeholders ....................... 22 Annex 6: Comoros Main Economic Indicators, 2009–14 ............................................ 23 Annex 7: List of Supporting Documents ...................................................................... 24 Country MAP ................................................................................................................ 25

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iv

DATA SHEET

A. Basic Information

Country: Comoros Program Name:

Economic Governance

and Reform Support

Grant

Program ID: P117229 L/C/TF Number(s): IDA-H5770

ICR Date: 07/17/2012 ICR Type: Core ICR

Lending Instrument: DPL Borrower: Union of the Comoros

Original Total

Commitment: XDR 2 M Disbursed Amount: XDR 1.99 M

Revised Amount: XDR 1.99 M

Implementing Agencies:

Ministry of Finance of the Union

Co-financiers and Other External Partners:

B. Key Dates

Process Date Process Original Date Revised / Actual

Date(s)

Concept

Review: 06/18/2009 Effectiveness: 10/12/2010 10/12/2010

Appraisal: 04/12/2010 Restructuring(s):

Approval: 06/01/2010 Mid-term

Review:

Closing: 06/30/2011 06/30/2011

C. Ratings Summary

C.1 Performance Rating by ICR

Outcomes: Moderately Satisfactory

Risk to Development Outcome: Significant

Bank Performance: Moderately Satisfactory

Borrower Performance: Moderately Satisfactory

C.2 Detailed Ratings of Bank and Borrower Performance (by ICR)

Bank Ratings Borrower Ratings

Quality at Entry: Moderately

Satisfactory Government:

Moderately

Satisfactory

Quality of

Supervision: Satisfactory

Implementing

Agency/Agencies:

Moderately

Satisfactory

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Overall Bank

Performance:

Moderately

Satisfactory Overall Borrower

Performance:

Moderately

Satisfactory

C.3 Quality at Entry and Implementation Performance Indicators

Implementation

Performance Indicators

QAG Assessments

(if any) Rating:

Potential Problem

Program at any time

(Yes/No):

No Quality at Entry

(QEA): None

Problem Program at

any time (Yes/No): No

Quality of

Supervision (QSA): None

DO rating before

Closing/Inactive status:

Moderately

Satisfactory

D. Sector and Theme Codes

Original Actual

Sector Code (as % of total Bank financing)

General Public administration 100 100

Theme Code (as % of total Bank financing)

Public expenditure, financial management and

procurement 70 70

Administrative and civil service reform 20 20

Other economic management 10 10

E. Bank Staff

Positions At ICR At Approval

Vice President: Makhtar Diop Obiageli Katryn Ezekwesili

Country Director: Haleh Bridi Johannes C.M. Zutt

Sector Manager: John Panzer Kathie Krumm

Lead Economist Alain d’Hoore Jacques Morisset

Task Team Leader: Noro Aina Andriamihaja Aurelien Kruse

ICR Team Leader: Noro Aina Andriamihaja

ICR Primary Author: Marcelo Andrade

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F. Results Framework Analysis

Program Development Objectives (from Project Appraisal Document)

The overarching objective of the operation was to strengthen Comoros’ transition from

fragility to resilience. It directly supported two of the country’s PRGSP six axes, namely

(i) axis one, on economic stabilization and equitable growth, emphasizing improvements

in government and fiscal operations; and (ii) axis three, on strengthening governance and

social cohesion, focusing on improvements in core personnel management systems. This

operation would contribute to one of the two objectives identified of the ISN FY10-12,

namely strengthen state capacity and accountability. It was complemented with a

technical assistance operation, the Economic Governance Technical Assistance Project,

approved on January 31, 2011.

Revised Program Development Objectives (if any, as approved by original approving

authority)

N/A

(a) PDO Indicator(s)1

Indicator Baseline Value

Original Target

Values (from

approval

documents)

Formally

Revised

Target

Values

Actual Value

Achieved at

Completion or

Target Years

Indicator 1: Timeliness of budget preparation and transparency of intergovernmental

relations

Value

(quantitative or

Qualitative)

(i) 2007 PEFA PI-8 on

transparency of

intergovernmental

relations rated C

(ii) 2007 PEFA PI-11

on organization and

participatory nature of

the budget preparation

process rated D+

(i) PEFA PI-8

rated as C+

(ii) PEFA PI-11

rated as C

n/a

Impact of reforms

on PEFA scores to

be assessed during

the 2012 PEFA

assessment,

scheduled to take

place in the third

quarter of 2012.

Date achieved 10/01/2007 12/31/2011 June 14, 2012

Comments

(incl. %

achievement)

The National Assembly approved the Budgets for 2011 and 2012 before the

beginning of the respective fiscal year. The Public Financial Management Law

(Loi des Operations Financières de l’État - LOFE) was approved by the

National Assembly on June 14, 2012. The new law modernizes the PFM legal

framework, including in aspects that deal with budget preparation and

intergovernmental relations.

1 Guidance on the criteria for Public Expenditure and Financial Accountability (PEFA) Framework Performance Indicators ratings is

provided on the website www.pefa.org.

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Indicator Baseline Value

Original Target

Values (from

approval

documents)

Formally

Revised

Target

Values

Actual Value

Achieved at

Completion or

Target Years

Indicator 2 : Timely production and public availability of historical budget execution

data

Value

(quantitative or

Qualitative)

(i) 2007 PEFA PI-4

on arrears monitoring

and accumulation

rated D

(ii) 2007 PEFA PI-10

on public access to

budgetary

information rated D

(i) PEFA PI-4

rated C

(ii) PEFA PI-10

rated C

n/a

Impact of reforms

on PEFA scores

to be assessed

during the 2012

PEFA assessment,

scheduled to take

place in the third

quarter of 2012.

Date achieved 10/01/2007 12/31/2011 May 23, 2012

Comments

(incl. %

achievement)

Publication of quarterly budget execution reports began at end of last

quarter of 2011. The first quarter of 2012 report has also been issued.

Quality of these reports is limited, as social expenditures are not

reported. Also, comparison to the budget is not possible for main

administrative headings. The reports have not been made available to the

public. Change in net domestic arrears (excluding the float) represented

an estimated 5.5 percent and 3.5 percent of GDP in 2010 and 2011,

respectively.

Indicator 3 : Progress on implementation of the PFM Action Plan

Value

(quantitative or

Qualitative)

(i) 2007 PEFA PI-5

on budget

classification rated C

(ii) 2007 PEFA PIs-

6&7 on budget

exhaustivity rated C

(iii) 2007 PEFA PI-

21 on the efficiency

of budget controls

rated D

(i) PEFA PI-5 on

rated C+

(ii) PEFA PIs-

6&7 rated C+

(iii) PEFA PI-21

rated D+

n/a

Impact of reforms

on PEFA scores

to be assessed

during the 2012

PEFA assessment,

scheduled to take

place in the third

quarter of 2012.

Date achieved 10/01/2007 12/31/2011 May 23, 2012

Comments

(incl. %

achievement)

PFM Action Plan implementation progressed well after June 2011. From

late 2011 to May 2012, the National Assembly approved: (i) legislation

on ministry personnel frameworks (organigram and staffing plans); and

(ii) the law adopting a new public procurement code consistent with

COMESA. Moreover, (iii) in February, the President approved the

decree to reform the Treasury and Public Accounting areas, (iv) in April,

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the Council of Ministers approved a draft decree to establish the General

Directorate of Financial Control (Direction Générale du Contrôle

Financier), and (v) in May, the President approved the decree creating

the Autorité de Régulation des Marchés Publics and defining other

important public procurement reform implementation issues.

Indicator 4 : Automatisation of payroll

Value

(quantitative or

Qualitative)

(i) 2007 PEFA PI-18

on the efficiency of

payroll controls rated

D

(i) PEFA PI-18

rated C n/a

Impact of reforms

on PEFA scores

to be assessed

during the 2012

PEFA assessment,

scheduled to take

place in the third

quarter of 2012.

Date achieved 10/01/2007 12/31/2011 May 23, 2012

Comments

(incl. %

achievement)

From July 2011 to March 2012, most of civil service salaries were

processed by the newly installed computerized system - GISE. The

fieldwork of a civil service census was completed in October 2011, but

cleaning up of the GISE personnel database is taking longer than

expected. The final list of civil servants is planned to be completed by

end-June 2012.

Indicator 5 : Share of new recruitments into the civil service made following a

competitive selection managed by the Civil Service High Authority

Value

(quantitative or

Qualitative)

N.A. 90 % n/a Not met.

Date achieved 04/05/2010

(Appraisal) 12/31/2011 May 23, 2012

Comments

(incl. %

achievement)

Occasionally, recruitment of “A” level staff at Union level followed

competitive procedures. Competitive procedures not followed at Island

level, where an important share of that recruitment takes place.

G. Ratings of Program Performance in ISRs

No. Date ISR

Archived DO IP

Actual

Disbursements

(USD millions)

1 05/10/2011 Moderately Satisfactory Moderately Satisfactory 3.13

H. Restructuring (if any)

Not Applicable

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1. Program Context, Development Objectives and Design

1.1 Context at Appraisal

1. The Union of Comoros is emerging from a long period of political instability. Since its

independence in 1975, the country has suffered 21 coups and coup attempts and the main source of

the conflict has historically been the sharing of power and resources between the three islands.

Successive regimes were unable to establish strong state institutions and attempts at building political

consensus have led to overlapping layers of decision-making mechanisms and bureaucracy leading to

administrative inefficiencies. In April 2006, democratic elections resulted in the country’s first

peaceful transfer of power. Resolution of the political crisis between the separatist island of Anjouan

and the Union in 2008, followed by passage of the May 2009 Constitutional Amendment presented

an opportunity to put the country back on a path of robust and sustained growth. The Constitutional

amendment aimed at streamlining the federal administration and enhancing central government

authority over budget and economic management.

2. The country is in

debt distress. With an average growth rate of 1.7 percent over the period 2005-09 and a population

growth of about 2.4 percent, growth has not been sufficient to reduce poverty. In 2004, the latest year

for which data was available, about 45 percent of the population lived below the poverty line, with

poverty incidence varying significantly across regions and being generally higher in rural areas and

on the island of Anjouan. Over the last two decades, the country has accumulated an unsustainable

level of public and publicly guaranteed external debt, estimated at US$285.9 million in nominal

terms at end-2009, which corresponds to US$213.6 in Net Present Value (NPV) terms and is

equivalent to about 45 percent of Gross Domestic Product (GDP), 330.6 percent of exports and 320.7

of fiscal revenues.

3. Comoros’ Poverty Reduction and Growth Strategy Paper (PRGSP) was officially

adopted on September 10, 2009. This strategy, resulting from a thorough and inclusive participatory

process, concentrates on the following six axes: (i) stabilizing the economy and laying the

groundwork for strong and equitable growth; (ii) strengthening key sectors by focusing on institution-

building and ensuring a broader role for the private sector; (iii) strengthening governance and social

cohesion; (iv) improving the health status of the general public; (v) promoting education and

vocational training; and (vi) promoting environmental sustainability and civilian security.

4. Since 2009, the donor community has substantially increased its support to Comoros.

This trend aimed at supporting increased political stabilization and the Union government’s

commitment to undertake a sound macroeconomic and structural reform policy agenda. Bilateral and

multilateral partners have provided substantial budget support in 2009 and 2010 and expressed

willingness to support the Government’s reform efforts in subsequent years. Also, the International

Monetary Fund (IMF) approved a Three-Year arrangement under the Extended Credit Facility

(ECF)2 on September 16, 2009 following the satisfactory performance under the Emergency Post-

Conflict Assistance-supported program. Given measured progress on political and economic reforms,

a Preliminary HIPC Document was discussed by the Bank’s Board of Directors on April 8, 2010.

2 The Extended Credit Facility has replaced the Poverty Reduction and Growth Facility (PRGF).

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5. The Board reviewed an Interim Strategy Note (ISN) for the period FY10-12 on June 1,

2010, jointly with the operation under review. It outlines a strategy to facilitate the implementation

of the country’s PRGSP and is structured around two objectives: (i) reducing social vulnerability, and

(ii) strengthening state capacity and accountability. To support consolidation of recently achieved

gains with respect to political stability and economic management, key ISN interventions in support

of the second objective included two development policy operations (DPOs), including the Economic

Governance Reform Support Grant (EGRSG) under review. The Bank’s strategy also aims at

supporting Comoros to achieve debt relief through the Highly Indebted Poor Countries Initiative

(HIPC) and Multilateral Debt Relief Initiative (MDRI). Implementation of the country’s reform

program, including those supported by this operation, was also to be supported by an Economic

Governance Technical Assistance (EGTA) Project that was approved on January 31, 2011.

1.2 Original Program Development Objectives (PDO) and Key Indicators (as approved)

6. The overarching objective of the operation under review was to strengthen Comoros’

transition from fragility to resilience. It directly supported two of the country’s PRGSP six axes,

namely (i) axis one, on economic stabilization and equitable growth, emphasizing improvements in

government and fiscal operations; and (ii) axis three, on strengthening governance and social

cohesion, focusing on improvements in core personnel management systems. This operation was

originally expected to be the first of a programmatic series of two DPOs. However, due to politically

related delays in the implementation of the reform process, and a delay in the completion of the 3rd

review under the IMF Enhanced Credit Facility (ECF) program, the planned second operation has

lapsed and this DPO ended up being a stand alone operation.

7. There were five prior actions and their impact was to be measured against a set of five

expected outcome indicators. Three of these indicators focused on public financial management

measures aimed at improving timeliness of budget preparation and transparency of intergovernmental

relations, timely production and public availability of historical budget execution data, and progress

on implementation of the 2010-12 PFM Action Plan. The remaining two indicators focused on

strengthening public sector efficiency and accountability aimed at improving wage bill management

and deployment of civil service human resources, respectively. Monitoring of the expected outcomes

indicators on PFM and wage bill management have largely drawn on selected 2007 PEFA

Performance Indicators to identify the baseline and target improvements to be confirmed by a new

PEFA assessment planned for the second half of 2012, after closure of the originally anticipated

second DPO.

1.3 Revised PDO

8. PDOs and result indicators remained unchanged during program implementation.

1.4 Original Policy Areas Supported by the Program (as approved)

9. The program supported reforms that are critical in helping the government stabilize the

economy, achieving equitable and robust growth over the medium and long-term and

improving governance, all central themes of the country’s PRGSP. The EGRSG reforms focus on

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two broad policy areas: (i) improving public financial management, primarily in areas of budget

preparation and execution, and (ii) strengthening public sector efficiency and accountability,

particularly improvements in core personnel management systems.

Improving Public Financial Management

10. The 2007 Public Expenditure and Financial Accountability (PEFA) assessment

concluded that the performance of Comoros’ public financial management (PFM) system

remains extremely weak. In 22 out of 28 PEFA performance indicators, the 2007 assessment rated

the country at the lowest possible score - D. Another five PEFA indicators were rated at C and only

one was rated A (the indicator comparing aggregated expenditure out-turn to original approved

budget). The assessment highlighted weaknesses at all levels of the PFM system from formal

institutions and procedures to actual implementation and processes.

11. The Constitutional Amendment approved by popular referendum on May 17, 2009

requires agreement on a revised and implementable legal and institutional framework of public

finances. The 2009 Constitutional changes reasserted some core federal fiscal competencies and to

cement national reconciliation it is imperative to define a clear fiscal framework for

intergovernmental division of labor and responsibilities. This was to be achieved in a phased

approach to allow time for solutions to be worked out and consensus to be reached among all

stakeholders. First, unlike in the past when the budget preparation process was the mere consolidation

of four separate exercises, the 2010 budget was consolidated through a participatory preparation

process in support of collective policy goals and involving relevant stakeholders (prior action 1).

Subsequently, the preparation of the new organic law governing the budget framework (Loi sur les

Operations Financières de l’État - LOFE) adapted to Comoros’ unique institutional setup should take

place. In this context, a new budget preparation calendar taking into account budget discussions at

island level should be defined and the outdated 2001 rigid revenue sharing formula should be

reviewed. An indicator of progress on this front, and a trigger for the Bank’s possible additional

budget support, is preparation of this new fiscal regulatory framework involving all interested parties

prior to submission for approval.

12. Budget execution reporting and accountability were slightly improved. Since late 2004, a

Budgetary Committee was set up to coordinate budget preparation and execution. After an

interruption due to the 2007 and 2008 political tensions, the Budgetary Committee resumed

operations providing key budget data for policy makers and donors. An outcome of the Budgetary

Committee meetings has been the compilation and validation of consolidated fiscal data from the four

entities and preparation of an updated TOFE (Table of Government’s Financial Operations). In this

context, quarterly budget execution reports were prepared for each of the four quarters of FY2009

(prior action 2). Further progress in this area and a trigger for the Bank’s possible next DPO,

focuses on ensuring that in-year budget execution reports are released on a quarterly basis by the

Budgetary Committee, incorporate basic information on social spending and are publicly disclosed.

13. The government adopted a PFM Action Plan for 2010-12 to support implementation of a

comprehensive PFM strategy for the coming decade (2010-2019). The strategy is structured

around four pillars: (i) modernizing the legislative and regulatory framework and strengthening

institutional capacity; (ii) rationalizing budget preparation; (iii) strengthening budget execution; and

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(iv) increasing transparency through improved internal and external controls. The strategy and first

three-year action plan address key structural weaknesses in the expenditure chain, public procurement

and fiduciary controls, is broadly endorsed by donors and provides a platform for donor support and

coordination. The Government’s commitment to PFM Strategy and Action Plan implementation was

demonstrated by the appointment of a focal point (CREF – Economic and Financial Reforms Unit)

tasked with responsibility for implementing the plan and reporting on progress (prior action 3).

Additional progress in this area, and a trigger for the Bank’s continued budget support, is to be

assessed by actual implementation of the first three-year plan demonstrating improved capacity in the

areas of budget organization and internal and external controls.

Strengthening Public Sector Efficiency and Accountability

14. Comoros’ civil service wage bill constitutes a serious burden on the Government’s

limited resources. This is the outcome of a disorderly process of decentralization agreed in 2001 to

resolve tensions between the Union and the islands. Basically, most central administrative entities

were simply duplicated in each autonomous island (with the Union and each island having a

President, cabinet and National Assembly). The civil service roster doubled to about 12,000 in the

period 1999 to 2008 and the wage bill increased from 6.2 percent to 9 percent of GDP. In 2009, civil

service wages and salary expenditures claimed about 65 percent of domestic revenues. Not

surprisingly, roles and responsibilities became blurred; wage arrears accumulated, staff morale

plummeted and poor quality services were provided to the population.

15. Renewed reform efforts should focus on improving the public administration’s

effectiveness and bringing the wage bill down to fiscally sustainable levels. Preliminary reforms

launched in 2005 stalled in 2007 due to the collapse of the Union-island cooperation. Later in 2008, a

new law of civil service was adopted providing for the setting up of a High Authority of Civil Service

(HACS) responsible for organizing the competitive selection process prior to all recruitments and for

managing the personnel roster of all civil service entities. In recent years, HACS has updated and

computerized the civil service roster for the Union and islands and contracted the development of

GISE - an integrated civil service and wage management software (prior action 4). Evidence that the

software is being used to manage civil service will measure future progress in this area and be a

trigger for continued development policy lending.

16. The HACS is operational, but much remains to be done. Centralized personnel

management units have been established in the finance administrations. A vast review of the existing

organizational structures of each administration was completed in April 2010 and the authorities have

established a Commission to start preparing a plan to reform the public administration. Now, the

HACS has the de jure responsibility for overseeing the competitive process leading to new

recruitments into the civil service of all level “A” civil servants (prior action 5). Further progress in

this policy area will require (i) that the HACS fully exercises its authority to lay the foundation of a

new meritocratic civil service, (ii) completion of a physical census of public employees to eliminate

“ghost” workers and validate the computerized database, and (iii) official adoption of the organic

frameworks of the various Comorian administrations, at Union and Island levels. A trigger for

continuation of the Bank’s budget support will be the systematic public disclosure (newspaper with

national coverage) of the lists of admitted candidates (ranked by order of merit) to competitive

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examination for entry into the civil service. This aims at ensuring that any deviations from the

suggested ranking are subject to public scrutiny.

1.5 Revised Policy Areas.

17. The policy areas were not revised during program implementation.

1.6 Other significant changes

18. There were no changes in design, scope and scale, implementation arrangements and

schedule, and funding allocations of this operation.

2. Key Factors Affecting Implementation and Outcomes

2.1 Program Performance

19. The program was supported by a single tranche operation3. The EGRSG approval was

subject to the implementation of five prior actions (see Box below). All prior actions were

satisfactorily met before the Board considered the operation. The grant was approved on June 1, 2010,

became effective on October 12, 2010 and closed on June 30, 2011.

Box 1: EGRSG Prior Actions

3 This operation was originally expected to be the first of a programmatic series of two DPOs. However, due to the slowness of the reforms and the

delay in implementation of the IMF program, the planned second operation has lapsed and the two operations had to be de-linked.

A. Strengthening public financial management

Prior action 1. The Recipient has prepared a consolidated budget for FY 2010, using a participatory

process involving all concerned stakeholders.

Prior action 2. The Budgetary Committee has met regularly on a quarterly basis during FY2009, and

produced budget execution reports for each of the four quarters of FY2009.

Prior action 3. The Recipient has taken initial steps for the implementation of the PFM strategy and

action plan, through the establishment of a focal point to be responsible for the implementation of the

plan and monitor progress.

B. Strengthening public sector efficiency and accountability

Prior action 4. The Recipient has developed and automated payroll system for the management of the

wage bill in of civil service.

Prior action 5. The Recipient has taken steps to reaffirm the pre-eminent role of HACS in the

recruitment of level A‘ civil servants, through the issuance of an administrative circular reminding

concerned ministries and agencies that no such recruitment can be undertaken otherwise than on the

basis of the outcome of a competitive selection process, responsibility for which vests exclusively in

HACS.

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20. Since 2009, encouraging progress has been achieved on economic reforms. In spite of a

difficult international environment and severe capacity and institutional constraints, the country

adopted a full-PRGSP in September 2009 and established a broadly satisfactory track record of

policy performance under IMF-supported programs. Progress achieved, helped Comoros to reach the

HIPC Decision Point on June 29, 2010 paving the way for achievement of the HIPC Completion

Point as early as the end of 2012.

21. During 2009 and 2010, a gradual move to better macroeconomic management has

allowed Comoros to weather the adverse impacts of domestic and external shocks. A renewed

commitment to macroeconomic stabilization and structural reforms resulted in modest but

encouraging developments, against the background of protracted fragility in domestic political

developments and the global financial crisis. The fiscal outturn remained broadly stable in 2009 and

improved in 2010 with the domestic primary fiscal deficit being reduced from 2.7 percent of GDP in

2008, to 2.6 percent in 2009 and 1.6 percent in 2010, respectively. Revenue collection was generally

consistent with projections, reflecting initial reform efforts to improve customs and tax administration,

including its enhanced computerization. At times, weakened focus or delays on tax and customs

administration reforms and difficulties in bringing the wage bill under control posed challenges, but

spending cuts on goods and services allowed the 2009 and 2010 targets on the domestic primary

fiscal deficit to be largely met.

22. A weak fiscal performance in the context of the December 2010 elections was reversed

by strong corrective measures in late 2011. Renewed political tensions in mid-2010 and the

subsequent long period until a new administration took charge in mid-2011 had a clear adverse but

temporary impact on fiscal management. Delays in tax revenue collection and increases in

expenditure, including a sizable public sector pay raise in late 2010, contributed to slippage in the

ECF program later in 2010 and during the first half of 2011, and a delay in the completion of the third

and fourth ECF reviews. Fiscal performance strengthened significantly during the second half of

2011, with restrained wage spending following the reversal of the 2010 public pay raise, stepped-up

tax arrears recovery, and strong one-off nontax receipts. The domestic primary budget deficit

(excluding one-off non-tax receipts) was limited to 1.4 percent of GDP and all wage arrears

accumulated in the earlier months of 2011 were cleared by end-year.

23. On the fiscal structural reform front, while uneven, substantial progress has been made

in implementing selected reforms supported by the EGRSG following the renewed impetus

since later in 2011. During the volatile 12-months period up to mid-2011, the loss of reform impetus

impacted adversely progress on structural reforms. However, since later in 2011 commitment to

reforms supported by the EGRSG has gained momentum. A draft organic law on the budget

framework (Loi sur les Operations Financières de l’État - LOFE) has been prepared, with support of

technical assistance recruited under the EGTA, after a consultative process involving the President of

the Comoros, representatives of autonomous islands, and key senior civil servants of public

administrations. On March 28, 2012, this draft law was adopted by the Council of Ministers and on

June 14, 2012 was approved by the National Assembly. In parallel with the Budget 2012, the

National Assembly approved legislation on ministry personnel frameworks (organigram and staffing

plans). Measures to strengthen public expenditure management included the publication of quarterly

budget execution reports, which began at end of last quarter of 2011. The first quarter 2012 report has

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also been issued. However, data on social sectors spending has yet to be reported and the reports have

not been disclosed to the public.

24. Moreover, implementation of the PFM Action Plan for 2010-12 has progressed well.4

The Budget Laws for 2011 and 2012 were approved before the beginning of the fiscal year,

demonstrating improved capacity in the area of budget organization. In February 2012, the National

Assembly approved a law adopting a new public procurement code consistent with COMESA

(Common Market for Eastern and Southern Africa). Also, on May 31, 2012, the President approved

the decree creating the Autorité de Régulation des Marchés Publics and defining other important

public procurement reform implementation issues. On February 29, 2012, the President approved the

decree to proceed with reform of the Treasury and Public Accounting areas and, shortly, is expected

to approve the decree to establish the General Directorate of Financial Control (Direction Générale

du Contrôle Financier) laying the foundation for improved internal budget controls. The latter was

already adopted by the Council of Ministers in April 2012. Moreover, from July 2011 to March 2012,

most of civil service salaries were processed by the newly installed GISE – civil service payroll

computerized system. In this regard, the fieldwork of a civil service census was completed in October

2011, but cleaning up of the GISE personnel database is taking longer than expected. Currently, the

plan is to complete the final list of civil servants by end-June 2012. As for the competitive

recruitment of the civil service for category “A” and systematically publication of the lists of

admitted candidates, ranked by order of merit, in a newspaper with national coverage little progress

has been made. At the Union level, the procedure was occasionally followed, but at the Island level it

was not. Given that an important share of recruitment takes place at the Island level, it is unlikely that

the 90 percent target spelled out in the Program Development Objectives Indicators has been met.

2.2 Major Factors Affecting Implementation

Adequacy of government’s commitment

25. After the 12-months volatile period through mid-2011, the Government renewed its

commitment to maintain macroeconomic stability and advance structural reforms in priority

policy areas. Following the bold decision of the Constitutional Court, on May 8, 2010, to rebuke

President’s Sambi attempt to extend his term beyond the initial limit of May 2010, rising political

tensions started to ease. The African Union mediation led to presidential elections and the elections

of Governors of the islands in December 2010. The political transition ended when the new President

was sworn into office in May 2011. Nevertheless, the long election and transition period weakened

the focus on reforms delaying their implementation and leading to slippage in the reform program in

the first half of 2011. However, by implementing strong corrective measures, the new administration

appointed in June 2011 considerably improved macroeconomic performance and accelerated

structural reforms (see paragraphs 23 and 24).

4 Reforms of the Treasury, Public Accounting and Financial Control areas and those related to the computerization of the civil service payroll have been

supported by the EGTA project, including its PPF.

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Soundness of the background analysis

26. The rationale for and focus of the DPO is spelled out in the Bank’s FY10-12 ISN. It

highlights the country’s (i) “gradual reformer” status within the Bank’s typology of fragile states, and

(ii) planned eligibility to assistance under the HIPC Initiative.5 The ISN stresses that governance has

been a persistent problem in Comoros, which ranks low on the quality of its budgetary and financial

management systems and the quality of public administration.6 The ISN identified strengthening state

capacity and accountability as one of the Bank’s two objectives to assist Comoros. The key

interventions to support this objective, are (i) two DPOs planned for FY10 and FY12, to assist the

government to focus on the right priorities; and (ii) an Economic Governance TA project, to proceed

alongside with the DPOs to build up capacity for reform implementation. This approach, coordinated

with other donor budget support, aimed at helping the country to build the track record needed to

become eligible to significant debt relief under the HIPC Initiative.

27. The EGRSG design has appropriately drawn on available country analytical work,

which fed into the formulation of the operation’s prior actions and expected results. The

country’s macroeconomic performance and planned policies have been assessed in the context of

joint Bank-IMF missions since 2009. In the PFM area, a thorough diagnostic of the strengths and

weaknesses of the public financial management system was provided by the diagnostic and dialogue

supported by trust funded (LICUS and IDF) technical assistance in 2006 and 2008, respectively, as

well as by the EU-funded 2007 PEFA assessment. With regard to civil service reform, the policy

dialogue benefited from a 2001 World Bank-financed study on the civil service composition and

wage profile, complemented by a 2005 diagnostic of the civil service wage bill and EGTA-funded

(under the Project Preparation Facility) recent analytical and material support to the development of

an integrated civil service management software. Finally, lessons learned by the Bank from DPO’s in

fragile environments as well as application of “Good Practice Principles for Conditionality” were

usefully incorporated into this DPO’s design. With regard to the former, a key lesson emerging from

DPO’s in fragile states is the importance of strengthening the budget process. Successful DPOs in

fragile states have helped government’s consolidate their budget systems and processes enabling

them to be used as a framework for policy and operational decision-making. This DPO has focused

on politically-feasible reforms that built momentum for changes, with a particular emphasis on

restoring and strengthening basic state functions—notably with respect to civil service and public

expenditure management.

Assessment of the operation’s design

28. The limited scope of reforms supported by this DPO was appropriate. As indicated in the

ISN, the purpose of the operation was to address a limited set of key policy reforms in two areas:

public financial management and public sector efficiency and accountability. The country’s growth

and poverty reduction strategy identifies these areas as being central to stabilize the economy and lay

the foundation to eligibility to significant debt relief under the HIPC Initiative. Also, this DPO

approach to pursue the gradual deepening of reforms was consistent with the country’s weak capacity

and fragile political environment. In addition, the reduced number of institutional counterparts,

5 World Bank (2005) Good Practice Note for Development Policy Lending: Development Policy Operations and Program Conditionality in Fragile

States. 6 The ISN indicates that in 2008, the country’s CPIA governance score averaged 2.2 (out of 6) compared with an African average of 3.0 and an IDA average of 3.1.

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Ministry of Finance of the Union and High Authority of Civil Service, simplified the design of the

operation. Finally, support by the Bank’s Economic Governance Technical Assistance (EGTA)

Project, as well as other donors’ capacity building initiatives, has proven to be critical in advancing

the reform agenda (e.g. computerization of payroll, civil service census, and budget management and

reporting).

Relevance of the risks identified at appraisal and effectiveness of mitigation measures

29. Risks were well identified in the Program Document, but could not be fully mitigated

(see Table 1). This resulted in an uneven implementation of reforms, with most progress being made

after June 2011.

Table 1: EGRSG - Anticipated Risks and Mitigating Factors

Risk Mitigating Factors

Political risk from stalling of reforms due to

renewed Union-island political tensions.

This risk did materialize. Renewed political

tensions emerged when President Sambi

attempted to extend his term beyond May 2010.

As anticipated in the DPO, the international

community pro-active involvement was key in

the easing of tensions. Mediation by the African

Union led to presidential elections in December

2010. The newly elected President was sworn in

May 2011 and installed his administration in

June 2011. However, the long political

transition had a clear adverse but temporary

impact on fiscal management.

Macroeconomic risk from inability of the

Government to adhere to the macroeconomic

framework due to (i) fiscal slippages, (ii)

accumulation of new arrears, and/or (ii) further

deterioration of the external environment –

through terms of trade shocks or fading

remittances.

This risk did materialize. The Government’s

weak fiscal performance in the context of the

December 2010 elections was further

exacerbated by the adverse impact of

international fuel and rice price pressures.

Strong corrective revenue and expenditure

measures in late 2011 were supported by close

economic and policy monitoring, notably by the

IMF and the Bank.

Implementation capacity risk from extremely

weak capacity.

Budget support with parallel technical

assistance and policy advice by IDA and other

donors has been instrumental in mitigating this

risk.

Fiduciary risk associated with weak national

fiduciary systems.

The Government’s Action Plan for PFM and

reforms supported by budget support are

contributing to the gradual improvement of

fiduciary standards.

Political economy risk due to lack of political

buy-in to reforms

Focus on few key reform areas and a gradual

reform process aligned with the objective of

achieving significant debt relief contributed to

marshal the country’s broad support.

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2.3 Monitoring and Evaluation (M&E) Design, Implementation and Utilization:

M&E design

30. Targets with specific indicators were identified for each prior action (Annex 2). The

PEFA assessment of 2007 provided a baseline for most of the policy areas. The PEFA planned for

2012 would provide a detailed evaluation of the set of 9 PEFA indicators chosen to track progress on

DPO-supported reforms aimed at improving the PFM system and overall financial accountability.

31. With the support of its development partners, the country is building up its M&E

capacity. The authorities are strengthening and developing their capacities to design, implement,

monitor, and evaluate their development and poverty reduction strategies. In particular, the European

Commission is supporting strengthening the capacity of the Commissariat General for Planning,

responsible in particular for aid coordination and poverty reduction strategy monitoring and

evaluation. AfDB is focusing on strengthening statistical capacity.

M&E implementation and utilization

32. The Ministry of Finance of the Union, with support from the Directorate of Planning,

was responsible for monitoring reforms, reporting progress and coordinating actions among other

public entities, including at the island level. The first Annual Progress Report on PRGSP

implementation was completed in mid-2011. The Government was also expected to appoint a

committee, responsible for steering and following up on reforms and the implementation of the PFM

Action Plan. In this regard, the authorities established CREF – Economic and Financial Reforms Unit

- that has been instrumental in moving forward the reform agenda.

33. The 2012 PEFA assessment will soon be launched. The operation under review was

originally expected to be the first of a programmatic series of two DPOs. In the politically difficult

context of the late 2010 elections, slower than expected implementation of reforms and slippages in

macroeconomic performance resulted in a considerable delay in launching the preparation of the

second DPO. The identification of the new operation has taken place in May 2012. Because the

planned second DPO has lapsed, the two DPOs had to be de-linked and preparation of this DPO’s

ICR has been accelerated and cannot benefit from the findings of the upcoming PEFA assessment.

The 2012 PEFA assessment, while taking place somewhat later than initially anticipated, will be

conducted in the third quarter of 2012.7

2.4 Expected Next Phase/Follow-up Operation

34. The EGRSG identified prior actions for a possible next operation by IDA (Box 2). In

anticipation of a follow-up DPO, the EGRSG identified a set of five reform measures to be

considered for possible future budget support from IDA. Overall, substantial progress has been made

in the implementation of those actions (see paragraphs 23 and 24). While prior actions 1 and 3 have

7 If the country’s performance would have justified processing the second DPO during the second half of 2011, the two DPOs would have been linked

and the respective single ICR could have benefited from findings of the soon to be launched PEFA assessment.

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been met, prior actions 2 and 4 have been substantially met. Prior action 5 was not met.

Box 2: Prior Actions for the Follow Up Operation

3. Assessment of Outcomes

3.1 Relevance of Objectives, Design and Implementation

35. The operation under review was and continues to be highly relevant to current country

and global priorities, and the Bank’s assistance strategy to Comoros. It was designed to support

implementation of the Government’s development strategy spelled out in its 2009 PRGSP and

endorsed by the new Government appointed in mid-2011. By focusing on macro-economic stability,

strengthening governance through PFM and Public sector reforms and laying the foundations for

eligibility to debt relief under the HIPC Initiative, the operation was and continues to be highly

relevant to global priorities and the Bank’s FY10-12 ISN and goals in fragile states. The operation

design appropriately targeted a limited number of prior actions and was framed as part of a concerted

multi-donor effort. Substantial progress on reforms supported by this operation is a key first step for

achieving the country and the Bank objectives stated in the PRGSP and ISN, respectively.

3.2 Achievement of Program Development Objectives

36. PDO Achievements: substantial progress has been made on 4 of the 5 PDO areas, as

summarized in Table 2, below. In spite of reported progress, in the case of 4 PDO indicators, a new

PEFA is not available to measure achievement of the respective targets. These were indicators

relating to PFM, and included: (i) timeliness of budget preparation and transparency of

intergovernmental relations; (ii) timely production and public availability of historical budget

execution data; (iii) progress on implementation of the PFM Action Plan; and (iv) automatisation of

the payroll. As for indicator 5, it has not been met.

A. Strengthening public financial management

Prior action 1. A draft organic law on the budget framework is prepared and discussed in a national

workshop prior to submission for approval.

Prior action 2. Quarterly reports are published on public website or newspaper with national coverage

and include basic information on social sectors.

Prior action 3. The government implements the first tri-annual PFM action plan 2010-12 demonstrating

improved capacity for budget organization and strengthened internal and external controls.

B. Strengthening public sector efficiency and accountability

Prior action 4. The system is operationalized to manage civil service human resources and payroll.

Prior action 5. The lists of admitted candidates (ranked by order of merit) to competitive examinations

for entry into the civil service for category “A” are systematically published in a newspaper with national

coverage.

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Table 2: Anticipated and actual outcomes of the EGRSG

Anticipated Result Actual Outcome

Indicator 1. Timeliness of budget preparation and

transparency of intergovernmental relations.

The National Assembly approved the Budgets for 2011 and

2012 before the beginning of the respective fiscal year. The

Public Financial Management Law (Loi des Operations

Financières de l’État - LOFE) was approved on June 14, 2012.

The new law modernizes the PFM legal framework, including

in aspects that deal with budget preparation and

intergovernmental relations.

Indicator 2. Timely production and public

availability of historical budget execution data

Publication of quarterly budget execution reports began at end

of last quarter of 2011. The first quarter of 2012 report has also

been issued. Quality of these reports is limited, as social

expenditures are not reported. Also, comparison to the budget

is not possible for main administrative headings. The reports

have not been made available to the public. Change in net

domestic arrears (excluding the float) represented an

estimated 5.5 percent and 3.5 percent of GDP in 2010

and 2011, respectively.

Indicator 3. Progress on the implementation of the

PFM Action Plan

From late 2011 to May 2012, the National Assembly approved:

(i) legislation on ministry personnel frameworks (organigram

and staffing plans); and (ii) the law adopting a new public

procurement code consistent with COMESA. Moreover, (iii) in

February, the President approved the decree to reform the

Treasury and Public Accounting areas, (iv) in April, the

Council of Ministers approved a draft decree to establish the

General Directorate of Financial Control (Direction Générale

du Contrôle Financier), and (v) in May, the President

approved the decree creating the Autorité de Régulation des

Marchés Publics and defining other important public

procurement reform implementation issues.

Indicator 4. Automatisation of payroll

From July 2011 to March 2012, most of civil service salaries

were processed by the newly installed computerized system -

GISE. The fieldwork of a civil service census was completed

in October 2011, but cleaning up of the GISE personnel

database is taking longer than expected. The final list of civil

servants is planned to be completed by end-June 2012.

Indicator 5. Share of new recruitments into the civil

service made following a competitive selection

managed by the Civil Service High Authority.

Competitive recruitment of the civil service for category “A”

occasionally followed at the Union level, but not at the Island

level. The latter represents an important share of total

recruitment of category ”A”. The 90 percent target for

coverage is unlikely to have been met.

37. Following improved performance since late 2011, the third review of the IMF-supported

ECF has been completed in June 2012. Economic growth is edging up with real GDP growth

continuing to accelerate from 1.8 percent in 2009, to 2.2 percent in 2011 and being projected at 2.5

percent in 2012 (Annex 6). Growth has been mainly driven by the favorable performance of the

agricultural sector, robust remittances and associated housing construction, and a modest recovery in

foreign direct investment. Despite favorable agricultural food production, average inflation

accelerated markedly to 6.8 percent in 2011, reflecting the rise of world food and oil prices and the

sizable rise in public sector wages in late 2010. Inflation has since subsided and is projected at 5.6

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percent in the current year. On the fiscal front, following slippages in the ECF program late in 2010

and the first half of 2011, fiscal performance strengthened significantly later in 2011. On the external

front, the current account deficit widened due to higher commodity prices and FDI-financed imports.

38. Overall, good progress has been made in the implementation of the HIPC Completion

Point (HIPC CP) triggers. A recent staff assessment, reports that to date, 14 out of 16 HIPC CP

triggers are on track for timely delivery, of which 6 have already been met. As a result, Comoros is

well positioned to reach the completion point later in 2012.

3.3 Justification of Overall Outcome Rating (combining relevance, achievement of PDOs):

39. The operation is rated moderately satisfactory, given that (i) the development objectives

were highly relevant to the country’s challenging circumstances and development priorities and

reflect the Bank’s strategy as outlined in the FY10-12 ISN and goals in fragile states; and (ii) most of

the operations’ development objectives were substantially met (see Table 2). However, compliance

with some reforms identified as prior actions for a follow up DPO fell short of expectations, namely:

(i) lack of public disclosure of budget execution reports, (ii) lack of widespread use of competitive

procedures to recruit staff at “A” level and disclosure to the public of their ranking, and (iii) delay in

cleaning up the GISE personnel database on the basis of the 2011 census. Also, the loss of reform

momentum from mid-2010 to mid-2011 delayed progress on macroeconomic and structural reforms.

3.4 Overarching Themes, Other Outcomes and Impacts (if any, where not previously covered or

to amplify discussion above):

(a) Poverty Impacts, Gender Aspects, and Social Development

40. The operation under review is expected to have a positive poverty reduction and social

impact over the medium-term. Improved fiscal and public sector management resulting from the

policy reforms supported by this DPO is expected to increase the fiscal space for social expenditures.

Improved PFM and public sector management is likely to benefit the public at large, and particularly

the poor, by (i) reducing leakages, namely through improved management of the wage bill, (ii)

ensuring better value for money of public expenditures through tightened controls over procurement

of goods and services, (iii) strengthening the focus on poverty reducing expenditures, and (iv)

stepping up the role of internal and external controls of public expenditures. By helping to pave the

way to significant debt relief under the HIPC Initiative, this operation further contributes to

increasing the fiscal space for pro-poor expenditures.

41. Comoros medium-term growth outlook is moderately favorable with real GDP growth

expected to allow for modest increases in GDP per capita. In fact, after strengthening moderately

from an estimated 2.2 percent in 2011 to 2.5 percent in 2012, real GDP is expected to accelerate to 4

percent in 2014, driven by continued macroeconomic stability, sustained housing and public

infrastructure construction related to robust remittances and projects financed by donors, and stronger

performance in the agricultural sector based on favorable international prices and additional

investment.

42. Reforms to improve wage bill management and civil service deployment might generate

adverse impacts within the civil service ranks. Nevertheless, the public at large is likely to respond

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positively to steps taken to make the civil service system more effective. Civil servants in Comoros

are among the better off within the population, as shown by an analysis of household expenditure

levels by socio-economic categories from the latest household consumption survey.

(b) Institutional Change/Strengthening

43. The operation under review was instrumental in laying the foundations for wide-ranging

institutional reforms in public financial management. Ongoing PFM reforms focused on the

modernization of the legal and regulatory framework to align country practices to good PFM

international practices. In the area of public sector efficiency and accountability, the implementation

of GISE is an important achievement, but cleaning up of the GISE personnel is key to complete

another significant change.

(c) Other Unintended Outcomes and Impacts (positive and negative)

44. Not applicable.

3.5 Summary of Findings of Beneficiary Survey and/or Stakeholder Workshops

45. Not applicable.

4. Assessment of Risk to Development Outcome

46. The risk to development outcomes is significant. Continued political stability remains the

key factor for sustaining the momentum for reforms that underpin the country’s positive growth and

poverty reduction prospects for the foreseeable future. While the absence of major elections in the

near future might contribute to ease tensions, addressing the root causes – sharing of power and of

resources between the three islands - of continued political instability during most of the time since

independence in 1975 continues to be a high priority. The positive impact on growth and poverty

reduction of some of the reforms that have been adopted, and the prospect of considerable debt relief

under the HIPC Initiative, might contribute to mitigate the underlying socio-political risks.

47. Careful management of the political economy of reform is required. Substantial reform,

particularly in strategic areas such as PFM and civil service, in weak governance environments such

as Comoros, come with non-negligible political economy risks especially if tangible benefits of

reforms do not become apparent to the population, or if costs of reform to narrow constituencies

become too high. In this regard, recent political economy analysis of civil service reform suggests

that greater public debate and open negotiation between the Union and Islands governments is

necessary to sustain reforms. The recent census of the civil service revealed that far more recruitment

of civil servants has taken place than previously estimated, especially within Island governments.

Moreover, the current fiscal decentralization framework, which allows each Island government to

control recruitment, necessitates close coordination and active participation in decisions related to

management of the wage bill by entities at the Union and Island levels.

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5. Assessment of Bank and Borrower Performance

5.1 Bank Performance

(a) Bank Performance in Ensuring Quality at Entry

48. Bank performance in ensuring quality at entry of the EGRSG is rated as moderately

satisfactory. As discussed in Section 3.1 above, the operation was highly relevant to the country and

the Bank priorities given that reforms agreed with the Government were adequately aligned with the

country’s own Poverty Reduction and Growth Strategy and with priorities highlighted in the Bank’s

FY10-12 ISN, prepared in parallel with the operation under review. The EGRSG identification and

appraisal has appropriately drawn on available analytical work on Comoros and the Bank’s lessons

from DPO’s in fragile states, particularly with regard to the importance of strengthening the budget

process (see paragraph 27). The Bank team worked closely with the Government teams and

coordinated preparation and appraisal of the operation with other donors (most notably the IMF, the

AfDB, the EU and France). In this context, while the IMF played a major role in discussing the

macroeconomic medium term framework, the Bank led the dialogue in the area of public financial

management and public sector reform. Moreover, technical assistance recruited under the EGTA

project proved to be key to assist the authorities to implement important PFM reforms supported by

this DPO. However, the link between the broad heading of Indicator 2 and the PEFA performance

indicators (PIs) used to measure it is not clear. For example, PEFA PIs 22, 24 and 25 might have

been better indicators of timely production of budget execution data than PI-4. Moreover, consistency

between heading of Indicator 3 and the PEFA PIs selected to measure progress could also have been

better. In this regard, EGTA targeted PEFA PI 2 as a PDO result indicator, instead of PIs 5, 6, 7 and

21. Also, the excessive reliance on a new PEFA assessment to measure achievement of several PDO

indicators seems to have been risky at the outset, given the country’s history of recurrent political

volatility. Finally, it would have been useful to plan for keeping a record on implementation of PFM

and civil service reforms and tangible outcome improvements through periodic Government reports,

supported by this DPO and possibly by other donors’ budget support.

(b) Quality of Supervision

49. Bank supervision performance is rated satisfactory. Given the complementarities between

the operation under review and the Economic Governance Technical Assistance (EGTA) project,

regular technical follow-up by Bank staff of the EGTA project was key to assess progress under the

PFM Action Plan and Civil Service reform, greatly contributing to monitor progress of EGRSG-

supported reforms. Supervision of progress made under this operation took place in March 2011, in

parallel with supervision of the EGTA project, and contributed to step up reform efforts in some areas

(e.g. computerization of civil service payroll and civil service census). Moreover, supervision was

also conducted during joint missions with the IMF to monitor macroeconomic developments and

progress towards the HIPC CP. Also, the absence of a Bank country liaison office did not allow the

degree of handholding that would be advisable, given the low implementation capacity of Comoros

ministries.

(c) Justification of Rating for Overall Bank Performance

50. As Bank performance for both quality at entry and supervision is rated moderately

satisfactory and satisfactory, respectively, overall Bank performance is rated moderately

satisfactory in accordance with the ICRR harmonized evaluation criteria guidelines.

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5.2 Borrower Performance8

(a) Government Performance: (see Overall Borrower Performance)

(b) Implementing Agency or Agencies Performance: (see Overall Borrower Performance)

(c) Justification of Rating for Overall Borrower Performance

51. The Government’s overall performance for the EGRSG is rated as moderately

satisfactory. Considerable progress was made towards improving public finance management and

public sector accountability and efficiency given the country’s difficult initial conditions and the

unfavorable international environment. However, the implementation of some reforms fell below

expectations (see paragraph 39). Moreover, the authorities did no address macroeconomic

management issues on a timely basis, later in 2010 and during the first half of 2011. Only the strong

efforts of the administration that took over in June 2011, allowed bringing the program back on track

by end-March 2012. M&E strengthening and its use for evidence-based decision making is a

medium-term goal being pursued with donor support. Fiduciary risks continue to be high as the

internal and external control environment of the use of public resources have yet to be fully

operational. The relationship and coordination with the Bank and other donors was satisfactory and

stakeholders were consulted, particularly at the time of PRGSP formulation.

6. Lessons Learned

52. Technical assistance complementary to budget support was, and continues to be, key to

building the Government capacity to implement reforms. In assessing this operation

achievements, it is clear that a substantial share of the reform program was achieved due to the

Government capacity to draw on extensive technical assistance provided by the Bank (EGTA project)

and other donors (AfDB, EU, IMF and France) to prepare and implement reforms.

53. It is important to push for core institutional reforms in fragile states. This DPO focuses

on key reforms on state capacity and institutional building through the focus on public finance and

civil service management. Reforms in Comoros are politically, economically and technically difficult

to implement. Moreover, the costs of reforms are significant and gains are slow to come. However,

the Bank’s coordinated action with other donors and the IMF helped the authorities to make

commendable improvements on civil service and PFM practices, even if later than initially expected.

54. Excessive reliance on future PEFA reports to evaluate DPO targets might be

counterproductive. Fragile states are typically open to unexpected political developments that can

delay the pace of reforms. Moreover, PEFA assessments are demanding both in terms of costs and

burden placed on the Government. Therefore, caution must be exercised in the use PEFA indicators

to assess DPOs targets. Selecting as targets specific element(s) of a PEFA indicator might be a more

realistic strategy.

8 According to the ICRR Guidelines, if Government and the implementation agency are indistinguishable, particularly for DPL operations, only an

overall rating is necessary.

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7. Comments on Issues Raised by Borrower/Implementing Agencies/Partners

(a) Borrower/Implementing Agencies:

55. The government of the Union of the Comoros has sent a letter to the Bank on July 12, 2012

with their comments on the ICR. The government’s comments are summarized in Annex 4.

(b) Cofinanciers:

N/A

(c) Other partners and stakeholders (e.g. NGOs/private sector/civil society):

N/A

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Annex 1: Bank Lending and Implementation Support/Supervision Processes

(a) Task Team members

(b) Staff Time and Cost (from SAP)

Stage

Staff Time and Cost (Bank Budget Only)

No. of Staff Weeks US$ Thousands

(including travel and consultant costs)

Lending

Total 0.00

Supervision/ICR9

Total 0.00

9 Supervision was conducted in parallel with the Economic Governance Technical Assistance Project, with costs charged to the latter. As for the ICR,

costs were charged to the DPO currently being prepared (PE-P122941-LEN-BB).

Name Title Unit

Lending (from Task Team in Program Document)

Johannes Zutt Country Director AFCE2

Kathie Krumm Sector Manager AFTP2

Aurelien Kruse Task Team Leader AFTP2

Wolfgang Fengler Lead Economist AFTP2

Charles Coste Consultant AFTFM

Roger Sullivan Consultant AFTP2

Raj Soopramanien Lead Counsel LEGAF

Luis Schwarz Sr. Finance Officer CTRFC

Javier Suarez Sr. Economist AFTFE

Johannes Widmann Country Officer AFCKE

Supervision (from Task Team Members in all archived ISRs)

John Panzer Sector Manager AFTP1

Jacques Morisset Lead Economist AFTP1

Aurelien Kruse Economist, TTL AFTP1

Anne Khatimba Program Assistant AFCE2

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Annex 2: Beneficiary Survey Results (if any)

N/A

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Annex 3: Stakeholder Workshop Report and Results (if any)

N/A

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Annex 4: Summary of Borrower’s ICR and/or Comments on Draft ICR

Positive feedback was received from the Borrower. Below is a summary of the letter from the

government dated on July 12, 2012.

Overall, the implementation of financial support for good economic governance has effectively

contributed to the reforms needed in the context of improving good economic governance and

particularly the monitoring of HIPC triggers. The choice of two out of six PRSP axes correctly

reflects the aspirations of the government to ameliorate macroeconomic stability and good

governance. Essentially, there are no major differences between the assessment conducted by the

Bank and the government.

However, the government regrets that the assessment of the PEFA indicators remains those of 2007

while many reforms have been well implemented.

The government therefore took the opportunity of the ICR exercise to renew their unwavering

commitment to intensify the implementation of future reforms, namely in taking into account the

CPIA components and process.

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Annex 5: Comments of Cofinanciers and Other Partners/Stakeholders

N/A

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Annex 6: Comoros Main Economic Indicators, 2009–14 (Percent of GDP, unless otherwise specified)

2009 2010 2011E 2012P 2013P 2014P

National Income and Prices

Real GDP growth (% change) 1.8 2.1 2.2 2.5 3.5 4.0

Inflation (% change, annual average) 4.8 3.9 6.8 5.6 3.1 2.1

Public Finance

Domestic Revenue (excl. grants) 1/ 13.9 14.3 16.1 14.0 14.4 14.8

Total expenditures (incl. net lending) 23.0 22.1 22.1 24.7 25.0 25.2

Domestic primary balance -2.6 -1.6 1.6 -1.1 -0.9 -0.5

Overall balance (incl. grants, cash) 0.8 0.9 -1.9 0.1 -1.6 -2.0

Financing gap 0.0 0.0 0.0 0.0 1.9 2.9

External Sector

Imports of goods and services 47.7 50.5 51.8 51.6 49.3 47.2

Exports of goods and services 14.5 15.6 15.3 15.7 16.0 16.3

Current account balance -7.8 -7.0 -9.5 -10.4 -9.6 -9.0 Gross reserves (months of imports) 6.8 6.3 6.4 6.2 6.2 6.1 External debt External debt, NPV 2/ 46.2 38.9 32.0 33.3 32.0 31.2 External debt service (% of exports) 13.5 19.5 5.4 6.4 8.7 9.7

Source: IMF and World Bank staff estimates.

E – Estimated; P-Projected. 1/Revenue for 2011 includes one-off nontax receipts (about 3 percent of GDP)

2/External debt ratios before traditional debt relief.

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Annex 7: List of Supporting Documents

1. World Bank, Program Document for the Economic Governance Reform Support Grant, Report

No.54335-KM, May 3, 2010

2. World Bank, Aide-Memoire, Economic Governance Technical Assistance Project Supervision, March

29-April 2, 2011

3. World Bank, Comoros, Development Policy Grant (P117229), Implementation Status and Results

Report, May 10, 2011

4. World Bank, Comoros Economic Governance Reform Support Grant, Minutes of Negotiations, April

16-17, 2010

5. World Bank, Project Appraisal Document, Economic Governance Technical Assistance Project,

Report No. 56604-KM, December 28, 2010

6. World Bank, Aide-Memoire, Economic Governance Technical Assistance Project Supervision,

November 22 to December 10, 2011

7. World Bank, Economic Governance Technical Assistance Project, Implementation Status and Results

Report, January 1, 2012

8. World Bank, Aide-Memoire, Economic Governance Technical Assistance Project Supervision, March

15-31, 2012

9. IDA and IMF, Joint Staff Advisory Note, Union of the Comoros: Poverty Reduction Strategy Paper

10. Union of the Comoros, Enhanced Heavily Indebted Poor Countries (HIPC) Initiative, Decision Point

Document, IDA and IMF, June 7, 2010

11. World Bank, Interim Strategy Note for the Union of the Comoros For the Period FY10-12, Report No.

52522-KM, April 29, 2010

12. World Bank, Comoros Development Policy Loan, Program Information Document, Concept Stage,

Report No. AB4859, June 11, 2009

13. World Bank, Comoros Development Policy Loan, Program Information Document, Appraisal Stage,

Report No. AB5673, April 19, 2010

14. International Monetary Fund, IMF Country Report No. 11/72, Union of the Comoros, Article IV

Consultation and Second Review under the Extended Credit Facility, March 2011

15. European Union, Comores, Étude PEFA, Rapport Définitif, Octobre 2007

16. World Bank, BTOR: Joint ISN/DPO Mission, November 15-27, 2009

17. Union of the Comoros, Poverty Reduction and Growth Strategy Paper, September 2009

18. Projet des Renforcement des Capacités Institutionnelles (PRCI - Comores), Termes des Références

Spécifiques, pour la préparation, la modération et la présentation des résultats de la 2ème évaluation

PEFA de l’Union des Comores.

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BoboniBoboni

DembDembéénnKouraniKourani

MbMbéénini

KoimbaniKoimbani

SimaSima

N J A Z I D J A

M WA L I

N Z WA N I

DjomaniChézani

Itsikoudi

Chamoni

Boboni

Sidjou

Tsangadjou

Pidjani

Dembén

Chindini

Ntsaouéni

Hahaîa

Ikoni

Mitsoudjé

Kourani

Mitsamiouli

Mbéni

Koimbani

Foumbouni

Ntsoudjini

Bangoua Kouni

Hoani

Djoyézi

SambiaNioumachoua

Ouallah

Miringoni

Itsamia

Ziroudani

Hamavouna

Hagnamouda

Jimilimé

Bambao

Domoni

Mramani

Pomoni

Moya

Bimbini

Ouani

Sima

Hajoho

Salapouni

Fomboni

Mutsamudu

MORONI

Anjouan

GrandeComore

Magnougni

Mohel i

KanzoniOuénéfou

Méa

Chandzi

INDIAN OCEAN

Mozambique Channel

Le Kartala(2360 m)

Ntingi(1595 m)

11°30'S 11°30'S

12°00'S

43°30'E 44°00'E

43°30'E 44°00'E

44°30'E

44°30'E

12°00'S

COMOROS

This map was produced by the Map Design Unit of The World Bank. The boundaries, colors, denominations and any other informationshown on this map do not imply, on the part of The World BankGroup, any judgment on the legal status of any territory, or anyendorsement or acceptance of such boundaries.

0 5 10

0 5 10 15 Miles

15 Kilometers

IBRD 33389

DEC

EMBER 2004

COMOROSSELECTED CITIES AND TOWNS

ADMINISTRATIVE SEATS

NATIONAL CAPITAL

MAIN ROADS


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