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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(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)
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
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
v
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
vi
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.
vii
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,
viii
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
1
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).
2
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
3
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
4
(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
5
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.
6
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
7
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.
8
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.
9
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.
10
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.
11
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.
12
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
13
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
14
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.
15
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.
16
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.
17
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
18
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
19
Annex 2: Beneficiary Survey Results (if any)
N/A
20
Annex 3: Stakeholder Workshop Report and Results (if any)
N/A
21
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.
22
Annex 5: Comments of Cofinanciers and Other Partners/Stakeholders
N/A
23
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.
24
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.
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