China: Observations on Confucius Institutes in the United States and U.S. Universities in China

Numerous U.S. universities and colleges have partnered with Chinese entities to establish (1) Confucius Institutes in the United States and (2) degree-granting institutions in China. Confucius Institutes are partnerships between Chinese entities and schools in other countries, arranged and funded in part by Hanban, which seek to promote Chinese language and culture. There were 96 institutes located at colleges and universities in the United States as of January 2019. U.S. universities have also partnered with Chinese universities to establish degree-granting institutions in China approved by the Chinese government.

School officials have noted these types of partnerships provide valuable educational, cultural, and other benefits. Some researchers, government officials, and others, however, have raised concerns about them, including about the contents of written agreements and the role of the Chinese government, which, according to the Department of State, has made efforts to restrict academic freedom and impose censorship at Chinese universities and other institutions. Some have expressed concern that U.S. universities partnering with the Chinese government may face similar restrictions.

This testimony discusses funding, agreements, and operations of (1) Confucius Institutes in the United States and (2) U.S. universities in China. This testimony is based on GAO's February 2019 report on Confucius Institutes in the United States and GAO's August 2016 report on U.S. universities in China.

GAO reviewed 90 agreements establishing Confucius Institutes and spoke to officials about benefits and concerns related to the institutes. Agreements between Hanban—an affiliate of the Chinese Ministry of Education—and U.S. colleges and universities generally describe similar activities, funding, and management, though institute operations vary in practice. Confucius Institutes receive funding from Hanban and U.S. schools, and do not receive direct federal funding. While 42 of 90 agreements contained language about the document being confidential, some were available online or upon request, and one-third of the 90 agreements explicitly addressed how U.S. school policies apply to the institutes. Officials GAO interviewed at 10 case study schools noted U.S. school policies apply to institutes at their schools. GAO also interviewed some researchers and others who expressed concern that the presence of Confucius Institutes could constrain campus activities and classroom content. For example, several suggested schools with institutes might avoid hosting events on topics that could include criticism of China, such as Taiwan or Tibet, so as to not offend Chinese partners. School officials offered examples to illustrate that these concerns did not apply to their institute, noting institutes had sponsored events on such topics. Nonetheless, school officials and others suggested ways schools could improve institute management, such as renegotiating agreements to clarify U.S. schools' authority and making agreements publicly available.

In August 2016, GAO reported that U.S. universities that have partnered with Chinese universities to establish degree-granting institutions in China emphasize academic freedom, but face internet censorship and other challenges. The 12 U.S. universities GAO reviewed generally reported receiving support for their institutions in China from Chinese government entities and universities, and 5 reported receiving U.S. government funding, mostly federal financial aid to U.S. students. Universities' agreements with Chinese partners or other policies GAO reviewed generally included language protecting academic freedom or indicating their institution in China would adhere to U.S. standards. University members generally indicated that they experienced academic freedom, but also stated that internet censorship, self-censorship, and other factors presented constraints. At several universities that lacked uncensored internet access, faculty and students noted that, as a result, they faced challenges teaching, conducting research, and completing coursework at that time.

I am pleased to be here today to discuss GAO’s work on U.S-Chinese  higher education partnerships, including Confucius Institutes at U.S.  colleges and universities and U.S. universities that have partnered with  Chinese universities to establish degree-granting institutions in China.  These types of U.S.-Chinese higher education partnerships have been  the subject of public debate and discussion in recent years. Some have  noted that these partnerships can provide valuable educational and  cultural resources, such as Chinese language training that may otherwise  not be available, while also enhancing research opportunities. Others  have raised various concerns, such as about the contents and  confidentiality of written agreements between U.S. universities and  Chinese partners, and about the role or influence of Hanban, an affiliate  of the Chinese Government’s Ministry of Education, in these partnerships.  As the Department of State has reported, the Chinese government has  engaged in activities within China to restrict academic freedom and  impose censorship at Chinese universities. China has increased efforts to  monitor internet usage and control internet content, and has taken  measures to restrict freedoms of speech, religion, and assembly,  according to the Department of State. Some have expressed concern that  U.S. universities partnering with the Chinese government may face such  restrictions.

My testimony summarizes the findings from our February 2019 report on  Confucius Institutes in the United States, and our August 2016 report on  U.S. universities in China. Accordingly, this testimony discusses (1)  funding, agreements, and operations of Confucius Institutes in the United  States and (2) funding, agreements, and experiences of students and  faculty at U.S. universities in China.

To conduct the work for our review of Confucius Institutes in the United  States, we reviewed 90 agreements signed between U.S. schools and  Hanban to identify how these documents address issues such as funding,  activities, and management. We also interviewed stakeholders, including  school officials, researchers, and others to gather perspectives on the  institutes. Stakeholders interviewed included school administrators,  Confucius Institute directors, and faculty from a non-generalizable sample  of 10 case study schools; researchers and representatives from various  organizations involved in higher education issues; officials at several  schools that closed or ultimately declined to establish a Confucius  Institute; and officials from the Departments of Defense, Education, and  State. For our 2016 review of U.S. universities in China, we reviewed 12  U.S. universities that, at the time of our review, we identified as having  partnered with Chinese universities to establish degree-granting  institutions in China. We developed and administered a questionnaire  asking for information on funding and other topics, and obtained and  reviewed nine agreements between U.S. universities and their Chinese  partners, as well as student and faculty handbooks and other university  policies. In addition, we interviewed administrators from all 12  universities, and visited five universities in China, where we interviewed  administrators and faculty; conducted discussion groups with U.S. and  Chinese students; and reviewed facilities, services, and other aspects of  these institutions. We also interviewed officials from the Department of  Education. More information on our scope and methodology can be found  in these reports.

The work upon which this statement is based was conducted in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

Confucius Institutes are entities that seek to promote Chinese language  and culture in foreign countries. Their establishment is guided by Hanban,  which is headquartered in Beijing, China, and, according to various  sources, is affiliated with the Chinese government’s Ministry of Education.  The first Confucius Institute in the United States was established in 2004,  and there were approximately 525 institutes worldwide as of September  2018, according to Hanban’s website. Most Confucius Institutes in the  United States are based at colleges and universities. We identified 96  Confucius Institutes in operation at U.S. colleges and universities in 44  states and the District of Columbia as of January 2019. See our February  2019 report on Confucius Institutes for a full list of the schools and their  locations. Figure 1 shows U.S. states with one or more Confucius  Institute on college or university campuses.

Additionally, in recent years, some U.S. universities have partnered with  Chinese universities to establish degree-granting institutions in China  approved by the country’s government. The Chinese government requires  that U.S. universities seeking to establish such an education arrangement  in China partner with a Chinese university, and establish written  agreements with the Chinese university defining the academics,  governance, operations, finances, and other aspects of the arrangement.  At the time of our review in August 2016, the 12 institutions we reviewed  ranged from fewer than 40 to more than 3,000 students. More than 90  percent of the students across the 12 institutions were Chinese, and less  than 6 percent were U.S. citizens.

Confucius Institute Arrangements Vary Across Universities, and Stakeholders Have Identified Related Benefits, Concerns, and Suggestions for Improvement Confucius Institute Management, Operations, and Agreements Vary by School Management

In February 2019, we reported that Confucius Institutes in the United  States that we reviewed were established as a partnership between a  U.S. school and a Chinese college or university, funded and arranged in  part by Hanban. Management of the institutes varies by school. Some  Confucius Institutes at U.S. schools are part of an academic department  or an administrative office, while others report directly to the school  president or other school leadership. Confucius Institute personnel  generally consist of a Confucius Institute director or directors, Confucius  Institute teachers, and a board of directors. At the 10 case study schools  that were part of our review, the Confucius Institute director was a U.S.  school employee—either a school administrator, faculty member, or  professional hired to manage the Confucius Institute. In addition, several  case study schools had a Chinese assistant director, who reported to the  Confucius Institute director from the United States, and often was an  employee at the Chinese partner university.

School Officials, Researchers, and Others Identified Both Benefits and Concerns, and Suggested Ways to Improve Confucius Institutes Perspectives on Institute Benefits

In February 2019, we reported that officials we interviewed from case  study schools stated that Confucius Institutes’ benefits include  opportunities for schools to forge international connections and receive  funding and other resources for China-related programs. These officials  noted that because Hanban pays the salaries of Confucius Institute  teachers who teach language and assist with Chinese programs at  schools, sparing the schools these costs, these schools could offer  Chinese language courses even when enrollment was low. Case study  school officials also stated that Confucius Institutes provide valuable  resources and opportunities to increase knowledge of and exposure to  China and Chinese culture within the school and in the broader  community.

Perspectives on Concerns Related to Institutes

Case study school officials, researchers, and others we interviewed also  offered various perspectives on whether having Confucius Institutes on  campuses could bring about undue Chinese influence. These parties  discussed the potential for or absence of Chinese interference in events  and activities at the institute and on campus. They also expressed views  on Confucius Institute teacher hiring, and quality of those teachers.

Several school officials, researchers, and others we interviewed  expressed concerns that hosting a Confucius Institute could limit events  or activities critical of China—including events at the institute and  elsewhere on campus. Two officials who expressed these concerns were  faculty members at one case study school who have not applied for  Confucius Institute funding for a research project because they believed  Hanban would not approve of the topic. In contrast, officials at multiple  case study schools noted that U.S. school faculty members make all  decisions regarding conference themes, guest speakers, and topics for  events at their institute. Officials at some schools offered examples of  events and activities their Confucius Institute had sponsored that  addressed topics that could be considered critical of China. Specifically,  they reported hosting a conference discussing intellectual property in  relation to China and events on Tibet, territorial disputes in the South  China Sea, and religion in China.

In addition, multiple researchers and others we spoke with expressed  concerns with the Confucius Institute teacher selection process whereby  Hanban or the Chinese partner school accepts initial applications from  potential Confucius Institute teachers and proposes candidates to the  U.S. school. These individuals noted that the Chinese entities could use  such a process to effectively screen out candidates based on  inappropriate criteria, such as political or religious affiliation. Officials we  interviewed at multiple case study schools that had Confucius Institute  teachers, however, expressed no concerns about the process for hiring  teachers. School officials stated that they believed their school generally  controlled the hiring process and were thus satisfied with it. Most officials  emphasized that while institute teachers often come from the Chinese  partner university, and are referred by the partner or Hanban, the U.S.  school makes the final hiring selection.

Case study school officials, researchers, and others also suggested ways  to improve the institutes, including changing the language in agreements  governing Confucius Institutes and policies for sharing these agreements.  These parties stated that schools should remove the confidentiality  section of their agreements and make the agreements publicly available  online. Several researchers and others also emphasized that making the  agreements publicly available would dispel questions and concerns over  their contents. Several representatives of higher education institutions  told us that they believed the confidentiality language in agreements was  unnecessary and schools should consider removing it from their  agreements. A few case study school officials, researchers, and others  we interviewed stated that schools should include stronger language in  the agreements to make it clearer that the U.S. school has executive  decision-making authority.

School officials and others we interviewed suggested other steps that  schools could take to ensure they protect against undue Chinese  influence. Several school officials stated that the schools should clearly  delineate between the Confucius Institutes’ programs and their own  Chinese language programs, such as by locating the institute apart from  these departments within the school’s organizational structure. A few  school officials and others noted that Confucius Institute teachers should  not teach credit-bearing courses, even if those courses use curriculum  developed by the school’s language department. One school  administrator, who stated that his school’s Confucius Institute would  never have a Chinese assistant director because the position suggests an  excessive degree of Chinese influence, recommended that other schools  remove the Chinese assistant director position from their institutes.  Officials from two case study schools and others we interviewed stated  that schools should organize events through the institute specifically  intended to address what some might perceive as a topic sensitive to  Chinese interests to demonstrate the school and institute were not  subject to undue Chinese influence.

U.S. Universities in China Emphasized Academic Freedom but Faced Internet Censorship and Other Constraints

U.S. Universities Reported Receiving Support from Chinese Entities, with Limited U.S. Support

In August 2016, we reported that the 12 U.S. universities we reviewed  generally reported receiving support for their institutions in China from  their Chinese partner universities and from Chinese government entities,  with limited funding from U.S. government agencies and private donors.  Most universities reported being granted land, resources for construction  of buildings, and the use of the Chinese university’s campus facilities. The  amount of support reported by the universities varied widely and was in  some cases substantial. For example, one university reported receiving  nearly 500 acres of land and a commitment from the Chinese provincial  and local governments to spend about $240 million for construction and  development of facilities. Five of the 12 universities reported receiving  federal funding, which in most cases consisted of federal financial aid to  U.S. students.

Agreements between U.S. and Chinese Partners and Other Policies Generally Outlined Academic Freedom Protections

At the time of our review, most universities we reviewed included  language in their written agreements or other policies that either  embodied a protection of academic freedom or indicated that the  institution in China will adhere to academic standards commensurate with  those at their U.S. campus. Six universities in our review included  language in either their written agreements or other university policies  that indicated a protection of academic freedom, such as permitting  students to pursue research in relevant topics and allowing students to freely ask questions in the classroom. For example, one university’s  agreement stated that all members of and visitors to the institution in  China will have unlimited freedoms of expression and inquiry and will not  be restricted in the selection of research, lecture, or presentation topics.  Another three universities’ written agreements included language  indicating that the institution in China will adhere to academic standards  commensurate with either the U.S. campus or the university’s accrediting  agency or other authoritative bodies.

Fewer agreements addressed other types of protections at the time of our  review. About half of the universities GAO reviewed addressed access to  information, such as providing faculty and students with access to  physical or online libraries, though a few universities’ agreements and  policies include language protecting internet access. Written agreements  and policies for about half of the universities we reviewed included  language that suggested a protection of at least one of the freedoms of  speech, assembly, and religion or worship, though the number of  universities addressing each freedom varies. For example, regarding  freedom of speech, student and faculty handbooks at a few of these  universities contained language indicating that students have the ability to  discuss sensitive topics. Regarding freedom of religion or worship,  several of the universities included language in their policy documents  indicating that religious practices will be protected.

U.S. University Members Generally Indicated They Experienced Academic Freedom, but Internet Censorship and Other Factors Posed Challenges

The more than 130 faculty and students we interviewed from universities’  institutions in China during our 2016 review generally reported that  academic freedom had not been restricted. Faculty told us they did not  face academic restrictions and could teach or study whatever they chose.  For example, several faculty members asserted that neither they nor their  colleagues would tolerate any academic restrictions, and one faculty  member told us he and his colleagues intentionally introduced class  discussions on politically sensitive topics to test whether this would trigger  any complaints or attempted censorship. Students also generally  indicated that they experienced academic freedom and could study or  discuss any topic. Some students who had also studied or knew others  who studied at Chinese universities contrasted their experiences at a U.S.  institution in China, noting that they could have interactive dialogue with  faculty, discuss sensitive topics, and freely access information at the U.S.  institution but not at a Chinese university. Through interviews and  responses to our questionnaire, university administrators reported that  academic freedom was integral to their institutions in China.  Administrators at several universities told us that academic freedom was  nonnegotiable, while others noted that the same curriculum used in the  United States also applied to their institution in China.

However, fewer than half of the universities we reviewed had uncensored  internet access at the time of our review. We visited universities with and  without uncensored internet access, and observed university members  accessing search engines, newspapers, and social media sites that have  been blocked in China—such as the New York Times, Google, and  Facebook—at some universities but not others. At several universities  that lacked uncensored internet access, students and faculty told us that,  as a result, they sometimes faced challenges teaching, conducting  research, and completing coursework. For example, one faculty member  told us that she sometimes asked others outside of mainland China to  conduct internet research for her because they can access information  she could not. Several students at another university told us their ability to  conduct academic research was constrained by the internet limitations.

We also reported in August 2016 that additional factors that could create  obstacles to learning at U.S. universities in China, including self- censorship and constraints specific to Chinese students.

Administrators, faculty, and students representing more than half of  the universities we reviewed gave examples of self-censorship,  including some cases where individuals were advised by teachers or  others in positions of authority to avoid certain topics. For example, an  administrator at one university noted that he believed it was advisable,  as a guest of China, to refrain from insulting China, while an  administrator at another university noted that the university advised  teachers to avoid discussing sensitive subjects in class.

In addition, we found that some conditions specific to Chinese  students may constrain their academic experience. For example,  some noted that Chinese students may know or suspect that their  Chinese classmates are government or Communist Party monitors  and will report on whatever the students say. An administrator at one  university told us that he assumed there were Chinese students and  faculty in the institution who reported to the government or the  Communist Party about the activities of other Chinese students.  Faculty members at several universities told us that they understood  there were Chinese students in class who intended to report on the  speech of faculty or Chinese students.

Finally, we also observed that three of the 12 universities we reviewed  that were approved by the Chinese Ministry of Education as having  independent legal status shared characteristics that may be correlated  with greater academic and other freedoms on campus. We found that  these three universities had campuses built specifically for the joint  institution that were located relatively far away from their Chinese  university partner’s campus, generally controlled their own day-to-day  operations, had uncensored internet access, and offered extensive  campus and student life programs. In contrast, the other nine universities  we reviewed did not consistently share these characteristics at the time of  our review.

Chairman Portman, Ranking Member Carper, and Members of the  Subcommittee, this completes my prepared statement. I would be  pleased to respond to any questions that you may have at this time.

If you or your staff have any questions about this testimony, please  contact Jason Bair, Acting Director, International Affairs and Trade at  (202) 512-6881 or bairj@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this statement. GAO staff who made key contributions to this testimony  are Joseph Carney (Assistant Director), Caitlin Mitchell (Analyst in  Charge), Joyce Kang, Neil Doherty, Melissa Emrey-Arras, Meeta Engle,  Elizabeth Repko, Aldo Salerno, Michael Silver, and Nicole Willems.

This is a work of the U.S. government and is not subject to copyright protection in the  United States. The published product may be reproduced and distributed in its entirety  without further permission from GAO. However, because this work may contain  copyrighted images or other material, permission from the copyright holder may be  necessary if you wish to reproduce this material separately.

The United States and China have established various higher education partnerships—there are nearly 100 Confucius Institutes at colleges and universities in the United States, and more than a dozen U.S. universities have opened institutions in China.

This testimony discusses our February 2019 report on Confucius Institutes in the United States and our August 2016 report on U.S. universities in China. In those reports, we noted that:

Confucius Institute establishing agreements were similar to one another, but institute operations varied.

U.S. universities in China emphasized academic freedom, but faced challenges such as internet censorship.


U.S. Assistance to Mexico: State Department Could Improve Its Monitoring of Mérida Initiative Projects

The Mérida Initiative is a bilateral U.S.-Mexico partnership to address crime and violence and enhance the rule of law in Mexico. Through this initiative, managed by State/INL and USAID, the United States has provided a wide range of assistance, including training and equipment. Since fiscal year 2008, U.S. funding for the Mérida Initiative has totaled about $3 billion. GAO has identified key practices for monitoring foreign assistance programs that agencies should implement to address impediments, effectively manage foreign assistance, and meet assistance goals. These practices are generally consistent with policies of State, USAID, and the Office of Management and Budget.

GAO was asked to review issues related to Mérida Initiative implementation and objectives. This report examines the extent to which State/INL and USAID follow key practices in monitoring Mérida Initiative projects and track project performance against established measures. GAO reviewed State and USAID documents and data for a nongeneralizable sample of 20 high-dollar value projects, and interviewed officials from State; USAID; and other U.S. agencies in Washington, D.C., and Mexico City.

For the 15 Department of State (State) Bureau of International Narcotics and Law Enforcement Affairs (State/INL) projects GAO reviewed, State/INL generally followed key monitoring practices about half of the time. (See figure.) For example, State/INL almost always assigned staff with appropriate qualifications to monitor Mérida Initiative projects. However, for most projects, State/INL did not generally follow the key practices for developing monitoring plans that identify project goals and objectives and address risks to achieving them. Furthermore, State/INL did not consistently track project performance data. By establishing procedures for following key monitoring practices, State/INL would be better positioned to stay well informed of its projects' performance, take corrective action when necessary, and help ensure that projects achieve intended results.

For the five United States Agency for International Development (USAID) projects GAO reviewed, USAID almost always followed key monitoring practices and tracked performance data. USAID established procedures, such as periodic portfolio reviews, to ensure its staff consistently monitored projects. While USAID identified risks to implementing projects, it did not address those risks in its monitoring plans. (See figure.) Developing monitoring plans to address risks could help USAID determine the appropriate level of oversight for each Mérida Initiative project and manage monitoring resources more cost effectively.

GAO is making two recommendations, including that State establish procedures to verify monitoring staff follow key practices, and that USAID ensure that monitoring plans address risks. State and USAID concurred with GAO's recommendations.

Crime and violence perpetrated by transnational criminal organizations  continue to raise security concerns on both sides of the U.S-Mexico  border. A 2019 Congressional Research Service report estimates that  more than 150,000 people have been killed in Mexico as a result of  organized crime since 2006. U.S. drug demand, bulk cash smuggling,  and weapons smuggling from the United States have fueled this violence.  Furthermore, fighting among criminal groups in Mexico intensified after  the extradition of drug kingpin Joaquin “El Chapo” Guzman in 2017  prompted battles between rival cartels to supply rising U.S. demand for  heroin and other opioids.

In October 2007, the United States and Mexico created the Mérida  Initiative and, in doing so, committed to working together to address crime  and violence, and enhance the rule of law in Mexico. Through this  bilateral partnership, the United States has funded Mérida Initiative  projects broadly related to the four pillars of the initiative—combating  transnational criminal organizations, rule of law and human rights, border  security, and building strong and resilient communities—with the goals of  mitigating the effects of the drug trade on the United States and reducing  violence in Mexico. Since fiscal year 2008, the United States has  allocated about $3 billion for assistance for Mexico under the Mérida  Initiative.

You asked us to review issues related to Mérida Initiative implementation  and objectives. This report (1) examines the extent to which the  Department of State (State), Bureau of International Narcotics and Law  Enforcement Affairs (State/INL) follows key practices in monitoring Mérida  Initiative projects and tracks project performance data against established  measures; (2) examines the extent to which the United States Agency for  International Development (USAID) follows key practices in monitoring  Mérida Initiative projects and tracks project performance data against  established measures; and (3) describes how State/INL uses data from  the Government of Mexico to help monitor the implementation of Mérida  Initiative projects.

To address these objectives, we reviewed relevant State and USAID  documents and interviewed agency officials from State, USAID, and the  Departments of Defense (DOD), Homeland Security (DHS), and Justice  (DOJ) in Washington, D.C., and officials from State and USAID in Mexico  City. To determine the extent to which State/INL and USAID followed key  practices in monitoring Mérida Initiative projects, we selected a  nongeneralizable sample of 15 high–dollar value State/INL projects and  five high–dollar value USAID projects that started between January 1,  2014, and December 31, 2016, some of which were still ongoing as of  September 30, 2019, or later. The value of the 15 State projects in our  sample is about $88 million, and the value of the five USAID projects in  our sample is about $107 million. Because State/INL implemented about  90 percent of Mérida Initiative projects during this period, we chose a  larger State/INL sample than a USAID sample.

We assessed the agencies’ monitoring of these 20 projects against eight  key project monitoring practices, largely derived from leading practices for  monitoring foreign assistance that GAO had previously identified. On the  basis of our review, we assessed whether the key practices were  “generally followed,” “partially followed,” or “not followed.” We rated the  extent to which the agency followed each key practice as “generally  followed” if we received evidence that all critical elements of the key  practice were conducted and documented to a large or full extent,  “partially followed” if we received evidence that some but not all critical  elements of the key practice were conducted and documented, and “not  followed” if we did not receive evidence that any of the critical elements of  the key practice were conducted and documented. To determine the  extent to which State/INL and USAID track project performance, we  chose a nongeneralizable subset of the 20 projects listed above.  Specifically, we chose a smaller sample of six projects—four from  State/INL and two from USAID—primarily based on their high–dollar  values. We reviewed these projects’ latest year of quarterly and annual  progress reports to assess the extent to which State/INL and USAID  tracked data on performance measures in these reports. These  performance measures were established in other monitoring documents  (e.g., monitoring plans and project narratives) in accordance with one of  the key monitoring practices.

To describe the type of Government of Mexico data State/INL uses to  monitor Mérida Initiative implementation, we reviewed data related to  Mérida Initiative projects collected by the Government of Mexico and  shared with State/INL.

We conducted this performance audit from November 2018 to May 2020  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

There were 445 State/INL and USAID Mérida Initiative projects active  from fiscal year 2014 through fiscal year 2018, which includes some  projects that started before this period and some that continued after this  period. State/INL funded 388 of the projects, and USAID funded 57.  USAID’s projects tended to be larger with higher funding amounts than  State/INL projects. State/INL projects generally focused on providing  training and assistance to Mexican officials from the justice sector, border  security, military, and law enforcement, as well as equipment, including  for forensic laboratories, drug detection, and border surveillance. USAID  projects were intended to engage with Mexican government institutions,  civil society organizations, and the private sector to address corruption,  promote trust in government, or prevent crime and violence, such as  through skill building for youth, efforts to advance human rights, or  technical support for judicial system development. State/INL allocated  about $542 million and USAID allocated about $182 million for assistance  to Mexico under the Mérida Initiative from fiscal year 2014 through fiscal  year 2018.

State/INL and USAID are the lead U.S. agencies for developing the  Mérida Initiative’s programming. In these roles, State/INL and USAID  work with Government of Mexico officials to outline plans, goals, and  objectives for Mérida Initiative projects. State/INL and USAID both  manage and fund the Mérida Initiative with the support of a wide range of  project implementers, including DOJ, DHS, and DOD, as well as private  contractors, nongovernmental organizations, and international  organizations. State/INL and USAID implement Mérida Initiative projects  primarily through contracts, grants, and agreements with international  organizations. State/INL also implements some Mérida Initiative projects  through interagency agreements with other U.S. agencies (e.g., DOJ,  DHS, and DOD).

State/INL and USAID contracting, grant, and agreement officers, are  responsible for administering and overseeing contracts, grants, and other  agreements that the agencies award, including for Mérida Initiative  projects. They delegate the day-to-day monitoring responsibilities to  agency officials located in Mexico City, particularly State/INL and USAID  Contracting Officer Representatives (COR) for contracts, State/INL Grant  Officer Representatives (GOR) for grants, State/INL Agreement Officer  Representatives (AOR) for interagency agreements or letters of  agreement with international organizations, and USAID AORs for grants  and cooperative agreements, according to agency officials. Key  monitoring responsibilities of the CORs, GORs, and AORs typically  include reviewing quarterly, annual, and other progress reports submitted  by project implementers; ensuring other required documents are  submitted; communicating with the implementers on the status of  assistance activities; and conducting site visits, among other things.

Key Practices for Monitoring Foreign Assistance Projects

In 2019, we reported on 14 leading practices for monitoring foreign  assistance that agencies should incorporate in their monitoring policies to  help ensure that they effectively manage foreign assistance, address  impediments, and meet their assistance goals. From these leading  practices we derived eight key practices that can help agencies monitor  the implementation and performance at the project level. To facilitate  discussing these key monitoring practices, we grouped them into three  areas: (1) assigning monitoring duties to qualified staff, (2) planning  monitoring approach, and (3) monitoring project implementation. (See  table 1.) These practices are generally consistent with the Office of  Management and Budget’s guidelines for Federal departments and  agencies that administer United States foreign assistance and related  guidance, as well as State’s and USAID’s monitoring policies.

For Projects We Reviewed, State Generally Followed Key Monitoring Practices About Half of the Time, but Did Not Consistently Track Performance Measures

We reviewed 15 of State/INL’s high–dollar value Mérida Initiative projects  to assess the extent to which State/INL followed key practices for  monitoring foreign assistance projects in the areas of assigning  monitoring duties to qualified staff, planning a monitoring approach, and  monitoring project implementation. For these projects, the agency  generally followed the key practices about half of the time, as shown in  figure 1, and for a subset of four selected projects, it did not consistently  track performance data or compare them to established performance  measures. State/INL does not have procedures in place for monitoring  staff to consistently follow all the key practices. Instead, officials said they  focused on tracking implementation of the projects’ activities. Consistently  following key monitoring practices would allow State/INL to stay well  informed of projects performance, take corrective action when necessary,  and help ensure that projects achieve their intended results.

For Projects We Reviewed, State Generally Followed Key Monitoring Practices about Half of the Time

Assigning Monitoring Duties to Qualified Staff

State/INL generally followed key practices for assigning monitoring duties  to qualified staff almost always. Assigning staff with the appropriate  certification helps ensure that they have the necessary knowledge and  skills to perform those duties. Establishing roles and responsibilities helps  ensure that the assigned monitoring staff are aware of their monitoring  duties. State/INL requires that staff responsible for monitoring Mérida  Initiative projects be certified as a COR, GOR, or AOR. State/INL also  assigns roles and responsibilities to monitoring staff through a  designation letter in which a contract or grant officer designates a COR,  GOR, or AOR to oversee each project. However, of the 15 projects we  reviewed, one had a gap in the documentation for staff certifications, and  four had gaps in the documentation of designation letters. For example, in  one case State/INL could not provide documentation to demonstrate that  the official responsible for monitoring a project on police training had been  officially designated or that the official had a valid certification during the  full implementation period of the project. According to State/INL staff, the  monitoring staff roles and responsibilities are also outlined in other  documents such as the State Department’s Foreign Affairs Manual and  the AOR Handbook, of which staff are expected to be aware. Figure 2  illustrates the extent to which State/INL followed each related key practice  for assigning monitoring duties.

State/INL generally followed key practices for planning a monitoring  approach a third of the time. Two projects—one for helicopter pilot  training and the other for aviation maintenance training—did not have  monitoring plans and thus did not meet any of the three key practices for  planning a monitoring approach. According to a State/INL manager,  State/INL is no longer working with this implementer due to long-standing  difficulties in obtaining documentation needed to monitor the projects.  Most of the other 13 projects partially met the key practices for planning a  monitoring approach. For example, goals and objectives were included in  planning documents other than the monitoring plan. Furthermore, while  only three of the projects had a monitoring plan that addressed risk, we  determined that 10 of the projects partially addressed this key practice,  because risks were assessed or considered, but the identified risks were  not addressed in the monitoring plan. In addition, almost all of the projects  had relevant project-level performance measures. Developing a  monitoring plan that identifies project objectives helps focus monitoring  efforts on assessing projects outcomes. In addition, identifying and  addressing risks in that plan helps focus monitoring efforts on those  aspects of project implementation that are most likely to threaten the  success of the project in meeting its goals. We did not see evidence that  State/INL had procedures in place to ensure that monitoring officials  consistently follow key practices in the area of planning monitoring  approach. Figure 3 illustrates the extent to which State/INL followed each  related key practice to planning a monitoring approach.

State/INL provided documentation to demonstrate that monitoring  managers generally followed key practices for monitoring project  implementation about half of the time. Monitoring project implementation  helps ensure that projects are meeting their objectives, so that any  necessary adjustments or corrective actions can be taken in a timely  manner. We found that State/INL did not generally collect all expected  progress reports from implementers for seven projects, and of those  seven, it did not collect any reports for three projects. Furthermore,  State/INL did not provide documentation for eight projects demonstrating  that monitoring staff had generally assessed and approved implementers’  periodic progress reports. We also found that for seven projects,  State/INL did not provide documentation demonstrating that monitoring  staff had generally conducted site or field monitoring visits or taken other  steps to validate the partner’s performance implementing the project. For  example, for one project that provided training to Mexican immigration  officers on the southern border, State/INL only provided one quarterly  progress report of the four we requested for the period of our review. For  this project, State/INL also did not provide documentation that monitoring  staff had taken steps to review and approve the report or that they had  conducted any monitoring site visits. A State/INL official explained that  they requested the quarterly reports, but at times implementers did not  submit them. Without implementing procedures to consistently collect,  assess, and approve performance reports from implementers, monitoring  staff may not have sufficient information to assess implementers’  performance and determine whether corrective actions are needed. We  did not see evidence that State/INL had procedures in place to ensure  that monitoring officials consistently follow key practices in the area of  monitoring project implementation. Figure 4 illustrates the extent to which  State/INL followed each related key practice for monitoring project  implementation.

State/INL Did Not Consistently Track Performance Data against Established Measures for Projects We Reviewed

State/INL monitoring officials did not consistently track performance data  against established measures for four Mérida Initiative projects we  reviewed; these four projects were a subset of the 15 State/INL projects  discussed above. Tracking performance data—a key practice for  monitoring project implementation—can provide meaningful information  on projects’ progress in achieving intended results. The four projects we  reviewed included two grants focused on police professionalization; one  interagency agreement focused on assistance to forensic laboratories;  and one agreement with an international organization focused on  conducting a survey on police standards, training, and  professionalization. We reviewed how State/INL tracked performance  data for these selected projects as part of its efforts to assess and  approve implementing partners’ periodic performance reports and data as  outlined in the key monitoring practices. Specifically, we analyzed the  extent to which State/INL tracked data contained in quarterly progress  reports and compared these data to established performance  measures. State/INL and the project implementers outlined these  performance measures in monitoring documents that these implementers  developed and State/INL approved. Some of these projects’ monitoring  documents also included data sources, data collection frequency, and  performance targets. State/INL did not track performance data for two of  the four selected projects and tracked such data inconsistently for the  other two selected projects. As a result, State/INL cannot ensure that it  has accurate and reliable performance data for its Mérida Initiative  projects. Such data could help State/INL determine whether projects are  achieving intended results and take necessary corrective actions to  improve project performance over time.

State/INL Did Not Track Performance Measures for Two of the Four State/INL Projects We Reviewed

For the two police professionalization projects we reviewed, State/INL did  not track performance data against established performance measures  outlined in the project narrative at the start of the projects. Some of these  projects’ performance measures reflected outputs—such as the number  of participants completing at least 25 hours of police training and the  number of citizen surveys conducted on public trust of law enforcement.  Other performance measures reflected outcomes—such as the  percentage of law enforcement officials who feel ready for promotion after  completing training and results of citizen surveys on perceived security  where law enforcement trainings were conducted. (See examples in table  2.) However, State/INL did not clearly track or reference such  performance measures in these two projects’ quarterly progress reports.  Instead, State/INL provided details in these reports on project activities  and training that did not clearly link to the projects’ performance  measures. For example, State/INL noted the number of participants who  took a specific training course on a certain date, but did not provide the  total number of participants’ training hours to compare them to the  performance measure on the total number of participants who completed  at least 25 hours of training. State/INL monitoring officials said they had  not systematically tracked data on the performance measures of these  projects over time, but instead focused on ensuring the trainings were  conducted and the number of training participants were tracked. These  officials acknowledged the need to improve their tracking of these  projects’ progress against their performance measures.

We also identified information in quarterly progress reports for two  projects suggesting that the reports did not accurately reflect project  activities in those quarters. For example, for one project, State/INL  included identical information in two separate quarterly reports even  though the implementer conducted different project activities in those two  quarters. Thus, at a minimum, the information in one of the quarterly  reports did not accurately reflect the project’s activities conducted in that  quarter. We found the same issue with another project’s reports.  State/INL officials said they were not aware that the project information in  these reports were identical.

State/INL Tracked Some Performance Measures for Two of the Four State/INL Projects We Reviewed, but Did So Inconsistently

For the two other State/INL projects we reviewed (one forensics  laboratory accreditation project and one police survey project), State/INL  tracked some performance data but did so inconsistently. These projects’  performance measures reflected outputs, such as the number of survey  pollsters hired and trained and the number of accredited forensic  laboratories that maintain their accreditation. Other performance  measures reflected outcomes, such as the percentage of forensic  laboratories trainees reporting improved knowledge of subject matter and  satisfaction rates for training courses for the forensics laboratory project.  (See examples in table 3.) In one of these two projects’ quarterly reports,  the project implementers inconsistently described and numbered some of  the performance measures, and they did not explain the discrepancies.  Also, the implementers mentioned different performance measures in  different quarterly progress reports—with some measures dropping off in  some quarters and new measures appearing in others—without providing  a rationale in the reports. As a result, State/INL could not consistently  track progress of some of the performance measures over time. State/INL  officials stated that these two implementers only included activities in the  quarterly reports that they conducted in that quarter, which would result in  different and inconsistent performance measures in each report.

In addition, some of the reported project activities did not consistently and  clearly align with the performance measures to allow State/INL to track  the project’s progress against these measures. For example, some  performance measures reflected percentages (e.g., 90 percent of  authorities responsible for forensic laboratories routinely attend regional  and national conferences), but the report listed the names of conference  participants, dates, and locations in a table next to that performance  measure. When asked about these discrepancies, State/ INL officials said  that they did not ensure that implementers provided complete information  to clearly track the project’s progress against performance measures.  However, they said that they also conduct monitoring through informal  methods not documented in the progress reports, such as through  communication via phone calls and emails with the implementers. Such  informal methods do not provide State/INL with the necessary data to  assess a project’s performance against its goals.

State/INL Monitoring Management Did Not Ensure Their Staff Tracked Performance Measures

For the four State/INL projects we reviewed, State/INL monitoring  managers did not establish procedures to collect and review project  performance data, such as the number of people who completed a  targeted number of hours of training, or the results of training surveys.  These managers said they did not prioritize establishing performance  tracking procedures and instead focused on the implementation of the  projects’ activities, such as counting the number of participants who  attended one training course for a particular month. For example, while  some monitoring staff sent monthly emails to their managers describing  project activities, State/INL monitoring managers did not establish  procedures—such as holding regular meetings with or requiring reporting  from monitoring staff—that focused on tracking the projects’ progress  against established performance measures.

State/INL Receives Activity Data from Implementers to Monitor Project Implementation

State/INL receives activity data from project implementers that it  considers useful in helping the agency monitor the projects’  implementation and activities. State/INL officials told us that project  activity data in the quarterly progress reports—such as when trainings  were conducted and how many people attended—help keep them  informed of and monitor the projects’ implementation.

In addition, since 2015, State/INL Mexico has collected detailed data and  information in tracking databases on (1) training events and related  surveys on that training, and (2) forensic laboratory accreditations and  correctional facility accreditations.

The training tracking database contains data on over 6,000 training  events, 100,000 trainee records, and over 20,000 survey responses  from training event participants. This database can generate  numerous reports covering the number of people who completed a  specific trained course, which training courses a specific person  completed, training survey results, and which implementer conducted  the training, among other information.

State/INL databases also collect information on the status of forensics  laboratories and correctional facilities across Mexico that are being  accredited through Mérida Initiative projects. The forensics database  includes pages for each laboratory with detailed information about the  level of accreditation received, and types of trainings conducted,  among other things. The correctional facilities database is structured  similarly to the laboratories database with pages for each facility with  detailed information on accreditation status and timeline, among other  things. According to State/INL officials, like the training tracking  system, the forensics and correctional facilities databases can  generate reports, such as monthly progress reports.

Finally, State/INL Mexico is implementing a new cloud-based monitoring  database—called DevResults—that will consolidate and track data on  activity, output, and outcome indicators for all Mérida Initiative projects.  According to State/INL officials, they implemented DevResults so that  State/INL could track a project’s progress and trends in real time against  its performance goals. According to State/INL officials, DevResults  included data for 84 projects as of February 2020. They also noted that  agency officials and implementers have completed training on  DevResults, and additional training will be provided as needed. State/INL  officials said they plan to continue adding data for past and present  Mérida Initiative projects in 2020.

For Projects We Reviewed, USAID Almost Always Followed Key Monitoring Practices and Tracked Performance Data, but Did Not Develop Monitoring Plans That Address Risk

We reviewed five of USAID’s Mérida Initiative projects to assess the  extent to which USAID followed key monitoring practices in the areas of  assigning monitoring duties to qualified staff, planning a monitoring  approach, and monitoring project implementation. For these projects,  USAID almost always followed key practices—as shown in figure 5—and  for a subset of two selected projects, it consistently tracked project  performance. According to USAID officials, USAID management  conducted periodic portfolio reviews to ensure that monitoring staff  adequately monitored Mérida Initiative projects and followed key  practices. However, for all five USAID projects we reviewed, monitoring  plans did not address identified risks, which could help the agency  allocate monitoring resources to those aspects of the projects that  warrant closer scrutiny.

For Projects We Reviewed, USAID Almost Always Followed Key Monitoring Practices

USAID generally established roles and responsibilities for technical staff  responsible for monitoring projects, but for two of the five projects we  reviewed it did not maintain documentation showing that it assigned staff  with appropriate certifications. Like State/INL, USAID requires that staff  responsible for monitoring Mérida Initiative projects be certified as CORs  or AORs, which typically includes periodic training in monitoring projects.  USAID assigns roles and responsibilities to these staff through a  designation letter in which a contract or agreement officer designates a  COR or AOR, respectively, to conduct technical oversight of each project.

For the five projects we reviewed, USAID properly designated monitoring  roles and responsibilities to technical staff, however there were gaps in  staff certification documentation for technical staff for two projects. For  example, we found that the person responsible for monitoring a project  promoting justice reform and rule of law in Mexico did not have a valid  certificate for 9 months of the project’s 4-year period of performance.  Maintaining complete documentation of monitoring-related activities helps  USAID management ensure adequate, continuous monitoring of projects.  According to USAID, the gaps in documentation were caused by staff  turnover and trouble accessing the government-wide system for recording  the certification of staff, which was difficult to access or down from  December 2017 to March 2018. Officials said that once the system to  record certificates was brought back online, they were able to track  certifications. Figure 6 illustrates the extent to which USAID followed each  related key practice for assigning monitoring duties.

USAID generally developed monitoring plans that included program goals  and objectives and project-level performance measures, but the  monitoring plans did not address project risks. All five projects generally  had a monitoring plan that identified project goals and objectives, and  relevant project-level performance measures. However, none of the  monitoring plans generally addressed identified risks related to achieving  project objectives. While USAID provided documentation showing that the  agency had conducted various assessments considering risk for each  project, the results of these assessments were not addressed in the  projects’ monitoring plans. For example, for a project to promote justice  and rule of law in Mexico, USAID assessed risks relating to terrorism,  environmental effects, sustainability, and gender equity in carrying out the  project. However, the project’s monitoring plan did not address identified  risk levels and related monitoring actions designed to mitigate risks  identified in these assessments. USAID explained that they address  ongoing monitoring of risk through several other processes, such as  project design, procurement actions, financial management, award  management and administration, semi-annual project portfolio reviews,  and annual risk-based assessments of the USAID’s portfolio in Mexico,  among others. However, identifying and addressing risks in the  monitoring plan can help ensure that monitoring staff are aware of  potential impediments to project success about which they need to be  vigilant or take steps to mitigate as they monitor the projects. Additionally,  determining which activities warrant greater oversight can also help  agencies manage monitoring resources cost effectively. Figure 7  illustrates the extent to which USAID followed each related key practice  for planning a monitoring approach.

USAID generally followed key practices for monitoring project  implementation about two-thirds of the time. We found that USAID  collected all progress reports for four of the five projects we reviewed. For  two projects, USAID did not provide documentation demonstrating that  monitoring staff had generally assessed and approved implementers’  periodic progress reports. For all five projects, USAID provided  documentation demonstrating that monitoring staff had generally  validated implementing partners’ performance through site visits. Figure 8  illustrates the extent to which USAID followed each related key practice  for monitoring project implementation.

USAID Consistently Tracked Established Performance Measures for the Two Projects We Reviewed

USAID monitoring officials consistently tracked performance data and  compared them to established performance measures for the two projects  we reviewed; these two projects were a subset of the five USAID projects  discussed above. To review the extent to which USAID assessed and  approved implementing partners’ periodic reports and data—one of the  eight key monitoring practices—we determined whether USAID tracked  performance data contained in quarterly or annual progress reports.  USAID funds one of the two projects through a cooperative agreement  focused on strengthening human rights, and the other project through a  contract focused on improving the criminal justice sector.

USAID and project implementers outlined these projects’ performance  measures in project-specific monitoring plans that both parties developed  at the start of the project or revised after the project was in place. Project  implementers developed these plans, and USAID approved them. The  plans included details related to the performance measures, such as data  sources, data collection frequency, and targets. In accordance with these  plans, USAID and project implementers tracked performance measures in  annual progress reports, while they primarily tracked detailed project  activity in quarterly progress reports.

The two USAID projects’ progress reports included tables that tracked  project performance. Some of the projects’ performance measures  reflected outcomes, such as prosecution rates of Mexican government  prosecution units that received technical support and the number of  improved measures to address serious human rights violations. Some  performance measures reflected outputs, such as the number of Mexican  officials trained in human rights advocacy areas. See table 4 for  examples of performance measures and information in the progress  reports we reviewed.

When the implementer and USAID changed performance measures, they  also revised project-specific monitoring plans to document these  changes. For example, for one project we reviewed, the established  measures were no longer effective in measuring progress toward the  project’s objectives, according to USAID officials. As a result, the  implementer and USAID modified the project’s monitoring plan at least  twice, revising the performance measures to better align with the project’s  objectives. The subsequent progress reports we reviewed for these  projects included data on the revised performance measures.

USAID has procedures to help ensure that monitoring staff track  performance data. According to USAID officials, USAID began sending  out a standard spreadsheet to all Mérida Initiative implementing partners  in 2018 that requires them to report performance data on a quarterly or  annual basis. USAID uses these spreadsheets to track Mérida Initiative  project performance data. Since May 2017, USAID has also conducted 6- month portfolio reviews in which monitoring managers and their staff review project activities and performance data collected for their projects  and discuss project successes and challenges. USAID managers told us  that they implemented these reviews to help ensure that their staff  monitor project performance.

Mexico Shares Indicator Data with State/INL for Monitoring the Efforts Related to the Mérida Initiative

According to State/INL, the Government of Mexico provides data to  State/INL that help the agency monitor its Mérida Initiative assistance  efforts and provides insights into the implementation of the initiative  overall. State/INL also noted that, in 2014, the agency hired a contractor  to work with both the U.S. and Mexican governments to develop a  comprehensive set of indicators to evaluate the progress and results of  the Mérida Initiative. In 2015, Mexico agreed that it would provide data to  State/INL on this set of indicators to demonstrate the effects of the Mérida  Initiative, according to State/INL officials. These officials told us that they  try to obtain the data on an annual basis. They also noted that the  purpose of collecting the data from Mexico was to establish a mechanism  to share information on the Mérida Initiative’s effects and to improve U.S.- Mexico cooperation on the initiative. According to State/INL officials,  various Mexican agencies collect the data, such as the Army, Air Force,  Navy, Tax Administration Service/Customs, Attorney General’s Office,  and National Institute of Statistics and Geography.

The Mexico data comprise about 170 indicators (data points) related to  the overall goals and program areas of the Mérida Initiative:  Counternarcotics/Special Investigations, Criminal Prosecutions, Border  Security and Ports of Entry, and Security and Law Enforcement. Some  data are closely linked to Mérida Initiative–funded projects, such as the  accreditation status of Mexican correctional facilities. Other data provide  broader context, such as Mexican civil society’s perception of Mexican  agencies. In addition, data, such as the number of accredited forensic  laboratories and correctional facilities, may reflect progress in institution  building. Other data, such as the number of accounts blocked by the  Mexican Financial Intelligence Unit, may reflect operational capacity  development. See table 5 below for examples of the indicators, as  reported by Mexico to State/INL.

State/INL officials said they use the indicator data in discussions with  Mexican officials to help monitor the implementation and activities of the  Mérida Initiative, including which best practices can be replicated across  Mexico. State/INL officials said the data also inform the agency’s internal  decision making on which Mérida Initiative programs are effective and  which programs it should modify. For example, according to State/INL  officials, the indicator data help track the use of equipment donated to  Mexico through the Mérida Initiative. If the data show extensive use of  equipment, State/INL can use the data to justify a request for additional  equipment or to approve maintenance of the equipment, according to  agency officials.

For over a decade, the Mérida Initiative has funded programs intended to  address serious challenges to security and the rule of law. As the United  States continues to support hundreds of Mérida Initiative projects in  Mexico, it is important that State/INL monitor these projects carefully and  stay well informed of the projects’ performance to ensure that they are as  effective as possible. USAID has established procedures that help ensure  that it follows most key monitoring practices, including those related to  assigning monitoring duties to qualified staff and monitoring project  implementation. State/INL management has not established such  procedures for the projects we reviewed, limiting its ability to stay well  informed of project performance and make course corrections to improve  performance when necessary. While State/INL and USAID often  conducted assessments to identify risks that may affect the achievement  of project objectives, they generally did not address the results of the risk  assessments in projects’ monitoring plans. Developing monitoring plans  to address risks would help establish the appropriate level of oversight  needed for each project, which in turn could lead to more cost-effective  management of these projects.

We are making the following two recommendations, one to State and one  to USAID:  The Secretary of State should ensure that State/INL establishes  procedures that verify that monitoring officials for Mérida Initiative projects  follow the key practices. (Recommendation 1)

The USAID Administrator should establish procedures to ensure that  monitoring officials for Mérida Initiative projects develop monitoring plans  that address risks. (Recommendation 2)

We provided a draft of this report to State, DOD, DHS, DOJ, and USAID  for review and comment. Some of the agencies provided technical  comments, which we incorporated as appropriate. State and USAID also  provided formal comments, which are reproduced in appendixes III and  IV.

State agreed with our recommendation to establish procedures for staff  monitoring Mérida Initiative projects to follow key practices. State  indicated that it is working to create new monitoring and evaluation  guidance consolidated across State/INL, based in part on GAO’s leading  practices. According to State, the new guidance will address the areas  highlighted in this report related to monitoring Mérida Initiative projects.  State/INL plans to institute annual program reviews in which monitoring  staff will assess project performance, effects, and alignment with current  and planned priorities. State indicated that annually reviewing State/INL  programming will help identify underperforming projects, give relevant  staff a forum to discuss any issues or challenges to implementation and  monitoring, and ensure the bureau follows the key monitoring practices  outlined in this report.

USAID also agreed with our recommendation to establish procedures to  ensure that staff monitoring Merida Initiative projects develop monitoring  plans that address risk. USAID indicated that USAID/Mexico is revising its  Project and Activity Design Mission Order to incorporate recently issued  USAID guidance and address our recommendation. According to USAID,  the mission order will provide a framework and guidance to ensure that  USAID/Mexico systematically addresses project risks and incorporates  them into the respective monitoring plan.

We are sending copies of this report to the appropriate congressional  committees, the Secretary of State, and the USAID Administrator. In  addition, the report will be available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-2964 or GurkinC@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made contributions to this  report are listed in appendix V.

Appendix I: Objectives, Scope, and Methodology

This report (1) examines the extent to which the Department of State  (State), Bureau of International Narcotics and Law Enforcement Affairs  (State/INL), follows key practices in monitoring Mérida Initiative projects  and tracks project performance data against established measures; (2)  examines the extent to which the United States Agency for International  Development (USAID) follows key practices in monitoring Mérida Initiative  projects and tracks project performance data against established  measures; and (3) describes how State/INL uses data from the  Government of Mexico to help monitor the implementation of Mérida  Initiative projects. To address these objectives, we reviewed relevant  State and USAID agency documents and interviewed agency officials  from the Departments of State (State), Homeland Security (DHS),  Defense (DOD), and Justice (DOD), and USAID in Washington, D.C., and  officials from State and USAID in Mexico City.

In 2019, we reported on 14 leading practices for monitoring foreign  assistance that agencies should incorporate in their monitoring policies to  help ensure that they effectively manage foreign assistance, address  impediments, and meet their assistance goals. From these leading  practices, which are focused on a high-level assessment of agency  monitoring policies, we derived eight key practices that can help agencies  monitor the implementation and performance at the project level, such as  those implemented under the Mérida Initiative. These eight key practices  include those that in our judgment directly relate to monitoring project- level performance activities. We did not address monitoring of financial  activities, because our review focused on performance monitoring. We  made minor modifications to the key practices selected to reflect the  focus of our review. We also grouped the selected key monitoring  practices into three areas: (1) assigning monitoring duties to qualified  staff, (2) planning a monitoring approach, and (3) monitoring project  implementation.

To determine the extent to which State/INL and USAID followed key  practices in monitoring Mérida Initiative projects, we selected a  nongeneralizable sample of 15 high–dollar value State/INL projects and  five high–dollar value USAID projects that started between January 1,  2014, and December 31, 2016. (See app. II for details on these 20  projects). Some of these projects were ongoing after fiscal year 2019. We  selected the projects from a list provided by State/INL and USAID. State’s  list included 388 projects, and USAID’s list included 57 projects for a total  of 445 projects under the Mérida Initiative. We selected projects  implemented through a variety of mechanisms. For State/INL, we  selected two letters of agreement with international organizations, four  grants, three contracts, and two interagency agreements implemented by  DOD, two interagency agreements implemented by DHS, and two  interagency agreements implemented by DOJ. For USAID, we selected  two contracts and three grants. The value of the 15 State projects in our  sample is about $88 million, and the value of the five USAID projects in  our sample is about $107 million. These 15 State/INL projects represent  about 25 percent of the total value of the State/INL projects that started  during this period. These five USAID projects were the highest value  contracts and grants cooperative agreements and represent about 70  percent of the total value of USAID projects that started during this period.  Because State/INL implements about 90 percent of all Mérida Initiative  projects, we chose a larger State/INL sample than USAID sample.

We assessed the agencies’ monitoring of the 20 selected Mérida Initiative  projects against eight key monitoring practices largely derived from  GAO’s Leading Practices for Monitoring Foreign Assistance. We  reviewed documents to determine the extent to which State/INL and  USAID followed the eight key monitoring practices for each of the  selected Mérida Initiative projects. Specifically, for each selected project,  we requested monitoring plans; work plans; risk assessments; Contract,  Grant, or Agreement Officer Representative Certificates; Contract, Grant,  or Agreement Officers Representatives Designation Letters; implementer  progress reports for the latest year of activity of each project (at the time  of our review); samples of field or site visit reports; and samples of  monitoring emails between monitoring staff and the implementers. We  reviewed available documents as they related to each key practice to  determine the extent to which the agency had taken steps to follow and  document the key practice for each project.

On the basis of our review, we assessed whether the key practices were  “generally followed,” “partially followed,” or “not followed.” We rated the  extent to which the agency followed each key practice as “generally  followed” if we received evidence that all critical elements of the key  practice were conducted and documented to a large or full extent,  “partially followed” if we received evidence that some but not all critical  elements of the key practice were conducted and documented, and “not  followed” if we did not receive evidence that any of the critical elements of  the key practice were conducted and documented. To perform these  analyses, two analysts reviewed the documents to rate the extent to  which each key practice was met. The analysts worked iteratively,  comparing notes and reconciling differences at each stage of the  analysis. In addition, GAO staff independent of the two analysts reviewed  the final analysis, and modified it as appropriate.

To determine the extent State/INL and USAID track project performance,  we chose a nongeneralizable subset of the 20 projects listed above.  Specifically, we chose six projects—four State/INL projects and two  USAID projects—primarily based on their high–dollar values. (See app. II  for details on these six projects.) We chose a small subset of State/INL  and USAID projects to conduct a detailed analysis of data in the projects’  annual and quarterly reports. Specifically, for the four State/INL projects,  we chose high–dollar value projects for each of the following  implementing mechanisms: grants, interagency agreements, and  agreements with international organizations. We excluded contracts from  the State/INL subset sample, because the high–dollar value contracts  generally did not have the project-level performance measures needed to  assess State’s tracking of performance data. We included a second grant  in our sample in place of a contract, because more Mérida Initiative  State/INL projects are grants than interagency agreements or agreements  with international organizations. As a result, our State/INL sample  consisted of two grants, one interagency agreement, and one agreement  with an international organization. For the USAID sample, we chose one  grant or cooperative agreement and one contract. We did not choose  other types of implementing agreements because grants/cooperative  agreements and contracts comprise over 98 percent of USAID projects  for the timeframe of our review.

For both the State/INL and USAID selected projects, we reviewed project  monitoring documents—such as project narratives, workplans, and  monitoring plans—and identified the performance measures outlined in  these documents for each project. We then reviewed these projects’  latest year of implementer quarterly and annual progress reports (at the  time of our review), and assessed the extent to which State/INL and  USAID assessed and approved implementing partners’ periodic  performance reports and data in accordance with the key monitoring  practice of assessing and approving performance information. We also  met with State/INL and USAID monitoring officials in Washington, D.C.,  and Mexico to understand the process for how these officials track the  performance of these selected projects, including in the projects’ quarterly  and annual reports. We also reviewed the reports to identify any  discrepancies or errors.

To describe the type of Government of Mexico data that State/INL uses to  monitor Mérida Initiative implementation, we reviewed data from fiscal  years 2015-2018 related to Mérida Initiative projects collected by the  Government of Mexico and shared with State/INL. We also met with  State/INL officials in Washington, D.C., and Mexico City to discuss the  data, including how it is used and its reliability. After our discussions with  State/INL officials, State/INL selected some unclassified examples of the  indicators, which we included in our report. The purpose of this  component of our review was to describe the nature and use of the  Mexico data.

We conducted this performance audit from November 2018 to May 2020  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

Appendix II: Selected State/INL and USAID Mérida Initiative Projects Assessed against Key Monitoring Practices

This appendix provides a list of the 15 Department of State (State),  Bureau of International Narcotics and Law Enforcement Affairs  (State/INL) Mérida Initiative projects, and five United States Agency for  International Development (USAID) Mérida Initiative projects selected for  our review. We assessed State/INL and USAID monitoring of these  projects against key monitoring practices as described in appendix I. The  subset of these projects (four State/INL and two USAID) selected for our  analysis of the agencies’ tracking of performance data is noted below.  State/INL provided the details in table 6, and USAID provided the details  in table 7.

Appendix III: Comments from the Department of State

Appendix IV: Comments from the U.S. Agency for International Development

In addition to the contact named above, James Michels (Assistant  Director), Francisco Enriquez (Analyst-in-Charge), Terry Allen, Ashley  Alley, Lilia Chaidez, Martin De Alteriis, Neil Doherty, Teresa Heger, John  Hussey, and Andrew Kincare made key contributions to this report.

Para la versión de esta página en español, ver a GAO-20-563SP.

Since 2008, the U.S. and Mexico have collaborated on the Mérida Initiative to fight violence, drugs, and transnational crime. U.S. agencies managed $3 billion in assistance projects, including training and equipment.

For the 15 State Department projects we reviewed, State monitored implementation and performance inconsistently—making it harder to assess progress and improve if needed.

For the 5 USAID projects we reviewed, USAID monitored implementation and performance well. But monitoring could be more cost-effective if plans addressed implementation risk to projects.

Our recommendations are to help the agencies improve their monitoring.