May 23, 2022
We recently spoke with Vielka Polanco, Executive Director of the Centro Nacional de Fomento y Promoción de Asociaciones sin Fines de Lucro (CASFL) to learn about the work undertaken in the Dominican Republic on civil society strengthening, the impact from the use of public resources and its accountability, as well as areas of opportunity for future improvement.
GS: What is the mission and objectives of the National Center for the Promotion of Non-Profit Organizations (NPOs) in the Dominican Republic?
VP: The National Center for the Promotion and Development of Non-Profit Organizations (CASFL) is the government body responsible for policies concerning non-profit organizations (NPOs), as well as for volunteer programs of public institutions and the private sector, at the national level. In this sense, CASFL, in accordance with Law 122-05, promotes the regulation and strengthening of NPOs. While CASFL is commonly known for the allocation of public funds to NPOs for their participation in the implementation of public policies and for monitoring the use of these resources, its role goes beyond that, by promoting a genuine participation of civil society in the public policy cycle. In other words, the spaces usually established by State regulations should not be limited to mere formalities and should be used by NPOs to influence and participate in public policies. In this regard, CASFL promotes the relationship between the State and civil society in the country.
One of the fundamental aspects of CASFL is that it is a participatory body through the CASFL Council, which is composed of 5 NPO representatives chosen by their peers every two years and of 5 public institutions (Ministry of Economy, Planning and Development; Ministry of Public Administration; the General Directorate of Budget; the Comptroller General of the Republic and the Attorney General of the Republic, the latter being responsible for the legal registration of NPOs). In other words, CASFL does not only promote the participation of NPOs in public policies but also their participation in CASFL’s own activities as part of its institutional strengthening.
As a governing body, the role of the CASFL Council is to define norms, methodologies and policies to be implemented by the sectoral public institutions with the support of CASFL regarding the sectoral registration of NPOs; the strengthening of the organizations through training activities and the allocation of funds; and the oversight and follow-up for the accountability of NPOs’ projects.
On the other hand, CASFL interacts with the public institutions (ministries or sectoral bodies, etc.) on an ongoing basis, since they are the ones who must maintain direct contact with the organizations. An important tool for this interaction is the technological platform known as the NPOs Integrated Management System (SIGASFL). For example, CASFL registers NPOs and recommends a sectoral public institution to each one. In turn, the sectoral institutions – through their joint evaluation commissions – issue the certificate to the organizations, which allows them to provide services. The requirements for accreditation of NPOs vary according to each sector. The CASFL supervises that the sectoral institutions comply with the common standards. It also provides trainin and advice throughout the process.
As the Chamber of Accounts is a constitutionally autonomous institution, CASFL’s relationship with it is less frequent. However, with the new authorities of the Chamber of Accounts, joint work is being done to explore a single system for uploading and reporting on NPOs accountability for the use of public funds. In other words, efforts are being made to ensure that the same accountability report prepared by an NPO is valid for the Chamber of Accounts, for the sectoral public institutions and for CASFL. The purpose of this single system is to ensure that everyone gets the same information and that the NPOs are not overburdened with different demands, since many organizations are small and have limited resources.
GS: How does CASFL collaborate with civil society to promote more effective NPO accountability? What type of accountability is required? To whom are NPOs accountable?
VP: CASFL collaborates by setting standards, providing training and guiding organizations on how to be accountable for the funds allocated. For the annual call for public funds to NPOs, CASFL elaborates the terms of reference for the call with overall requirements and criteria. A methodology gets then developed to evaluate the project applications where – based on the provisions of Article 93 of the Regulation No.40-08 of Law 122-05 – a set of variables are assessed, such as: History of NPO accountability (by reviewing whether the NPO applicant presented its reports in a timely manner based on the amount transferred in the previous period) and Justification of the use of public funds (by granting a deadline of no more than 90 days for the submission of their accountability reports).
We also evaluate the quality in the execution of the funds granted, by checking that the expenses reported correspond to the activities budgeted in the application and that they are aligned with the objectives and mission of the organization. On the other hand, we review the quality of the accountability of the funds granted, by examining that the administrative costs do not exceed the 20% allowed by law; and that the supporting documentation provided is in sync with the expenses reported in the NPO Integrated Management System, and that there are no payments to founding members of the organization for salaries or recurring costs. Each of these variables is associated to a set of indicators.
Currently, NPOs submit accountability reports to the Chamber of Accounts, to the sectoral public institutions and to CASFL. It is worth noting that both CASFL and the sectoral institutions review the accountability reportsthrough the SIGASFL platform.
Regarding public funds allocated to NPOs for 2022, 2,056 million pesos were granted, representing an increase of 11.7% of the budget as compared to the previous year; however there was a decrease in the number of recipient organizations, which contributes to reduce dispersion and improve the overall impact of the interventions. Likewise, 1388 applications were received and 756 NPO proposals were approved, allocating 32% of the funds for NPOs with projects linked to the Ministry of Public Health and Social Assistance, and 16% to the Ministry of Education – which are the most benefited sectors.
The CASFL establishes guidelines on accountability that are then incorporated and adapted by the sectoral public institutions in their projects with NPOs. NPO accountability is key to strengthen and promote the legitimacy of civil society, as well as to prevent political clientelism or partisan political use of the NPOs. Among the criteria used for the allocation of public funds, we examined the background of the organizations; their governance; their accountability in previous years; and the technical quality of their projects. With respect to the evaluation criterion on accountability track record, we examined whether the NPO met its accountability obligation in 2020 and/or 2021 through SIGASFL.
Based on an analysis of data collected by CASFL, 51% of the NPOs were up to date in their accountability reporting to the State, being the NPOs with projects associated to the Ministry of Tourism, Energy & Mines, Ministry of Women, CONAPE and the Ministry of Public Health the ones with the best scores. In addition, from 64 audits conducted to NPOs by CASFL during the first quarter of 2022, the following findings were identified: NPOs that have expenses without proper supporting documentation; NPOs with administrative expenses higher than 20% of the total costs; NPOs with late accountability reports; NPOs with payments made to their own board members; and NPOs with precarious accounting records.
CASFL seeks to ensure that NPOs embrace a culture of accountability, not only to donors or funders, but also to the communities where they operate. Yet, the latter is still an area for improvement in the future. To date, financial accountability has been prioritized, so we must go a step further and promote accountability for the results and impact of the actions or projects implemented by NPOs. This is key because the communities targeted by the work of NPOs should know about the results of these projects and provide feedback.
On the other hand, the institutionalization of social audit committees made up of communities members to verify the work reported by the NPOs is still pending, since the CASFL could only audit a sample of projects.
Last but not least, transparency is a prerequisite for effective accountability. Therefore, CASFL has embarked on making available a high volume of information on NPOs and funded projects by developing various dashboards on our website that provide publicly available online information. CASFL has also published a step-by-step accountability manual for NPOs. In addition, on the occasion of the recent celebration of the Integrity Week in the Dominican Republic, CASFL published the NPO Code of Ethics with the support of Alianza ONG, and then developed a self-assessment tool which is complemented by an action or improvement plan.
GS: How are NPO accountability reports being used, and by whom?
VP: Prior to my arrival at CASFL in August 2020, there was a disconnect between NPO accountability reporting and the decision-making process for public funds’ allocation and other matters. For example, an NPO could fail to be accountable yet a work plan was not developed to help it become accountable or a sanction was not applied (by interrupting funds to the NPO or removing it from the budget for the next year, being both measures established by Law 122-05).
Thus, there were no consequences; although this is sometimes difficult because several NPOs work with vulnerable groups or are small organizations with limited capacities, so it is difficult for public authorities to make tough decisions. However, the law must be complied with and public resources must be used properly. For this reason, CASFL has promoted training to strengthen NPOs’ accountability, while a regime of sanctions is applied when there is a lack of willingness to be accountable. CASFL has first encouraged NPO accountability, and then promoted better quality of the accountability reports. Also, I continuously use such data within public administration, in particular, in my interaction with the sectoral institutions.
GS: What are the future areas of opportunity for strengthening NPO effectiveness in the Dominican Republic?
VP: There are several areas of opportunity that should be pursued in the future. First, it is important to empower sectoral public institutions and for CASFL to provide them with the instruments so that they themselves can monitor the NPOs, as the sectoral institutions are the ones that know their organizations and are the first ones to benefit from these public-private alliances. Sometimes, CASFL assumes certain functions when the sectoral institutions are in the process of strengthening their own capacities, but this should be on a temporary basis.
Another area for further improvement is NPO accountability for the results and impact of the activities implemented, and how these activities have an effect or change in the communities targeted by the projects. In addition, it is necessary to move forward with the single-reporting system. In this regard, we need to complement the resources that each of us has and avoid duplicating efforts, by working in an integrated manner. Finally, the reputation of the organizations must be strengthened because there is some public perception that there are ‘ghost’ organizations which do not do the job. In this regard, civil society organizations are key to the consolidation of a democratic state and their growth and independence must be nurtured and promoted, by connecting them with spaces such as the Open Government Partnership (OGP) and others.