Request for Categorical Exclusion

TRACKING ID: LAC-IEE-18-06

ACTIVITY DATA

Activity Name: / Health Leadership Project
Amendment (Y/N): / N
Geographic Location(s) (Country/Region): / Haiti
Implementation Start/End: / 6/2018-9/2023
Solicitation/Contract/Award Number: / TBD
Implementing Partner(s): / TBD
Tracking ID/link:
Tracking ID/link of Related RCE/IEE (if any):
Tracking ID/link of Other, Related Analyses:

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):
(e.g. Mission or Bureau or Office) / Haiti/Health
Funding Operating Unit(s):
(e.g. Mission or Bureau or Office) / Haiti/Health
Funding Account(s): / GHP MCH, GHP POP, GHP State
Funding Amount: / $15,000,000[1]
Amendment Funding Date: / Amendment Funding Amount:
Other Affected Unit(s):
Lead BEO Bureau: / LAC
Prepared by: / Katie Qutub, Activity Planner
Date Prepared: / 10/16/2017

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: / Request for Categorical Exclusion
Environmental Determination(s): / Categorical Exclusion
Categorical Exclusion Expiration Date: / 12/2023
Additional Analyses/Reporting Required:
Climate Risks Identified (#): / Low __X____ Moderate ______High ______
Climate Risks Addressed (#): / Low __X___ Moderate ______High ______

THRESHOLD DECISION MEMO AND SUMMARY OF FINDINGS

PURPOSE AND SCOPE OF THE REQUEST FOR CATEGORICAL EXCLUSION

The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of health activities under the USAID/Haiti “Health Leadership Project,” and on this basis, to recommend determinations for these activities. Upon final approval, these recommended determinations are affirmed as 22 CFR 216 Threshold, and conditions become mandatory elements of implementation.

ACTIVITY SUMMARY

The overall purpose of the five-year Health Leadership Project (HLP) is to strengthen the Government of Haiti in its role as steward of the health sector, increasingly in control of its own necessary financial and human resources, over a coordinated system that is less reliant on external partners for equitable delivery of quality health services. This will be achieved by working in close collaboration with the Ministère de la Santé Publique et de la Population (MSPP), both at the central and departmental levels, to advance two interrelated objectives:

1. Build Government of Haiti capacity to lead and finance the health sector.

2. Improve Government of Haiti planning and oversight of the health workforce.

Together with USAID’s other investments in Haiti’s health sector, implementation of HLP is expected to incrementally advance the MSPP’s ability to sustain improved health outcomes.

ENVIRONMENTAL DETERMINATIONS

The threshold determinations for activities under this program are summarized below.
Categorical Exclusions
A Categorical Exclusion is recommended for those activities that have no adverse impacts on the environment. These activities, or classes of activities, fall under the following citations from 22 CFR §216.2(c)2. The environmental determination applicable to the Health Leadership Project is “Categorical Exclusion” per classes of actions, see Table 2 . Upon approval of this document, the determinations become affirmed, per Agency regulations (22 CFR 216).

Climate Risk Management

Since October 1, 2016, all new projects and activities are required to undergo climate risk screening per USAID guidance (https://www.usaid.gov/sites/default/files/documents/1868/201mal.pdf). This IEE provides a screening for broad health-related activities covered under the HLP (see Section 2.1). In addition, project implementers must include an analysis of climate risk related to activities, as well as consider the contribution of such activities to climate change. The implementer must also complete a climate risk screening matrix for its activities, which will be shared with the GCC/Climate Risk Management Facilitator, and further shared with the LAC BEO through the AOR.

IMPLEMENTATION

In accordance with 22 CFR 216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in Section 3 of this Request for Categorical Exclusions (RCE) and any BEO Specified Conditions of Approval.

Caveat:

While the above activities are categorically excluded from further environmental review, this RCE nevertheless recommends that environmental health and quality considerations be incorporated into all relevant steps along HLP implementation, as part of quality assurance and hygiene approaches. To this end, HLP has an opportunity to include solid waste management messages. Positive messages about proper disposal of refuse and other potentially harmful materials should be delivered, as appropriate. These messages should be included in training, meetings, protocols, and guidelines and the success of such messages should be monitored and documented in HLP’s reports. Considering that many meetings and training programs include food and refreshments for participants, USAID has the opportunity to recommend environmentally positive measures in the preparation and service of food and drinks, and to require that institutions comply with local environmental regulations.

USAID Approval Of Request for Categorical Exclusion

ACTIVITY NAME: Health Leadership Project

Clearance: / ______
Alyssa Leggoe, Health Office Chief / ______
Date
Clearance: / ______
Juan Carlos Martinez Sanchez, Acting Mission Environmental Officer and Climate Integration Lead / ______
Date
Clearance: / ______
Robert Clausen, Regional Environmental Advisor / ______
Date
Clearance: / ______
Brandy Witthoft, PCPS Office Chief / ______
Date
Clearance: / ______
Christopher Ryder, Regional Legal Officer / ______
Date
Clearance: / ______
Christian Barratt, Deputy Mission Director / ______
Date
Approval: / ______
Jene Thomas, Mission Director / ______
Date
Concurrence: / ______
Diane Shannon, Bureau Environmental Officer / ______
Date

1.0 ACTIVITY DESCRIPTION

1.1 Purpose and Scope of RCE

The purpose of this document is to establish that the proposed project and its activities belong to classes of actions eligible for Categorical Exclusions as set out in Agency regulations (22 CFR 216.2(c)) and that there are no foreseeable significant direct or indirect impacts that would preclude them from receiving a Categorical Exclusion. Upon approval of this document, the Categorical Exclusions are affirmed for the Activity. This analysis also documents the results of the activity-level Climate Risk Management process in accordance with USAID policy (specifically, ADS 201 mandatory reference 201mal). This RCE is a critical element of a mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation.

1.2 Project Overview

● Build Government of Haiti capacity to lead and finance the health sector.

● Improve Government of Haiti planning and oversight of the health workforce.

Together with USAID’s other investments in Haiti’s health sector, implementation of HLP is expected to incrementally advance the MSPP’s ability to sustain improved health outcomes.

1.3 Project Description

The HLP will be USAID’s key activity to support implementation of the Financing Strategy. The Financing Strategy will lay out a way forward for the three components of health financing - resource mobilization, risk pooling, and resource allocation and purchasing. The GOH is committed to improving health financing in order to net sufficient funding to meet population health needs without causing financial hardships. This means creating financial protection to avert financial catastrophe, especially for the poor, women, girls, and people with disabilities, as well as using resources more efficiently and effectively. This may also help lay the foundation for the new Haitian Administration’s goal of establishing a universal health insurance program. The existence of a health financing strategy will help the GOH regain its leadership role in financial planning, management and advocacy.

The Project will build on support to the MSPP to improve results based financing (RBF) implementation, which provides a unique opportunity for the MSPP and USAID to identify and address Public Financial Management (PFM) weaknesses in real-time and to learn-by-doing, while managing small amounts of funding. This tests the system’s fiduciary responsibility, allowing for identification of challenges and opportunities for capacity building. HLP will continue to strengthen financial management skills in the Budget and Administration Unit (DAB) and systematize financial management professional development in the MSPP from the central level and throughout the system.

HLP will work to improve financial regulations, capacitate the MSPP to manage and monitor the timeliness of the disbursement of funds for planned health system operations, and collaboratively resolve bottlenecks with key stakeholders. By the end of the project, public health facilities and MSPP at the central and department levels will manage more of their own resources. In the MSPP’s Planning Unit, UEP, the focus is on building the MSPP’s capacity to effectively plan its activities and track health resources. The Project will work with the MSPP to develop standardized norms and policies to strengthen the MSPP oversight of development assistance from various donors. Success in these efforts will build the capacity that the GOH needs to become Parliament’s trusted steward of health resources.

The HLP will build capacity of the MSPP to govern the health system at all levels. The objectives are to build GOH capacity to develop policies and procedures, regulate, manage, and monitor health system functions. By the end of the project, the MSPP will be more accountable to and transparent with the public and the interagency in its use of resources, and citizens, private sector organizations and government at all levels will engage more effectively with each other. Layers of government and the interagency will improve their collaboration in health. The GOH will institutionalize policies, procedures and regulations pertinent to health. Health policies will better reflect the health needs of vulnerable and marginalized groups.

With technical assistance from the HLP, MSPP will lead donor coordination with mutual responsibility and accountability and strengthen its role as steward over the health and well-being of the population. Building upon work USAID has supported with for the Global Fund to Fight AIDS, TB and Malaria Country Coordinating Mechanism and utilizing the Table Sectorielle, the HLP will help the MSPP in its ambition to lead and improve donor and partner coordination, as well as coordination among the Directorates within the MSPP. Standardized tools and processes to improve the operations of the whole health system may foster a more coordinated and harmonized approach to health service delivery.

The HLP will build GOH capacity to reform and revise policy frameworks and regulations for planning and management of health institutions/services, including private sector partners, with clearly defined rules, roles, relationships and distribution of resources for better results. The HLP will strengthen mechanisms for engagement with civil society organizations and community leaders to make the health system more transparent and accountable. The GOH will communicate key health issues to internal and external stakeholders to garner trust and collaboration in making improvements.

The HLP will support the GOH in implementing the new Human Resources for Health Strategy. This will include working with the GOH to develop profiles, classifications, qualifications and strengthening the required performance management systems, especially for the health workforce most critical to delivering the Essential Services Package. HLP will also support plans to transition health worker salaries from USAID to MSPP or private sector partners.

The Project will also support the GOH in its goal of developing a Community Health Worker (CHW) program. It will prepare the GOH to absorb the cadre by the end of implementation, as it will possess the necessary precursors for CHW and other cadres such as having an oversight/supervisory structure, projections of staff needs, a workforce in the pipeline at training institutions, and ready to implement costed strategies to improve retention. The HLP will perform this work in close collaboration with the USAID/Haiti Health Service Delivery Project, which is presently responsible for training and financing of the majority of Haiti’s CHW workforce. Collaboration with other donor-funded activities employing health workers is also encouraged.

The HLP will provide support to improve planning for distribution of health personnel and personnel management to increase coverage and productivity, including continuing to build the capacity of the MSPP Decentralization Unit (UADS) to strengthen the decentralized functions of the departments. The HLP will build on USAID’s support to the GOH in developing fit-for-need targets and costed action plans towards a more equitably distributed workforce. As two of the greatest challenges to workforce are distribution in rural areas and that doctors leave Haiti after finishing their training, the HLP will support innovative approaches to fill gaps in underserved areas. This may include activities such as a labor market analysis for the health workforce, which would help to better understand the drivers that motivate health workers.

TABLE 1: ILLUSTRATIVE SUB-ACTIVITIES

Activity / Health Leadership Project
Sub-activities / ● Technical Assistance (TA) to the GOH for strategy implementation.
● TA to GOH and civil society to build capacity to advocate for health. Analysis and technical assistance to the GOH in options for resource mobilization, pooling, and allocation.
● Assessing and monitoring approaches to ensure there is not a negative, unintended impact on women, girls, people with disabilities, people living in rural areas, or other vulnerable groups.
● Advising GOH on health finance, governance and human resources approaches that promote gender equity, covering priority health interventions for both men and women, boys and girls.
● Supporting the revision of related health policies and action plans to reflect gender-sensitive approaches, objectives and concrete actions.
● Providing shared-learning opportunities with MSPP, Ministry of Finance and others.
● TA to the GOH in establishing, fulfilling and monitoring core competencies for the health workforce. Institutionalizing health workforce professional development programs.
● Provide recommendations on organizational structures and processes for better management.
● Investigate fraud and inefficiencies in the health system.
● Collaborate with health actors to develop and implement a comprehensive plan for MSPP donor and interministerial coordination.
● Supporting the development of workforce policies and programs that challenge gender discrimination and transform gender relations.
● TA to transfer workforce and service contracts from implementing partners to GOH management.
● Support to strengthen coordination between public and non-state actors.
● Responding to the GOH needs for support to ensure pre-service education quality assurance.
● Support health workforce labor market analyses for forecasting and planning workforce, coupled with collaboration with training institutions to help them meet demands.
● TA towards development of National Health Workforce Accounts.

2.0 ENVIRONMENTAL ANALYSIS

2.1 Justification for Categorical Exclusion