Monday, May11, 2020 / 07:39 AM / by OAGF / Header Image Credit: Ecographics

1. Introduction

The rapid spread of Coronavirus and the resulting highfatality rate due to absence of a vaccine and cure have created a global healthemergency never seen in generations. COVID-19, the disease caused byCoronavirus, has been classified as a pandemic by the World Health Organization(WHO). It is now both a public health emergency and an economic catastrophe. Ina bid to curtail its spread and impact, Nigeria like most countries in theworld, is implementing total lockdown.

Around the world, governments are channellingresources towards fighting the pandemic and the hardship it imposed oncitizens. The private sector has also stepped in to support government effortswith generous financial and material donations.

In Nigeria; the organized private sector, wealthyindividuals and ordinary citizens are rising to the occasion through financialand material donations for the provision of critical medical facilities andequipment as well as palliatives for vulnerable citizens. According to astatement by the Central Bank of Nigeria (CBN) on Friday, April 17 2020;donations to the Private Sector Coalition Against COVID-19 (CACOVID) Funddomiciled at the CBN was N25.8 billion.

Inaddition to the main CACOVID Fund Account with CBN; Mr. President has approvedthe opening of five COVID-19 Donor Accounts which form part of the existing TSAarrangement in the following commercial banks:

a)Zenith Bank

b)Access Bank

c)Guarantee Trust Bank,

d) UBA;and

e)First Bank.

2. Scope of the Framework

ThisFramework covers all public funds allocated and dedicated to the fight againstCOVID-19 including the Fiscal Stimulus Package. It also applies to alldonations by corporate bodies and individuals to the Federal Government ofNigeria towards the fight against COVID-19 and the mitigation of its social andeconomic effects on citizens at large including donations under the PrivateSector Coalition Against COVID-19 (CACOVID) Fund domiciled at the CBN . Lastly,it provides clarity on the operation of the five newly opened COVID 19 DonorTSA Sub-Accounts domiciled in commercial banks.

3. Objective of the Framework

FederalGovernment recognizes citizens expectation that these resources be prudentlyapplied towards the fight against COVID-19. In accord with citizensexpectations, Government is committed to managing these funds with the highestsense of transparency and integrity.

ThisFramework is therefore designed to articulate the measures put in place byGovernment for the transparent and accountable management of COVID19 DonorFunds as an expression of its commitment towards bridging the trust gap.

4. Scope of Commercial Bank TSA Sub Account

The TSASub Account in commercial banks are to be used for the purposes of receivingCOVID-19 donations only. On no account shall any other fund of FederalGovernment Ministries, Departments and Agencies (MDA) be deposited into theaccounts or any other account in commercial banks. All other government accounts are to be maintained at theCentral Bank of Nigeria (CBN) in line with the Presidential directive on TSA,the TSA Guidelines and related extant Circulars.

5. Visibility of Collections

Allaccounts with commercial banks are to be linked with the TSA at CBN to providea single consolidated view of aggregate Government cash balances. This willprovide a single window for real time access to details of receipts andpayments across all commercial bank accounts. In the absence of a ready tool toaccomplish this requirement, the current CBN Payment Gateway may be deployed.

6. Sweeping of Funds to Sub-Recurrent Account at CBN

Allcollections into the Commercial bank accounts are to be swept into FGNSub-Recurrent Account with the CBN. Failure to sweep all balances within 24hours shall be deemed a violation of the Presidential directive on TSA whichshall attract sanctions.

7. Disbursement

Disbursementsof all COVID 19 Fund including those being collected directly by CBN and thosedomiciled with commercial banks shall be through appropriation.

TheHonourable Minister of Finance, Budget and National Planning may liaise withthe National Assembly for emergency passage of a supplementary budget for theutilization of COVID-19 donation based on estimated total collection for theyear.

Fundsare to be appropriated directly to participating MDA and spending units likeMinistry of Health, Ministry of Humanitarian Affairs, Nigerian Centre forDisease Control, etc rather than to an intermediary agency like thePresidential Task Force (PTF). Administrative cost of the PTF shall beappropriated separately to the PTF Secretariat.

The advantageis that the respective spending units and their Accounting Officers take fullresponsibility for funds appropriated to them and likely bottlenecks at the PTFare eliminated. Furthermore, transparency is enhanced when funds are spread tomore MDA than when a huge amount is put under the control of a single entity.

Giventhat there is a national emergency to which everyone including NASS is investedin addressing, there is no doubt that NASS will be willing to fast track itspassage. This will bind all spending units to the Appropriation Act and, infact, provide the greatest measure of credibility and transparency to themanagement of the donation.

Toensure equity and transparency in fund allocation, the HMFB&NP may workwith the PTF to determine the needs of participating MDA such as Health,Humanitarian Affairs, NCDC, etc.

AffectedMDA shall present details of their needs together with estimated cost. Thiswill form the basis for allocation of funds and enables post expenditurereporting and audit. Funds are to be transferred to TSA Sub Accounts ofspending units based on approved allocations.

8. Accounting

Forcollection of donations and disbursements therefrom, a new line for COVID 19Donations under Fund Source segment is to be added to the Chart of Accounts.This will make it possible for all receipts and payments relating to COVID 19Fund to be uniquely tracked and reported.

Iffunds are to be disbursed based on NASS appropriation, then all payments are tobe effected using GIFMIS.

Wherethe extra-budgetary option applies, MDA shall spend using the REMITA platform

In allcases; extant laws, rules and regulations including those relating to PublicProcurement Act (subject to the guidance of the Bureau for Public Procurement)shall apply.

9. Reporting

WhereGIFMIS is used, Fund based Budget Performance reports shall be generated foreach participating MDA using all applicable segments to provide additionallevel of details and transparency. Otherwise, MDA are to prepare the reportsmanually providing all relevant details similar to a standard BudgetPerformance report or Expenditure Return at the SubAccount Class level ofdetails [A draft format will be provided for guidance].

10. Financial Transparency Policy

All therequirements of the Financial Transparency Policy of the Federal Governmentshall be complied with.

Foravoidance of doubt the following shall strictly apply:

a) TheOffice of the Accountant General of the Federation shall publish a DailyTreasury Statement for COVID-19 Fund outlining all the inflows into the Fundand all the outflows. The inflow information shall indicate the source of thefunds while the outflow information shall indicate the MDA responsible for eachpayment out of the Fund.

b) Eachparticipating MDA shall publish a Daily Payment Report indicating theBeneficiary, Purpose of the Payment and the amount for any payment above N5million made out of the COVID-19 Fund.

c) Thepublications in 9 (a) and (b) above shall be made on the Open Treasury Portal (www.opentreasury.gov.ng) not laterthan one week following the respective transaction. In addition each MDA shallpublish a detailed report of its activities relating to COVID-19 Fund on itswebsite at the end of every week.

d) TheMonthly Budget Performance Report for the COVID-19 Fund shall be published onthe Open Treasury Portal not later than 14 days following the end of the month.

e) Inaddition, a comprehensive report of all receipts and payments shall bepublished on the OAGF Transparency Portal as well as other Government websitesincluding those of Federal Ministry of Finance, Budget and National Planning;Secretary to the Government of the Federation and Office of theAccountant-General of the Federation (OAGF) not later than two weeks followingthe end of the pandemic.

Furthermore,it is mandatory for all participating MDA to provide information on all COVID-19Fund transactions to any member of the public - individual or corporate - underthe Freedom of Information Act (FOI) within 7 days of receiving the request.

Failureto publish timely report of COVID-19 activities in the prescribed format and atthe stipulated intervals or to respond to FOI request will constitute earlywarning signs of mismanagement and shall be deemed as contravention of thisGuideline.

11. Audit

InternalAudit procedures shall apply to all transactions relating to COVID19 Funds. Inthe event that, due to the urgent nature of expenditures under this Fund,proper pre-payment audit was not carried out or even where proper pre-paymentaudit was carried out; Internal Auditors are mandated to carry out detailedpost-payment audit and review of all transactions and to promptly forward theirreports to the Audit Monitoring Department of OAGF.

A copyof their report shall be sent to the TSA Department to test the adequacy of theoverall TSA architecture in re-enforcing internal controls and blockingleakages.

InternalAuditors are also to ensure that published reports give true and fair view ofthe underlying transactions and accounts.

InternalAuditors are further reminded that they have enormous role to play in ensuringthat these funds are prudently spent, and optimum value-for money achieved.

AnyInternal Auditor that encounters any challenge in the discharge of his dutiesunder this Guideline should immediately report to the Accountant General of theFederation in writing for the attention of Director, Audit Monitoring. A copyof the report shall be sent to Director, Treasury Single Account.

12. Contravention of Guidelines/Sanctions

ParticipatingMDA are reminded that the COVID Fund is a public fund in the truest sense ofit. For that reason, the public is invested in ensuring that the funds areutilized in the most transparent and prudent manner. For this reason, anyparticipating MDA that contravenes this Guideline may be sanctioned fromcontinued participation in the programme. Also, the names of the MDA and itsprincipal officers shall be made public as additional measure of transparency.

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