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Financial Management Assessment

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Financial Management Assessment Shanxi Inclusive Agricultural Value Chain Development Project (RRP PRC 48358) FINANCIAL MANAGEMENT ASSESSMENT A. Executive Summary 1. The financial management assessment (FMA) was conducted in accordance with the Asian Development Bank’s (ADB) Guidelines.1 The FMA considered the financial management capacity of the Shanxi Provincial Government (SPG), the executing agency (EA); the 17 project county governments, the implementing agencies (IAs); and the 19 project agribusiness companies and cooperative (PACs), the project implementation units (PIUs). The assessment covered funds flow arrangements, staffing, accounting and financial reporting systems, internal and external auditing arrangements, and financial information systems. 2. The Shanxi Provincial Finance Department (PFD), particularly its international division, as the project imprest account holder, has sufficient financial management experience for donor- funded projects, including ADB project loans. The PFD has disbursed over $1 billion of the ADB loans involving the sectors of transport, agriculture, power, and environment to date. The FMA identified the main financial management risks at the level of the implementing agencies and PIUs. 3. The FMA identified the main financial management risks as follows: (i) implementation risk—the IAs’ and the PIUs’ lack of familiarity with ADB’s disbursement procedures and requirements which could delay project implementation; (ii) compliance risk—the IAs’ and the PIUs’ lack of familiarity with ADB’s financial management requirements, particularly on accounting, reporting, and auditing which may delay project reporting and derail identification of issues on the use of loan proceeds; (iii) foreign exchange risk—the IAs’ lack of experience in managing foreign exchange that might increase the financial burden to the potential depreciation of Chinese yuan. The overall financial management risk rating of the project before considering mitigating measures is moderate. 4. The identified financial management risks will be closely monitored during project implementation. The financial management action plan is as follows: Table 1: Proposed Action Plan for Financial Management Action Agency Timing Recruitment of experienced consultant EA Upon the loan effectiveness Development of financial management manual(s) EA, consultant 2 months after the loan effectiveness Training on ADB’s financial management requirements, ADB, EA, 3 month after the loan including accounting and auditing, loan disbursement, and consultant effectiveness foreign exchange risk management to the IAs and the PIUs ADB = Asian Development Bank, EA = executing agency, IA = implementing agency, PIU = project implementation unit. Source: Asian Development Bank. 5. The EA and the IAs will enhance their coordination and capabilities by (i) setting clear institutional arrangements; (ii) recruiting a financial management consultant; (iii) undertaking training on ADB’s disbursement and financial management requirements for all financial management staff; (iv) developing uniform financial management handbook(s) for the budgeting, accounting, internal controls, reporting, and auditing arrangements in line with project activities; (v) streamlining of approval processes of the use of the loan proceeds; and (vi) close monitoring of loan covenants and compliance status during project implementation. With these appropriate mitigation measures, the project financial management arrangements are considered satisfactory. 1 ADB. 2005. Financial Management and Analysis of Projects. Manila; ADB. 2009. Financial Due Diligence: A Methodology Note. Manila; and ADB. 2015. Financial Management Technical Guidance Note: Financial Management Assessment. Manila. 2 B. Methodology Being Used for the Assessment 6. The FMA was conducted in accordance with ADB’s Guidelines on the Financial Management and Analysis of Projects 2 and the Financial Management Due Diligence: Methodology Note.3 The FMA questionnaire (FMAQ) was used as a tool to collect necessary information for the FMA from the EA, the IAs, and the PIUs. The responses to the FMAQs were reviewed; and the financial staff of the EA, the IAs, and the PIUs were interviewed to ensure that the FMAQs had been correctly understood and responded. The conclusions of the FMA were drawn based on the corrected responses to the FMAQs. C. Financial Risk Assessment Table 2: Financial Management and Internal Control Risk Assessment Risk Risk Type Assessment Risk Description Mitigation Measures Inherent Risk Assessment Country specific M The lack of capacity at municipal Reinforce currently ongoing support risk and county level may both hamper in assessing and strengthening the effective financial control and public financial management constrain the shift of focus from capacity at subprovincial level controlling inputs to managing through skills training, knowledge results. sharing, and organizational reviews Entity specific risk M Financial management and internal The EA to provide assurance that control in place, but there may be a necessary control will be in place delay in withdrawal application for and ensure proper coordination the ADB loan. mechanism to enhance processing of ADB’s disbursement Control Risk Assessment Implementing M Some IAs do not have experience The EA will develop a set of Agency with the ADB loan and financial management regulations management of foreign currency specifically for the project before risks. the effectiveness of the project. Training and assistance from the EA will be provided to mitigate the foreign currency risk. Funds Flow L The IAs’ and the PIUs’ lack of Training will be conducted before familiarity with ADB’s disbursement loan effectiveness to ensure that requirements and procedures the IA and the PIU staff acquire the required knowledge. Staffing L Staff are in place and are Training provided by ADB and the adequately qualified; but most of project management consultant them, except staff from the EA and team support in capacity building a few IAs, have previous and development, especially in experience in financial procurement, disbursement, and management and are familiar with project monitoring and reporting ADB’s guidelines and policies. requirements. Accounting and L None An accounting policy and Reporting procedures manual for the PIUs will be drafted, covering the national accounting standards and the requirements of ADB. Internal Audit L None Develop the financial management manual 2 ADB. 2005. Financial Management and Analysis of Projects. Manila. 3 ADB. 2009. Financial Due Diligence: A Methodology Note. Manila. 3 Risk Risk Type Assessment Risk Description Mitigation Measures External Audit L The IAs are audited by the Consolidated financial statements Provincial Audit Offices every year. will be audited by the Shanxi Provincial Audit Office, which has rich experiences with the ADB projects. Reporting and L Financial reports are prepared Prepare financial reports in monitoring using cash-based accounting accordance with accrual-based systems. accounting system established by the requirements of ADB and the Ministry of Finance. Training will be provided for the accrual-based accounting system. Information L Financial reports are generated by The EA and the IAs will use stand- Systems the computer system. Imprest alone computerized accounting account will be generated system. Control mechanism will be manually. provided on imprest account reconciliation. Overall Risk M ADB = Asian Development Bank, EA = executing agency, H = high, IA = implementing agency, L = low, M = moderate, PIU = project implementation unit, S = substantial. Source: Asian Development Bank. D. Summary of Strengths and Weaknesses identified and their related risk mitigations 7. Overall, the organization structure, experience, and number of qualified accountants of the EA and the IAs are appropriate for the project management. The accounting policies and procedures, budgeting, and audit arrangements applied to the project by the EA, the IAs, and the PIUs are in place. The project can rely on the prevailing structure and system for its fiduciary arrangements in required quality with necessary mitigation actions taken to address identified weaknesses. 8. Although SPG and its agencies has implemented and is currently implementing a number of foreign-funded projects, some of the IAs and all PIUs do not have experience in managing foreign-funded projects. Currently SPG, the Shanxi Provincial Finance Department (PFD), and the Shanxi Poverty Alleviation and Development Office (SPADO) have limited staff to financially manage the project given the significant number of the IAs and the PIUs. It was suggested to hire a qualified external financial management consultant to assist and support the EA, the IAs, and the PIUs to provide the necessary financial management capacity, especially on disbursement, project monitoring, and reporting requirements. There are existing accounting policies and procedures, and the financial management system and controls are in place in the EA and the IAs. However, the IA and the PIU staff need proper guidance on ADB’s requirements; thus, it is recommended that the EA will develop a financial management manual based on the requirements of ADB and the Ministry of Finance (MOF) on project accounting and financial reporting, including appropriate internal control and coordination mechanism. E. Country and Sector Financial Management Issues 9. The country partnership strategy (CPS) for the People’s Republic of China (PRC),
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