102 Yakubu Gowon Crescent Telephone: (+234) 703 583 0641-4 Asokoro District (+234) 708 999 6090-1 P.M.B. 339, Garki Fax: (+234) 9 314 5267 Abuja, FCT Nigeria April 30, 2024 Ref: FMOFIER-240430-FGIP-F734 Mr. Wale Edun Honorable Minister of Finance and Coordinating Minister for Economy Federal Ministry of Finance Central Business District, Abuja, FCT ATTENTION: Mr. Stanley Nyeso George, Director, International Economic Relations Nigeria: Fiscal Governance and Institutions Project, Credit No. 62880 Implementation Support Mission March 19 – April 5, 2024 I appreciate the Federal Ministry of Finance’s support during the World Bank’s implementation support mission for the Nigeria Fiscal Governance and Institutions Project (FGIP) in Abuja from March 19 through April 5, 2024. The mission aimed to: (i) assess progress since September 2023; (ii) assess the government’s proposal for activities and results for extending and restructuring of FGIP beyond June 30, 2024; and (iii) provide guidance on the way forward. Additionally, the World Bank reviewed the Government Integrated Financial Management Information System (GIFMIS) to verify its functionality and identify constraints affecting financial tracking and decision-making on public financial management. The project continues to perform at a Moderately Satisfactory rating both on achievement of the Development Objective (DO) and Implementation Progress (IP). To maintenance or improve these ratings over the next two months, continued attention to the following key issues is required: Completion and submission for verification of the following Performance-Based Conditions (PBCs) no later than May 17, 2024: o PBC 2.3 – Cost-benefit analysis of tariff incentives on import and export duties (Technical Services Department, TSD). The analysis is completed but is awaiting publication on the FMoF website. o PBC 2.4 – FMoF formally sends the draft Tax Codification and Simplification Bill document through a Memo to the Federal Ministry of Justice (FMoJ) to prepare a Draft Tax Codification and Simplification Bill (TSD). The draft bill is being drafted by the Presidential Fiscal Policy and Tax Reforms Committee (PFPTRC). Upon completion of the draft, FMoF is to formally submit draft bill document to the FMoJ. The timeline for finalization of the draft by PFPTRS is unclear, therefore the PBC is at risk of not being achieved. o PBC 2.5 – Review of customs tariffs from the perspective of regional trade integration: impact analysis of the harmonization of exemptions; impact analysis of the Continental Free Trade Agreement completed (TSD). The analysis is completed but is awaiting publication on the FMoF website. o PBC 4.3 – Deployment of a National Budget Portal to publish Government of Nigeria’s (FGN and at least 20 States) approved budgets (BOF). Upon finalization of the data quality assurance, BOF needs to notify FMOF about their readiness for PBC verification. Mr. Wale Edun 2 April 30, 2024 o PBC 7.10 – National Strategy on Development of Statistics (NSDS) for 2024-2028 approved by NBS board (National Bureau of Statistics, NBS). The draft NSDS has been prepared and validation is scheduled at the end of April. After the validation NBS needs to finalize the NSDS, get it approved and notify FMoF about their readiness for PBC verification. Timely processing of withdrawal applications and payments. The Withdrawal Application for $11 million for PBCs achieved by the Office of the Accountant General of the Federation and the Office of the Head of Civil Service of the Federation, has been pending with IERD PCU for four months. This delay is slowing disbursement and should be resolved by April 30, 2024. During the mission, the government reiterated its interest in extending the project for 18 months. The FMoF has submitted a proposal to the Bank team, followed by a formal request detailing new results to be achieved in that period. The request prioritizes implementation of the central billing and revenue assurance system by FMoF and OAGF, strengthening management and coordination of the FMoF and enhancing government asset management and management of State-Owned Enterprises (SOEs). The proposed extension will need the approval of the World Bank Regional Vice President, with a final decision expected to be conveyed to government by mid-May 2024. Based on discussions during the mission any extension would be subject to the following parameters:  Twelve months maximum (through June 30, 2025).  Focused on a subset of core priority initiatives critical for the government to enhance its capacity to manage its financial position that enjoy strong government ownership and contribute to the project PDO. This includes the revenue assurance and centralized billing and disbursement initiative, strengthened management and coordination of FMOF priority initiatives on economic reforms and internal processes for improved FMOF performance, and implementation of the National Statistics Development Strategy.  Closure of the project implementation units and workstreams of the OAuGF, TSD (FMoF), BOF, BPP, OHCSF, and CAC, as of June 30, 2024.  Partial cancellation (approx. $25 million) of the expected unspent funds of $47.5 million as of June 30, 2024. Pending the final decision on the project extension, the government should begin preparing for the closure of subcomponents that will not be continue, even if extension is granted. To facilitate this process, government is requested to:  Not start any new activities under the following beneficiary agencies OAuGF, TSD, BOF, OHCSF, BPP and CAC, only activities completed on or before June 30, 2024, will be eligible for financing.  Prepare and submit before the end of June 2024 an Interim Project Completion Report (ICR) covering activities completed, results achieved, and lessons learnt to date.  Update the status of all procurements in the STEP system by April 30, 2024.  Document expenditures incurred for all TA resources withdrawn – all PIUs should Mr. Wale Edun 3 April 30, 2024 do it once a month.  Submit External Audit reports for 2023 to the World Bank by June 15, 2023.  OAuGF, BOF, TSD (via IERD PCU), OHCSF (via IERD PCU) CAC, BPP complete all payments for the activities completed by June 30, 2024, and refund any unspent IDA funds to the World Bank by October 31, 2024. The World Bank task team in collaboration with FMoF, OAGF and NBS will prepare and submit a restructuring package for managerial decision, proposing a 12- month extension to finance the most critical results of the new government, aligned with the FGIP Development objectives. The World Bank management decision will be communicated to the government by the mid- May 2024. For further details on the mission findings and next steps please refer to the attached Aide Memoire. Please accept the assurances of my highest regards. Sincerely, Shubham Chaudhuri Country Director, Nigeria Western and Central Africa Region Mr. Wale Edun 4 April 30, 2024 CC: Federal Ministry of Budget and Economic Planning  Senator Abubakar Atiku Bagudu, Honorable Minister Budget Office of the Federation  Mr. Ben Akabueze, Director General, Budget Office of the Federation Bureau of Public Procurement  Mr. Ahmadu Mamman, Director General, Bureau of Public Procurement National Bureau of Statistics  Prince Adeyemi Adeniran, Statistician-General of the Federation, National Bureau of Statistics Office of the Accountant General of the Federation  Ms. Oluwatoyin Madein, Accountant General of the Federation Office of the Auditor General of the Federation  Mr. Shaakaa Kanyitor Chiraghu, Auditor General of the Federation Office of the Head of Civil Service of the Federation  Dr. Folashade Yemi-Esan, Head of Civil Service of the Federation  Dr. Deborah O.N. Odoh, Permanent Secretary, SPSO Corporate Affairs Commission  Mr. Hussaini Ishaq Magaji, Registrar General, Corporate Affairs Commission Federal Ministry of Finance  Mrs. Lydia S. Jafiya, Permanent Secretary (Finance)  Ms. Fatima Hayatu, Director TSD, Federal Ministry of Finance  Mr. Stephen Ohaeri, Deputy Director, International Economic Relations Department  Mr. Babatunde Adebayo, Assistant Director, IERD, Federal Ministry of Finance  Mr. Fidel Odey, Lead Consultant, FGIP PCU, Federal Ministry of Finance IDA-IBRD  Ms. Ayanda Dlodlo, Executive Director for Nigeria, Angola and South Africa, IDA-IBRD  Ms. Zainab Ahmed, Alternate Executive Director for Nigeria, Angola and South Africa, IDA-IBRD  Ms. Gladys Anthony Ekwere, Senior Advisor to the Executive Director, Nigeria, Angola and South Africa, IDA-IBRD Mr. Wale Edun 5 April 30, 2024 Nigeria: Fiscal Governance and Institutions Project, Credit No. 62880 (P163540) Implementation Support Review March 19 – April 5, 2024 Aide Memoire I. INTRODUCTION 1. Between March 19 – April 5, 2024, a World Bank team conducted an implementation support mission for the Nigeria Fiscal Governance and Institutions Project (FGIP). The objectives of the mission were to: (i) assess implementation progress since the implementation support mission of September 11-23, 2023, and project restructuring completed in December 2023; (ii) assess the government’s proposal for activities and results for a possible extension and restructuring of FGIP beyond the current closure date of June 30, 2024; (iii) participate in the Project Steering Committee meeting to discuss the way forward on FGIP implementation. As a part of the mission the World Bank conducted a review of Government Integrated Financial Management Information System (GIFMIS) to confirm its functions in operation and limitations, constrain the government capacity to track their financial position and make informed decisions on public financial management. The list of the World Bank team mission members is provided in Annex 1. 2. The mission met with the FGIP Project Coordination Unit at the Department of International Economic Relations (IER) of the Federal Ministry of Finance (FMoF), and the following implementing agencies: Budget Office of the Federation (BOF); Bureau of Public Procurement (BPP); National Bureau of Statistics (NBS); Office of the Accountant-General of the Federation (OAGF); Office of the Auditor-General of the Federation (OAuGF); Technical Services Department (TSD) of the FMF; Office of the Head of Civil Service of the Federation (OHCSF); Corporate Affairs Commission (CAC). The mission appreciates the active participation of the agencies during the mission and specifically, Director IER, Mr. Stanley Nyeso George and his team. The draft Aide Memoire was presented and discussed with the FMoF during the mission wrap up meeting on April 5, 2024, chaired by the Permanent Secretary Finance (PSF). The final version of the Aide Memoire was endorsed by Bank management. The Steering Committee has not taken place during the time of the mission. II. PROJECT DATA AND RATINGS Table 1: Key Project Data and Ratings Project Data USD (millions) Original Project Amount $125 million Total Disbursement $ 52.19 million1 Disbursement in FY 24 $ 12.52 million Closing Date June 30, 2024 Project Ratings: Previous Current (September (February 2023) 2024) PDO MS MS 1 An additional $11 million has been authorized for disbursement but not withdrawn as of April 5, 2024, awaiting FMoF to submit a Withdrawal Application. Mr. Wale Edun 6 April 30, 2024 Project Ratings: Previous Current (September (February 2023) 2024) IP MS MS Project Management MS MS Financial Management MS MS Procurement MS MS M&E MU MS III. IMPLEMENTATION PROGRESS AND KEY FINDINGS Achievement of Development Objectives 3. The Project continued making Moderately Satisfactory progress towards achieving the Project Development Objective (PDO) based on the updated PDO indicators: a. PDO Indicator 1 - Non-Oil Revenue Outturn. Based on the preliminary OAGF fiscal report for December 2023, the indicator is partially achieved. While FAAC non-oil revenue outturn is estimated at 125.3% of budgeted revenues, FGN independent revenue is only 42.1% of budgeted revenue, bringing the indicator to an average of 81.5% of budgeted revenue and below the target of 85%. This indicates a deterioration of non-oil revenue performance in 2023 in comparison with 2022, when the indicator was overachieved with both FAAC non-oil revenue and FGN independent revenue actual collection exceeding 100% of the budgeted amounts. It is worth noting that the deterioration of the independent revenue outturn is explained by a significantly higher level of independent revenue approved in the FGN budget in 2023 in comparison with 2022, but actual collection was over 50% higher in nominal terms than in 2022. However, it also reveals institutional weaknesses in the FGN capacity to collect independent revenues – such as MDAs remitting revenues from multiple TSA sub-accounts, delays in remittance of revenues by MDAs and Government Owned Enterprises (GOEs) to the Consolidated Revenue Fund (CRF), exclusion of GOEs and foreign currency denominated inflows from Single Treasury Account (TSA). The FMoF issued a Finance Circular on December 28, 2023, to address weaknesses in the collection of Independent Revenues from fully funded, partially funded and self-funded Federal GOEs (FGOEs), providing guidance to FGOEs on compliance, utilization and remittances of internally generated revenue. To support the guidelines implementation the FMoF and OAGF have embarked on the development of a Central Billing and Revenue Assurance IT system - an integrated ERP Application as a centralized platform for managing MDAs and FGOEs revenue operations, thereby improving transparency, minimizing revenue leakages, and optimizing treasury management processes across the government. The FMoF has requested FGIP support for this system, should there be a project e extension. b. PDO Indicator 2 – Capital Expenditure Execution Rate. Based on the preliminary OAGF fiscal report for December 2023 the indicator shows slightly improved performance on capital expenditures execution, indicating a capital expenditure execution rate of 56.4% for the 2023 budget, compared to 51.7% in 2022. It is worth noting that the 2022 budget was extended through March 2023, and accordingly the 2023 capital expenditures calculated for purposes of this indicator started only in April 2023. It remains partially achieved against the target of 65%. Mr. Wale Edun 7 April 30, 2024 c. PDO indicator 3 – Publication of Reconciled Datasets has been fully achieved with publication of two datasets of the Labor Force Survey on August 24, 2023. However, Business Census data, initially planned to be published, is still pending, due to inconsistencies of sensitive data identified with other datasets. It will be published after the update is completed, and it is not likely to be completed before June 30, 2024. Table 2: Progress on PDO Indicators Baseline Previous Current PDO Indicator (as in Target Status Actual Actual PAD) 1. Non-oil revenue 64.9% 85% 111.8% 81.5% Partially achieved [TBC outturn based on final fiscal report for Dec. 2023] 2. Capital expenditure 40.6% 65% 51.7% 56.4% Partially achieved [TBC execution rate based on final fiscal report for Dec. 2023] 3. Publication of 0 6 4 6 Achieved reconciled fiscal and economic datasets Key Issues in Implementation Status 4. In December 2023 the closing date of the Project was extended through June 30, 2024, to ensure completion and verification of outstanding results under the current scope. The government also expressed interest in developing a proposal for new scope and activities toward the PDO which could be considered as part of an extended project within the financial envelope. 5. The Project maintains a Moderately Satisfactory Implementation Progress (IP) rating due to the achievement of additional results by OAGF, OHCSF and NBS for a total value of $14.2 million since the last Aide Memoire (dated October 22, 2023). An additional $3.2 million has been disbursed to the project since October 2023, bringing the total disbursement to date to $52.19 million (45% of total financing). Results achieved by OAGF and OHCSF in December 2023 to the value of $11 million is in the process of disbursement, and when completed, the total disbursement will be $63.19 million. As of March 27, 2024, the following 5 PBCs have been verified by the IVA and confirmed by the Bank as fully achieved, since the time of the last mission in October 2023: Component 2: Strengthening Controls, Transparency, and Accountability a. PBC/DLI3: DLR 3.1 - Pilot implementation of the bottom-up cash planning policy covering 30 percent of MDAS (Office of the Accountant General of the Federation - OAGF) – fully achieved, $5 million authorized for disbursement. b. PBC/DLI3: DLR 3.4 - Implementation of the commitment controls and cash management GIFMIS module covering 50 percent of MDAs (OAGF) – fully achieved, $5 million authorized for disbursement. Mr. Wale Edun 8 April 30, 2024 c. PBC/DLI 6: DLR 6.3 – The IPPIS HR module rolled out in an additional 11 core MDAs covering all staff in grades 12 and above (Office of the Head of Service of the Federation - OHCSF) - fully achieved, $1 million authorized for disbursement. Component 3: Strengthening Economic and Fiscal Statistics d. PBC/DLI 7: DLR 7.5 - Second round of Labor Force Survey completed (NBS) - fully achieved, $0.5 million disbursed to NBS. e. PBC/ DLI7: DLR 7.6 - First half of field work for the Nigeria Living Standards Survey completed (NBS) - fully achieved, $2.7 million disbursed to NBS. 6. Four additional PBCs with a total possible value of $2.2 million are currently under verification. During the mission the draft IVA report was available and shared with OAGF (for three PBCs) and NBS (one PBC) for comments. Upon their response, verification of these PBCs will be finalized and submitted to the World Bank. The three PBCs under Component 2 are OAGF PBCs on implementation of the FGN Fiscal Transparency Policy and Implementation Guidelines (2019): 3.5 on publication of selected fiscal reports for Quarter 1 and Quarter 2 of 2023 at the Open Treasury Portal (OTP) ($0.5 million), 3.6 on publication of selected fiscal reports at OTP for Quarter 3 of 2023 ($0.5 million) and 3.7 on publication of selected fiscal reports at OTP for Quarter 4 of 2023 ($0.5 million). These PBCs are likely to be partially achieved as the Central Bank of Nigeria (CBN) did not make Bank statements available, and the OAGF could not make unaudited, consolidated quarterly financial statements and reconciled Fiscal Reports available on OTP within the prescribed timeframe. While the issue with CBN has now been resolved, the OAGF still needs to reconcile the backlog of prior years’ transactions, which causes delay with reconciliation and publication of reports for 2023. Under Component 3 the NBS completed PBC 7.8 on the 3rd round of Labor Force Survey ($0.7 million) and the PBC has been verified as achieved. 7. An additional seven PBCs worth up to $7.5 million have been completed and submitted for verification. These include OAuGF PBCs 1.2 on revenue assurance audits of the Federal Inland Revenue Service (FIRS) and the Nigeria Customs Service (NCS) for 2018 ($1 million), 1.3 on revenue assurance audits of FIRS and NCS for 2019 ($1 million), 1.5 on revenue assurance audits of FIRS and NCS for 2020 ($1 million) and 1.6 on revenue assurance audits of FIRS and NCS for 2021 ($1 million); the BOF PBC 4.2 of at least two MDAs with largescale capital budgets compliance with the Public Investment Management guidelines ($1.5 million); and NBS PBC 7.7 on completion of the second half of the field work for the Nigeria Living Standards Survey ($1.3 million) and PBC 7.9 on completion of the 4th round of Labor Force Survey ($0.7 million). IVA Report 5, covering these PBCs, is expected to be completed by April 30, 2024. 8. The following five PBCs worth up to $7.2 million are yet to be completed, but it is necessary to complete them and submit for verification by May 17, 2024: a. PBC 2.3 – Cost-benefit analysis of tariff incentives on import and export duties ($1.5 million, TSD). Though the Trade Taxation and Customs Policy Study has been completed, the achievement requires publication of the study on the FMoF website. TSD committed to publishing the study by April 15, 2024, but this has yet to be done. b. PBC 2.4 – FMoF formally sends the draft Tax Codification and Simplification Bill document through a Memo to the Federal Ministry of Justice to prepare a Draft Tax Codification and Simplification Bill ($2 million, TSD). The PBC is at risk of not being achieved by June 30, 2024. Though the Domestic Tax Study, which informs the Bill, Mr. Wale Edun 9 April 30, 2024 has been completed, the Bill has now been taken up by the Presidential Committee on Fiscal Policy and Tax Reforms (PCFPTR), and the timeline for completion is unclear. c. PBC 2.5 – Review of customs tariffs from the perspective of regional trade integration: impact analysis of the harmonization of exemptions; impact analysis of the Continental Free Trade Agreement completed ($2 million, TSD). Though the Trade Taxation and Customs Policy Study have been completed, the achievement requires publication of the study on FMoF website. TSD committed to publishing the study by April 15, 2024, but this has yet to be done. d. PBC 4.3 – Deployment of a National Budget Portal to publish Government of Nigeria’s (FGN and at least 20 States) approved budgets ($1 million, BOF). The implementation continues with a delay. The software development has been completed, but BOF continues to undertake data quality assurance, and plans to complete the work and submit the PBC for verification by end of April 2024. e. PBC 7.10 – National Strategy on Development of Statistics (NSDS) for 2024-2028 approved by NBS board ($0.7 million, NBS). The implementation also continues with a delay. NBS has prepared the draft NSDS. Validation with government and non- government stakeholders is scheduled at the end of April 2024, and in May 2024 NSDS is planned to be approved and submitted for verification. 9. Three PBCs of $2.5 million in value will not be achieved before June 30, 2024: a. PBC 1.4 - IT audit of ITAS and ASYCUDA or NICIS for FY 2019 (OAuGF, $1 million) – OAuGF was not able to get access to the relevant IT systems. b. PBC 1.7 - IT audit of ITAS and ASYCUDA or NICIS for FY 2021 (OAuGF, $1 million) – OAuGF was not able to get access to the relevant IT systems. c. PBC 4.4 (b) – BOF implements a capital project tracking system for 10 MDAs (BOF, $0.5 million). In the course of implementation BOF identified bottlenecks preventing development of the tracking system, including a lack of mandate to undertake project tracking and a need to coordinate with the OAGF and relevant FMoF departments, as well as the need to have a policy in place requiring MDAs to provide geo-data tagging of projects, before the system is implemented. BOF has proposed including this requirement in the Draft Budget Implementation Guideline, but even if it is approved for implementation, there is no time to develop the system in coordination with other MDAs before June 30, 2024. The updated status of all PBCs is presented in Annex 2. 10. The majority of activities under TA have been completed by implementing agencies but a few activities were added or extended and will need to be delivered by June 30, 2024, by FMoF (TSD and IERD), NBS and OHCSF. Under Component 1, all TA activities have been completed. TSD indicated interest in conducting follow up workshops on findings of the Customs Policy and Trade Taxation and Domestic Tax Studies and submitted a draft Concept Note and cost estimates for the Bank’s review. Under Component 2, OAGF completed consultancy on GIFMIS Security Assessment in December 2023, and its findings informed the technical GIFMIS review by the Bank’s team conducted during the mission. OAGF would like and submitted a revised draft Concept Note and cost estimates to conduct training for government stakeholders on bottom-up cash planning. OHCSF completed development of training materials on performance management and intends to use them for the delivery of the training for Performance Management Champions in federal MDAs. The World Mr. Wale Edun 10 April 30, 2024 Bank encouraged OHCSF to make the training materials available to civil servants, including through the OHCSF web-site. OHCSF submitted an updated workplan for January – June 2024, and the World Bank provided No Objection for implementing activities to support roll out of IPPIS HR Module in 40 non-core MDAs, delivery of training on Performance Management to federal level MDAs and completion of ICT training. 11. The CAC launched the Register of Beneficial Ownership on May 25, 2023, and completed the contract with the vendor after making adjustments to the system based on user feedback. Compliance with timely reporting of Persons with Significant Control (PSCs) remains an issue: as of end February 2024, only 804,000 out of 2.1 million registered companies2 (38 percent) reported their PSCs. CAC is monitoring compliance in annual reporting and applies sanctions to those not found to be incompliance with the requirement to report PSCs. The Bank team encouraged CAC to continue monitoring and improving compliance to support the impact of the public disclosure of PSCs on reducing risks of corruption. 12. NBS has hired and extended through June 30, 2024, two individual consultants to support LFS and NLSS implementation and a consultant for media engagement. NBS has also submitted an updated workplan for January – June 2024, and the World Bank approved for implementation a number of workshops to support validation and launch of the National Statistical Development Strategy, sensitize stakeholders on the new NLSS and launch Full Year Nigeria LFS. It is critical for NBS to submit Concept Notes and cost estimates for World Bank No Objection at least 3 weeks before these events are planned. In addition, NBS requested to hire an individual consultant to support Consumer Price Index Rebalancing and shared draft ToR for the Bank’s review during the mission. To be able complete the assignment by June 30, 2024, the consultant needs to be procured no later than April 15, 2024. 13. Despite new activities added, overall utilization of TA funds is expected to be below the allocations made under the restructuring in June 2023 (see Table 3). About $10 million is expected not to be utilized by June 30, 2024. Table 3: FGIP - TA Disbursement and Utilization Expenditures documented Allocated Disbursed Agency (IFRs as of ($m) ($m) February 15, 2024, $m) FMoF PCU 6 5.42 0.46 TSD 2 - - OHCSF 1.5 - - OAGF 1 - - OAuGF 1 0.7 0.15 BOF 1.5 2* 0.92 BPP 5.5 0.5 0.28 2 It was also not clear how many companies out of registered ones are not active. Mr. Wale Edun 11 April 30, 2024 Expenditures documented Allocated Disbursed Agency (IFRs as of ($m) ($m) February 15, 2024, $m) CAC 0.4 0.37 0.37 NBS 9 9.63 9.11 TOTAL 27.9 18.62 11.29 *$1m out of $2m have been mistakenly disbursed to BOF as TA, rather than reimbursement for the achievement of PBC 2.2. During the mission BOF has submitted documentation to re- classify the disbursement transaction and it is currently being processed by the World Bank. 14. Implementation of BPP TA component continues to be stalled due to the unresolved dispute between BPP and the vendor, European Dynamics (ED) on the implementation of e-Government Procurement (e-GP) contract, and e-GP will not be completed by the current project closing date of June 30, 2024. The Adjudication decision guiding the next steps in completion of the contract was issued on February 15, 2024. During the mission BPP informed the Bank team that in spite of their effort to follow the Adjudicator’s decision, disagreements continued with the vendor and the dates established by the Adjudicator’s decision have lapsed. BPP is consulting the Attorney General of the Federation on the possibility of termination of the contract. The World Bank team requested BPP to inform the Bank about their decision in writing as soon as possible before April 30, 2024. BPP indicated their commitment to implement e-GP through alternative means, although this would not be done under FGIP. 15. The Bank team further requested BPP PIU to complete outstanding payments under on-going contracts and cancel activities (such as Change Management Consultancy) in the Procurement Plan that cannot be implemented due to delay of e-GP implementation. The Bank team reminded BPP that if the payments are not completed within the grace period of 4 months after the Project closing date of June 30, 2024, the Government of Nigeria will become responsible for all liabilities related to the Project. 16. FMoF IERD PCU has continued supporting the project implementation with accelerated capacity in procurement and coordination, but problems continue with contract management, payments and withdrawal applications. After the project extension through June 30, 2024, critical PCU consultancies including IVA contract and contracts of the Lead Consultant and Project Assistant were extended, but some of the contracts including External Auditor contract and OHCSF consultant contracts were not extended before closure of the original contracts and required opening of new contracts. The Project Report for July – December 2023 was submitted with a delay. Disbursement of $11 million for the results achieved by OAGF and OHCSF in December 2023 was still pending during the mission. The World Bank team reiterated the need to monitor contract implementation by contract managers closely and process extensions before contract closing dates. Timely payments have been affected by management changes and changes of signatories in CBN payment platform, but the majority of outstanding payments were completed by the start of the mission. Selected payments, including payment to an international consultant on GIFMIS Security Enhancement who completed the assignment in December 2023 is still outstanding and needs to be completed as soon as possible. Conversion from USD to Naira is still done on a transaction basis and this Mr. Wale Edun 12 April 30, 2024 contributes to payment delays. This issue as well as delays with withdrawals are covered in the Fiduciary section. Government Proposal for the Project Extension and Restructuring 17. During the mission IERD reiterated the desire of the FGN to extend the project by 18 months and submitted to the World Bank a proposal for new results. FMoF proposal included results in the following areas: (i) Implementation of the central billing and revenue assurance system by FMoF and OAGF. These results are associated with an ongoing Fiscalization and Revenue Project, implemented by FMoF, OAGF, CBN and the Nigeria Interbank Settlement System (NIBSS). The project pursues development and deployment of an integrated ERP Application as a centralized platform for managing MDA and Federal Government Owned Enterprises (FGOEs) revenue operations, thereby improving transparency, minimizing revenue leakages, and optimizing Treasury Management processes across the government. The proposed PBCs would: (1) incentivize establishment of a TSA sub account for foreign currency denominated inflows for FGOEs; (2) automate the remittance of revenues by FGOEs to the CRF in compliance with the split mandated by the December 28, 2023 Financial Circular; and (3) implement a digital solution for revenue assurance billing and collections that will further enable a revenue assurance dashboard providing real time account balances for MDAs and FGOEs. The application will further create a centralized disbursement solution that can enhance the implementation of bottom-up cash management. Proposed PBCs would incentivize the issuance and implementation of a Circular that would require OAGF to make payments for capital expenditures to vendors based on warrants issued by HMoF. (ii) Strengthened management and coordination of FMoF priority initiatives on economic reforms and internal processes for improved FMoF performance. This is planned to be achieved through the establishment of a Project Management Office (PMO) under the Permanent Secretary Finance (PSF), which will take responsibility for implementation of priority cross agency initiatives (e.g. Fiscalization and Revenue Project) and internal projects, focused on enhancing FMoF performance (e.g. implementing performance management in FMoF). As of now FMoF structural units are function based and they lack convening power to implement cross-agency initiatives. PMO will address this bottleneck. (iii) Enhancing Government Assets and State-Owned Enterprises (SOEs) Management. This set of results is associated with enhanced approaches to SOE management being implemented by FMoF through a reformed Ministry of Finance Incorporated (MOFI). The proposed results are focused on MOFI kick-off portfolio of 39 GOEs and government-linked companies and will cover development of National Asset Registry (NAR), SOEs portfolio management framework and enhancing corporate governance of SOEs. 18. The World Bank and FMoF FGIP team hosted a workshop on March 28, 2024, to discuss the proposed results. During the workshop the World Bank provided comments on the proposals and a follow up working session on clarification of potential results under the Fiscalization and Revenue Project was conducted on April 3, 2024. The proposed results which could inform PBCs under the potential extension are attached in Annex 3. 19. In addition, during the mission the World Bank conducted a technical review of GIFMIS to confirm the scope of GIFMIS operations and its limitations for tracking the Mr. Wale Edun 13 April 30, 2024 financial position in order to make informed decisions on public financial management. The review included critical issues of inter-operability with other government systems and the findings of OAGF’s recent GIFMIS Security Assessment. The GIFMIS technical review findings and recommended actions are presented in Annex 4. 20. During the mission NBS shared their action plan under the NSDS for 5 years and a specific set of results to be achieved in the upcoming 18 months. The World Bank reviewed and provided comments on the list during the mission. The results which can inform PBCs under the potential extension are reflected in Annex 3. 21. OAuGF’s proposal for new results is on performance audits of the management of the Anchor Borrowers’ Program by the Central Bank of Nigeria (CBN) from 2018 to 2023, administration/management of the Risk Sharing Fund by the Nigeria Incentive-based Risk Sharing System of Agricultural Lending (NIRSAL) PLC from 2018 to 2023, the Conditional Cash Transfer Program by the National Social Investment Program Agency (NSIPA) from 2018 to 2023 and the management of the Civil Service Pension by the PTAD and PENCOM. Proposed PBCs are reflected in Annex 3. The mission provided guidance that these results could not be included in a possible project extension as they were not core to the FGIP PDO. 22. TSD, OHCSF, CAC and BOF proposals were focused on TA needs related to the already achieved results rather than initiatives that can support the PDO through a new set of PBCs. Some of these activities such as workshops can be delivered before the current project closing date of June 30, 2024, or financed by the government to sustain the results achieved under FGIP. Fiduciary 23. The management of procurement activities continues to be Moderately Satisfactory. The Bank conducted a procurement session with all participating PIUs and reminded all the PIUs of the need to regularize documentation in STEP before the project closing. The list of all pending activities for STEP update was shared with all the PIUs before the mission. Since most PIUs have no ongoing contracts and most of their procurement activities have been already completed, all activities in STEP should have the process status marked as “Completed”. As of the end of the mission, only NBS PIU managed to have fully updated status in STEP. The World Bank requested BPP, BOF, OAuGF, CAC PIUs and FMoF PCU to complete update of the status of activities on STEP by April 30, 2024. 24. The overall FM performance is Moderately Satisfactory, and the overall FM risk rating remains Substantial. There is no outstanding unaudited interim financial report (IFR). The IFRs for the semester ended December 31, 2023, have been submitted by all the PIUs and PCU to the Bank. However, timeliness in submission of the IFRs remains an issue, with most of the PIUs submitting their IFR only after the deadline date. The mission encouraged the PIUs and PCU to make compliance with the submission deadline for IFRs a priority and request support when in need. Compliance with the June 30, 2024, submission deadline date for FY2023 audit reports was discussed during the mission and all the PIUs and PCU committed to prepare their annual financial statements by April 10, 2024, in readiness for the audit. 25. Disbursement for results achieved continued to happen with delays and accelerated implementation is not fully reflected in the disbursement ratio. This is partially due to challenges with access to Client Connection. During the mission the Bank task team assisted FMoF PCU in addressing the issue with preparation and submission of reimbursement withdrawal application in Client Connection. The Bank encourages the PIUs to monitor the status of withdrawal applications and report issues with access to Client Connection Mr. Wale Edun 14 April 30, 2024 immediately to the Bank task team. The Bank team encourages all PIUs to place their withdrawal applications for the results achieved within 10 days after they receive the Letter of Authorization from the World Bank. 26. Documentation of expenditures is not happening in a timely way. There is significant delay in the documentation of expenditures by the PIUs and PCU. During the mission a dedicated session was held with the PIUs and PCU on documentation wherein the requirement for at least once a month documentation of expenditures was reiterated and guidance provided on preparing withdrawal application for documentation in client connection. Following the session NBS, BOF, CAC and BPP recorded reduction in their outstanding documentation. Also, during the mission, hand holding was provided in resolving the issue of wrong classification of PBC reimbursement disbursement in the case of NBS and BOF. Two staff in OAuGF PIU are retiring in April 2024, and OAuGF is to update their Authorized Signatories Letter to be able to document the expenditures. 27. In-depth Fiduciary Review Findings. The review of the expenditures revealed inadequate supporting documentation for incurred expenditures amounting to NGN109,920,200.00 in the OAuGF. The OAuGF is preparing a response to be submitted to the World Bank by April 13, 2024. Table 4: Fiduciary – Key Points Item Rating Key Points (Trend) (- Accomplishments; x- Issues; ☼- Information) Procurement MS ☼ Contract management module should be updated with contract signing and contract completion details. In exceptional cases, there are a few new consultancy packages under implementation with contracts expected to be completed by end June 2024. Completion of procurement procedures and documentation is part of the project’s fiduciary obligations as stated in the financing agreement. ☼ BPP, BOF, OAuGF, CAC PIUs and FMoF PCU to complete update of the status of activities on STEP by April 30, 2024. Financial MS  FMoF PCU, CAC, NBS, BOF, BPP and OAuGF submitted Management & their IFRs for July 1- December 31, 2023. Disbursement X OAuGF to resolve issues of inadequate supporting documentation for incurred expenditures in the sum of N109.92m flagged in the in-depth fiduciary report on or before April 13, 2024.All FGIP PIUs are to prepare their AFS by April 10, 2024 in readiness for the annual audit and submit their audit report to the Bank by June 15, 2024. ☼ Documentation for expenditures incurred on DAs should be done by the PIUs and PCU at least once a month. ☼ All PIUs are to prepare cash forecasts until the Project closing date and, if necessary, submit WAs for TA advances before the end of April 2024. ☼ FMoF and OAuGF are to submit the WAs for documentation by April 20, 2024. Mr. Wale Edun 15 April 30, 2024 Item Rating Key Points (Trend) (- Accomplishments; x- Issues; ☼- Information) ☼ OAuGF is to update their ASL to be able to document the expenditures by April 20, 2024. ☼ All FGIP PIUs are to submit WAs for the future results achieved within 10 days from the date of receipt of the Letter of Authorization. Safeguards Performance 28. The project’s environmental risk level is Low being a category C project with no civil works activities, and environmental performance rating is Satisfactory owing to the low-risk nature of the project, utilization of renewable energy and commitment towards continuous improvement in safeguards performance. The project promotes the utilization of renewable energy in offices by procurement of solar panels and inverters. Since April 2022 inverters have been procured for the OHCSF and FMOF PCU. In February 2024 FMOF launched a procurement of an additional set of inverters. These offices are further urged to exercise due diligence in handling the inverters by ensuring proper ventilation in the storage areas and staff are not working in proximity to the batteries. The project required that FMoF and OHCSF ensure regular maintenance of these inverters and sharing the quality control certification in the project report, however Progress Report for July – December 2023 did not include information about quality control. The World Bank request FMoF and OHCSF report on the quality control procedures before April 30, 2024. The project is further urged to encourage good waste management practices in all offices by reducing, reusing and if possible, recycling office wastes such as stationery and appliances. To ensure safety of workers, the client is encouraged to promote the use of ergonomic chairs, ensure all offices are fitted with fire extinguishers and emergency preparedness procedures are developed and implemented. 29. The project activities by design do not give rise to any risk associated with land acquisition, gender-based violence, labor influx, social conflict etc., and the project social risk performance remains Satisfactory. To ensure full participation of all stakeholders, adequate stakeholder engagement and consultation has been integrated into the program activities particularly activities under components 1-3 of the project. This process builds on the already established citizen engagement and social accountability system using communication, sensitization, and awareness to engage stakeholders (beneficiaries and non-beneficiaries) on the benefit and objectives of the project activities. Since the last mission conducted in September 2023, stakeholder engagement activities were conducted by TSD on Domestic Tax Study and Trade Taxation and Customs Policy Study. This consultation process under the project will continue to be implemented throughout the project implementation phase while project activities will be monitored closely to ensure early identification and mitigation of any unintended social risk resulting from the project activities. 30. The World Bank team reiterated the importance of timely payments to vendors under the project and address complaints on payments delay with urgency. During the last mission in September 2023 the project through NBS has received a complaint which has to do with contractors on National Agriculture Sample Census, who have been not compensated in full for the work completed 6 months ago. NBS confirmed the outstanding payments have been made. In March 2024 FMoF PCU received a complaint from the International Consultant who completed GIFMIS Security Enhancement Review in December 2023 and has not been paid. The World Bank requested to complete the payment as soon as possible and respond to the Consultant with an update on the status of his payment. Mr. Wale Edun 16 April 30, 2024 Table 5: Environmental & Social Safeguards – Key Points Item Rating Key Points (Trend) (- Accomplishments; x- Issues; ☼- Information) Environmental S  The project has conducted stakeholder engagement and & Social consultation on Domestic Tax Study and Trade Taxation (E&S) and Customs Policy Study. Safeguards X FMoF and OHCSF report to the World Bank on regular maintenance of inverters and air quality control by April 30, 2024. X FMoF PCU is to complete the payment to the Consultant on GIFMIS Security Enhancement as soon as possible and update the Consultant on the status of his payment. ☼ The project is further urged to encourage good waste management practices in all offices by reducing, reusing and if possible, recycling office wastes such as stationery and appliances. NEXT STEPS AND AGREED ACTIONS 31. The World Bank noted the government desire to extend the project for 18 months and a new set of results proposed. The Bank’s team advised that this extension requires the approval of the World Bank Regional Vice President, and the final decision will be conveyed to government by mid-May 2024. 32. Based on the proposals discussed during the mission, any extension would be subject to the following parameters: a) Twelve months maximum (through June 30, 2025). b) Focused on a subset of core initiatives that enjoy strong support and momentum and are aligned with the PDO. This could include the revenue assurance and centralized billing and disbursement initiative, strengthened management and coordination of FMoF priority initiatives on economic reforms and internal processes for improved FMoF performance, and implementation of the National Statistics Development Strategy. c) Closure of the project implementation units and workstreams of OAuGF, TSD, BOF, BPP, OHCSF and CAC as of June 30, 2024. d) Partial cancellation (approx. $25 million) of the expected unspent funds, estimated at $47.5 million. 33. OAuGF, TSD, BOF, OHCSF, BPP and CAC are advised not to embark on activities with completion date beyond June 30, 2024, as only activities completed on or before June 30, 2024, will be eligible for financing. After the closing date, payments can continue to be made within the 4 months grace period for activities completed on or before June 30, 2024. Liabilities for any activity not paid for from IDA funds during the grace period are to be taken over by Government, any unspent IDA funds refunded to the World Bank and the bank accounts opened by the PIUs at the CBN closed. 34. The government is to prepare and submit their Interim Project Completion Report (ICR) for the subcomponents expected to be closed on June 30, 2024. The report Mr. Wale Edun 17 April 30, 2024 will need to be finalized and submitted to the World Bank by June 20, 2024. If the extension for 12 months is confirmed by the World Bank management, this can be included in the Project Progress Report for January 1 – June 30, 2024. FMoF PCU will need support in preparing the Interim ICR and will procure an individual consultant to assist with this task. The consultant needs to be procured by early May 2024. FMoF PCU will share draft ToR for an individual consultant with the World Bank team by April 15, 2024. 35. The FMoF is yet to submit a formal request for the project extension with the set of new results proposed to be financed with their cost estimates. These results are expected to be achieved and verified within 12 months from the current closing date, that is by June 30, 2025. 36. The World Bank task team will prepare and submit for the managerial decision a restructuring package, proposing 12 months extension to finance most critical results of the new government, supporting FGIP PDO, by the end of April 2024. The World Bank management decision will be confirmed to the government by the middle of May 2024. 37. The summary of agreed actions is reflected in Table 6. Table 6: Summary of Agreed Actions Actions Responsible Due Date High Priorities 1 External Audit for 2023: - Contract with External Auditor is signed IERD PCU April 10, 2024 IERD PCU - Implementing Agencies submit 2023 Project annual Audit Reports to WB & IAs June 15, 2024 2 FMoF sends an official request for the project IERD April 15, 2024 extension, which includes justification for the new scope of results 3 World Bank confirms management decision on World Bank May 15, 2024 the extension and restructuring of the project 4 Preparation of the Interim Project Completion IERD PCU Report: April 15, 2024 - IERD submits to WB draft ToR for an individual consultant to prepare Interim Project Completion Report - Interim Project Completion Report for the results achieved and sub-components June 20, 2024 closing on June 30, 2024, is submitted to WB Result-Based Conditions 5 IVA final verification report 4, covering IVA/IERD April 15, 2024 verification of PBCs 3.5, 3.6, 2.7 and 7.8 with PCU the notice of the results achievement, is submitted to the World Bank Mr. Wale Edun 18 April 30, 2024 6 Acknowledgement on the results achievement WB April 30, 2024 for PBCs covered in IVA Report 4 is issued by the World Bank 7 IVA final verification report 5, covering OAGF April 30, 2024 verification of PBCs 1.2, 1.3, 1.5, 1.6, 4.2, 7.7 and 7.9 with the notice of the results achievement, is submitted to the World Bank 8 Acknowledgement on the results achievement WB May 17, 2024 for PBCs covered in IVA Report 5 is issued by the World Bank 9 TSD submits for verification PBCs 2.3 and 2.5 TSD April 15, 2024 10 BOF submits for verification PBC 4.3 BOF April 30, 2024 11 TSD submits for verification PBC 2.4 TSD May 17, 2024 12 NBS submits for verification PBC 7.10 NBS May 17, 2024 13 IVA verification report 6, covering verification IVA/IERD June 10, 2024 of PBCs 2.3, 2.4, 2.5, 4.3 and 7.10 with the PCU notice of the results achievement, is submitted to the World Bank 14 Acknowledgement on the results achievement WB June 20, 2024 for PBCs covered in IVA Report 6 is issued by the World Bank Technical Assistance (TA) 15 TSD shares with WB for comments: TSD April 15, 2024 ‐ Draft final report on PPP Guidelines 16 OAGF shares with WB draft revised Concept OAGF April 15, 2024 for the workshop to follow up on recommendations from PBCs verification 17 OHCSF: OHCSF ‐ shares with WB the revised Concept for April 5, 2024 Performance Management training and ‐ delivers the training June 30, 2024 18 OHCSF ICT Skills Development Training: OHCSF ‐ OHCSF shares List of Participants for April 5, 2024 Module 4 19 OHCSF organizes for 40 non-core MDAs. OHCSF / ‐ Sensitization workshop IERD PCU June 30, 2024 ‐ User training 20 NBS signs the contract with a consultant on CPI NBS April 15, 2024 rebalancing 21 NBS shares with WB draft Concepts, programs NBS At least 3 weeks and cost estimates for the workshops approved in before the event their workplan in April – June 2024 date 22 BPP informs WB about their next steps with BPP April 30, 2024 implementation of e-GP contract IERD PCU 23 Outstanding payments for more than 30 days are IERD PCU April 15, 2024 completed Mr. Wale Edun 19 April 30, 2024 24 Weekly procurement and contract management IERD PCU / Weekly meetings are conducted TSD/ OHCSF/ OAGF/ WB 25 IERD completes Process Audit and Training IERD April 30, 2024 Needs Analysis Procurement and Financial Management 26 BPP, BOF, OAuGF, CAC PIUs and FMoF PCU BPP, BOF, April 30, 2024 to complete update of the status of activities on OAuGF, STEP CAC PIUs, IERD PCU 27 OAuGF submits the updated ASL OAuGF, April 20, 2024 IERD PCU 28 OAuGF resolves issues of inadequate supporting OAuGF April 13, 2024 documentation for incurred expenditures in the sum of N109.92m flagged in the in-depth fiduciary report 29 Documentation for expenditures incurred on IERD PCU/ One a month DAs should be done by the PIUs and PCU at all least once a month FGIP PIUs 30 FMoF PCU is to complete the payment to the IERD PCU April 15, 2024 Consultant on GIFMIS Security Enhancement as soon as possible and update the Consultant on the status of his payment 31 Submission of WA: ‐ IERD PCU submits Withdrawal April 5, 2024 Application for $11 million for OAGF and OHCSF results achieved in All IAs December 2023 Within 10 days ‐ WAs for future approved results from the date of receipt of the Letter of Authorization April 30, 2024 WA for TA advances before the end of the Project 32 OAuGF, BOF, TSD (via IERD PCU), OHCSF OAuGF, October 31, 2024 (via IERD PCU) CAC, BPP complete all BOF, CAC, payments for the activities completed by June 30, BPP PIUs 2024 and refund any unspent IDA funds to WB and FMoF PCU Environmental and Social Safeguards 33 FMoF and OHCSF report to the World Bank on IERD PCU, April 30, 2024 regular maintenance of inverters and air quality OHCSF control Annexes: Annex 1: List of officials met and composition of the World Bank team Mr. Wale Edun 20 April 30, 2024 Annex 2: Status of Results-Based Conditions Annex 3: Results Proposed for the Potential Extended Scope of the Project Annex 4: GIFMIS Review Findings Mr. Wale Edun 21 April 30, 2024 Annex 1: List of Persons Met and Composition of the World Bank Team S/N Name Designation Federal Ministry of Finance 1 Lydia S. Jafiya Permanent Secretary Finance 2 Stanley Nyeso George Director IERD 3 Stephen Ohaeri Deputy Director, IERD 4 Ogbonna Grace M. Director 5 Joseph Faluyi Director 6 Babatunde Adebayo Project Officer 7 Chinyere Oranezi Senior PO Procurement 8 James Ere Asst Project Accountant 9 Odinoye Friday Project Assistant 10 Fidel Odey Lead Consultant FGIP 11 Obuzor Alex Procurement Officer 12 Junaidu Musa Kalgo Procurement Officer 13 Aminu Umar Khalifa PAO 14 Shanyen Henry AD 15 Nuhu John PAO 16 Uche Eronini PAO 17 Faith John Budget Office of the Federation 18 Ben Akabueze Director General 19 Alfred Okoh Project Coordinator 20 Ginika Etison Osung Project Officer Olatunde Olusegun 21 Account Officer Sam Technical Service Department 22 Fatimah Hayatu Director 23 Haruna Ladan Assistant Director 24 Frank Oshanipin Assistant Chief 25 Igwe Jonas C. PAO Corporate Affairs Commission 26 Hussaini Ishaq Magaji Registrar General 27 Terver Ayua Project Coordinator 28 Osakwe Nkechi PIA 29 Yakubu Sembele Project Accountant 30 Yusuf Hassan Procurement Officer 31 Rasheed Mahe Public Affairs Officer 32 Sadiq Mohammed Ali CSO Mr. Wale Edun 22 April 30, 2024 33 Dorothy Ezeokonkwo Media Assistant 34 D.O Inyang Public Affairs Officer National Bureau Statistician Prince Adeyemi 35 Statistician-General Adeniran 36 Musa Muhammad Director 37 Elutade Akinloye Assistant Director, 38 Fafunmi Elisha Director, ICT 39 Audu Olokpo Director, Procurement 40 Odionye Oliver Chief Accountant 41 Babalola D.A. Director 42 Samuel Adakole Project Coordinator 43 Emuesiri Ojo TA to SG 44 I.N.D Wakili Director 45 Engr. Nicholas Ata Senior Procurement Officer Bureau of Public Procurement 46 Aliyu E. Aliyu Director 47 Nasir Bello Director 48 Adebowale Adedokun Director 49 Omotola Olusegun Director 50 Isiah Yesufu Director Joel Adeoye 51 Deputy Director Christopher 52 Robinson N.T. Assistant Director 53 Anyanwu O. Isiah Assistant Director 54 Abubakar R. Salihu Assistant Director 55 Elijah Barka Gituna E-GP Information 56 Kanu Praise E-GP Team 57 Timothy Njara Muje Assistant Chief Legal Officer 58 Mokuolu Adesina Procurement Officer 59 Amagbakhen O. Roland Project Accountant 60 Rabiat Ozigis E-GP Team 61 Suleman A. Audu PA 62 Ngozi Anyaelezu Principal Info. Officer Office of the Head of Civil Service 63 Dr. Deborah O. Odoh PS-SPSO 64 Azoro G.C Deputy Director (CSR-C) 65 Dada A.A Director (ICT) 66 Olatunji Madonna E. Deputy Director 67 Atta Anne Consultant (IPPIS) Mr. Wale Edun 23 April 30, 2024 68 Bello Sarki CSTD 69 Mani Yusuf SAO 70 Oko Emmanuel PAO 71 Fasulu Olatubosun SA-PS 72 Nkwonta O. Adaugo Admin 73 Uzor Uche Greg PA-IPPIS Office of the Accountant General of the Federation- GIFMIS 74 Ogundairo F. O Director (Revenue and Investment) 75 Emmanuel Danasabe GIFMIS Programme Manager 76 Joshua Daniel GIFMIS 77 Adeoti Olasukanmi GIFMIS Office of the Auditor General 78 Shaakaa Kanyitor C. Auditor General 79 Abbey Oweiziarerebo DFA 80 Mamwan Daniel DA-Procurement Officer 81 Ibrahim Zakari ADA 82 Babalola I. O DDA 83 Panni I. S DDA 84 Apotti S. A SA-Tech Ministry of Finance Incorporated 85 Oluwakemi Babalogbon Executive Director, Risk Management 86 Paula Faniran Head, Transformation management Office 87 Yasmin Ahmed Head, Portfolio Planning & Strategy 88 Zainab Ibrahim Portfolio Analyst 89 Rounbi Halliday Project Officer World Bank Team 90 Deborah Isser Lead Governance Specialist 91 Maya Gusarova Senior Public Sector Specialist 92 Cem Dener Lead Governance Specialist 93 Moses Kajubi Senior Public Sector Specialist 94 Ikechukwu Nweje Senior Public Sector Specialist 95 Akinrinmola Akinyele Senior Financial Management Specialist 96 Barbara Ziolkowska Senior Procurement Specialist 97 Helen Okeke Senior Operations Officer 98 Godstime Eigbiremolen Economist 99 Ugonwa Unaogu Public Sector Specialist (ETC) 100 Alhassan Bangura Consultant 101 Gideon Adogbo Consultant 102 Chinwe Ukpong-Bassey Senior Program Assistant Mr. Wale Edun 24 April 30, 2024 103 Lydia Jonah Inwang Team Assistant Mr. Wale Edun 25 April 30, 2024 Annex 2 Status of Performance-Based Conditions as of April 1, 2024 Achieved/ Under /ready for Expected to At risk/ requires Not Partially verification be met intervention Achieved achieved Amount Responsible PBC USD Status IA million PBC 1: Regular external audit reports for revenue oversight completed ($6.5m) 1.1 Revenue assurance audit of FIRS and NCS for 2017 OAuGF 0.5 Partially achieved (50%); disbursed 1.2 Revenue assurance audit of FIRS and NCS for 2018 OAuGF 1 Completed by OAuGF, under verification by IVA 1.3 Revenue assurance audit of FIRS and NCS for 2019 OAuGF 1 Completed by OAuGF, under verification by IVA 1.4 IT audit of ITAS and ASYCUDA or NICIS for 2019 OAuGF 1 Not feasible to achieve 1.5 Revenue assurance audit of FIRS and NCS for 2020 OAuGF 1 Completed by OAuGF, under verification by IVA 1.6 Revenue assurance audit FIRS and NCS for 2021 OAuGF 1 Completed by OAuGF, under verification by IVA 1.7 IT audit of ITAS and ASYCUDA or NICIS for FY 2021 OAuGF 1 Not feasible to achieve PBC 2: Revenue analyses institutionalized at the FMFBNP ($7.5m) 2.1 Analysis of tax expenditure completed BOF 1 Achieved and disbursed 2.2 A system for SOEs and parastatals budget monitoring and financial BOF 1 Achieved, disbursement is in progress performance management is completed and functioning Mr. Wale Edun 26 April 30, 2024 2.3 Cost-benefit analysis of tariff incentives on import and export duties TSD 1.5 Expected submission for verification by mid April 2024 2.4 FMoF formally sends draft Tax Codification and Simplification Bill document TSD 2 Expected submission for verification by (through a Memo) to the Federal Ministry of Justice to prepare a Draft Tax May 17, 2024, if the draft Bill Document Codification and Simplification Bill. prepared by FMoF and PCFPTR is finalized and ready to be submitted to the Ministry of Justice as required by PBC. At risk of not being achieved! 2.5 Review of customs tariffs from the perspective of regional trade integration: TSD 2 Expected submission for verification by impact analysis of the harmonization of exemptions; impact analysis of the mid April 2024 Continental Free Trade Agreement completed PBC 3: Enhanced utilization of the Financial Management Information System ($14.5m) 3.1 Pilot implementation of bottom-up cash planning policy in MDAs covering 30 OAGF 5 Fully achieved, disbursement is in percent of MDAs progress 3.2 Approval of policy for bottom-up cash planning for roll-out across FGN OAGF 0.9 Partially achieved (90%), in the process of disbursement 3.3 Migration of legacy assets and inventory items in the GIFMIS application for OAGF 1.9 Partially achieved (95%), in the process 85% coverage of assets and inventory of disbursement 3.4 Implementation of commitment controls and cash management GIFMIS module OAGF 5 Fully achieved, disbursement is in covering 50% of MDAs progress 3.5 OAGF publishes no later than July 30, 2023, and maintains on the Open OAGF 0.5 Draft report verified it as partially achieved. To Treasury Portal for FY2023 Q1 and Q2: be confirmed in IVA final report by April 10, a. Daily Payment Reports covering payments of at least NGN10 million outlining 2024 the MDA responsible, the beneficiary, purpose and amount of each payment. b. Monthly Budget Performance Reports generated by GIFMIS by MDAs, functions and economic activities performed, by all Federal Government Agencies c. Monthly Fiscal Accounts. d. Unaudited consolidated quarterly financial statements. Mr. Wale Edun 27 April 30, 2024 3.6 OAGF publishes and maintains on the Open Treasury Portal for FY2023 Q3: OAGF 0.5 Draft report verified it as partially achieved. a. Monthly Treasury Statements within 14 days of the end of the month. To be confirmed in IVA final report by April b. Daily Payment Reports covering payments of at least NGN10 million outlining 10, 2024 the MDA responsible, the beneficiary, purpose and amount of each payment. c. Monthly Budget Performance Reports generated by GIFMIS, within 7 days of the end of the month by MDAs, functions and economic activities performed, by all Federal Government Agencies d. Monthly Fiscal Accounts within 14 days of the end of the month. e. Unaudited consolidated quarterly financial statements, within 30 days of the end of the quarter. 3.7 OAGF publishes and maintains on the Open Treasury Portal for FY2023 Q4: OAGF 0.5 Draft report verified it as partially achieved. a. Monthly Treasury Statements within 7 days of the end of the month. To be confirmed in IVA final report by April b. Automated Daily Payment Reports covering payments of at least NGN10 10, 2024 Million outlining the MDA responsible, the beneficiary, purpose and amount of each payment. c. Monthly Budget Performance Reports generated by GIFMIS, within 7 days of the end of the month by MDAs, functions and economic activities performed, by all Federal Government Agencies d. Monthly Fiscal Accounts, generated fully by GIFMIS within 14 days of the end of the month. e. Unaudited quarterly financial statements by MDA and unaudited consolidated quarterly financial statements, within 30 days of the end of the quarter. f. Accountant General of the Federation issues a Treasury/Finance Circular requiring Government-owned Enterprises to publish and maintain Audited Financial Statements on their websites within the statutory timeline. PBC 4: Strengthened monitoring and evaluation of public investment projects ($7m) 4.1 Adoption by the Budget Office of the Federation of a guideline for PIM, as an BOF 3 Achieved, disbursement is in progress. annex to its 2022 Budget Circular 4.2 Compliance rate with PIM guidelines in at least two MDAs with largescale BOF 1.5 Completed by BOF, under verification by capital budgets IVA 4.3 Deployment of a National Budget Portal to publish Government of Nigeria’s BOF 1 Expected submission for verification by (FGN and at least 20 States) approved capital projects (including April 15, 2024 supplementary budgets, if any) 4.4 (a) Deploy GIFMIS capital/project module in 10 MDAs BOF 1 Achieved, disbursed. 4.4 (b) BOF implements capital project tracking system for 10 MDAs BOF 0.5 Not feasible to achieve. PBC 5: MDAs in compliance with improved procurement standards ($2m) 5.1 Signing of e-GP contract awarded through Open Competition BPP 2 Achieved and disbursed PBC 6: Improving controls and efficiency in the civil service payroll ($3m) 6.1 HR module rolled out in 12 core MDAs covering all staff grades 12 and above OHCSF 1 Achieved, disbursed. 6.2 HR module rolled out in additional 11 core MDAs covering all staff grades 12 OHCSF 1 Achieved, disbursed. and above 6.3 HR module rolled out in further additional 11 core MDAs covering all staff OHCSF 1 Achieved, disbursement is in progress. grades 12 and above Mr. Wale Edun 28 April 30, 2024 PBC 7: Generated and validated statistical datasets ($25.1m) 7.1 Business Sample Census completed NBS 10 Achieved and disbursed 7.2 1st round Labor Force Survey completed NBS 0.5 Achieved and disbursed 7.3 Field work for the agriculture census listing completed NBS 6 Achieved and disbursed 7.4 Agriculture sample census completed NBS 2 Achieved, disbursed. 7.5 2d round of labor force survey for completed NBS 0.5 Achieved, disbursed. 7.6 First half of the Nigeria Living Standards Survey completed NBS 2.7 Achieved, disbursed. 7.7 Second half of the field work for the Nigeria Living Standards Survey completed NBS 1.3 Under verification by IVA 7.8 3rd round of Labor Force Survey completed NBS 0.7 Verified as partially achieved in the draft IVA report. To be confirmed in the final IVA report by April 10, 2024. 4th round of Labor Force Survey completed NBS 0.7 Under verification by IVA 7.10 National Strategy on Development of Statistics (NSDS) for 2024-2028 NBS 0.7 Expected to be submitted for verification by approved by NBS board May 17, 2024. TOTAL PBCs 65.6 Achieved or partially achieved 1.1 (partially), 2.1, 2.2, 3.1, 3.2 (partially), 3.3 (partially), 3.4, 4.1, 4.4(a), 5.1, 6.1, 6.2, 6.3, 7.1, 7.2, 7.3, 7.4. 7.5 and 7.6: $46m Under verification or ready for verification 1.2, 1.3, 1.5, 1.6, 3.5, 3.6, 3.7, 4.2, 7.7, 7.8 and 7.9: up to $9.7m Under implementation 2.3, 2.5, 4.3, 7.10: $5.2m At risk of not being achieved 2.4: $2m Not feasible to achieve 1.4, 1.7, 4.4(b): $2.5m Mr. Wale Edun 29 April 30, 2024 Annex 3 Results Proposed for the Potential Extended Scope of the Project Implementation of central billing and revenue assurance system by FMoF and OAGF PBC 1 - A new TSA sub-account is established for Foreign Currency Denominated inflows covering at least 55 FGOEs. PBC 2 - Revenues of all FGOEs are split and automatically remitted to CRF/TSA-Sub Recurrent Account based on the relevant Finance Circular. PBC 3 – Payments to vendors under FGN budget capital expenditures are disbursed through a centralized process in GIFMIS. 3.1 A Circular introducing centralized disbursement processes is approved and issued by HMoF. 3.2 OAGF makes payments under FGN budget capital expenditures directly to vendors based on warrants issued by HMoF, in line with the government bottom-up cash planning policy. PBC 4 - Revenue Assurance Billing and Collections digital solution is implemented 4.1 Revenue Assurance Billing and Collection digital solution is piloted with 5 FGOEs and 10 MDAs. 4.2 Rollout of Revenue Assurance Billing and Collection solution to 55 GOEs and 100 MDAs is completed. 4.3 Revenue Assurance Dashboard which allows access to all federal MDAs and at least 55 FGOEs account balances in real time is developed and operational. Enhancing Government Assets and State-Owned Enterprises (SOEs) Management Development of a National Assets Register (NAR) PBC 1. Launch of a robust NAR registry showing the kickoff portfolio corporate assets (Portfolio companies – PCs), historical financial information, shareholding & corporate governance details. PBC 2. Availability of the NAR to the public through the Federal Ministry of Finance Website and the MOFI website. PBC 3. Availability of the Portfolio report detailing MOFI key activities for the year. Implementation of Governance Portfolio Policy PBC 4. Development of a robust document that details procedures for managing SOEs. The document will include: a) Publication of audited statements by PCs b) Performance management framework c) Provisions on merit-based appointment of independent directors to the boards of PCs PBC 5. Adoption and implementation of the performance management framework by at least 25% of the MOFI kick off asset companies. PBC 6. Development of a Corporate Governance Scorecard & Implementation by SOEs PBC 7. Development and implementation of a robust portfolio management and reporting system to aid the management of the SOEs. Mr. Wale Edun 30 April 30, 2024 Strengthened Management and Coordination of FMoF Priority Initiatives on Economic Reforms and Internal Processes for Improved FMoF Performance Establishment of a Program Management Office (PMO) – Delivery Unit, which take responsibility for implementation of priority cross agency initiatives (e.g. Revenue Assurance and Centralized Disbursement Project) and internal projects, focused on enhancing FMoF performance (e.g. implementing performance management in FMoF). NBS Results associated with National Strategy for Statistical Development PBC 1. Completion of Quarterly Job Creation Surveys (4 Quarters) PBC 2. Completion of Annual Establishment Survey including Listing and Updating of the Business Register PBC 3. Completion and Release of Quarterly Nationwide Labor Force Surveys (5 Rounds), including the publication of the results with the Microdata in line with the NBS Data Release Calendar (only supplementary resources matching the budget allocated) PBC 4. Production of an SDGs Tracking Report PBC 5. Deployment of First Phase of System of Administrative Statistics (Key Federal MDAs) PBC 6. Production of State GDP OAuGF Results on performance audits PBC 1. Performance audit of the management of the Anchor Borrowers’ Program by the Central Bank of Nigeria (CBN) from 2018 to 2023 PBC 2. Performance audit of administration/management of the Risk Sharing Fund by the Nigeria Incentive-based Risk Sharing System of Agricultural Lending (NIRSAL) PLC from 2018 to 2023, PBC 3. Performance audit of Conditional Cash Transfer Program by the National Social Investment Program Agency (NSIPA) from 2018 to 2023 PBC 4. Performance audit on the management of Civil Service Pension by the PTAD and PENCOM. Mr. Wale Edun 31 April 30, 2024 Annex 4 Findings of the Review of the Federal Government of Nigeria (FGN) Government Integrated Financial Management Information System (GIFMIS) 1. Background. GIFMIS is a complete financial management system which covers major financial management activities including budgeting, expenditure management, and reporting of the Federal Government of Nigeria (FGN). The solution was custom developed for the FGN by an Estonian software firm (Nortal) based on requirements submitted to the vendor. It is a web-based application developed using Java development technology running on underline Oracle 12c database. The application and the Oracle database was delivered as one-off (perpetual) license, whereas Oracle Support license runs annually. 2. GIFMIS runs as an integrated system comprising of:  Application subsystem o GIFMIS application o Exchange server (mail service) o Active Directory  Database subsystem o Oracle database (housing transactions data) o PostgreSQL (housing reporting data)  Network subsystem  Infrastructure subsystem 3. While GIFMIS application and Oracle Database run on Linux, the other subsystems such as Microsoft Email Exchange and Active Directory Services run on Windows 2016 Server. Both operating systems run on annually paid support licenses. All application, database and network subsystems generate loads of activity logs suitable for determining health status and other related transactional investigation. By end March 2024, the application user license count was 32843 active users with concurrent access. The GIFMIS user account is unlimited, mainly due to the custom developed application of which the intellectual ownership is the FGN. 4. GIFMIS went live on 2nd of April 2012 with a pilot at Ministries of the FGN. Later on, as per the rollout phased approach, the application has been successfully rolled out to all MDAs (800+) of the FGN, excluding Federal Government Owned Enterprises (FGOEs), The National Assembly, The Judiciary, and Foreign Missions. The application is hosted centrally at the Office of the Accountant General of the Federation (OAGF) and via web access, users at MDAs access the application to record their transaction and execute their budgets. The Disaster Recovery Site (DRS) is located at Gombe State (500+km from Abuja), North East Region of Nigeria. Currently, there is no maintenance contract in place. Information is that OAGF is waiting on the National Security Agency (NSA) to give clearance for the GIFMIS supplier to be in country to engage the OAGF on maintenance contract and enhancement of the system. 5. GIFMIS review. On March 19-29, 2024, the World Bank team, comprised of Cem Dener, Lead Governance Specialist and Global GovTech Lead, and Alhassan Bangura, Consultant, conducted GIFMIS review with the objective to confirm GIFMIS functionalities in operation, gaps and bottlenecks undermining credibility in public financial management, and improvements that would address these gaps. The World Bank’s team also followed up on the status of implementation of cash management, supported by FGIP, and OAGF Performance Mr. Wale Edun 32 April 30, 2024 Based Conditions (PBCs) on implementation of FGN Financial Transparency Policy and Implementation Guidelines (2019). 6. GIFMIS Status. The review was conducted through documentary review and interviews of key stakeholders in OAGF, including a live demonstration of GIFMIS functioning modules. It was verified the below listed modules/functionalities are configured and operational:  Appropriations- budget planning and execution  Procurement- purchase requisitions and goods receipt  Payables- commitments & obligations and non-commitments expenses  Receivables- receipting, sales invoices and periodic invoices  Cash Management- cash planning, warrants and payments/disbursements  Accounting- general ledger, journals, reporting, etc.  Inventory- store management  Assets- acquisition, valuation, depreciation, disposal  Master Data Management- configuration of CoA, controls, access rights, etc. 7. Treasury Single Account (TSA). The TSA is designed with Consolidated Revenue Fund (CRF) and TSA-Sub-Recurrent accounts are maintained by the OAGF. The MDAs maintain Sub-TSA accounts and those accounts are mainly for non-budgeted items, such as aid and grant, revolving fund and receipts and payments. All MDAs Sub- TSA accounts are linked to the FGN CRF, therefore, at any given time, the OAGF and CBN are in a position to know the cash position of the FGN. 8. Links with other government IT systems. Personnel expenditures are processed in the Integrated Personnel and Payroll Information System (IPPIS), but there is no interface of IPPIS and GIFMIS. The business operation is that monthly emoluments are processed in IPPIS and the outcome of the IPPIS payroll is then recorded in GIFMIS (personnel budget expense by MDA). This is then consolidated by the OAGF as part of the monthly cash needs of the FGN. When the payroll warrant is approved by the cash management policy committee- chaired by the HMoF, the warrants are then disbursed by officials of the IPPIS through GIFMIS. In summary, the role of GIFMIS for personnel payments, is to record MDA personnel expenses against their budgets and then IPPIS officials through GIFMIS disburse the funds to the personnel accounts (net pay) and deductions to the respective deductions receiving entities (pensions, insurance, etc.) via the Remita interface (GIFMIS and CBN data exchange). 9. Currently, the GIFMIS has a functioning interface with the below listed systems:  CBN - via Remita platform. This platform is used to process payment requests from GIFMIS to CBN and then CBN to third party. The first leg of the interface is GIFMIS to CBN (cash and bank). The second leg of the interface is CBN to third party (beneficiary).  FIRS - validation of supplier details as part of supplier registration in GIFMIS. The FIRS’s tax administration system (ITAS) has an interface with GIFNMIS that validate supplier information when a vendor is created in GIFMIS. In GIFMIS, there are mandatory fields required as part of vendor registration and validation and data for such fields (supplier TIN, address, etc.), are populated via the ITAS interface. 10. There is an ongoing plan for GIFMIS and new DMO IT system integration. The new DMO system is in development and the current status of this could not be determined as the DMO is expecting experts from the Commonwealth Secretariat to visit Abuja and provide advice in April 2024. Request for system utilization/loading, status of audits trail was made to Mr. Wale Edun 33 April 30, 2024 the GIFMIS team. As at time of GIFMIS review by the World Bank team, the report was yet to be received. A follow up with the OAGF will be done. 11. GIFMIS Limitations/Important Gaps. Though the application modules are operational, some of the limitations observed are:  Budget implementation planning. With the introduction of bottom-up cash management, the GIFMIS should be enhanced with a capability for budget implementation planning. This functionality would then be aligned with the various procurement milestones of capital expenditures to determine quarterly future cash needs. Currently, the bottom-up cash management is addressing monthly cash needs - this is good as the first step in this reform. An interim mitigation to this is the use of Microsoft Excel templates. The cash management technical secretariat at the OAGF has in place an excel worksheet to consolidate the manual submissions of budget implementation plan by MDAs. MDAs are issued with an excel template to manually prepare their budget implementation plan and transmit via email to the secretariat. The manual consolidation (800+ MDAs) is a daunting tasks that is manually done and has no linkage with GIFMIS. With a quarterly cash needs approach, the GIFMIS and DMO would be in a position to align the borrowing schedules which would then enhance the borrowing plans of the FGN in alignment to expected quarterly disbursements.  Foreign currency operations. Currently, the GIFMIS is not developed with capability to record and process foreign currency operations. The application is mainly developed to handle Naira based operations for both budget planning and budget execution. Hence, it is limited in terms of capability scope to handle transactions outside the Naira based operations, except an exchange rate is applied and journal entries recorded.  Operational Acceptance. It was found out the OAGF issued a provisional operational acceptance certificate to the GIFMIS vendor. The provisional acceptance was issued with list of defects to be resolved by the vendor after which, a full operational acceptance certificate will be issued. It could not be determined the status of those defects and it hoped the OAGF consider those defects in the planned GIFMIS enhancement arrangements.  Source Code. The GIFMIS vendor is required to hand over the source code to the OAGF. This is a fundamental requirement for custom software development. To-date, the source code is yet to be delivered by the vendor. The OAGF is advised to prioritize the delivery of all source code (application and all custom developed materials) during the enhancements discussions with the vendor. 12. OAGF progress on achievement of results under FGIP. The review followed up on the status of cash management implementation. In December 2023 two PBCs related cash management were verified as fully achieved. Pilot implementation of bottom-up cash planning policy has been undertaken in 71 percent of 641of MDAs, including 90 percent of 20 MDAs with the highest budget expenditures. Of these, 54 percent demonstrated consistent operation of the GIFMIS cash management module. However, some recommendations were provided by IVA and the World Bank followed up on these recommendations during the review. The IVA report recommended to enhance the GIFMIS cash management module by (i) improving the consolidation process and ensuring that timely submissions of cash plans by MDAs are duly acknowledged; (ii) reducing manual interventions in checking the downloaded reports; and (iii) strengthening the GIFMIS system controls for the timely submission of cash plans and budget requests within the ceilings established in the approved MDA budgets. It was found out during the review that time stamp of transaction is maintained. This was verified at the warrant review and approval process within GIFMIS. At each stage of the workflow, the user action and Mr. Wale Edun 34 April 30, 2024 processes are timestamped from the initiation up to the approval/issuance of warrant. The warrant is the consolidated cash plans, with cash limits of each entity’s cash need for the period. A meeting/discussion was held between the OAGF and IVA on Thursday 4th April 2024. Purpose of the meeting/discussion was for OAGF and IVA to discuss PBCs currently under verification (PBC3.5 – PBC 3.7). 13. Capital expenditures management. All capital expenditures are recorded in GIFMIS. Such expenditures are captured either as a (1) Contract (2) Purchase Requisition (3) Job Order. In either case, a commitment is recorded against each expenditure type as legal commitments and upon delivery and acceptance of goods or services, the legal commitment is then transitioned to a financial commitment. The financial commitment is an obligation and at each MDA, transactions that are at financial commitment stage are then used to prepare the cash plan/needs by each MDA. The OAGF then consolidate the cash needs/plans at a national level and then submit for approval and issuance of warrants. The approved warrants are then used to fund the MDAs cash needs, while MDAs are responsible for disbursement of funds released for capital budget execution. Centralization of capital budget disbursement in OAGF can improve the timely disbursement of capital expenditure which will in turn improve capital expenditure execution rate. 14. GIFMIS Security. The review team also followed up on findings and recommendations of GIFMIS security enhancement review, undertaken by OAGF GIFMIS team under FGIP in October – December 2023. As a part of implementation of the security recommendations, the OAGF has developed a draft version of an information security policy document for the OAGF. This document in its current draft state has coverage of most of the audit recommendations, and it is planned to be discussed at a national security retreat/workshop to be held with key security institutions of the FGN. Once this is done and the document is finalized, it shall then be issued for use and enforcement across the OAGF. Some aspects of the recommendations of the GIFMIS security enhancement review can inform PBCs and activity work plan if the FGIP extension is approved. 15. Revenue Assurance and Billing. During the review, the team learnt about a new revenue assurance, billing and payment IT system, being developed by FGN. It is hoped this system will improve collection and reporting on independent revenues and payments, which will then improve on the TSA operations across the federal government. The system is expected to include a dashboard facility that will be displaying real-time financial information and access shall be granted to the FMoF, OAGF, FGOEs, and MDAs. Restrictions shall be configured that FGOEs and MDAs shall be restricted to view only financial information related to their respective institutions, while global access shall be granted to the FMoF and OAGF. 16. Recommendations. To improve the government capability to manage FGN finances, the following priority actions are recommended based on the review conducted: a. Complete GIFMIS operational acceptance as soon as possible and obtain the source code from the vendor. b. Consider enhancing GIFMIS with a capability for budget implementation planning and capability to record and process foreign currency operations. c. Develop interfaces with DMO. d. Implement centralized disbursement capability for capital budget to allow OAGF make payments under FGN budget capital expenditures directly to vendors based on warrants issued by HMoF, in line with the government bottom-up cash planning policy. Mr. Wale Edun 35 April 30, 2024 e. Implement revenue assurance and billing solutions to improve TSA operations across FGN. f. Finalize, approve and implement OAGF Information Security Policy as guided by the GIFMIS information security audit recommendations.