Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) Report Number: ICRR0023406 1. Project Data Project ID Project Name P163560 Benin ACCESS Country Practice Area(Lead) Benin Social Protection & Jobs L/C/TF Number(s) Closing Date (Original) Total Project Cost (USD) IDA-D3430 30-Jun-2022 38,003,085.42 Bank Approval Date Closing Date (Actual) 06-Jul-2018 30-Jun-2022 IBRD/IDA (USD) Grants (USD) Original Commitment 40,000,000.00 0.00 Revised Commitment 40,000,000.00 0.00 Actual 38,003,085.42 0.00 Prepared by Reviewed by ICR Review Coordinator Group Judith Hahn Gaubatz Salim J. Habayeb Eduardo Fernandez IEGHC (Unit 2) Maldonado 2. Project Objectives and Components DEVOBJ_TBL a. Objectives According to the Financing Agreement (page 4) and the Project Appraisal Document (PAD, page 12), the project objectives were as follows:  To improve access to decentralized basic social services and social safety nets, and to strengthen the social protection system. Page 1 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) b. Were the project objectives/key associated outcome targets revised during implementation? No c. Will a split evaluation be undertaken? No d. Components (Note: "Actual" amounts are approximate, as the final amounts were reported in CFA francs). 1. Improving Decentralized Service Delivery (Appraisal: US$ 23.8 million; Actual: US$ 21.1 million): This component aimed to improve the delivery of basic services at the decentralized level. Activities included: fiscal transfers to local governments (communes) to be used for investments contained in their Commune Development Plans; and technical assistance to national and local institutions, and the communes, to implement the investments. 80% of the transfers would fund grants to communes for single-community level investments, executed through a community-driven development (CDD) approach; the remaining 20% of the transfers would fund grants to communes for multi-village level investments. 10% of the former type of grant was to be allocated on a first-come, first-served basis to communes that opt to delegate responsibility for execution of an investment to communities on their own initiative. Eligible expenditures included projects in the areas of education, health, rural roads, and market infrastructure. There was a particular emphasis on education by supporting classroom construction, in collaboration with the Education Sector Infrastructure Construction Agency. 2. Social Safety Nets and Social Protection Systems (Appraisal: US$ 12.8 million; Actual: US$ 9.5 million): This component aimed to scale up the safety nets pilot initiated under the prior Bank-supported project and strengthen the social protection system. Activities included: unconditional cash transfers to all targeted poor households (through community identification); labor-intensive public works for those same households to provide an opportunity to earn an additional transfer during the agricultural lean season; training and microentrepreneurial support to those households; and development of a National Social Registry. 3. Project Management (Appraisal: US$ 3.4 million; Actual: US$ 3.9 million): This component supported project management and coordination. e. Comments on Project Cost, Financing, Borrower Contribution, and Dates Project cost  The project cost at appraisal was US$ 40.0 million. The actual project cost at completion was US$ 38.0 million. Financing  The project was financed entirely by an IDA grant of SDR 27.6 million (US$ 40.0 million equivalent). Page 2 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) Borrower contribution  There was no planned Borrower contribution. Dates  July 2018: Project approval.  January 2019: Project effectiveness.  November 2020: Mid-term review.  June 2022: The project closed as planned. 3. Relevance of Objectives Rationale Benin is a small West African country with a per capita income of US$800 (2016) and a total population of approximately 10 million. Despite political stability, significant agricultural potential, and moderate GDP growth in the past two decades, Benin remains a low‐income country. According to the National Institute for Statistics and Economic Analysis (INSAE), national headcount poverty rates have stagnated over the past decade, moving from 37.5% in 2006, to 35.2% in 2010, and 40.1% in 2015. While progress has been made in recent years to improve access to basic services, Benin still faces large gaps in service coverage, especially in poor and remote areas, amidst a context of low capacity at the commune level (including in budget execution). The government adopted a decentralization framework, in which the 77 communes have the responsibility for the delivery of key basic services including primary education, health, water, local roads, and social assistance. However, other than a small number of urban communes, most communes have low levels of own revenues with which to finance development activities. Therefore, the government’s mechanism for transferring resources to communes - FADeC (Fonds d’Appui au Développement des Communes) is a critical source of financing for decentralized services. The Government Action Plan (GAP) for 2021-26 identified one of three priorities to increase the social welfare of the population in a sustainable way. Similarly, the Bank's Country Partnership Framework for FY19-23 identified the improvement of social protection systems as a key objective, with the number of households enrolled in the national social registry as a key indicator. Rating Relevance TBL Rating High 4. Achievement of Objectives (Efficacy) Page 3 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) EFFICACY_TBL OBJECTIVE 1 Objective To improve access to decentralized basic social services Rationale The theory of change for this objective was clear. Fiscal transfers from the national government to local communes were to be used for investments identified in their Commune Development Plans, such as projects in the areas of health, education, rural roads, and market infrastructure. All 77 communes were eligible to participate, although communities within the communes were selected by means of a poverty map and an index measuring access to services and poverty. Utilization of a community driven development approach was likely to increase ownership, relevance and sustainability of the projects. Capacity building support was also likely to lead to the intended outcome of increased access to basic services. Outputs  Fiscal transfers to communes to provide grants (maximum of US$S 42,000) for single-community level projects, of low complexity and covering a single village or urban neighborhood.  Fiscal transfers to communes to provide grants (average of US$ 51,000 based on an allocation formula) for multi-village level projects, of higher complexity and covering multiple communities.  Technical assistance to Ministry of Decentralization and Local Government (MDGL) to support targeting methodology, implementing the CDD approach, and supervising decentralized service delivery.  Capacity building to National Commission for Local Finance (CONAFIL) to facilitate fiscal transfers.  Capacity building to communes on procurement, CDD, and also the Grassroots Management Training (GMT) program on the entire project cycle (information and communication, community organization, participatory evaluation of poverty, participatory planning, participatory monitoring and evaluation, procurement, financial management, and maintenance). 600 local government officials in all 77 communes received training in procurement, which contributed to 51% of communes (target: 20%) showing improvement on their annual procurement audits by the end of the project. 225,370 community members were trained in GMT (target: 70,000). These led to the creation of several community associations, of which 51% were led by women (target: 40%). Outcomes  380 community infrastructure projects were carried out, surpassing the target of 360. These included 23 health facilities (target: 20), 515 classrooms (target: 400) and 95 school canteens (target: 80). The ICR (page 24) reported that the government had asked to remove water-related interventions from the project (since it was introducing a national water plan to connect the different villages to water sources), which led to facilities being disconnected from water sources. The ICR did not specify which facilities were disconnected but noted during field visits that the canteens were still not connected to water sources, thereby negatively impacting handwashing and cooking.  31,939 students were enrolled in schools constructed/ rehabilitated by the project, surpassing the target of 21,000.  2.0% of domestic revenues were transferred by the government to communes through FADeC (on top of the project's financing of fiscal transfers), falling short of the target of 4.6%. The ICR (pages 13-14) Page 4 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) reported that this is mainly due to the sharp increase of the denominator from baseline to closing, as domestic revenues grew significantly following the efforts to enhance tax collection. Tax revenues grew from 6.3% to 7.0% of GDP between 2019 and 2021, and GDP grew from US$12.7 billion in 2017 to US$17.59 billion in 2021. Although the budget of FADeC decreased relative to revenues, it did increase in absolute terms. (Note: The ICR (page 14, footnote 9) reported that official statistics for these budget figures were not available at the time of writing of the ICR). However, there were no outcomes reported for access to other basic services such as health care or markets. Achievement of this objective is Substantial due to surpassing of targets in subproject implementation and student enrollment, although the target for percentage of domestic revenues transferred by government to communes fell short in percentage terms though not in absolute terms. Rating Substantial OBJECTIVE 2 Objective To improve access to social safety nets Rationale The theory of change for this objective was clear. Unconditional cash transfers, conditional cash transfers based on labor-intensive public works, and accompanying measures (microentrepreneurship training) were likely to provide a safety net for the poorest households. These programs were a scaling up of activities piloted in a predecessor Bank-supported operation. These activities were likely to contribute to the intended outcome to increase access to social safety nets for the poorest households. The program covered 180 communities in 16 communes across all 12 departments. Outputs  Unconditional cash transfers in the amount of 5,000 CFA per month for 24 months. 100% of payments were made within five days of due dates.  Labor-intensive public works (offered to the same households) to provide additional predictable transfers (1,000 CFA per day for two years) during the lean agricultural season (to encourage beneficiary households to avoid negative coping decisions, such as withdrawing children from school). The public works resulted in 1,768.2 km of rehabilitated roads, removal of 145 illegal trash dumps, cleaning of 35 public spaces, and upgrading of 170 hectares of community agricultural land. 100% of public works schemes were completed with satisfactory technical quality. 81.25% of total cost of the public works projects were allocated to wages (target: 70.0%).  Community identification of poor households and public works projects. 100% of safety net transfers were received by households ranked as poor or extremely poor through proxy-means testing. Page 5 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560)  Microentrepreneurial training including preparation of a simple business plan with support from facilitators, and a grant of CFA 25,000 to launch a business activity or expand an existing activity. Outcomes  19,216 households received unconditional cash transfers, surpassing the target of 18,000. This represented approximately 100,000 people. Due to the delay in establishing the National Social Registry (see Objective 3 below), there was only 18 months before the closing date to complete the full 24 months of cash transfers. Therefore, the remaining six months of cash transfers were provided in tranches, timed to have a positive effect on the beneficiaries’ productive inclusion activities supported by the project. The first tranche coincided with the completion of training on income generating activities, to allow for a capital infusion to boost economic activities; the second tranche was disbursed after having carried out the income generating activity for a short period. Overall, however, the significantly delayed delivery of cash transfers (by more than 24 months) created a critical time lag for the targeted poor populations, who still received the cash transfers but likely did not realize the full benefits of such support.  Of the above, 17,812 households participated in the additional labor intensive public works, surpassing the target of 16,200.  Of the above, 12,006 households received microentrepreneurial training, surpassing the target of 9,000.  An evaluation of a sample of about 4,000 households of the 12,006 households receiving support for income generating activities showed that almost 100% of activities remained operational near the end of the project and noted impacts in the short-term on household incomes, food security, and households’ savings. Specific evidence of these short-term "impacts" is not reported in the ICR, but it was provided later by the project team (report source: Rapport Statistique Suivi N3 IPR _mai_2022 vu SE ce 29 JUIN 2022) such as: higher average monthly income for beneficiaries compared to non- beneficiaries; and proportion of beneficiary households consuming three meals per day compared to non-beneficiary households. Achievement of this objective is rated Substantial due to achieving of targets in access to safety net programs and participation in labor activities. Rating Substantial OBJECTIVE 3 Objective To strengthen the social protection system. Rationale The theory of change for this objective was clear. The main activities to collect household data and to establish a national social registry were likely to lead to the intended outcome to strengthen the national social protection sector. Page 6 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) Outputs  Capacity building to refine the national targeting methodology for poor and extreme poor households, as well as information technology and administrative support for the national social registry. This also included developing linkages with the national identification system.  National household data collection for the national registry (including advance financing through a project preparation advance). Steps included (i) community pre-identification of likely poor and vulnerable households; (ii) verification of the poverty status of pre-identified households through a proxy means test; (iii) community validation of PMT results and grievance resolution. The grievance redress mechanism included a digital platform which collected 423 complaints over the lifetime of the project. All complaints received were followed up, and the results fed back to the complainants Outcomes  Development of a National Social Registry, which became operational by project closing and covered the entire country. The ICR (page 16) reported that this was considered to be transformative, having come to be regarded as a crucial platform across government by the Ministry of Finance and other sectoral ministries, such as the energy and water sectors and some donor partners. Compared to neighboring countries, Benin’s registry is significantly more advanced in terms of its national coverage, usage by multiple programs, country ownership, availability of household GPS coordinates for crisis response and outreach, and linkage to the national identification system which assures the uniqueness of households in the registry.  As reported in the ICR (page 26), until the last Implementation Supervision Report, the number of households and individuals registered in the social registry was unclear, nor whether ANPS and ARCH used the data on the 16 communes as they were collected to develop the National Registry. The project team subsequently reported that these data were in fact utilized to identify beneficiaries. However,  As reported in the ICR (pages 15-16), institutional changes and capacity constraints led to significant delays in the collection of household data. The community pre-identification stage was carried out and completed in July 2018, but in early 2019, the government created the Agence Nationale de Protection Sociale (ANPS), becoming the lead agency for development of the Registry. The National Institute for Statistics and Economic Analysis (INStaD), which was the agency charged with carrying out the PMT survey, lacked sufficient numbers of staff until two additional consultant statisticians were made available to accelerate the survey work. These challenges affected the timeline of the social registry, leading to a delay in the cash transfer activities (which had to be disbursed in 18 months instead of 24 months) and an overlap with the micro entrepreneurship activities. The achievement of this objective is rated as Substantial, as several elements of the social protection system were implemented as planned. However, there were significant delays in some cases that affected the timely provision of benefits (notably a 29-month delay in delivering the first round of cash transfers). Page 7 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) Rating Substantial OVERALL EFF TBL OBJ_TBL OVERALL EFFICACY Rationale Achievement of the first objective to increase access to decentralized basic services is Substantial due to surpassing of targets in subproject implementation and student enrollment, although the target for percentage of domestic revenues transferred by government to communes fell short in percentage terms though not in absolute terms. Achievement of this objective is rated Substantial due to achieving of targets in access to safety net programs and participation in labor activities, but with significant implementation delays that likely decreased benefits to beneficiaries. Achievement of the third objective to strengthen the social protection system is rated Substantial as several elements of the social protection system were implemented as planned, albeit sometimes with significant delays. Therefore, the overall Efficacy is rated Substantial. Overall Efficacy Rating Substantial 5. Efficiency The main economic rationale at appraisal (PAD, pages 24-25) referred to prior evidence that the CDD approach is the most cost‐effective means of constructing basic infrastructure. Data compared the costs of infrastructure built through delegation to communities, versus those built through any other approach. At completion (ICR, pages 16-19), the analysis used the same rationale as above to show that the CDD approach enabled the construction of 380 infrastructure projects at a lower cost and of higher quality than any other alternative available in the country. While cost data for comparable infrastructure were not available for the same time period, a ‘natural experiment’ that occurred during the prior Bank-supported project provided some idea of the cost-effectiveness of this project (which used an identical approach and same key actors). In the course of implementing the prior project, it was found that three communes had incorrectly signed contracts for constructing three village schools that were only allowed under community-implemented subprojects. The Task Team Leader agreed at the time to allow this one instance of digression to assess costs between the commune and community-implemented projects. The findings showed that primary-school classrooms built directly by communes cost 11% more than comparable classrooms built by communities, even after taking into account the costs of training communities. Also, those built by contract management agencies recruited by the Ministry of Education under a separate Global Partnership for Education (GPE) financing cost 63% more. Inflation and disrupted global supply chains led to a considerable increase in the cost of construction materials. The strengthening of the US dollar against the FCFA offset some of these rising construction costs. There were also some delays in the launch of construction projects due to these higher costs, the COVID-19 pandemic, and Page 8 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) fiscal tightening by the government which led to a higher Value-Added Tax (VAT). During the pandemic, the project activity was halted between March and May 2020, and training had to be rearranged to accommodate social distancing protocols. The cost increase also caused some contracted entrepreneurs to re-evaluate their finances, run at a loss as prices kept increasing throughout the project lifetime, pay penalties, and/or have their contracts terminated. However, as clarified by the project team, the Bank was able to make the appropriate adjustments such that the stretched resources could still achieve the targets. In addition, the following were indications of cost-effectiveness of project activities: the project delivered a higher quantity of outputs than planned in key areas (the number of cash transfer beneficiaries, number of labor intensive works cash transfers, number of microfinance activities, and number of community infrastructure projects). Also, the share of project administrative costs was lower for this project (11.1%) compared to similar projects in the region: for example, an IFAD study comparing administrative costs of CDD projects found average administrative costs of 16%; the Togo Community Development and Safety Nets project (2012–2017) costs were 15%; the Second Northern Uganda Social Action Fund Project (2009–2016) costs were 16%. The ICR also suggested that there was high allocative efficiency due to the participatory decision making process, to ensure responsiveness to local priorities, although no specific data were provided. However, there were several shortcomings in implementation that decreased efficiency. As mentioned in the ICR (pages 25-26), the shifting of the government's social protection agenda and social registry timeline, as well as COVID-19 and floods, led to significant disruptions and delays; also, collaboration between agencies was sometimes challenging, and it was not clear whether data sharing took place effectively. There were delays in household data collection (in addition, the costs of the first two phases of the survey exceeded initial estimates, in part due to the need to finance the biometric registration of households that had not been covered by the earlier government information campaign) which impacted the timing of payments to beneficiaries although not the total number of beneficiaries. Overall, there was a 29-month delay in the delivery of cash transfer benefits, which likely significantly impacted the ability of poor households to fully realize benefits from the project activities. However, implementation was largely completed with targets met by the project closing, without a project extension. Efficiency Rating Substantial a. If available, enter the Economic Rate of Return (ERR) and/or Financial Rate of Return (FRR) at appraisal and the re-estimated value at evaluation: Rate Available? Point value (%) *Coverage/Scope (%) 0 Appraisal 0  Not Applicable 0 ICR Estimate 0  Not Applicable * Refers to percent of total project cost for which ERR/FRR was calculated. Page 9 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) 6. Outcome Relevance of objectives is rated High due to strong alignment with country conditions, country strategy and Bank strategy. Achievement of objectives is rated Substantial due to Substantial efficacy of the first objective, Substantial efficacy of the second objective, and Modest efficacy of the third objective. Efficiency is rated Substantial. Therefore, overall outcome is rated Satisfactory. a. Outcome Rating Satisfactory 7. Risk to Development Outcome The infrastructure built, including roads, schools, and health posts, are under the ownership of communes. Because they exercise legal ownership of the infrastructure, communes are responsible for their maintenance. Communities were trained in basic maintenance to enable them to carry out basic maintenance tasks without requesting support from the commune. The sustainability of the National Social Registry is also likely given its high level of utilization by multiple agencies. Lastly, the new IDA $100 million pipeline social safety nets Project for Results (P4R) will build on the National Social Registry (NSR) for a massive expansion of cash transfer coverage. 8. Assessment of Bank Performance a. Quality-at-Entry The project built upon prior ten years of Bank experience in the country, supporting decentralization and participatory development projects. The prior Decentralized Community Driven Services Project (PSDCC), which ended in December 2017, had modeled FADeC’s fiscal transfers, resulting in the completion of over 1,000 basic infrastructures executed by communities and also piloted a cash transfer program that built on the CDD approach for identification of beneficiaries and execution of labor intensive public works. The project design also drew from a Bank-supported government review of the existing safety net program (following severe floods in 2010) which made recommendations on developing a new safety net program. Implementation arrangements also built upon the prior operation's institutional arrangements. The results chain was clear, with the M&E framework providing relevant and measurable indicators. Significant risks were identified at appraisal in the areas of governance and fiduciary performance, with mitigation measures to strengthen capacity and supervision. However, as noted in the ICR (page 24), the risk mitigation measures did not sufficiently account for the risk of delays in data collection for the social registry, especially given that it was a prerequisite for the cash transfer component. While project components could still be implemented, the 29-month delay in initiating cash transfers may have increased the likelihood of targeted households resorting to negative coping strategies during that period. Page 10 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) Quality-at-Entry Rating Moderately Satisfactory b. Quality of supervision The Bank team provided effective supervision, amidst significant challenges due to COVID and the delays in household data collection. The pandemic caused a project slowdown from March to May 2020, when the government imposed a strict lockdown. The restrictions were slowly loosened up around summer, and the project team was able to get back in the field although some construction activities never resumed and the training activities were also disrupted. The key activity of cash transfers to beneficiaries relied on the delivery of the National Social Registry; however, even with a project preparation advance of US$2 million, the cash transfer component experienced a two-year implementation delay until an alternate data collection plan could be agreed upon with the government. These two factors were largely outside the control of the Bank team (although the project design could have taken more effective measures to ensure timely availability and quality of data). Despite these factors, the Bank team persisted in working closely with the project stakeholders to resolve issues (in particular related to the social registry), conducted physical site visits, produced clear and detailed supervision reports, and followed up with the government when required. Safeguards were effectively supervised, aided by the use of standardized environmental and social safeguard plans for each type of infrastructure. Fiduciary performance was overall satisfactory, utilizing arrangements already in place from the prior project. Quality of Supervision Rating Satisfactory Overall Bank Performance Rating Moderately Satisfactory 9. M&E Design, Implementation, & Utilization a. M&E Design The project objectives were clearly stated, although the objectives could have reflected more ambitious outcomes (i.e. higher income or food consumption level) in view of the prior ten years of Bank engagement and development history in the country's social protection undertakings. The overall M&E framework was sound, with relevant and measurable indicators identified for each of the project objectives. However, the key indicator measuring "improved access to basic services" only measured access to education, not other services such as health services or markets, or travel time. Also, as noted in the ICR (page 27), the indicator to measure the third objective to "strengthen the social protection system" was limited and somewhat unclear, whether referring to: i) the poorest households pre-identified, surveyed with the proxy means test, and confirmed by the community being added to the social registry, or ii) any household the project collected data on being routinely added to the registry. It was also unclear Page 11 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) whether the project at design was referring to the National Social Registry or a social registry within the Ministry of Social Affairs. Monitoring arrangements were clear, with decentralized entities using a smartphone-based monitoring tool to regularly report data to the project implementing unit. Planned evaluative activities included technical audits of infrastructures built under component 1 (at mid‐term and end of project), audits of adherence to environmental and social safeguards (at mid‐term and end of project), and audits of procurement performance of communities and local governments (annually). b. M&E Implementation The project implementation unit effectively implemented M&E by regularly collecting key project data. It relied on its six regional representatives to report implementation, financial, and procurement indicators, as well as on several consultants and volunteers from Community Development Agents (CDA) within the communes and communities that provided community training and reporting. Due to COVID- 19 related travel restrictions and social distancing measures, the project team relied on a smartphone geo-referencing tool (GEMS) to collect community level data and monitor project progress. The two planned technical audits were conducted to evaluate the soundness and quality of the infrastructure built under the project; the annual procurement audit assessed the compliance of communes and communities with national standards; and two audits evaluated compliance with the environmental and social safeguards. The project implementing unit also produced other reports on microfinance viability and a satisfaction survey for capacity-building training. c. M&E Utilization M&E data was used to monitor implementation progress and assess project achievements. Also, as noted in the ICR (page 27), the auditing procedures and the preparation of timely monitoring and quality check reports kept track of project status and enabled timely identification of issues and appropriate responses. M&E Quality Rating Substantial 10. Other Issues a. Safeguards The project was classified as an Environmental Category "B" project due to small-scale public works projects which might cause site-specific environmental impacts. An Environmental and Social Management Page 12 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) Framework was prepared, building on experience of similar activities in the prior operation, to provide environmental screening and risk mitigation tools. The infrastructure projects had the possibility to restrict access to assets or sources of livelihood, entail acquisition of land/assets, or lead to digging during civil works. Therefore, safeguard policies on Pest Management (OP/BP 4.09), Physical Cultural Resources (OP/BP 4.11) and Involuntary Resettlement (OP/BP 4.12) were triggered. The Resettlement Policy Framework from the prior operation was to be used as a roadmap for preparing Resettlement Action Plans, if necessary. The ICR did not report on Environmental or Safeguards performance. The project team clarified that these areas were evaluated during each supervision mission by Specialists, with findings reported in Aide- Memoires. Implementation Supervision Reports consistently rated both as Satisfactory and the overall safeguards rating recorded in the Operations Portal was Satisfactory. b. Fiduciary Compliance Financial management: Financial management arrangements were similar to those used for the prior Bank-supported operation, with the main project implementing unit deemed to have adequate fiduciary capacity. The FM rating in the last Implementation Status Reports (ISR) was Satisfactory, noting overall good quality but minor delays in the submission of interim financial reports. Fiduciary staff at decentralized levels were hired to ensure fiduciary compliance by communes and communities. Regular internal audit missions were completed by the government’s internal audit institutions (IGF and IGAA), which strongly focused on activities at decentralized levels. Annual reviews were undertaken of a sample of subgrants and disbursements under the social safety net component to monitor the appropriate use of community grants. No major misuse of project funds were reported. At the time of the writing of the ICR, the general audit report had not yet been received by the Bank team; the team subsequently confirmed that the report was received, with no qualifications. Procurement: Procurement performance is also reflected as Satisfactory in the latest ISR, although the ICR (page 28) noted that not all the steps in the procurement process up to the signing of contracts and the payment of certain contracts were recorded. c. Unintended impacts (Positive or Negative) --- d. Other --- 11. Ratings Page 13 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) Reason for Ratings ICR IEG Disagreements/Comment Outcome Satisfactory Satisfactory Quality-at-entry is rated Moderately Satisfactory due to Bank Performance Satisfactory Moderately Satisfactory shortcomings in mitigation measures (risks related to data collection, institutional capacity). Quality of M&E Substantial Substantial Quality of ICR --- Substantial 12. Lessons Lessons drawn from the ICR (page 30-31) and adapted by IEG:  Community-driven development (CDD) can have significant social benefits, in addition to being cost-efficient. In the case of this project, the capacity building and training at the community-level led to strong levels of participation and ownership over community subprojects to ensure relevance (and utilization) and to monitor quality of infrastructure. Also, with the low complexity subprojects, local procurement led to cost- efficiency and higher likelihood of hiring local workers.  Despite its complexities, the central government can utilize CDD to effectively deliver local infrastructure on a broad scale. In the case of this project, the provision of capacity building to commune governments and communities, use of standardized training program delivered by a broad network of community agents and volunteers, and use of standardized architectural plans (i.e. classrooms) and related environmental and safeguard compliance plans all contributed to the central government's ability to implement CDD widely. In addition,  Tightly sequenced project activities that rely on government actions can be derailed by unexpected institutional changes. In the case of this project, one year into the project implementation period, the government launched a new agency that became the government champion for social protection. This led to a change in timeline for creating the national social registry, which was a critical project activity to the cash transfer component, and caused delays and compressed delivery of the cash transfers. 13. Assessment Recommended? Yes ASSESSMENT_TABLE Page 14 of 15 Independent Evaluation Group (IEG) Implementation Completion Report (ICR) Review Benin ACCESS (P163560) Please Explain To verify that the CDD approach, the community infrastructure subprojects, and the National Social Registry are being sustained and continuing to have impact. 14. Comments on Quality of ICR The ICR was internally consistent, concise, and results-oriented (linking project outputs to development outcomes). The quality of evidence was overall satisfactory, although additional evidence (subsequently provided by the project team) and more elaborated results framework would have strengthened the findings reported in the ICR. Lessons were clearly drawn from project experience, particularly for the community-driven development aspect. The ICR was candid and overall consistent with guidelines, although a shortcoming was the lack of reporting on Environmental and Safeguards performance (Section B, pages 27-28). a. Quality of ICR Rating Substantial Page 15 of 15