ICRR 13759 Report Number : ICRR13759 IEG ICR Review Independent Evaluation Group 1. Project Data: Date Posted : 05/31/2012 Country : Iraq Project ID : P096774 Appraisal Actual Project Name : Emergency US$M ): Project Costs (US$M): 19.50 16.70 Disabilities Project L/C Number : Loan/ US$M ): Loan /Credit (US$M): 19.50 16.70 Sector Board : Health, Nutrition and US$M): Cofinancing (US$M ): Population Cofinanciers : Board Approval Date : 11/23/2005 Closing Date : 09/30/2007 12/31/2010 Sector (s): Other social services (50%); Health (50%) Theme (s): Injuries and non-communicable diseases (50% - P); Conflict prevention and post -conflict reconstruction (25% - S); Other social protection and risk management (25% - S) Prepared by : Reviewed by : ICR Review Group : Coordinator : Judyth L. Twigg George T. K. Pitman Soniya Carvalho IEGPS1 2. Project Objectives and Components: a. Objectives: The project’s original objective, according to the Trust Fund Grant Agreement (p. 10) and the Technical Annex (p. 8), was “to support the delivery of improved rehabilitation and prosthetic services that reduce the burden of physical disability.� The objective as revised on March 8, 2009 (Restructuring Project Paper, p. 1) was “to improve access of the disabled population in the targeted areas in Iraq to rehabilitation and prosthetic services ." b.Were the project objectives/key associated outcome targets revised during implementation? Yes If yes, did the Board approve the revised objectives /key associated outcome targets? Yes Date of Board Approval: 03/08/2009 c. Components: The project initially contained three components : 1. Policy Development and Partnerships (appraisal, US$ 0.75 million; actual, US$ 0.00 million): Development of a comprehensive policy and legislative framework, and of partnerships between the Ministry of Health (MOH), other ministries, and civil society in the area of disabilities . The component included the establishment of a multi -sectoral Disabilities Working Group (DWG) as an initial step in the policy development process; data collection and assessment of existing non -governmental organizations (NGOs) in the area of disabilities; and support to the MOH to contract NGOs for provision of a selected number of specific services (registration of disabled persons, distribution of wheelchairs, and community-based surveys). 2. Delivery of Services to Disabled Persons (appraisal, US$ 18.04 million; actual, US$ 16.27 million): Construction of nine new rehabilitation facilities (three of which would have workshops for the production and repair of prostheses and orthoses); renovation of five existing rehabilitation facilities; procurement of equipment and materials for prosthetic workshops and medical aids; and training activities to improve services for physical rehabilitation . 3. Project Management (appraisal, US$ 0.71 million; actual, US$ 0.43 million): Project coordination to be carried out by a Project Management Team (PMT) in the MOH, with responsibility for implementation of the components to rest with relevant MOH departments. The component included financing for office equipment and supplies, technical assistance and training for PMT staff, annual external audits, and operating costs for the PMT . At restructuring, Component 1 was cancelled, and Components 2 and 3 were re-numbered as Components 1 and 2, respectively. The ICR (p. 21) points out that the Restructuring Project Paper does not include the revised costs by component. d. Comments on Project Cost, Financing, Borrower Contribution, and Dates: Project Cost: At restructuring, US$ 4.81 million had been disbursed, or 28.6% of the revised US$ 16.8 million Grant amount. At restructuring: (i) eight of the original fourteen project sites were cancelled, so that the revised activities involved six new rehabilitation facilities in six governorates; (ii) the funds under Component I were cancelled (not reallocated), as were the relevant contracts for national and international consultants for the DWG, public awareness campaigns, and service contracts with NGOs; and (iii) procurement of prosthesis and orthosis materials was cancelled, with the agreement that MOH would procure them with its own resources . Financing: The US$ 19.5 million Grant was from the World Bank Iraq Trust Fund (ITF), a multi-donor fund that finances grants for rehabilitation /construction and capacity building /technical assistance projects . Funds from all donors were commingled in one account . At closing, US$ 2.79 million was cancelled. Borrower Contribution: There was no planned Borrower contribution . Dates: The project closing date was extended three times . The first extension was on June 15, 2007, when the closing date was extended from the initial date of September 30, 2007 to September 30, 2009, to provide sufficient time to complete the workshops /rehabilitation centers civil works and equip the facilities, to carry out training activities, to develop a national policy on disabilities, to complete contract payments, and to enable the Iraqi team and the task team to evaluate the project . The second extension was at restructuring on March 8, 2009, because of delays in implementation caused by : (i) the unstable political and security context in the country; (ii) lack of continuity in MOH leadership and project management; (iii) lack of familiarity of the MOH, contractors, and consultants with bank guidelines and procedures; and (iv) devaluation of the Iraqi Dinar coupled with high domestic inflation (ICR, p. 3). At that time the closing date was extended from September 30, 2009, to June 30, 2010. The restructuring was intended to ensure that the project would implement activities successfully and meet its development objectives within the revised time frame . The third extension, on June 21, 2010, moved the closing date from June 30, 2010, to December 31, 2010, to permit use of unallocated funds to procure additional electric wheelchairs, to complete remaining contracts, and to give extra time for data collection and analysis of project outputs and outcomes . 3. Relevance of Objectives & Design: a. Relevance of Objectives: High . Once considered one of the best in the region, at the time of preparation the Iraqi health Original Objectives : High. system had declined significantly in terms of quality of care and resource allocations . Health outcomes were among the poorest in the region, well below levels found in countries of comparable income . The many successive wars had increased the burden of disability, with the cumulative number of persons suffering from physical disabilities estimated at 250,000. Care of the disabled had deteriorated as a result of the conflicts; existing rehabilitation centers and facilities that manufactured prosthetics had been looted, and most had suffered heavy physical damage . The number and status of centers and hospitals dedicated to disability care was too modest to meet the expanding needs of disabled persons. Many NGOs were operating to help disabled people, but most were of recent creation, were small, and lacked resources and capacity . The Iraq Transitional Government had placed high priority on improving services for persons with disabilities (PWD) and their re-entry into productive life. A reform of physical and psycho -social rehabilitation services had been recognized as a priority area by the MOH . In November 2004, the MOH had prepared a draft national strategy for the physically disabled that included planned interventions to improve the quality of and access to care for PWD . The project’s objectives are highly relevant to this strategy . In October 2004, the MOH approached the Bank concerning support to persons with disabilities resulting from the war and related accidents . This area had not yet been specifically addressed by the donor community . The objectives are also highly relevant to the Bank ’s third Interim Strategy Note (ISN) for Iraq (FY2010-2011). This ISN envisages three thematic areas of engagement, the first of which is continuing support to ongoing reconstruction and socio-economic recovery efforts. Activities under this theme support Government policies and pubic investments that will help to restore and modernize Iraq ’s physical and human capital . High based on the above. Revised Objectives : High, b. Relevance of Design: Original Design : Modest . The Technical Annex (p. 22) contains a results framework linking the project ’s components to outputs and plausibly anticipated outcomes . The outcomes are stated in broad terms, without specific targets, but the project was explicitly designed, given the emergency situation, as one where key performance indicators would be output - rather than outcome-oriented. The project’s design was intended primarily to support immediate needs for physical reconstruction, renovation, and equipping of rehabilitation centers and workshops, as well as staff training, as a first step in supporting the needs of persons with disabilities . The project team pointed out that removing support for disabled persons from hospitals was an important part of project design, as hospitals were not performing this function effectively . The ICR (p. 6) asserts that the policy development component (original Component 1) was not necessary for successful completion of the project and should not have been included in the project’s design, and that the project ’s overall initial scope was overly ambitious, given the time frame, prevailing security conditions, and client capacity . The project team added that MOH commitment during preparation was quite high, making an ambitious design and inclusion of a policy development component feasible at that time. Revised Design : Substantial . The project revision at restructuring reduced the scope of the investment . Although narrower, the focus was more on the access and availability of rehabilitation services and prosthetics to the targeted population of disabled people, to ensure that the objectives and activities were better aligned with the realities on the ground (ICR, p. 4). Even with these revisions, however, the design remained ambitious, given the security conditions and client capacity. 4. Achievement of Objectives (Efficacy): The project supported redefining the roles and responsibilities within Government for persons with disabilities, shifting services delivery from the Ministry of Defense to the MOH . No policy framework was developed, as envisioned under the original project design, and the MOH did not enter into any agreements with NGOs for the provision of services to disabled persons and their families . The planned Disabilities Working Group was not formed . However, the ICR (p. 11) states that the project contributed to a dialogue on the definition of disability and to informed decisions on the eligibility of different categories of disabled persons for services. Although a substantial amount of training took place, initial targets for rehabilitation center construction were not met . The number of persons who received medical aids through the project before restructuring was half of the target, limiting the extent to which the project reduced the burden of physical disability . Later in the project after restructuring this improved. Original objectives To support the delivery of improved rehabilitation services that reduce the burden of physical disability : Substantial . — Six new basic rehabilitation centers were constructed and equipped, against an original target of 11 (6 to be constructed and 5 existing centers to be renovated ), and a revised target of 6. Rehabilitation equipment was delivered and installed for a seventh center . — The average number of disabled clients who have used these newly constructed and equipped facilities is 1,000 per month, doubling the revised project target of 500 per month. The Region subsequently stated in March 2012 that the number of patients using the six centers each day was 40, reaching 60 a day in the Basra center. On this basis for a six-day week, about 1,500 patients a month would have used the facilities – three times the project target. To support the delivery of improved prosthetic services that reduce the burden of physical disability : Modest . — Two new prosthetic workshops were constructed, against an original target value of 3 and a revised target of 2. An additional set of workshop equipment and tools has been procured for a third hospital . — 65 hospital-based physiotherapists were trained (against a target of 78), and 16 hospital-based physicians were trained (against a target of 30). 59 prosthetics technicians were trained overseas (against a target of 47), and 18 technicians were trained in-country (against a target of 30). 15 facility managers were trained in the area of facility management, against a target of 20. While the ICR did not specify whether the technicians receiving overseas training returned to Iraq, the project team later verified that all trainees returned to Iraq . 38.697 medical aids (wheelchairs, crutches, walking sticks, walking frames, walking rollators, and tripods ) were procured, against a target of 39,900. The ICR provides contradictory data on the number of disabled persons who have received medical aids through the project; on pages iii and 12, it states that this number is not known, but on page 25, it says that 18,508 (48% of the number procured) have been dispensed to PWD . According to the ICR (pp. iii, 25), distribution of medical aids to disabled persons is slow because of bottlenecks in the MOH process of validating and allocating the aids to Directorates of Health, and also because of limited monitoring and reporting capacity of MOH. The Region in March 2012, using data that became available after completion of the ICR, stated that the rate of dispensed medical aids increased to 63% of the target. Revised objectives According to the ICR (p. 12), “in the revised wording of the project development objectives, the terms ‘to improve access of the disabled population in the targeted areas to rehabilitation and prosthetic services ’ meant ensuring the availability of equipped rehabilitation facilities with workshops and trained staff as well as the availability of medical aids.� To improve access of the disabled population in the targeted areas in Iraq to rehabilitation services: Substantial , based on evidence presented above . Personnel were trained, revised targets for facility and workshop construction were met, and the monthly usage rate of the new facilities is more than double the target . To improve access of the disabled population in the targeted areas in Iraq to prosthetic services : Substantial The number of persons receiving medical aids through the project (24,390) increased to almost two-thirds of the target (39,900). However, continued conflict and threats of physical violence to medical staff did not accelerate the rate of staff training, and the numbers of therapists, physicians, and facility managers trained did not reach targets (as described above). Even so, the Region stated in March 2012 that all the centers are fully staffed, some with more than their complement of staff. As noted above, the number of disabled patients using facilities significantly exceeded targets. 5. Efficiency: Efficiency is rated Modest . During preparation, the lack of reliable statistical data, limited economic information, and the speed with which the project was prepared prevented the conducting of a detailed financial and economic analysis. The ICR did not carry out such an analysis at completion or assign a rating for Efficiency (pp. 14, 28), explaining that Iraqi expertise in economic evaluation is not strong, and that Bank staff cannot carry out the analysis at this time because of the security situation in the country . The only qualitative evidence on efficiency noted in the ICR (pp. 14, 28) is the observation that the rehabilitation and prosthetic services offered to PWD by the project have facilitated their re-entry into productive life, as well as the existence of an acceptable number of bidders for each contract. The ICR mission was unable to obtain information on the efficiency of the construction of new facilities, measured in comparison with the costs of similar rehabilitations carried out under other projects; the ICR (p. 28) states that “there is no reason to believe that Iraq did not also get good value for money for the new rehabilitation facilities.� The ICR did not provide information on the efficiency of use of project funds by the Bank team, and the project team stated that the security conditions in the country made it impossible to collect systematic evidence on the efficiency of use of project funds . ERR )/Financial Rate of Return (FRR) a. If available, enter the Economic Rate of Return (ERR) FRR ) at appraisal and the re-estimated value at evaluation : re- Rate Available? Point Value Coverage/Scope* Appraisal No ICR estimate No * Refers to percent of total project cost for which ERR/FRR was calculated. 6. Outcome: Original objectives: Based on High relevance of objectives, Modest relevance of design, Substantial achievement of one objective but Modest achievement of the other, and Modest efficiency, the outcome based on the original project objective is rated Moderately Unsatisfactory (corresponding to a rating of 3 on the 6-point scale). Revised objectives: Based on High relevance of objectives, Modest relevance of design, Substantial achievement of both objectives, and Modest efficiency, the outcome based on the revised project objective is rated Moderately Satisfactory (corresponding to a rating of 4 on the 6-point scale). The overall project outcome is based on the average of these ratings, weighted by the amount of the total loan disbursed before (28.6%) and after (71.4%) restructuring, as follows: Outcome – original objectives = Moderately Unsatisfactory (3) X .286 = .858 Outcome – revised objectives = Moderately Satisfactory (4) X .714 = 2.856 Total: 3.714, which rounds to 4, or Moderately Satisfactory The project’s objectives were highly relevant to the country context at appraisal, and they remained highly relevant to Government strategy and to the Bank ’s strategy for Iraq. The project contributed to the construction of rehabilitation centers and workshops at a level that met revised targets, and disabled persons are using those facilities that are fully staffed even though training of personnel and distribution of medical aids remained below the target . The ICR chooses not to rate the project ’s efficiency, arguing that the country capacity and security context precludes a traditional financial or economic analysis; it provides insufficient data in this area . a. Outcome Rating : Moderately Satisfactory 7. Rationale for Risk to Development Outcome Rating: The facilities constructed and equipped by the project remain operational, with trained physicians and physiotherapists on-site and available. Their recurrent costs are being met by the MOH operational budget . The project management staff who received training through the project in procurement, financial management, and project management have brought these skills to other parts of the MOH (ICR, p. 15). However, according to the ICR, “the situation in Iraq remains fragile, and there is a risk of collapse for lack of security � (p. 16). These external risks outweigh other considerations . a. Risk to Development Outcome Rating : Significant 8. Assessment of Bank Performance: a. Quality at entry: Risks were unusually thoroughly identified . These risks included: unknown outcomes from December 2005 government transition; security risks; the Bank ’s inability to carry out in-country supervision due to security risks; failure of Government to meet incremental operating and maintenance costs; difficulties in establishing the DWG and subsequent national strategy on disabilities; lack of capacity on procurement and financial management; high demand in construction industry; and limited Bank knowledge about Iraqi government financial systems, controls, and procedures (Technical Annex, pp. 18-21). The focus on output indicators, according to the ICR (p. 6), made sense, given the short timeline and urgent nature of the operation . However, according to the ICR (p. 5), preparation did not take into account the main lesson from the Bank ’s prior experience with post-conflict countries: that for emergency recovery projects, a simple project design that can be quickly and visibly implemented is most effective . Project design was complex, mixing policy development and partnerships with civil works rehabilitation and construction for fourteen facilities in thirteen governorates, as well as provision of equipment and training . (The ICR, p. 16, acknowledges that selecting a smaller number of sites to be rehabilitated would have been politically difficult .) Given this complexity, the planned implementation period of 22 months was also unrealistic. According to the ICR (p. 6), “the original project scope and implementation time frame were not tailored to the realities on the ground .� It is not clear that appropriate synergies were achieved with, or lessons learned from, the simultaneous Emergency Health Project (2004-2010, US$ 25 million). Procurement plans for goods and consultant services were not well detailed and showed global costs that turned out to be underestimated. Arrangements for monitoring and evaluation (M&E) were not described in the Technical Annex, and the only indicator for delivery of services to the disabled (the number of disabled beneficiaries) had no baseline and no target . at -Entry Rating : Quality -at- Moderately Unsatisfactory b. Quality of supervision: Because of the security environment, on -site supervision was not possible, requiring the Bank team to operate from Amman. To substitute for the lack of on -site supervision, the task team made good use of a Fiduciary Monitoring Agent (FMA), maintaining close communication with the FMA during implementation and inviting them to participate in all supervision missions . Management gave high priority to this project (ICR, p. 17) and invested substantial time in assisting the task team . Candor, detail, and reporting of project progress in aide memoires and implementation status reports were of high quality . The task team was proactive in dealing with implementation problems. Throughout implementation, the Bank team helped the MOH /PMT team to monitor implementation of project components through the preparation of detailed output monitoring tables for each rehabilitation facility and workshop . On many occasions, the Bank team drew the attention of senior MOH officials to the need to track the project ’s achievements more closely. The Bank team also closely followed up on the Action Plan proposed by a 2009 Independent Procurement Review . Although restructuring should have taken place sooner, the opportunity to engage with the Government on this issue was limited until late in implementation because of continual changes in MOH leadership and unwillingness of the government to discuss restructuring. Quality of Supervision Rating : Moderately Satisfactory Overall Bank Performance Rating : Moderately Satisfactory 9. Assessment of Borrower Performance: a. Government Performance: According to the ICR (p. 7), Government commitment to the project was strong at the time of appraisal and approval. However, during the first two years of implementation, security conditions in the country deteriorated rapidly, and the MOH was “virtually non-functioning� (ICR, p. 7). Ownership of and commitment to the project greatly diminished as a result of the security situation in many parts of the country; the security context made it difficult for MOH staff and contractors to move about in the country and carry out their assignments . Politically, the continued sectarian conflict had a major impact on the MOH, with frequent changes of ministers and deputy ministers. In 2006, the Deputy Minister of Health was kidnapped and has never been seen again . Even when present, MOH leadership was “often unable or unwilling to provide the leadership required for project implementation� (ICR, p. 18). The Bank recommended in 2006 that the MOH contract an M&E specialist for the project, but this did not occur . Starting in late 2007, new MOH leadership became much more attentive to the project. However, it is a sign of continuing low commitment to the project that the Government disbanded the full PMT before the project was completed . No policy framework was developed, as envisioned under the original project design, and the MOH did not enter into any agreements with NGOs for the provision of services to disabled persons and their families . The planned Disabilities Working Group was not formed . The MOH did not complete a full Project Implementation Manual, despite a commitment in the Trust Fund Grant Agreement to do so before February 28, 2006. Government Performance Rating Unsatisfactory b. Implementing Agency Performance: The Ministry of Health was the implementing agency . Staffing of the PMTwithin the MOH was unstable, and its staff required a significant amount of training because of limited experience in project management and Bank policies and procedures. However, according to the ICR (p. 18), “the PMT staff and the FMA faced very dangerous situations, such as death threats, kidnappings, the constant potential for random harm, or to be discovered as being associated with an international organization; yet most still worked, displaying great courage and dedication during this period, literally risking their lives .� By mid-project, the PMT was more stable and effective due to accumulated experience in project management (ICR, p. 18). The PMT was able to monitor implementation on the basis of detailed output monitoring tables for each rehabilitation facility; however, it was not able to track outcomes on access to or quality of services (ICR, p. 19). Distribution of medical aids to disabled persons was slow because of bottlenecks in the MOH process of validating and allocating the aids to Directorates of Health, and also because of limited monitoring and reporting capacity of MOH . There were shortcomings in both procurement and financial management (see Section 11) that were resolved through proactive corrections and interventions by the PMT and the Bank . Implementing Agency Performance Rating : Moderately Satisfactory Overall Borrower Performance Rating : Moderately Unsatisfactory 10. M&E Design, Implementation, & Utilization: a. M&E Design: The Ad Hoc Committee Appraisal/Negotiations Review Meeting held on October 27, 2005 described the project as a “pilot activity that could be scaled up through future support � (ICR, p. 8). Yet there were limited provisions for monitoring and evaluating project activities appropriately for a pilot . Arrangements for M&E were not described in the Technical Annex, and the only indicator for the delivery of services to disabled persons (the number of disabled beneficiaries) had no baseline and no target . The indicator on the MOH’s capacity to manage, supervise, and monitor the project was vague and difficult to measure (ICR, p. 8). b. M&E Implementation: During implementation, the Bank team helped the MOH /PMT to prepare detailed output monitoring tables for each rehabilitation facility and workshop . The Technical Coordinator left the PT in early 2006, and subsequently the Bank team recommended that the MOH contract an M&E specialist for the project, but that recommendation was not followed. The project team added that there were questions during implementation about the quality of the M&E data being provided. The revised results monitoring framework (Restructuring Project Paper, pp . 5-6) contained appropriate baselines and targets . c. M&E Utilization: According to the ICR, “it is not known whether M&E data were evaluated or used to inform decision -making and resources allocation at the ministry level � (ICR, p. 9). The project team confirmed that M&E data were not used in this manner. M&E Quality Rating : Modest 11. Other Issues a. Safeguards: The project was categorized as Environmental Category B under OP 4.10 Environmental Assessment, with impacts associated mainly with construction of new rehabilitation facilities . The following standards were applied during implementation: (i) inclusion of standard environmental codes of practice (ECOP) in the bid documents for civil works; (ii) use of Safeguard Procedures for Including in the Technical Specifications of Contracts; and (iii) use of the Checklist of likely Environmental and Social Impacts of Subprojects . There was no involuntary relocation of populations or expropriation of privately owned land, and no cultural finds were discovered during excavations . Although compliance with the environmental safeguards was the responsibility of the MOH ’s Maintenance Department, the PMT designated two of its staff to act at Environmental Safeguards Focal Points . Checklist forms for all project sites were completed by the Focal Points and were submitted to the Bank during the April 2010 implementation support mission. The ICR does not state whether there was compliance with all safeguards . The project team later confirmed that there was compliance with all safeguards . b. Fiduciary Compliance: The Bank engaged an FMA to verify the physical implementation of the project and monitor compliance with fiduciary policies, including financial management and procurement procedures . The Bank prior-reviewed over 9% of all procurement under the project, and the remaining contracts were reviewed by the FMA . An Independent Procurement Review (IPR) in 2009 commented that record-keeping and filing by the PMT were not up to standards; the Bank team followed up on the Action Plan proposed by the IPR, addressing shortcomings . During implementation, the PMT recruited an international procurement advisor, and in consultation with that advisor and with Bank procurement staff, performed well in finding practical solutions to many difficult procurement issues . Financial Monitoring Reports (FMRs) were satisfactory and were submitted in a timely manner . During the project period, there were issues related to weaknesses in the internal control systems of the PMT, budgeting, and records reconciliation; most of these problems were resolved through the high commitment and proactivity of the PMT and the Bank’s implementation support. Audit reports were submitted on time, with the exception of late submission of the 2006 report. Audits were unqualified except for 2008, which was qualified due to identified ineligible expenditures and other shortcomings (missing elements, instances of inconsistency, inaccurate amounts, and incomplete disclosures); the 2008 report had to be revised and resubmitted . As requested by the Bank, in January 2010 the PMT submitted an action plan to remedy the weaknesses identified by the external auditor . The next audit report was to cover the year 2010 plus the four-month grace period and was due on June 30, 2011; an escrow account was established for that audit report . That report was submitted to the Bank on August 3, 2011. According to the project team, "the auditor issued an unqualified 'clean' audit opinion on the Project's financial statements and did not report any significant issues." c. Unintended Impacts (positive or negative): Project procurement under Bank guidelines contributed to introducing transparency and breaking existing monopolies by allowing other suppliers to enter the Iraq market (ICR, p. 9). d. Other: 12. 12. Ratings : ICR IEG Review Reason for Disagreement /Comments Outcome : Moderately Moderately Satisfactory Satisfactory Risk to Development Significant Significant Outcome : Bank Performance : Moderately Moderately Satisfactory Satisfactory Borrower Performance : Moderately Moderately Unsatisfactory Unsatisfactory Quality of ICR : Satisfactory NOTES: NOTES - When insufficient information is provided by the Bank for IEG to arrive at a clear rating, IEG will downgrade the relevant ratings as warranted beginning July 1, 2006. - The "Reason for Disagreement/Comments" column could cross-reference other sections of the ICR Review, as appropriate. 13. Lessons: Security challenges and other contextual factors limiting normal supervision missions can be overcome, at least in part, through the employment of an fiduciary monitoring agency to monitor physical implementation of projects and verify that funds are spent for the purpose intended and in accordance with Bank rules and procedures . Allocating more time for thorough project preparation, even in an emergency situation, saves time during implementation. Speeding up the preparation process does not allow for developing essential aspects of some project details. A common result of accelerated preparation is implementation delays during the early years, particularly in countries that are not familiar with Bank requirements and procedures . A deliberate investment in careful preparation can actually result in faster and more effective implementation . Project design should aim not only for assumed best practice, but also for best fit to country conditions . This project was designed in 2005 based on similar projects financed by the Bank in other countries; however, Iraq ’s security situation and many years of isolation produced a starkly different context . At the design stage, it would have been appropriate to involve the client more fully in discussions and studies to identify the project ’s essential and unique requirements. In fragile, post-conflict states, the design of emergency projects should be simple, manageable in scope, and suitable to the country context, and should include straightforward M&E arrangements . In such contexts, low institutional capacity and high staff turnover should be assumed . Planning should begin early for mainstreaming of project activities into regular ministry structures, even when the project is dealing with an emergency situation . A system should be established that will continue activity after the project has closed, one that can live within the constraints of ministry budgets . In this case, the project management team was disbanded even before project closing, and some day -to-day project functions have not been continued. 14. Assessment Recommended? Yes No 15. Comments on Quality of ICR: The ICR is clear, concise, and evidence -based, and it follows established procedures for evaluating a project with formally revised objectives. It does not assign a rating to the project ’s Efficiency, and it provides contradictory information on one key output indicator (the number of disabled persons receiving medical aids ). Its lessons (pp. 19-20) are not as fully fleshed out as they might have been . The ICR did not state whether there was compliance with environmental safeguards. a.Quality of ICR Rating : Satisfactory