Report No: RES00538 INTERNATIONAL DEVELOPMENT ASSOCIATION RESTRUCTURING PAPER ON A PROPOSED PROGRAM RESTRUCTURING OF Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results APPROVED ON 25-MAY-2021 TO THE Federal Republic of Nigeria Water Western And Central Africa The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization. The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) CURRENCY EQUIVALENTS Exchange Rate Effective Dec 31, 2024 Currency Unit = Nigeria Naira (NGN) US$ 1 = NGN 1534.20 US$ 1 = SDR 0.770710 FISCAL YEAR January 1 - December 31 Regional Vice President: Ousmane Diagana Country Director: Ndiame Diop Regional Director: Chakib Jenane Global Director: Saroj Kumar Jha Practice Manager: Anna Cestari Task Team Leader(s): Ndeye Awa Diagne, Judith Ibiada Warmate The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) ABBREVIATIONS AND ACRONYMS APT Annual Performance Target DLI Disbursement-linked Indicator DLR Disbursement-linked Result FCT Federal Capital Territory FMWR&S Federal Ministry of Water Resources and Sanitation FPIU Federal Program Implementation Unit IA Implementing Agency IDA International Development Association IPF Investment Project Financing IVA Independent Verification Agent GDP Gross Domestic Product GoN Government of Nigeria LGA Local Government Area M&E Monitoring and Evaluation MDA Ministries, Departments and Agencies NAP National Action Plan for the Revitalization of Nigeria’s Water, Sanitation, and Hygiene Sector PCU Program Coordination Unit PDO Program Development Objective PEF Program Expenditure Framework PFMU Project Financial Management Unit PforR Program for Results PIAP Performance Improvement Action Plan PIR Policy, Institutional and Regulatory PIU Program Implementation Unit PMC Project Management Consultancy POM Program Operations Manual RA Results Area RC Reform Component SDG Sustainable Development Goal SWA State Water Authority WASH Water Supply, Sanitation, and Hygiene The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) @#&OPS~Doctype~OPS^dynamics@pfrrestrhybridbasicdata#doctemplate BASIC DATA Product Information Operation ID Operation Name Nigeria Sustainable Urban and Rural Water Supply, P170734 Sanitation and Hygiene Program-for-Results Product Operation Acronym Program-for-Results Financing (PforR) SURWASH Operation Status Approval Date Active 25-May-2021 Does this operation have an IPF component? Yes Environmental and Social Risk Classification (ESRC) Moderate ACCOUNTABILITY Region/Country Who is the primary beneficiary of this operation? Beneficiary country/countries (borrower, recipient) Country or Group of Countries Nigeria Geographical Identifier Nigeria Requesting Unit AWCW2 (6548) Will regional institutions act as the borrower/implementer? No Implementing Unit i The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) Responsible Unit (e.g. EECG1) Practice Area (Lead) SAWW4 (10403) Water Contributing Practice Areas Education, Health, Nutrition & Population, Urban, Resilience and Land @#&OPS~Doctype~OPS^dynamics@pfrrestrhybridoperationstatus#doctemplate OPERATION STATUS Development Objective (DO) Development Objective The Project Development Objectives (PDO) are to increase access to water, sanitation, and hygiene services and to strengthen sector institutions in participating states of Nigeria. Disbursement Summary (in USD million) Source of Funds Net Commitment Disbursed Undisbursed % Disbursed IBRD -- -- -- 0 IDA 648.68 93.59 556.38 14.40 Grants -- -- -- 0 Policy Waivers Does this restructuring trigger the need for any policy waiver(s)? No @#&OPS~Doctype~OPS^dynamics@restrhybridmpa#doctemplate ii The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) TABLE OF CONTENTS I. PROJECT STATUS AND RATIONALE FOR RESTRUCTURING ........................................................................................1 II. DESCRIPTION OF PROPOSED CHANGES ....................................................................................................................4 III. PROPOSED CHANGES ..............................................................................................................................................10 IV. DETAILED CHANGE(S) .............................................................................................................................................11 ANNEX 1: RESULTS .......................................................................................................................................................13 ANNEX 2: PROGRAM ACTION PLAN ............................................................................................................................23 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) I. PROJECT STATUS AND RATIONALE FOR RESTRUCTURING A. Program Background 1. Nigeria’s water, sanitation, and hygiene (WASH) Sector is in a state of emergency. Approximately 60 million Nigerians lack access to basic drinking water services, with 38% of improved water points being non-functional and 30% failing after the first year. Piped water access has declined significantly, from 32% in 1990 to just 7% in 2019. Poor sanitation and hygiene practices are widespread, with 48 million Nigerians practicing open defecation. Only 11% of schools and 6% of healthcare facilities have basic water supply and sanitation services1. Inadequate access to WASH services has severe implications for public health, economic development, and overall quality of life. In Nigeria, inadequate WASH leads to 73% of the total burden of enteric infections and over 255,000 preventable deaths each year. Nigeria invests an average of 0.32% of its gross domestic product (GDP) annually in the WASH sector, which is much lower than the African average of 0.7%. To achieve the Sustainable Development Goals (SDGs) by 2030, at least 1.30% of GDP investment is required. There is also a shortage of skilled personnel to manage and maintain services, and environmental challenges such as water pollution and climate change affect the quality and availability of services. Social and institutional barriers, such as limited community participation and transparency, significantly impact the sustainability of WASH programs and projects. 2. In response to this critical situation, the Government of Nigeria (GoN) launched the National Action Plan (NAP) for the Revitalization of Nigeria’s Water, Sanitation, and Hygiene Sector in 2018 to serve as a 13-year strategy aimed at ensuring universal access to sustainable and safely managed WASH services by 2030. The Sustainable Urban and Rural Water Supply, Sanitation, and Hygiene (SURWASH) Program (P170734) was designed and approved on May 25, 2021 to support the implementation of the NAP. The Program became effective on January 14, 2022. With a total financing envelope of US$ 700 million (IDA Credit No. 6882-NG), the Program Development Objectives (PDO) are to increase access to water, sanitation, and hygiene services and to strengthen sector institutions in participating states of Nigeria. The program focuses on two results areas: a. Results Area 1 (RA 1): Strengthened sector policies and institutions for improved services. This area focuses on enacting necessary policy reforms and enhancing the capacity of institutions required for effective and sustainable service delivery. It aims to improve the governance, management, and accountability mechanisms within the WASH sector. b. Results Area 2 (RA 2): Improved access to water supply, sanitation and hygiene services. This area supports an integrated package of investments to expand access to and the use of WASH services in urban and rural areas and small towns. It promotes a local government area (LGA)-wide approach to WASH service delivery, addressing critical gaps simultaneously in WASH, and within communities, public institutions, and public places 3. The SURWASH Program is currently being implemented in seven states: Delta, Ekiti, Gombe, Imo, Kaduna, Katsina, and Plateau. These states were selected by the Federal Ministry of Water Resources and Sanitation (FMWR&S) based on eligibility and readiness criteria through a fair and transparent process. The program leverages financing from the World 1Federal Ministry of Water Resources (FMWR), Government of Nigeria, National Bureau of Statistics (NBS), and UNICEF (2022). Water, Sanitation and Hygiene: National Outcome Routine Mapping (WASHNORM) 2021: A Report of Findings. FCT Abuja, Nigeria. 1 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) Bank using the Program-for-Results (PforR) instrument to support and incentivize infrastructure investment and the strengthening of policies, institutions, and regulations (PIR). Additionally, a US$ 60 million Investment Project Financing (IPF) component was included to provide technical assistance to address implementation gaps. Allocations under the PforR and IPF components are notional, with final allocations determined based on performance. The program also allows for the incorporation of additional states over time. Currently, assisted states such as Abia, Anambra, Bauchi, Edo, Jigawa, Kwara, Niger, Oyo, Taraba, and the Federal Capital Territory (FCT) receive technical assistance from FMWR&S through the IPF to address weaknesses and achieve readiness for investment under the PforR. 4. The program aims to benefit an estimated 6,100,000 people by providing basic drinking water services, 1,400,000 people with access to improved sanitation services, and 2,000 schools and healthcare facilities with improved WASH services. Additionally, it targets 500 communities to become open defecation free and aims for seven states to achieve their PIR targets. The Program is expected to close on June 30, 2027. B. Program Status 5. The Program has completed its third year of implementation in December 2024 with subpar performance. Substantial acceleration in implementation is needed to achieve the PDO by program closing in 2027. While states have shown good progress on reforms- and performance-related disbursement-linked indicators (DLIs), progress with access to services is significantly lagging with the following results after Program Year 2: a. basic drinking water to 58,585 people against a target of 610,000 people; b. improved sanitation services to one (1) household against a target of 37,000 households; c. improved water supply, sanitation and handwashing facilities to 22 schools and healthcare facilities against a target of 200. 6. The Program midterm review (MTR), conducted between September 9 and October 4, 2024, was designed to gain a deeper understanding of the implementation challenges and why the program is not able to meet its yearly targets. Several critical issues were identified. First, the PforR instrument wasn’t sufficiently socialized among state-level decision-makers which led to significant delays in budget allocations, fund releases and program execution, as many stakeholders continued to operate under the assumption that the traditional IPF approach is still in use. Consequently, the benefits of the PforR instrument, such as timely fund releases and the use of country systems, remain unrealized, hindering the program’s overall progress and achievements. In a context where the WASH sector has been historically neglected and underfunded, participating states didn’t fully grasp that ensuring a steady cash flow for capital-intensive infrastructure projects is crucial for the SURWASH PforR to be effective. Without this steady cash flow, it is challenging to implement the necessary processes to ultimately provide more people with WASH services. Table 1 summarizes the status of the program at midterm including the associated cumulative disbursements. Disbursements currently stand at US$93.59 million (14%). 7. The PDO and Implementation Progress (IP) ratings remain Moderately Unsatisfactory, and SURWASH is currently a problem project in the Portfolio due to significant delays. 2 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) TABLE 1: PROGRAM PERFORMANCE AT MIDTERM (2024) Associated Cumulative Achievement at Percentage Total Allocated DLI End Target (2027) Disbursements at Midterm Midterm (2024) Achievement Amount (US$) (US$) DLI 1: Design of National WASH Fund to Yes No 0% 0 5,000,000 enable its establishment DLI 2: Design, adoption and implementation of State PIR Plans and achievement of annual 7 6 86% 6,500,000 35,000,000 targets DLI 3: People provided with basic drinking 6,100,000.00 58,585 1% 3,604,150 233,500,000 water service under the Program DLI 3.1: Performance improvement of state Yes No 90% 8,500,000 52,500,000 water supply implementing agencies DLI 4: People with access to a sustainably 3,575,000 0 0% 0 33,300,000 functioning water service DLI 5: Households with improved sanitation facilities constructed or rehabilitated under 280,000 1 0.00036% 465 156,050,000 the Program DLI 5.1: Performance improvement of state Yes No 90% 6,833,333 52,500,000 sanitation implementing agencies DLI 6: Communities having achieved community-wide sanitation status (ODF+) or 500 0 0% 0 16,650,000 number of ODF+ communities having maintained their status DLI 7: Schools and healthcare facilities with functional, improved water supply, sanitation 2,000 22 1% 610,500 55,500,000 and handwashing facilities constructed or rehabilitated under the Program 3 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) A. Rationale for Restructuring 1. With two and a half years remaining in the Program, the current pace and ambitious targets necessitate restructuring to address the challenges and improve the program's performance. The midterm review has recommended to expand the Program to more states and to increase the verification cycles to at least two cycles per year. On November 20, 2024, the Honorable Minister of Water Resources and Sanitation sent a call for expression of interest to all remaining states, inviting them to express interest and share documentation by December 23, 2024 to assess their eligibility and readiness to be onboarded. Given the time required to onboard new states and the urgency to address implementation bottlenecks, it was recommended to proceed with two consecutive Level II restructurings. 2. The first restructuring was requested by the Federal Ministry of Finance (“The Borrower”) through an official letter dated December 23, 2024. The objective of this first restructuring is to adjust the results and introduce scalability in order to reward progress rather than perfection to facilitate achievement. These changes as detailed below, are intended to enhance the overall effectiveness of the SURWASH Program. This restructuring is crucial to swiftly address the urgent challenges related to achieving sectoral reform, performance outcomes, and sanitation targets, as well as improving overall Program coordination and risk management. By implementing these adjustments, the program will be better positioned to enhance the performance of the current seven participating states, achieve the intended outcomes, and deliver sustainable benefits to the target communities. This first restructuring is expected to already positively impact the results for 2024 by i) improving payments for results under DLIs 2, 3.1, and 5.1 through the introduction of a scalable performance framework; and ii) aligning the sanitation DLIs 5 and 6 with the national sanitation strategy. DLIs 2, 3.1 and 5.1 are among the best performing, and simplifying the reward framework based on realistic assessments will enhance feasibility and achievement, thereby improving cash flow. 3. A second restructuring will be processed later this FY to onboard more states and adjust the Program accordingly. GoN will send a detailed request once the ongoing assessments of eligibility and readiness are finalized, and an updated Program Expenditure Framework (PEF) is available. 4. This constitutes the first restructuring of the SURWASH Program, and there are currently no outstanding audit or financial reports. II. DESCRIPTION OF PROPOSED CHANGES 5. The following changes are proposed: a. Adjustments of Results. The proposed restructuring will revise the description of DLIs 2, 3.1 and 5.1 to align with the 2022 global PIR framework. Following the MTR, it was recommended to simplify the performance assessment process for the PIR and Performance Improvement Action Plan (PIAPs). Rather than continuing to be based on states achieving activity-level targets presented as annual performance targets (APTs), a performance framework has been introduced for each of these three DLIs: i. making it simpler by introducing performance thresholds based on a 0-5 progress scale to reward progress rather than perfection and hence facilitating achievement of PIR targets and ultimately improving cashflow with the payments for results; the current framework incentivizes the implementation of all annual reform 4 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) or performance improvement targets rather than achievement of actual PIR reforms or performance improvement outcomes; ii. giving states more discretion and flexibility on setting priorities for reforms and performance improvement actions; and iii. focusing more on achievement of the actual performance improvement outcomes rather than on rewarding the implementation of all activities. b. Under DLI 2, the six reform areas are maintained. However, their description has been aligned with the updated global PIR framework. There will also be 17 reform components (RCs) to align with the proposed changes instead of 11 (Table 2). The increase from 11 to 17 reform components is a strategic decision to ensure comprehensive coverage of the reform areas. This expansion allows the Program to address the breadth of reform components across urban and rural settings, water supply, sanitation, service provision, policies, institutional strengthening, and regulations. Given the identified weaknesses at the subnational levels, it is crucial to cover the different elements of the 2022 PIR framework thoroughly. This will strengthen the program's effectiveness and ensure that all critical aspects of water supply and sanitation reforms are adequately addressed. c. No changes have been made to the list of Essential Elements under DLIs 3.1 and 5.1. Flexibility in the design and implementation of the PIAPs is retained. However, it is imperative that each PIAP addresses the relevant Essential Elements. These Essential Elements are critical for guaranteeing service quality and sustainability and are categorized into two overarching categories: Accountability and Sustainability. The flexibility provided allows for tailored approaches that best suit unique contexts and challenges of the implementing agencies. Nonetheless, adherence to the Essential Elements ensures a standardized baseline of quality and sustainability across all PIAPs. By focusing on Accountability, transparency, governance, and stakeholder engagement are enhanced. The Sustainability category emphasizes the long-term viability of services, including technical, financial, environmental, and operational aspects. 5 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) TABLE 2: REVISED DLI 2 REFORM AREAS AND REFORM COMPONENTS Reform Area 1* - Reform Area 4* - Ensure Reform Area 5 - Reform Area 6 - Reform Area 2* - Reform Area 3* - Consolidation and PIR functioning and Operationalize a WASH Participation of Consolidation and PIR Consolidation and PIR Strengthening of rural accountable urban water E&S screening and women and youth in Strengthening of urban Strengthening of urban water and sanitation provider(s) assessment mechanism the sector sanitation sector water sector sector RC-6a (P) RC-2b (P) RC-1b (P) RC-3a (P) Gender mainstreaming Prepare urban sanitation Develop and adopt rural water Develop legal, policy and in human resources Policies (P) policy in accordance with and sanitation policy operational framework for policies to address gaps city/LGA-wide inclusive framework urban water supply in technical and sanitation managerial positions RC-5a (I) RC-6b (I) RC-1c (I) RC-3c (R/I)* RC-4b (I) Establishment and Development and Ensure functioning and RC-2a (I)* Ensure functioning urban Ensure functioning and implementation of E&S implementation of a Institutions (I) accountable rural water and Ensure functioning urban water regulator with a clear accountable urban water screening and assessment young professional sanitation department and/or sanitation authority regulatory framework provider(s) mechanism (guided by program authority comprehensive manual) RC-2c (R) RC-3b (P/R/F) Develop state-level standards Prepare and implement poor- Regulations (R) and regulations for urban inclusive tariff policy with sanitation sustainable cost recovery RC-4a (P/I/F) Establish and operationalize RC-2d (F) RC-3d (F) RC-1d (F) performance contract with Develop and implement Develop and implement Develop and implement financing and service Finance (F) recurrent subsidy and capital recurrent subsidy and capital recurrent and capital funding agreements between state funding plan to improve funding plan to improve urban plan to improve rural WASH government and state water urban sanitation water authority (SWA) Board of Directors RC-1a (Intergov) Intergovernmental Establish LGA WASH Context (Intergov) Departments with adequate budget allocation and release Note: Yellow boxes indicate proposed additional reform components. Grey boxes indicate the unchanged reform components. Asterisks (*) indicate changed wording of reform areas/reform components. 6 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) a. The proposed performance framework for DLIs 2, 3.1, and 5.1 will no longer follow an all-or-nothing approach to trigger disbursements. Instead, thresholds of moderate and standard performance have been introduced to generate a performance score, based on an aggregation of progress scales. This new framework allows for partial disbursements of 50 percent based on performance thresholds, as outlined in Table 3. The details of what constitutes moderate and standard performance under DLIs 2, 3.1, and 5.1 will be defined in the Program Operations Manual (POM). This change aims to provide a more nuanced and flexible approach to disbursements, ensuring that progress is recognized and rewarded. By introducing these performance thresholds, the framework encourages continuous improvement and acknowledges varying levels of achievement, which can be particularly important in addressing the diverse challenges faced by different states and implementation agencies. TABLE 3: PROPOSED CHANGES IN THE DIRSBURSEMENT CALCULATIONS UNDER DLIS 2, 3.1 AND 5.1 Disbursement Calculation Disbursement Calculation Formula as approved in Formula as proposed in the Disbursement Linked Disbursement Linked 2021 restructuring Indicator (DLI) Result (DLR) (as applicable, expressed in (as applicable, expressed in US$) US$) DLR 2.3-2.6: 1,000,000 per Participating Achievement of annual Design, adoption and State for standard performance targets set out in State implementation of State (full disbursement) PIR Plans for each 1,000,000 per Participating PIR Plans and subsequent Program State achievement of annual 500,000 per Participating State Year (from Program targets (DLI 2) for moderate performance Year 3 to Program Year (partial disbursement) 6) DLR 3.1.3-3.1.6 1,500,000 per Participating Performance Achievement of annual State for standard performance improvement of State PIAP targets for each (full disbursement) 1,500,000 per Participating water supply Sector subsequent Program State Institutions and service Year (from Program 750,000 per Participating State providers (DLI 3.1) Year 3 to Program Year for moderate performance 6) (partial disbursement) 1,500,000 per Participating DLR 5.1.3-5.1.6 State for standard performance Performance Achievement of annual (full disbursement) improvement of 1,500,000 per Participating PIAP targets for sanitation Sector State Program Years 3* 750,000 per Participating State Institutions (DLI 5.1) through 6, inclusive. for moderate performance (partial disbursement) b. As part of the restructuring, it is proposed to make the wording of DLI 2 consistent across different documents. Henceforth, DLI 2 will refer to ‘Design, adoption and implementation of State PIR Plans and achievement of annual targets’ as per the Financing Agreement rather than ‘States achieving PIR plan targets’ as found in the results framework. 7 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) c. Additionally, DLIs 5 and 6 will be revised to align with the definitions of improved sanitation and Open Defecation Free (ODF+) in the updated national sanitation strategy and ODF protocol. This alignment aims to avoid confusion at both the federal and state levels between the Program and sector activities. Implementing states have raised concerns regarding the misalignment of different national programs. While some states are making entire LGAs ODF, they are struggling to make communities of 500 households ODF under the Program. This gap in understanding and the confusion with the requirements under the national ODF campaign and the SURWASH program have been identified. d. Going forward, the definition of "ODF+" used under the Program is aligned with the updated protocol. To declare a community open defecation free, it must meet the following criteria: (a) no exposed feces in the community or surroundings; (b) households have and use toilets; (c) public places have separate toilets for males and females; (d) pit toilets have fly-proof drop-hole covers (ventilated improved pit or VIP and pour flush toilets are exempt); (e) handwashing facilities are present inside or near toilets; and (f) at least 50% of community toilets are improved. e. DLI 5 measures the number of households with improved sanitation facilities constructed or rehabilitated under the Program. Household improved sanitation facilities include (i) flush toilets connected to a septic system in urban areas or (ii) double pit pour-flush latrines in rural areas. Facilities must include a superstructure and a handwashing station and adhere to technical standards and criteria as defined in the POM and aligned with the most up-to-date national sanitation strategy. f. The results framework has been updated to incorporate these changes and to align with the new World Bank scorecard. g. Risks. A reassessment of the program risks has been conducted at midterm based on current implementation realities, including the identification and inclusion of mitigation measures to address these risks effectively. The aim is to ensure that potential challenges are proactively managed, thereby minimizing their impact on the program's progress. Table 4 provides an overview of the reassessed risks, their former and current ratings, descriptions, and the proposed mitigation measures. TABLE 4: REVISED RISK ASSESSMENT AT MIDTERM Rating at Approval Proposed Rating Rationale for Change and Proposed Risk Category (2021) (2025) Mitigation Measures Since the 2023 elections, the political landscape in Nigeria has undergone significant changes, affecting the pace and overall buy-in on the Program at both federal and state levels. The commitment to WASH varies greatly across states, and the poor program outcomes indicate Political and that this commitment is largely insufficient. The Substantial High Governance initial strategy to mitigate political risks involved ensuring that each participating state's governor's office demonstrated strong commitment to the sector through eligibility and readiness criteria. However, the current political environment has introduced new challenges that necessitate a reassessment of the political 8 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) risk to high. To address this, enhanced stakeholder engagement will be pursued to build broader support for the Program among key stakeholders, including local communities, civil society organizations, and the private sector. Targeted capacity-building initiatives will be provided to state implementation teams to improve their ability to manage and execute the Program and communicate about it effectively. A robust communication strategy will be developed and implemented to keep all stakeholders informed about the Program's progress, challenges, and successes, maintaining transparency and building trust. Additionally, a scorecard has been developed to track the Program's progress and identify potential risks early, and to ensure consistent political support and accountability at both federal and state levels. Macroeconomic Substantial Substantial Sector Strategies Moderate Moderate and Policies Technical Design of Project or Substantial Substantial Program Institutional Capacity for Moderate Moderate Implementation and Sustainability The Financial Management review at midterm revealed serious internal control issues, leading to a downgrade in the financial management risk rating to Moderately Unsatisfactory and an increase in the risk rating to High. The internal control systems are very weak in PIUs and characterized by monies paid into personal accounts of project staff, overpricing of Fiduciary Substantial High activities, high level of unretired advances. To address the issues, the Bank is to conduct prior review of all requests for payment for all PIUs until the situation improves. The state Project Financial Management Units (PFMUs) are to ensure strict adherence to the project financial implementation manual especially regarding retirement of advances. Any staff who has outstanding retirement will not be granted 9 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) further advance. The project financial manual provides two weeks for retirement of advances. Environmental Substantial Substantial and Social Security has been a main concern in most of the states the Program is being implemented in. These challenges have disrupted program activities, posed risks to the safety of staff, contractors, and beneficiaries, and hinder the overall success of the program. To mitigate this risk, it is recommended to enhance the existing security management plan by addressing the Other Substantial Substantial identified gaps. This includes implementing stricter security protocols, collaborating with local authorities, leveraging technology, conducting regular risk assessments and monitoring, providing security training and awareness programs, and developing contingency plans for different security scenarios. Overall Substantial Substantial h. Institutional and Implementation Arrangements. The restructuring will involve the assessment and incorporation of any relevant implementing agencies (IAs) responsible for WASH service delivery, policy setting, or regulatory oversight in the participating states. The Program Implementation structures will be revised to improve support to the IAs. To better reflect their role in coordination and technical assistance to IAs, the Program Implementation Units (PIUs) will now be referred to as Program Coordination Units (PCUs). i. Revised Implementation Schedule. The program schedule will be adjusted to align with the above revisions. Despite the delays, the aim is still to achieve all targets by 2027. Therefore, the implementation pace will be accelerated in 2025 and 2026. This acceleration will be supported by the recruitment of a large Project Management Consultancy (PMC) firm, which will assist with technical designs, procurement, Environmental and Social (E&S) safeguards, and Monitoring and Evaluation (M&E) as well as an additional IVA to support two verification cycles per year. These measures are necessary to ensure that all activities are completed within the revised Program timeline, thereby facilitating the achievement of the program's objectives. @#&OPS~Doctype~OPS^dynamics@restrhybridsummarychanges#doctemplate Summary changes III. PROPOSED CHANGES Operation Information Proposed Changes Operation Information Proposed Changes Results Yes Institutional Arrangement Yes Risks Yes Implementation Schedule Yes 10 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) Disbursements Estimates Yes Loan Closing Date Extension No Development Objective No Loan Cancellations No Summary Description No Reallocations No (Operation Abstract) Legal Operational Policies No Financial Management No MFD/PCE No Procurement No Legal Covenants No Other Change(s) No Conditions No Implementation Modalities No Disbursements Arrangements No Clients No Program Action Plan No @#&OPS~Doctype~OPS^dynamics@pfrrestrhybriddetailedchanges-disclose#doctemplate IV. DETAILED CHANGE(S) COSTS & FINANCING Is this an MFD-Enabling Project (MFD-EP)? Is this project Private Capital Enabling (PCE)? DISBURSEMENTS Operation Dates & Projection Details Reasons to change the full Disbursement date and/or the projection Restructuring Implementation Start Date Operation Closing Date 25-May-2021 30-Jun-2027 Projected Date for Full Disbursement 30-Jun-2027 Expected Disbursements (in US $) (Absolute) 11 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) Original Estimation at Preparation Actual Year Revised Estimation (Approval Package – 25 May 2021) FY2021 32,000,000.00 0.00 0.00 FY2022 3,000,000.00 58,750,074.00 58,750,074.00 FY2023 50,000,000.00 14,387,189.05 14,387,189.05 FY2024 67,000,000.00 7,217,681.25 7,217,681.25 FY2025 118,000,000.00 43,232,168.69 13,232,168.69 FY2026 153,000,000.00 250,000,000.00 0.00 FY2027 229,000,000.00 326,412,887.01 0.00 SYSTEMATIC OPERATIONS RISK-RATING TOOL (SORT) Last Approved Risk Category Proposed (ISR Seq. 07) - 29 Oct 2024 Political and Governance High High Macroeconomic Substantial Substantial Sector Strategies and Policies Moderate Moderate Technical Design of Project or Substantial Substantial Program Institutional Capacity for Moderate Moderate Implementation and Sustainability Fiduciary High High Environment and Social Substantial Substantial Stakeholders Moderate Moderate Other  Substantial Overall Substantial Substantial LEGAL 12 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) ANNEX 1: RESULTS COUNTRY: Nigeria Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results @#&OPS~Doctype~OPS^dynamics@pfrrestrannexpolicyandresult#doctemplate PDO Indicators by PDO Outcomes Increase access to water, sanitation, and hygiene services and strengthen sector institutions Indicator Name Baseline Actual (Previous) Actual (Current) Closing Period Result Month/Year Result Date Result Date Result Month/Year Revise Design, adoption and 0.00 May/2021 7.00 23-Aug-2024 6 16-Jan-2025 6 Jun/2027 implementation of State PIR Plans Comments on achieving targets Six out of 7 states met this DLI in Program Year 2 (86% achievement). Verification for Program Year 3 (2024) is and achievement of annual targets ongoing. (Number) DLI 0.00 May/2021 58,585 23-Aug-2024 58,585 17-Jan-2025 6,100,000.00 Jun/2027 Comments on achieving targets The results for Program Year 2, as verified by the Independent Verification Agent (IVA), indicate that 58,585 people were reached by this indicator. The number initially reported by the states for verification was 83,580 People provided with basic drinking people. The shortfall in achieving the desired targets can be attributed to the delayed commencement of the water service under the Program procurement process by the states. Currently, there are work activities underway in several states, including (Number) DLI Kaduna, Ekiti, Katsina, and Plateau. In Year 2, only four states—Delta, Ekiti, Gombe, and Katsina—submitted their results for verification. Notably, two contracts for Urban Water in Delta were terminated. The breakdown of the verified results by state is as follows: Gombe – 11,750; Delta – 10,000; and Katsina – 36,835. People provided with basic 0.00 May/2021 28,882 23-Aug-2024 28,882 17-Jan-2025 3,007,300.00 Jun/2027 drinking water service under Comments on achieving targets As per the demographic information, assuming at least 49.3% of the reported beneficiary are female. the Program - female (Number) DLI People provided with basic 0.00 May/2021 23,500 23-Aug-2024 23,500 17-Jan-2025 4,473,333.00 Jun/2027 drinking water service under the Program - rural (Number) DLI 13 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) People provided with basic 0.00 May/2021 35,085 23-Aug-2024 35,085 17-Jan-2025 1,626,667.00 Jun/2027 drinking water service under the Program - urban and small towns (Number) DLI Revise Performance No Yes No Yes improvement of state Water Comments on achieving targets Almost all IAs met the targets (90%) in Program Year 2 (2023). Verification for Program Year 3 (2024) is ongoing. Supply implementing agencies (Yes/No) DLI People provided with access to 0.00 May/2021 5 23-Aug-2024 5 17-Jan-2025 1,400,000.00 Jun/2027 improved sanitation services Comments on achieving targets Katsina was the only state that submitted results under this DLI. However, out of the eighty-six (86) sanitation (Number) facilities that were reported by the state, only one fully adhered to the stipulated standards and requirements. People provided with access 0.00 2 2 690,200.00 to improved sanitation services - Female (RMS requirement) (Number) People provided with access 0.00 5 5 1,150,000.00 to improved sanitation services - rural (Number) People provided with access 0.00 0.00 0.00 250,000.00 to improved sanitation services - urban (Number) Schools and healthcare facilities with 0.00 May/2021 22 23-Aug-2024 22 17-Jan-2025 2,000.00 Jun/2027 improved water supply, sanitation Comments on achieving targets The submitted number reported for verification was 43. However, as per the verification report, only 22 and handwashing facilities adhered to standards. The lag was due to the late start of the procurement process in some of the states and constructed or rehabilitated the late understanding of the design specifications for institutional WASH facilities. Works activities are ongoing (Number) DLI in Kaduna. The breakdown of verified results as follows: Ekiti - 7; Gombe – 6; and Katsina - 9. Schools and healthcare 0.00 May/2021 4 23-Aug-2024 4 17-Jan-2025 1,500.00 Jun/2027 facilities with improved water supply, sanitation and handwashing facilities constructed or rehabilitated - rural (Number) DLI Schools and healthcare 0.00 May/2021 18 23-Aug-2024 18 17-Jan-2025 500.00 Jun/2027 facilities with improved water supply, sanitation and handwashing facilities 14 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) constructed or rehabilitated - urban and small towns (Number) DLI ReviseCommunities having achieved 0.00 May/2021 0.00 23-Aug-2024 0.00 16-Jan-2025 500.00 Jun/2027 and/or maintained community-wide Comments on achieving targets There has been a lot of confusion regarding this DLI and no state so far (even those declaring entire LGAs ODF) sanitation status (declared and has achieved any results under it as of Program Year 2 (2023). Verification for Program Year 3 (2024) is ongoing. verified as ODF+) (Number) DLI Communities having achieved 0.00 May/2021 0.00 23-Aug-2024 0.00 17-Jan-2025 375.00 Jun/2027 and/or maintained community-wide sanitation status (declared and verified as ODF+) - rural (Number) DLI Communities having achieved 0.00 May/2021 0.00 23-Aug-2024 0.00 17-Jan-2025 125.00 Jun/2027 and/or maintained community-wide sanitation status (declared and verified as ODF+) - urban and small towns (Number) DLI Intermediate Results Indicators by Results Areas Results Area 1: Strengthened sector policies and institutions for improved services Indicator Name Baseline Actual (Previous) Actual (Current) Closing Period Result Month/Year Result Date Result Date Result Month/Year Share of workers managing public 0.00 May/2021 0.00 23-Aug-2024 0.00 17-Jan-2025 10.00 Jun/2027 sanitation facilities built under the Comments on achieving targets Public sanitation facilities have not yet been constructed under the Program. Program who are persons with disabilities/other group identified as excluded (Percentage) Proportion of WASHCOMs supported 0.00 May/2021 0.00 23-Aug-2024 0.00 17-Jan-2025 30.00 Jun/2027 under the Program with at least one Comments on achieving targets Data regarding the number of women in leadership positions in WASHCOMs is limited. Anecdotal data suggests woman holding a leadership position that women rarely hold leadership positions and instead hold the treasurer's position. (Percentage) 15 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) Share of newly created engineering 0.00 May/2021 0.00 23-Aug-2024 0.00 17-Jan-2025 40.00 Jun/2027 or technical positions filled by Comments on achieving targets None have been reported at this time. women through internal promotion or external recruitment among service providers participating in the Program (Percentage) Grievances registered and addressed 0.00 May/2021 100.00 23-Aug-2024 100.00 17-Jan-2025 80.00 Jun/2027 in a timely manner under the Comments on achieving targets One grievance was recorded by Katsina RUWASSA for the wrong siting of a borehole while two grievances were Program (Percentage) recorded by the Katsina Urban Water Board. The three were resolved in under two weeks. No May/2021 No 23-Aug-2024 No 17-Jan-2025 Yes Jun/2027 National WASH Fund established and operational (Yes/No) DLI Comments on achieving targets The Ministry plans to review and select the option going forward after holding stakeholder consultative fora across the country. Results Area 2: Improved access to water supply, sanitation and hygiene services Indicator Name Baseline Actual (Previous) Actual (Current) Closing Period Result Month/Year Result Date Result Date Result Month/Year People provided with water, 0 23-Aug-2024 58,585 17-Jan-2025 6,100,000 May/2027 sanitation, and hygiene (Number of people) CRI People provided with water, 0 23-Aug-2024 38,666 17-Jan-2025 4,026,000 May/2027 sanitation, and hygiene – Youth (Number of people) CRI People provided with water, 0 23-Aug-2024 28,882 17-Jan-2025 3,007,300 May/2027 sanitation, and hygiene – Female (Number of people) CRI People with enhanced resilience to 0 23-Aug-2024 58,585 17-Jan-2025 6,100,000 Jun/2027 climate risks (Number of people) CRI People with enhanced 0 23-Aug-2024 38,666 17-Jan-2025 4,026,000 Jun/2027 resilience to climate risks – Youth (Number of people) CRI 16 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) People with enhanced 0 23-Aug-2024 28,882 17-Jan-2025 3,007,300 Jun/2027 resilience to climate risks – Female (Number of people) CRI 75.20 May/2021 75.20 23-Aug-2024 75.20 17-Jan-2025 88.30 Jun/2027 Population using basic water supply Comments on achieving targets The indicator measures the proportion of the population using basic water supply services for the 7 participating services (Percentage) states. These account for population growth of 2.6% per year and underlying coverage increases of 1% for basic water using JMP trends [RF Coverage assumptions]. 69.30 Apr/2021 69.30 23-Aug-2024 69.30 17-Jan-2025 72.30 Jun/2027 Population using improved sanitation Comments on achieving targets The indicator measures the proportion of the population using improved sanitation for the 7 participating (Percentage) states. These account for population growth of 2.6% per year and underlying coverage increases of 0.5% for improved sanitation using JMP trends [RF Coveragessumptions]. Revise Households with improved 0.00 May/2021 1 23-Aug-2024 1 16-Jan-2025 280,000.00 Jun/2027 sanitation facilities constructed or Comments on achieving targets Only Katsina reported a number of 86 households for the verification by IVA in Program Year 2 (2023). Only one rehabilitated under the Program of the facilities adhered to standards as per the final verification report. Verification for Program Year 3 (2024) is (Number) DLI ongoing. Households with improved 0.00 May/2021 1 23-Aug-2024 1 17-Jan-2025 230,000.00 Jun/2027 sanitation facilities Comments on achieving targets Only Katsina reported a number of 86 households for the verification by IVA. Only one of the facilities adhered constructed or rehabilitated to standards as per the verification report. under the Program - rural (Number) DLI Households with improved 0.00 May/2021 0.00 23-Aug-2024 0.00 17-Jan-2025 50,000.00 Jun/2027 sanitation facilities constructed or rehabilitated under the Program - urban and small towns (Number) DLI Revise Performance No No No Yes improvement of state Comments on achieving targets Almost all IAs met the targets (90%) for Program Year 2 (2023). Verification for Program Year 3 (2024) is sanitation implementing ongoing. agencies (Yes/No) DLI People with access to sustainably 0.00 May/2021 0.00 23-Aug-2024 0.00 17-Jan-2025 3,575,000.00 Jun/2027 functioning water service Comments on achieving targets Tracking of the indicator will start in Program Year 3. (Number) DLI 17 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) 0.00 May/2021 0.00 23-Aug-2024 0.00 17-Jan-2025 400.00 Jun/2027 Public places provided with WASH facilities (Number) Comments on achieving targets No public places have been provided with WASH facilities yet under the Program. Utilities achieving at least 10 percent 0.00 May/2021 0.00 23-Aug-2024 0.00 17-Jan-2025 5.00 Jun/2027 average increase in energy Comments on achieving targets The indicator hasn't been tracked yet. efficiency/reduction in water loss (Number) Share of rural and small town water 0.00 May/2021 0.00 23-Aug-2024 0.00 17-Jan-2025 60.00 Jun/2027 supply beneficiaries using systems Comments on achieving targets This indicator has not been tracked yet. However, all the schemes larger than handpump boreholes constructed relying on renewable energy under the program are solar-powered across all the states (Subject to tracking and further verification). (Percentage) Water supply systems with regular 0.00 May/2021 0.00 23-Aug-2024 0.00 17-Jan-2025 70.00 Jun/2027 water quality and quantity Comments on achieving targets This indicator has not yet been tracked specifically. The indicator tracks the proportion of water supply systems monitoring to improve resilience of with regular water quality and quantity monitoring to improve resilience of populations in climate-vulnerable populations in climate-vulnerable areas. areas within Program LGAs (Percentage) Disbursement Linked Indicators (DLI) Actual (Previous) Actual (Current) DLI Name Baseline End Target Result Date Result Date 1 National WASH Fund Value No Yes established and operational (Yes/No) Allocated No 23-Aug-2024 No 29-Jan-2025 0.00 0.00 Total Allocation:5,000,000.00 Amount Revise 2 Design, adoption and Value 0.00 6 implementation of State PIR Plans and achievement of 7.00 23-Aug-2024 6 29-Jan-2025 Allocated annual targets (Number) 0.00 7,000,000.00 Amount Total Allocation:35,000,000.00 18 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) 3 People provided with basic Value 0.00 6,100,000.00 drinking water service under the Program (Number) 58,585 23-Aug-2024 58,585 29-Jan-2025 Allocated Total 0.00 38,257,042.00 Amount Allocation:233,500,000.00 People provided with Value 0.00 basic drinking water service under the Program - female Allocated 28,882 29-Jan-2025 0.00 (Number) Amount Total Allocation:0.00 People provided with Value 0.00 basic drinking water service under the Program - rural Allocated 23,500 29-Jan-2025 0.00 (Number) Amount Total Allocation:0.00 People provided with Value 0.00 basic drinking water service under the Program - urban and Allocated 35,085 29-Jan-2025 0.00 small towns (Number) Amount Total Allocation:0.00 Revise 3.1 Performance Value No Yes improvement of state Water Supply implementing agencies 14.00 23-Aug-2024 No 29-Jan-2025 Allocated (Yes/No) 0.00 10,500,000.00 Amount Total Allocation:52,500,000.00 Value 0.00 0.00 23-Aug-2024 0.00 29-Jan-2025 3,575,000.00 19 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) 4 People with access to sustainably functioning water Allocated service (Number) 0.00 16,650,000.00 Amount Total Allocation:33,300,000.00 Revise 5 Households with Value 0.00 280,000.00 improved sanitation facilities constructed or rehabilitated Allocated 1 23-Aug-2024 1 29-Jan-2025 under the Program (Number) 0.00 41,587,500.00 Total Amount Allocation:156,050,000.00 Households with Value 0.00 improved sanitation facilities constructed or rehabilitated under the 1 29-Jan-2025 Allocated Program - rural 0.00 Amount (Number) Total Allocation:0.00 Households with Value 0.00 improved sanitation facilities constructed or rehabilitated under the 0 29-Jan-2025 Allocated Program - urban and 0.00 Amount small towns (Number) Total Allocation:0.00 Revise5.1 Performance Value No Yes improvement of state sanitation implementing Allocated 14.00 23-Aug-2024 No 29-Jan-2025 agencies (Yes/No) 0.00 10,500,000.00 Total Amount Allocation:52,500,000.00 Value 0.00 0.00 23-Aug-2024 0.00 29-Jan-2025 500.00 20 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) Revise 6 Communities having achieved community-wide sanitation status (ODF+) or Allocated number of ODF+ communities 0.00 4,364,000.00 Amount having maintained their status (Number) Total Allocation:16,650,000.00 Communities having Value 0.00 achieved and/or maintained community- wide sanitation status 0 29-Jan-2025 Allocated (declared and verified as 0.00 Amount ODF+) - rural (Number) Total Allocation:0.00 Communities having Value 0.00 achieved and/or maintained community- wide sanitation status (declared and verified as Allocated 0 29-Jan-2025 0.00 ODF+) - urban and small Amount towns (Number) Total Allocation:0.00 7 Schools and healthcare Value 0.00 2,000.00 facilities with functional, improved water supply, sanitation and handwashing facilities constructed or Allocated 22 23-Aug-2024 22 29-Jan-2025 0.00 5,550,000.00 rehabilitated under the Amount program (Number) Total Allocation:55,500,000.00 Value 0.00 Schools and healthcare facilities with improved Allocated 18 29-Jan-2025 water supply, sanitation 0.00 Amount 21 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) and handwashing facilities constructed or rehabilitated - urban and small towns (Number) Total Allocation:0.00 Schools and healthcare Value 0.00 facilities with improved water supply, sanitation and handwashing facilities constructed or Allocated 4 29-Jan-2025 0.00 rehabilitated - rural Amount (Number) Total Allocation:0.00 22 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) ANNEX 2: PROGRAM ACTION PLAN . @#&OPS~Doctype~OPS^dynamics@pfrrestrannexprogramactionplan#doctemplate PROGRAM ACTION PLAN PAP_CHANGE_TBL Completion Action Description Source DLI# Responsibility Timing Measurement Action Establishment of Technical State PIUs Other SPIUs est. with SPIUs, including at required staff (w/ clear least a coordinator ToRs) by 3 mths after and specialists in effectiveness or prior procurement, 3 months after to disbmt for any state, financial effectiveness or whichever is earlier. management, prior to Staff maintained No change environmental, social disbursement, through and inclusion, whichever is implementation. planning, and M&E, earlier Training module & as well as technical implementation staff. Implementation support supervision of capacity building report of WB team. program. Prepare Program Technical Federal/State Other POM completed and Operational Manual PIUs disseminated to (POM), with Prior to stakeholders prior to No change comprehensive effectiveness effectiveness. POM guidelines for E&S adopted by SPIUs prior due diligence and to disbursement. 23 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) core inclusion Associated training activities, such as provided, guidelines gender, SEP, SEA/H, operationalized, and resettlement and relevant POM protection of requirements are vulnerable groups. applied to all Program Use POM for all activities. implementation. Hire the IVA to verify Technical Federal/State Other IVA hired with Bank- DLIs annually against PIUs accepted verification protocol contract/TORs no later and conduct quarterly than 90 days after monitoring of 90 days after effectiveness. Submit progress on E&S risk effectiveness; qtly reports to Bank management, Every 3 months including progress of No change particularly regarding during Program implem. of actions & the compliance of implementation compliance with E&S Program activities risk management & with the PAP & E&S anti-corruption due diligence, and guidelines. E&S due ACG. diligence per POM. Ensure that a robust Environmental Federal/State Other Screening mechanism E&S screening and Social PIUs manual prepared and mechanism is in place Systems Prior to submitted to the Bank and guides E&S prior to effectiveness. No change effectiveness management of IVA to submit quarterly proposed reports to the Bank interventions 24 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) throughout throughout implementation, implementation. supported by a comprehensive manual which will include inter alia the Exclusion List (to be included in the POM). Establish a strong Environmental SPIUs, Other Appropriate GRM grievance redress and Social Implementing protocol and staffing mechanism (GRM) Systems Agencies are in place. Prior to start of system to ensure that activities in No change the stakeholders are relevant state well sensitized ahead of any implementation. Establish a gender- Environmental SPIUs, Other First minutes of based violence (GBV) and Social Implementing committee meeting, response committee Systems Agencies Prior to start of including committee at the state level to activities in composition, No change proactively create a relevant state satisfactory to the safe place for all Bank. gender related issues. Preparation and Fiduciary FPIU Other SPIUs prepare and submission of Systems 45 days after submit program consolidated calendar the end of the financial reports to the No change relevant FPIU, and the FPIU consolidates the 25 The World Bank Nigeria Sustainable Urban and Rural Water Supply, Sanitation and Hygiene Program-for-Results (P170734) semester program calendar reports with its own financial reports. semester and submits to the Bank. Protocol adopted and Fiduciary FPIU Other Protocol adopted by implemented for Systems FPIU prior to reporting, effectiveness. Report management and on fraud and Prior to investigation of fraud corruption allegations effectiveness; No change and corruption submitted bi-annually Semi-annually allegations as part of Program operationalized in implementation MDAs implementing progress report. SURWASH program. Finalization and Fiduciary Min. Budget and Other Funds Release policy adoption of a ‘Funds Systems Planning; Min. finalized and MDAs Release policy’ for Finance BERs showing improved By cumulative budget No change predictability of funds effectiveness releases against flow to MDAs appropriations. implementing SURWASH. Proposed Action Description Source DLI# Responsibility Timing Completion Measurement . . 26