The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) Ghana Secondary Cities Support Program (P164451) WESTERN AND CENTRAL AFRICA | Ghana | Urban, Resilience and Land Global Practice | Requesting Unit: AWCW1 (6547) | Responsible Unit: IAWU4 (10402) IBRD/IDA | Program-for-Results Financing | FY 2019 | Team Leader(s): Smile Kwawukume, Su Jung Song, Catherine Lynch Seq No: 12 | Archived on 08-Jul-2024 | ISR00929 | Created by: Su Jung Song on 07-Jun-2024 | Modified by: Catherine Lynch on 28-Jun-2024 1. PROJECT DEVELOPMENT OBJECTIVE 1.1 Development Objective Original Development Objective (Approved as part of Approval package on 24-Sept-2018) to improve urban management and basic urban services in participating municipal assemblies 2. OVERALL RATINGS Name Previous Current Progress towards achievement of lModerately Satisfactory lModerately Satisfactory PDO Overall Implementation Progress (IP) lModerately Unsatisfactory lModerately Satisfactory Overall Risk Rating lSubstantial lSubstantial 3. KEY ISSUES & STATUS 3.1 Implementation Status and Key Decisions The Ghana Secondary Cities Support Program (GSCSP, P164451) was approved by the World Bank Board on September 25, 2018, with an envelope of US$100 million. An additional financing of US$145 million IDA was approved in 2022 and the Program closing date was extended to December 31, 2025. The cumulative disbursement to date is USD135.5 million, representing 55.85% of the total credit. The original credit (CR.6319-GH) has disbursed 99%, while the AF new credit (CR.7141-GH) has disbursed 26%. Based on the results of the fourth Annual Performance Assessment, about US$56.0 million is expected to be disbursed to the MLGDRD by the end of June 2024. While there have been delays in the delivery of infrastructure at the Municipal Assembly (MA) level, positive progress has been made over the past 6 months. As of April 2024, 35 MAs utilized 78% or more of their Urban Development Grants for infrastructure delivery. Some of the completed sub-projects include 36.9 km of urban roads, 13 km of stormwater drain, and 18 urban Jul 08, 2024 Page 1 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) markets and bus terminals. Staff and consultants from the Ministry of Local Government, Decentralization, and Rural Development and the Office of the Head of Local Government Service, and Regional Coordinating Councils continued to provide technical back-up support and coaching to the MAs to facilitate implementation of the Program. 4. DATA ON FINANCIAL PERFORMANCE 4.1 Disbursements (by loan) Loan/Credit/ Cancelle Undisburs Status Original Revised Disbursed % Disbursed TF d ed IDA-63190 Closed 100.00 100.00 0.00 97.44 0.24 97.44% IDA-71410 Effective 145.00 145.00 0.00 38.09 106.91 26.27% 4.2 Key Dates (by loan) Orig. Rev. Loan/Credit/TF Status Approval Signing Effectiveness Closing Closing 25-Sept- 12-Dec- 30-Jun- IDA-63190 Closed 05-Feb-2019 30-Jun-2024 2018 2018 2024 05-Sept- 31-Dec- 31-Dec- IDA-71410 Effective 08-Jun-2022 05-Oct-2022 2022 2025 2025 4.3 Program Action Plan Hiring of a Social Development Specialist at the Program Execution level in Action Description addition to the current Environmental Specialist under the LGCSP. Source DLI# Responsibility Timing Timing Value Status Other NA MLGRD Due Date 31-Jan-2019 Completed Completion IVA contract. Measurement Comments Completed before the Program effectiveness in 2019. Establishing the E&S Team of MMA with clear terms of reference Action Description comprising of (i) Safeguards Focal person; (ii) 2-3 team members preferably from the Engineering, Health and Social Welfare Units of MMAs Jul 08, 2024 Page 2 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) Source DLI# Responsibility Timing Timing Value Status Environmental and NA MMA, OHLGS Due Date 31-Dec-2018 Completed Social Systems Completion Field verification. Measurement E&S team established and verified before the Program effectiveness in Comments 2019 Annual E & S performance review of MAs to validate existence of a Action Description functional E & S system and assess compliance. Source DLI# Responsibility Timing Timing Value Status Environmental MLGRD, EPA, In and Social NA Independent Recurrent Continuous Progress Systems consultants Completion ToR for the performance review and annual performance review report. Measurement The annual E&S performance review/audit has been conducted each year. 2022 E&S audit report was submitted; challenges, areas for improvement, Comments next steps and actions were identified to enhance the performance. 2023 E&S audit will be conducted in 2024. Strengthen consultations, information disclosure and grievance redress by Action Description developing guidelines on consultations and stakeholder engagement with support from the World Bank. Source DLI# Responsibility Timing Timing Value Status Other NA MLGRD, MAs Due Date 31-Dec-2018 Completed Completion Guidelines on consultations and stakeholders engagement. Measurement Guidelines on consultations and stakeholders engagement were Comments developed. Coordination and implementation of gender related activities between the Action Description MGCSP, MLGRD, RCCs and the MAs Source DLI# Responsibility Timing Timing Value Status MLGRD, RCC, In Technical NA Recurrent Yearly MAs Progress Jul 08, 2024 Page 3 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) (i) The dissemination of the gender strategy in 2022 or 2023 and provision Completion of trainings/workshops for RCCs and MAs with CSOs and NGOs in 2023- Measurement 2025. (ii) Gender activities documented in the annual progress report during Year 4-7(2022-2025) Dissemination of the Gender Strategy has been rescheduled to the third quarter of 2024. This will be followed with training workshops for the MAs Comments and RCCs. Some gender activities undertaken were documented in the 2023 Semi-Annual Progress Report. Action Improvement in MA revenue mobilization drive; Building capacity of MA Description revenue officers for improved IGF mobilization and collection Source DLI# Responsibility Timing Timing Value Status Fiduciary MoF, OHLGS, In NA Recurrent Continuous Systems RCC Progress Completion Increase in IGF Measurement IGF has been monitored as one of the intermediate indicators, demonstrating an increasing trend. To assess the real impact, the increase Comments in program MAs' IGF will be compared with the IGF performance of all 261 MMDAs and documented. Training and capacity building for producing financial reports through Action Description GIFMIS; with Regional transaction processing centers located at RCCs used by participating MAs that have no direct access to GIFMIS Source DLI# Responsibility Timing Timing Value Status Semi- In Fiduciary Systems NA CAGD/GIFMIS Recurrent Annually Progress Completion Adoption and implementation of annual MLGRD/MDAs technical back-up Measurement support plan to support continuous development of accountants. All Participating MAs have access to GIFMIS. CAGD has provided training in Comments the usage of GIFMIS to all RFOs; however, CAGD is yet to migrate them unto the system as of March 31, 2024. Enforce follow-up measures and address audit recommendations (internal Action and external) as per PFM Act 2016, Act 921. Strengthen internal audit units Description to effectively report financial improprieties Source DLI# Responsibility Timing Timing Value Status Jul 08, 2024 Page 4 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) Fiduciary MDAs, OHLGS, In NA Recurrent Continuous Systems RCC, MAs Progress Completion Follow-up reports (statement of audit recommendation implementation) Measurement On-going every year. MAs had carried through their 2023 action plans Comments which addressed audit recommendations in their quarterly audit reports. Action Strengthen Audit Committees (ACs) in terms of training and capacity Description building on reviewing audit reports and following up on recommendations. Source DLI# Responsibility Timing Timing Value Status MoF, IAA, Fiduciary In NA OHLGS, RCC, Recurrent Continuous Systems Progress MAs Adoption and implementation of annual MLGRD/MDAs technical back-up Completion support plan. Measurement Evidence of AC meetings to review audit recommendations. On-going every year. Inauguration and training by IAA completed. AC Comments review report of audit recommendations is required to submit and share with the WB. Action Continuous M&E of procurement execution and contract performance, and Description undertake annual procurement assessment Source DLI# Responsibility Timing Timing Value Status Fiduciary MLGRD, PPA, In NA Recurrent Continuous Systems RCC, MAs Progress Completion Procurement and contract performance tracking form Measurement Procurement and contract performance tracking form was developed and Comments utilized. Generate and maintain up-to-date records of grievances received, treated, referred to other agencies. Prepare annual grievance redress report, Action Description showing grievances received, proportion handled and cases referred to CHRAJ and other agencies. Source DLI# Responsibility Timing Timing Value Status Jul 08, 2024 Page 5 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) Environmental CHRAJ, MLGRD, In and Social NA Recurrent Continuous MAs Progress Systems Completion Annual grievance redress report. Measurement Biannual CHRAJ report. Semi-annual and annual progress report include grievance redress report, Comments and CHRAJ reports have been collected since 2022. Action Description Develop grievance redress manual/guideline Source DLI# Responsibility Timing Timing Value Status Other NA MLGRD Due Date 31-Dec-2019 Completed Completion Grievance redress manual/guideline Measurement Comments Grievance redress manual/guideline was developed. Action Develop websites for participating MAs; Ensure publication of key fiscal Description information on notice boards Source DLI# Responsibility Timing Timing Value Status In Other NA MLGDRD Recurrent Continuous Progress (i) POM defines key fiscal information, (ii) MAs’ websites and notice boards Completion with the key fiscal information published, (iii) document the status of Measurement websites and notice boards in annual progress report All the participating MAs have developed their own websites; MLGDRD has Comments been undertaking annual assessments on MAs’ governance capacity and specifically their capacity for Information Disclosure. Action All participating MAs appoint Audit committee members in accordance with Description the PFM Act 2016 Source DLI# Responsibility Timing Timing Value Status Fiduciary In NA MLGDRD, MAs Recurrent Continuous Systems Progress Completion Annual Audit Committee report Measurement All participating MAs have established Audit Committees and they are Comments functional Jul 08, 2024 Page 6 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) Develop a robust E&S screening mechanism and management framework Action Description process using the GOG’s guidelines, and ensure publication of key E&S documents on Ministry and MA websites. Source DLI# Responsibility Timing Timing Value Status Environmental and MLGDRD, EPA, In NA Recurrent Yearly Social Systems MAs Progress Completion Screening mechanism manual prepared and submitted to the Bank. E&S Measurement instruments disclosed on websites of the Ministry and MAs. The screening mechanisms have been revised for the screening of the Comments multi-year investments (UDGs 3-5). The revision included updating EPA’s EIA Form1 and enforcing the use of updated Urban Resilience Checklists. Sexual Exploitation and Abuse (SEA) and Sexual Harassment (SH) Action Description response committee at the MA level to proactively create a safe place for all gender-based violence related issues. Source DLI# Responsibility Timing Timing Value Status Environmental and In NA MLGDRD Recurrent Yearly Social Systems Progress Completion First Minutes of Committee Meeting including the Committee composition Measurement satisfactory to the Bank The Program has leveraged the existing Public Relations and Complaints Comments Committees (PRCC) at the various MAs to take chage of SEA ahd SH issues as per the Section 26 (1)(d) of the Local Government Act, 2016 (Act 936). MOU with EPA Training Institute to develop and deliver training modules to MLGRD, EPA staff, RCCs, MMAs and their E & S consultants: (i) Action Description Procurement procedures to manage relevant E&S risks; (ii) ESHS monitoring procedures and reporting Source DLI# Responsibility Timing Timing Value Status Environmental In and Social NA MLGDRD, EPA Other Continuous Progress Systems Completion Training modules developed and trainings delivered to the associated Measurement entities recorded in annual progress report The EPA Training Institute has developed and updated training modules. Comments The trainings held are documented in annual progress report. Jul 08, 2024 Page 7 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) Action All Implementing Agencies to use the Ghana e-GP for the procurement Description under the Program Source DLI# Responsibility Timing Timing Value Status Fiduciary MLGDRD, MAs, In NA Recurrent Continuous Systems OHLGS Progress Completion Trained, onboarded and start using e-GP after the AF effectiveness Measurement 100 percent of planned activities were carried out using GHANEPS at all Comments implementing entities. 5. KEY DATES Key Events Planned Actual Approval 25-Sept-2018 25-Sept-2018 Effectiveness Not Available 05-Feb-2019 Mid-Term Review No. 01 17-Nov-2021 04-Mar-2022 Operation Closing/Cancellation 31-Dec-2025 6. SYSTEMATIC OPERATIONS RISK-RATING TOOL Rating at Last Approved Approval Rating Risk Category Approval Proposed Rating ISR Seq. 011 - 28 Package - 25 Sep Dec 2023 2018 Political and Governance lModerate lSubstantial lSubstantial Macroeconomic lSubstantial lSubstantial lSubstantial Sector Strategies and Policies lModerate lModerate lModerate Technical Design of Project or lModerate lSubstantial lModerate Program Institutional Capacity for lModerate lModerate lModerate Implementation and Sustainability Jul 08, 2024 Page 8 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) Fiduciary lSubstantial lSubstantial lModerate Environment and Social lSubstantial lSubstantial lSubstantial Stakeholders lModerate lModerate lModerate Overall lSubstantial lSubstantial lSubstantial Jul 08, 2024 Page 9 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) 7. RESULTS 7.1 PDO Indicators by PDO Outcomes To improve urban management and basic urban services in participating Municipal Assemblies Baseline Actual (Previous) Actual (Current) Closing Period Indicator Name Value Month/Year Value Date Value Date Value Month/Year 0.00 Jun/2018 962.00 20-Nov- 2,050.00 Dec/2025 People provided with 2023 improved urban Comments on This is to measure the cumulative number of direct beneficiaries provided infrastructure/services achieving targets with improved access to infrastructure and services under the Program under the GSCSP through Urban Development Grants. The target is set to benefit 40 (Number (Thousand)) percent of the population of Program Participating ciies. 0.00 Jun/2018 497.00 20-Nov- 1,040.00 Dec/2025 2023 Comments on This is to measure the number of female direct beneficiaries, provided of which female achieving targets with improved access to infrastructure and services through Urban (Number Development Grants. The number of female direct beneficiaries will be (Thousand)) further disaggregated by type of investment. Number of females who benefited from streetlights, pedestrian walkways, sanitation facilities in urban parks and markets will be monitored (gender tagging indicator). Composite annual 0.00 Jun/2018 75.5 07-Jun- 75.5 07-Jun- 80.00 Dec/2023 average urban 2024 2024 performance Comments on Average percentage score of institutional performance benchmarks (DLI3) benchmark percentage achieving targets that the participating sub-national entities have achieved score by Progam MAs (Percentage) Jul 08, 2024 Page 10 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) 7.2 Intermediate Results Indicators by Results Areas Results Area 1: Institutional Performance at Program MAs Baseline Actual (Previous) Actual (Current) Closing Period Indicator Name Value Month/Year Value Date Value Date Value Month/Year Program MAs with 0.00 Jun/2018 18.00 20-Nov- 35.00 Dec/2025 Municipal Structure 2023 Plans (15 years) Comments on This is to measure the number of participating MAs with Municipal (Number) achieving targets Structure Plans (15 years). Program MAs with 0.00 Jun/2018 29.00 20-Nov- 35.00 Dec/2025 Municipal Local Plans 2023 covering at least 30% Comments on This is to measure the number of Program participating MAs with local of the municipal area achieving targets plans covering at least 30% of MA’s administrative boundary. (Number) 0.00 Jun/2018 13.00 20-Nov- 35.00 Dec/2025 Program MAs 2023 monitoring key Comments on This is to measure the number of Program participating MAs that monitor municipal services achieving targets key municipal services as defined and guided in the POM (linked to DLI 3 (Number) performance benchmark). 0.00 Jun/2018 15.00 20-Nov- 35.00 Dec/2025 MAs that execute at 2023 least 80 percent of Comments on This is to measure the number of Program participating MAs that execute at their O&M budget achieving targets least 80 percent of their O&M budget. (Number) MAs with improved and 0.00 Jun/2018 9.00 07-Jun- 9.00 07-Jun- 35.00 Dec/2025 up to date Revenue 2024 2024 Administration Comments on This is to measure the number of Program participating MAs that have an (Computer-based) achieving targets improved and up to date Revenue Administration (Computer-based) systems (Number) systems, as defined and guided in the POM. Jul 08, 2024 Page 11 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) MAs that satisfy at 0.00 Jun/2018 15.00 20-Nov- 30.00 Dec/2025 least 80% of the 2023 defined governance Comments on This is to measure the number of Program participating MAs that satisfy at capacity criteria achieving targets least 80% of the governance capacity criteria, defined in the POM (Number) MAs that implement at 0.00 Jun/2018 14.00 20-Nov- 35.00 Dec/2025 least 80% of the 2023 planned gender Comments on This is to measure the number of Program participating MAs that programs as per the achieving targets implement at least 80% of the planned gender programs as per the annual annual action plan action plan (Number) MAs that implement to be Mar/2022 35 07-Jun- 35 07-Jun- 35 Dec/2025 climate/disaster urban updated 2024 2024 resilience checklist at Comments on This is to measure the number of Program participating MAs that planning, designing, achieving targets implement climate and disaster urban resilience checklist at planning, construction, and O&M designing, construction, and O&M stages, as defined and guided in the stages (Text) POM Results Area 2: Infrstructure delivery Baseline Actual (Previous) Actual (Current) Closing Period Indicator Name Value Month/Year Value Date Value Date Value Month/Year 0.00 Jun/2018 76.20 20-Nov- 100.00 Dec/2025 2023 Cumulative average Comments on This is to measure cumulative average delivery rate of UDG infrastructure urban infrastructure achieving targets investments in the Program participating MAs. The indicator will be delivery percentage by determined based on actual and cumulative delivery of infrastructure Program MAs investments against annual delivery targets, the methodology of (Number) calculating delivery rate will be specified in the POM and the APA guideline. 0 Jun/2018 36.91 km 07-Jun- 36.91 km 07-Jun- Set as per Dec/2025 2024 2024 accumulated Jul 08, 2024 Page 12 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) in work plans for Urban roads built or Program rehabilitated using UDG cities (Text) Comments on This is to measure the cumulative km of roads rehabilitated/constructed achieving targets under the Program 0 Jun/2018 14 20-Nov- Set as per Dec/2025 2023 accumulated Municipal local in work economic infrastructure plans for built or rehabilitated Program using UDG (Text) cities Comments on This is to measure the number of municipal local economic infrastructure achieving targets built or rehabilitated under the Program 0 Jun/2018 13.03km 20-Nov- Set as per Dec/2025 2023 accumulated in work Drains built or plans for rehabilitated using UDG Program (Text) cities Comments on This is to measure the km of drains built or rehabilitated under the achieving targets Program 0 Jun/2018 1 20-Nov- Set as per Dec/2025 2023 accumulated Public parks and in work greenery built or plans for rehabilitated using UDG Program (Text) cities Comments on This is to measure the cumulative area of green parks achieving targets constructed/rehabilitated under the Program. Jul 08, 2024 Page 13 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) to be Apr/2022 n/a 20-Nov- to be Dec/2025 updated 2023 determined Satisfaction of Comments on This is to measure the satisfaction of the beneficiaries with improved access beneficiaries with achieving targets to infrastructure and services supported by the Program. The baseline will improved access to and the end target will be established by the 2022 satisfaction survey. The infrastructure and final satisfaction survey in 2025 will measure the success of the services supported by indicator. Baseline survey is planned as soon as the Program fund disburse the Program (Text) after the effectiveness. The ToR is drafted and the baseline study will be completed within the first half of 2023. Results Area 3: Regional and National Government Support to MAs Baseline Actual (Previous) Actual (Current) Closing Period Indicator Name Value Month/Year Value Date Value Date Value Month/Year RCCs Annual Capacity 0.00 Jun/2018 94.60 20-Nov- 100.00 Dec/2025 Support Plans for MAs 2023 implemented Comments on This is to measure the percentage implementation of RCCs Annual (Percentage) achieving targets Capacity Support Plans OHLGS Annual Capacity 0.00 Jun/2018 100.00 20-Nov- 100.00 Dec/2025 Building Plan 2023 implemented Comments on This is to measure the percentage implementation of OHLGS Annual (Percentage) achieving targets Capacity Building Plan MLGRD/MDAs approved 0.00 Jun/2018 100.00 07-Jun- 100.00 07-Jun- 100.00 Dec/2025 Annual Workplan 2024 2024 implemented Comments on This is to measure the implementation rate of MLGRD/MDAs approved (Percentage) achieving targets Annual Workplan Improved - Jun/2018 September 20-Nov- October 1 of Dec/2024 Intergovernmental 30, 2022 2023 2024 Jul 08, 2024 Page 14 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) Fiscal Transfer System Comments on This is to measure whether improved Intergovernmental Fiscal Transfer (IGFTS) adopted with achieving targets System (IGFTS) adopted with timely allocation and publication of UDGs to timely allocation and MAs publication of UDGs to MAs (Text) 7.3 Disbursement Linked Indicators (DLI) Actual (Previous) Actual (Current) Closing PBC Name Baseline Value Date Value Date Period 1:Extent to Value 0.00 31.00 31.00 0.00 which Participating Municipal Assemblies 20-Nov- have achieved Allocated 20-Nov-2023 0.00 0.00 2023 0.00 Capacity Amount Support Grant (CSG) Minimum Conditions (Number) DLI allocation 7,168,844.00 2:Extent to Value 0.00 35.00 35.00 35.00 which Participating 20-Nov- Municipal Allocated 20-Nov-2023 0.00 0.00 2023 10,790,697.00 Assemblies Amount have scored equal to or Jul 08, 2024 Page 15 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) above the national average DPAT Score (Number) DLI allocation 55,953,782.00 3:Extent to Value 0.00 73.20 73.20 80.00 which Participating Municipal Assemblies 20-Nov- have achieved Allocated 20-Nov-2023 0.00 0.00 2023 27,372,091.00 Urban Amount Performance Benchmarks Targets (Percentage) DLI allocation 145,446,570.00 4:Extent to Value 0.00 44.60 44.60 90.00 which Participating Municipal Assemblies have 20-Nov- Allocated 20-Nov-2023 implemented 0.00 0.00 2023 4,899,597.00 the Annual Amount Infrastructure Service Delivery Target (Percentage) DLI allocation 22,157,163.00 Value 0.00 15.00 20-Nov-2023 15.00 16.00 Jul 08, 2024 Page 16 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) 5:Regional Coordinating Councils have adopted and implemented Allocated 20-Nov- 0.00 0.00 960,000.00 their Annual Amount 2023 Capacity Support Plans (ACSP) for MAs. (Number) DLI allocation 4,652,166.00 6:DPAT/APA September, 30, September, 30, Value - October 1 Assessments 2022 2022 Results 20-Nov- 20-Nov-2023 Published by Allocated 2023 October 1 of 0.00 0.00 750,000.00 Amount each FY (Text) DLI allocation 3,105,975.00 7:Timely Value - Yes Yes Yes Allocation and Release of Program Funds to Municipal Assemblies; and 20-Nov- Implementation Allocated 20-Nov-2023 0.00 0.00 2023 750,000.00 of MLGRD/MDAs Amount Annual Workplan to support Participating MAs (Text) Jul 08, 2024 Page 17 of 18 The World Bank Implementation Status & Results Report Ghana Secondary Cities Support Program (P164451) DLI allocation 3,730,965.00 8:Key RCCs and Value No Yes Yes Yes MAs staff have been assigned and OHLGS Annual Capacity Building Plan 20-Nov- (ACBP) to Allocated 20-Nov-2023 0.00 0.00 2023 600,000.00 support Amount Particpating MAs and RCCs has been implemented (Text) DLI allocation 2,784,536.00 Jul 08, 2024 Page 18 of 18