Agreements with Sub-sub-recipients
Sub-sub-recipients (SSRs) are Sub-recipients (SRs) of SRs. Engagement of SSRs carries high risks for UNDP, primarily because UNDP remains as fully accountable to the Global Fund for SSR activities as it is for SR activities, while having less control and oversight of them. Recent Office of Audit and Investigations (OAI) reports confirm that engagement and monitoring of SSRs remain a significant source of potential liability for UNDP. To minimize these risks, as well as to promote best practices, it is recommended that SSRs be engaged only in exceptional circumstances and that grant implementation activities be carried out by SRs or UNDP directly.
Where SSRs ought to be engaged, the SR in question must undertake a capacity assessment and select an SSR (or SSRs), based on the results of the assessment, in a transparent and documented manner. It must then obtain UNDP’s written approval and clearance of each selected SSR. Each SSR agreement must be consistent with the terms of the SR agreement. This is the SR’s responsibility and, while the CO may offer or agree to review the terms of the SSR agreement, such review should not rise to the level of approval of the SSR agreement, as this might create the impression that UNDP is a party to the SSR agreement, thereby increasing the risk for the organization.
Once the SSRs are engaged, UNDP must, at a minimum, make sure that the SR sets up adequate monitoring plans to oversee the activities of the SSRs.
Provision must be made to ensure that SSRs are audited at least once during the grant lifecycle. In the case of countries falling under the Global Fund’s Additional Safeguard Policy, SSRs must be audited annually.
For specific legal requirements that must be met prior to the engagement of an SSR, please see Art. XXV of the Grant Regulations to SR agreements with civil society organizations (CSOs) and government entities.