Public integrity is key to a resilient response to the COVID-19 crisis, ensuring that government action benefits those in need. This crisis creates opportunities for many integrity violations and could intensify fraud and corruption, particularly in public procurement, economic stimulus packages and public organisations. This could significantly undermine government action. Both short- and long-term measures are needed to address these risks, focusing on procurement strategies, the resources of internal audit functions, and integrity strategies in public organisations, among others. This policy brief discusses the key integrity challenges and recommends measures that can help governments ensure an effective response and recovery from the COVID-19 crisis.
The COVID-19 crisis is obliging governments to make quick decisions and implement drastic measures to protect communities at risk and limit the economic consequences that will follow. Past crises have shown that emergencies and subsequent rapid responses create opportunities for integrity violations, most notably fraud and corruption, seriously weakening the effectiveness of government action. Although fraud and corruption are not new phenomena, early evidence shows that they are occurring during the current crisis, while past experience suggests that their effects will likely be intensified in the near future. For example, there are instances of contracts for personal protective equipment being awarded to dubious companies; price gouging of key medication and healthcare equipment; doctors stockpiling treatments for friends and family; or various types of online fraud, amongst others. ;;;;;;;
In addition, as governments transition from addressing the immediate crisis to focusing on economic recovery, integrity violations may continue to rise and undermine recovery efforts. It is therefore imperative that fundamental safeguards of public integrity are not weakened or disregarded in both the immediate response as well as the longer-term recovery from COVID-19. The following three issues deserve particular attention, as they have a high impact on the success or failure of current and future government interventions:
Integrity challenges in public procurement.
Accountability, control and oversight of the economic stimulus packages.
Increased risks of integrity violations in public organisations.
The COVID-19 crisis has created three main integrity challenges for governments in the area of public procurement. First, governments are urgently procuring large quantities of goods and services, such as hospital equipment, medical ventilators, hand sanitisers, face masks, and health services, in order to meet the immediate needs of the health sector and affected communities. To address this, many OECD governments are enacting or reinforcing their emergency procurement procedures, using provisions that authorise and specify special procedures for emergencies. These provisions allow to procure necessary supplies directly from or via a pre-approved list of suppliers, without going through the standard, albeit lengthy, procurement processes. This may increase the integrity risks of procuring services and goods that do not meet quality standards and/or that are procured through corrupt means. While risks of fraud and corruption are always present in public procurement, they are elevated in emergency procurement processes. Past health and humanitarian crises, such as Hurricane Katrina in 2005 or the Ebola outbreak in 2014-16, have shown how these processes can be abused at the expense of those most in need of said goods and services ;;. Without the proper integrity and transparency safeguards in place, such emergency processes are vulnerable to abuse.
A second integrity consideration emerging from the COVID-19 crisis is the lack of stockpile preparedness across many OECD countries, leading to increased competition for necessary supplies globally. In this situation, the mechanics and bargaining powers of the public and the private sectors are reversed. Thousands of contracting authorities and private institutions are scouring the market for the same products that are produced by only a small number of suppliers. Furthermore, production in some of these companies is suspended or seriously affected by the lockdown measures. This exacerbates competition among public agencies and introduces haphazard practices in what is being described as an extremely chaotic market. Additionally, many countries are introducing export curbs to satisfy their national needs, which affects product availability at the global scale. Given market dominance, many transactions are taking place off-book, and price volatility is extreme, with often significant advance payments required by vendors. This could contribute to a paradigm shift in corrupt schemes, as buyers could now corrupt sellers in order to receive essential goods and services -- the reverse of what normally happens. Further, this risk could diffuse throughout the supply chain, since many of the supplies needed rely on scarce raw materials.
Finally, besides the procurement of goods and services required to directly address the current COVID-19 crisis, governments also have to manage ongoing public contracts. They must identify those particularly at risk and provide effective responses for suppliers seriously affected by the crisis and its impact on economic development. Governments, alongside their contracting authorities, must ensure that the suppliers most at risk are in a position to resume normal contract delivery once the outbreak is contained. Public procurement legislation often provides exceptional measures for paying ongoing contracts in emergency situations, for example allowing specific advance payments or exempting suppliers from penalties for the deficient performance of contracts. Such derogations to established practices that govern contractual relationships could open the door to corrupt practices, should those derogations not be subject to transparent guidelines communicated to all contracting authorities.
Some governments are putting strategies, regulations and guidelines in place to help their contracting authorities manage their suppliers portfolio, and making sure that fair, transparent and equitable mechanisms continue to govern contractual relationships. For example, the central purchasing body of Ireland, the Office of Government Procurement, developed an information note on good practices for contracting authorities during the COVID-19 outbreak. Similarly, the Ministry of Internal Affairs and Communications of Japan issued “Measures to be taken for public procurement by local governments in response to COVID-19”. In the United Kingdom, the Cabinet Office issued a procurement policy note on “Supplier relief due to COVID-19”. To ensure business and service continuity, the policy note provides that contracting authorities should pay all suppliers as quickly as possible to maintain cash flow and protect jobs. The note also emphasises that contracting authorities and suppliers should work collaboratively to ensure there is transparency during this period. Suppliers in receipt of public funds on this basis and during this period must agree to operate according to an ‘open book’ policy. This means they are required to make any data, including from ledgers, cash-flow forecasts, balance sheets, and profit and loss accounts, available to the contracting authority as requested, in order to demonstrate that payments have been made to the supplier under contract in the manner intended. Similarly, France and Italy have also developed and implemented new emergency procurement laws or guidance that deal specifically with the COVID-19 crisis ;.
The current crisis requires governments to take a number of measures to ensure integrity in public procurement processes. These include:
Maintaining and retaining documentation of procurement processes: basic documentation and record-keeping requirements should apply, including recording of information about procurement proceedings, any departures from or modifications of normal procurement procedures, the solicitation and submission of bids, recording of the grounds for any use of non-competitive procedures, information on bidders, evaluation of bids and contract awards.
Developing detailed guidelines on procurement strategies under a crisis, which deals not only with the procurement of emergency products but also with good practices to document the management of ongoing contracts or procedures.
Putting further emphasis on contract management, so that established procedures are applied to reinforce accountability and transparency.
Favouring existing collaborative procurement instruments such as framework agreements whenever possible to avoid awarding contracts without any competition and conduct emergency procurement within an already established contractual framework.
Ensuring maximum openness of information, including open data, as well as full disclosure of the measures used and their destination, stored in an accessible location.
Setting up a central price and supplier tracking system for key products and services that helps with identifying red flags, collusion, price gouging, counterfeits and other misbehaviours.
Subjecting all emergency procurement processes to audit and oversight.
Adapting audit and oversight strategies, as well as analyses of potential corrupt patterns in relation to the COVID-19 situation, where bargaining powers of the public and the private sectors are drastically reversed, including effects on competition.
Respecting the sunset clauses in place for the emergency procurement rules and extending only after applicable approvals (e.g. parliamentary oversight).
The COVID-19 crisis is already revealing gaps in existing emergency procurement plans, with some countries lacking the ability to respond quickly. Governments have had to rush to prepare legislation and policies to ensure they can secure required goods. Similarly, the lack of available stockpiles shows a vulnerability in preparedness. These issues present multi-faceted challenges, including those related to integrity and transparency. To address integrity challenges in the long term, once the immediate emergency is over, governments can consider the following:
Reviewing existing emergency procurement legislation to ensure that it is relevant for future global health emergencies, thereby avoiding the need to create new legislation or guidelines under tight timeframes.
Using or expanding existing e-procurement platforms to record transactional information on the procurement of emergency items. A database could be created to analyse bidding patterns and identify potential red flags, signalling risks posed to integrity.
Allowing remote access by auditors and oversight bodies to all procurement records, to ensure that audits can continue despite restrictions on carrying out physical inspections and paper-based reviews.
Ensuring an appropriate cadre of trained public officials who have the skills to carry out an emergency procurement procedure.
Preparing mechanisms to address future supply-chain disruptions for critical goods or services that are becoming evident in the crisis, for example the provision of personal protection equipment, since a shortage in supply is creating more potential for corruption. The European Union has already decided to create a stockpile of emergency medical equipment in this regard.
Creating digital and easily accessible tools to allow the public to track all emergency purchases undertaken in line with emergency procurement measures.
To mitigate the economic recession caused by COVID-19, governments are developing significant economic stimulus packages. Previous experiences with economic stimulus packages, most notably the one following the 2008 global financial crisis, show that the breadth and scope of such measures offer opportunities for and high risks of corruption, fraud, waste and abuse ;. Paradoxically, governments are relaxing controls in order to urgently spend funds, further amplifying these as well as strategic and operational risks, which can undermine the effectiveness and efficiency of such programmes.
This context puts pressure on public financial management systems, and more specifically internal control systems within public organisations. For instance, the pace of implementation of the economic stimulus packages requires adapting or relaxing routine control measures and ex ante due diligence. This can also involve simplifying requirements, such as limiting or delaying reporting, to allow managers time to focus on delivering services to the public.
Moreover, this situation is exacerbated by disruptions to the institutions that are typically responsible for accountability and oversight in government. These include internal audit functions, supreme audit institutions and parliamentary oversight committees. For example, in some cases, parliamentary oversight committees have been suspended, due to public health concerns or concerns over expediency. Many supreme audit institutions (SAIs) are also facing difficulties conducting audits and have postponed the publication of audit reports.
Despite the pressures facing internal control, internal audit and oversight functions within government, it is key to recall that these actors play a critical role in ensuring that public integrity is not compromised in the management of the economic stimulus packages and that these, in turn, produce the intended economic benefits. For example:
Internal auditors can act as backstops to address any temporary control gaps and flag risks to management as controls and requirements change, and can provide real-time assurance on the validity of transactions as a result of emergency measures, using data matching and other analytical methods.
SAIs can keep abreast of the modifications made to the public financial management systems and identify potential risk areas and, where necessary, adapt their routine end-of-year report audit activities, due to the volume of additional demands on the SAI’s audit capacity.
Internal audit functions, SAIs and other oversight bodies can help promote transparency and high-quality open data to enlist the public in holding government officials accountable. The 2008 financial crisis and the subsequent recession offer useful examples for the current circumstances, demonstrating the mutual dependencies of transparency and accountability. In the United States, the Recovery Accountability and Transparency Board, which co-ordinated the work of the inspectors general monitoring the implementation of the American Recovery and Reinvestment Act of 2009, created an analytical platform that could identify recipient anomalies, and then tasked the inspector general for the particular programme to address issues. This had the dual benefit of preventing both fraud and corruption, while also building the capacity of the inspector general functions within the line ministries . The public platform, Recovery.gov, allowed journalists and citizens to track their taxpayer money and see how the government was spending it.
Both internal and external auditors are also well placed to support governments in managing risks in the short term. For instance, they can provide useful insights to decision makers on the integrity risks associated with emergency measures, such as cash outflows to businesses and individuals.
To ensure that the internal control, internal audit and oversight functions can exercise effective accountability and oversight of the economic stimulus packages, a number of measures could be taken immediately. These include:
Ensuring that SAIs and internal audit functions have the resources they need: For instance, the United States' stimulus package also allocates funding to the Government Accountability Office (GAO), the SAI, enabling it to assist Congress in conducting oversight of overspending in relation to the current crisis. As such, governments can allocate, where necessary, the appropriate funding to ensure the necessary resources for conducting real-time audits of the economic stimulus packages.
Establishing or leveraging existing legislative committees: For example, in New Zealand, a bipartisan parliamentary oversight committee has been established and given the task of overseeing the government’s response to the current crisis, including the economic stimulus package. The committee meets remotely via video conferencing platform, and publishes these meetings online to ensure transparency.
Establishing specialised oversight bodies, while ensuring they have a clear and coherent mandate relative to existing accountability actors: For instance, the Pandemic Response Accountability Committee was established to ensure oversight of the economic stimulus package in the United States. To avoid duplication and draw on existing capacities, the Committee will be made up of independent Inspectors General with responsibilities for conducting and co-ordinating audits and investigations to provide accountability and identify waste, fraud, and abuse in crisis-related spending.
Articulating clear responsibilities and lines of communication to ensure that all public officials are accountable for their actions: As noted, the COVID-19 crisis and economic downturn creates risks for the public financial management system, and the standard policies and processes for internal control and risk management. While some controls may be relaxed to meet immediate needs, and the work environment has temporarily changed due to social distancing measures, managers remain a critical “first line” of assurance. Programme management can reinforce this individual responsibility and at the same time communicate the expectations to all staff of the need for continued vigilance over public funds.
Ensuring that the appropriate integrity risk assessments are carried out: Given the rapid pace at which these programmes are required to be rolled out, it may not be feasible to conduct a comprehensive integrity risk assessment. Public officials can, at the very minimum, be encouraged to document and report any obstacles and workarounds as they arise. This can include documenting changes to control activities in order to accommodate short-term objectives.
Ensuring that adequate procedures are in place to design, review and approve programmes urgently: For example, in order to ensure efficient yet accountable implementation of the 2008 Economic Action Plan, the Privy Council Office and Treasury Board Secretariat in Canada established an accelerated process for financial and policy approvals, reducing the timeframe from 6 months to 2 months. In the particular context of the COVID-19 crisis, with many public officials working from home, this could also include establishing protocols for using electronic signatures.
External oversight bodies can be a key partner for governments as they transition from the immediate crisis and prepare for the long-term repercussions. In particular, auditors can highlight the potential for emerging integrity risks associated with longer-term recovery measures. For instance, auditors can report to decision makers on ex post lessons learned to improve policy-making, especially on preparedness for future crises. Performance audits can give a wider perspective than just the financial and compliance aspects, and provide insights about the effectiveness, efficiency and economy of the programme, thus fulfilling their obligation to be “a credible source of independent and objective insight and guidance to support beneficial change in the public sector”.
SAIs can also adopt a risk-based and data-centred approach, while going beyond oversight to offer insights and foresight for better managing both the crisis and its aftermath. In particular, SAIs can support the centre of government and other public organisations, to identify and interpret evidence that can shape policies and improve the government’s capacity to act in real time in the face of evolving issues and risks.
While the majority of public sector employees have high standards of integrity, evidence from past recessions has shown that economic downturns lead to increased occupational fraud, embezzlement, bribery of public officials, and other integrity violations ;;. Such risks increase when the following three factors are at play, which is particularly the case in sudden economic downturns: financial pressure, opportunity and rationalisation. As an immediate and longer term consequence of the COVID-19, many individuals and especially small and medium enterprises will be facing increased financial shortcomings which may trigger corrupt behaviour or fraud. At the same time, mass redundancies that are especially pervasive during a recession create gaps in organisations' internal control and audit systems, leaving them more vulnerable to internal fraud and corrupt practices. Given the pressures, individuals may also rationalise wrongdoing through justification such as “everybody does it” or “if I don’t take the opportunity, others will” .
Emerging corruption cases and scandals may also negatively impact on citizens’ perceptions of corruption and thereby undermining support for government measures and reform. In the worst case, they also provide further rationalisation for wrongdoing. In turn, an increased level of corruption at various levels and areas raises the transaction costs of doing business and will have a negative impact on the resilience of economies after the crisis and be an obstacle to economic recovery.
In anticipation of this, public sector organisations can proactively improve controls that would prevent and detect corruption and occupational fraud during the recession. This could include:
Review and strengthen existing public integrity systems in public organisations. In the post COVID-19 economic recession, this will require a risk-based approach to identify which public organisation employees may be at higher risk and identify targeted mitigation measures. The OECD Recommendation of the Council on Public Integrity provides ample guidance on how to apply a systematic approach to fraud and corruption, building a culture of integrity and ensuring effective accountability.
Ensuring core internal controls, such as management certification of financial statements, anti-fraud policies, surprise audits and job rotations are in place, fit-for-purpose, and communicated to employees .
Leveraging and improving digital tools to promote integrity and accountability, especially by ensuring that relevant government data is available in an open and re-usable way allowing for social control or by ensuring the effectiveness of online reporting mechanisms.
Establishing or supporting employee counselling or financial assistance programmes, to support employees in addressing the increased financial pressures and feelings of helplessness that stem from economic crises.
Raising awareness of integrity standards, to ensure that all staff continue to abide by the rules and uphold public sector values to a high standard.
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Julio BACIO TERRACINO (✉ [email protected])
For example, most cases subject to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions are related to public procurement. See OECD Foreign Bribery Report: An Analysis of the Crime of Bribery of Foreign Public Officials, 2014.