1. IEG INDEPENDENT EVALUATION GROUP
World Bank
Budget Support to
IDA Countries
Anjali Kumar
Independent Evaluation Group, World Bank
Presentation to the UK Department for International Development
London, September 24th, 2010

2. IEG INDEPENDENT EVALUATION GROUP
World Bank
Budget Support to
IDA Countries
Anjali Kumar
Independent Evaluation Group, World Bank
Presentation to the Swiss Development
Corporation
Bern, September 27th, 2010

3. PRSCs reflected the Bank’s response to shift s in the aid paradigm
Anchored in country-owned development strategies
Implementation through country systems
Responsible fiduciary environments
Explicit poverty-oriented growth
Pro-poor service delivery
SHARES OF BANK LENDING (TOTAL, PBL, IDA, etc.)
Share of the PRSC in total IDA disbursements (including investment lending) grew from 5 percent in FY02 to a peak of 17 percent in FY05, declining to 11.3 percent in FY08
By FY2005, PRSCs accounted for:
25% of total Bank (IDA + IBRD) policy based lending
60% of IDA policy based loans
Over 50% of total (IDA?) Bank lending to many PRSC countries (e.g. Benin, Burkina Faso, Ghana, Rwanda, and Uganda)
In some years, over 60 percent of IDA flows (Burkina Faso) and 80 percent (Uganda).
PRSC disbursements averaged (over what time period??) a third of total disbursements to PRSC countries in years they had a PRSC operation
For all recipient countries, the share of PRSCs in total World Bank disbursements has averaged % over the past five years
PRSC shares in Bank disbursements have declined recently, as has their contribution to budget support in recipient countries
PRSCs have never made up a large part of government budget needs
7 percent for PRSC recipients in 2001
5.4 percent in 2004
Share has declined steadily since then to 1.5 percent in 2008.
PRSCs have declined relative to total aid and total budget support aid PRSC countries have received from all sources
(despite some proportional decline in aid flows to PRSC countries, relative to their national income, from over 15 % to around 10 %, reflecting an overall increase in budget support aid as a proportion of total aid, at least until 2006.
Some Bank operations have PRSC characteristics but not the label 3

4. From 2001-09, 99 PRSC operations were approved
From 2001 to September 2009, 99 PRSC operations were approved
From , 99 PRSC operations were approved
…worth $8 billion, in 27 countries
20 more operations ($1.7billion) under preparation (for FY10)
One-fourth of Bank policy lending but 30-40% of disbursements to PRSC countries
But PRSC share of country budgets is declining (7 % in 2001; 1.5% in 2008)
Countries with ongoing PRSCs
GROWTH
PRSC operations initially grew rapidly in number and importance
From 21 operations in FY01-04…
To 66 operations in FY05-08:
From 2 per year in FY01-02
To 10 per year in FY04, and
Between per year from FY05-08
Number of countries w/ ongoing PRSC operations increased to 20 by FY05, and fluctuated around this level thereafter.
TOTALS
PRSCs expanded from 21 operations in FY01 to FY04 to 66 in FY05-FY08 (Figure 3, Appendix Table A1.3). Over this period the Bank approved 87 PRSC operations. Total approvals by end FY08 amounted to $ 6.6 billion. Further approvals of $1.3 billion brought the total to 99 operations by end-September Another 20 operations amounting to $1.7 billion are under preparation
From FY01-FY08: 87 PRSC operations approved: $ 6.6 billion
By end-September 2009: further approvals of $1.3 billion  total of 99 operations.
Currently under preparation: 20 more operations = $1.7 billion.
New PRSCs approved each year rose (Figure 3). The
Total of 27 countries have received PRSC funding through FY08
Of these, 10 have embarked upon their second or even third
Another 9 have had a single PRSC series so far.
In 8 countries, PRSC operations were abandoned, and did not mature into a full programmatic series.
Some early PRSCs began preparation as Structural Adjustment Credits—Vietnam, Lao PDR, and Nicaragua.
Bank also had poverty-focused programmatic loans that did not bear the PRSC label (e.g. Bangladesh Development Credits, Tajikistan Programmatic Development Policy Grants.
Esp. b/w 2002 and 2005, several other IDA countries considered or began preparation of PRSCs but did not proceed.
PRSCs had other implicit criteria; broad-based support to countries with strong reform commitment. The group of PRSC lookalikes is small.
This evaluation does not adjust, through omission or inclusion, for those operations that have PRSC characteristics but do not bear its name.
Africa—began using PRSCs early (Uganda FY01, Burkina Faso FY02)
Always largest portfolio of PRSCs (13 countries by FY08).
Clear vision for the PRSC from 2003, as a reward for high performers with trustworthy public financial management systems.
PRSCs there have strongly emphasized building & using country systems / donor harmonization around common medium-term reform framework.
East Asia and Pacific
Vietnam’s first PRSC largely a continuation of Bank lending in 1990s.
Lao PDR budget support provided via the PRSC leveraged government reforms accompanying support for large-scale hydroelectric projects and envisaged Bank investment.
Europe and Central Asia
In the 5 ECA countries that had PRSC (Albania, Armenia, Azerbaijan, Georgia, and Moldova), PRSCs generally provided small share of country budget.
PRSC policy measures are less focused on building country systems (as in Africa), more on transitions toward market-led growth.
Donor harmonization has not been a major element due to limited other budget support. Overall regional role is small.
In FY09, Georgia is only country with active PRSC program.
Three ECA PRSC countries have graduated from IDA or chosen other instruments.
Latin America and Caribbean
3 countries had embarked on PRSCs (Guyana, Honduras, and Nicaragua), but currently no ongoing operations.
PRSCs were discontinued largely due to political changes limiting reform sustainability.
Middle East and North Africa
PRSC has never a part of MNA lending portfolio. Only 3 IDA-eligible countries (Djibouti, Sudan, and Yemen).
2 of these (Djibouti and Yemen) had high Country Policy and Institutional Assessment (CPIA) scores history of adjustment lending/development policy lending and may have been PRSC eligible. Yemen’s Institutional Reform Credit, approved in December 2007, focuses on growth and governance, and did not use the PRSC label.
South Asia
Nepal, Pakistan, and Sri Lanka initiated PRSCs over , but currently no ongoing operations.
Nepal and Sri Lanka’s PRSCs terminated after first operation b/c of political instability
Pakistan’s PRSC lost relevance-overtaken by domestic events.
PRSCs in South Asia supported ongoing reform efforts though the longer-term capacity development approach of Africa was less evident.
New PRSCs approved

5. Introduced under Interim Guidelines in 2001
…PRSCs were not a separate instrument after 2004, but the PRSC label retains many distinguishing features:
Built around credible poverty reduction strategies
Broad-based programmatic support
For better-performing IDA countries
Oriented toward poverty-reducing growth
Add – Changes in aid architecture (see box)
Country ownership
CDF and poverty reduction measured in multiple dimensions
Budget support instead of project support
Donor coordination 5 5

6. Three Key Findings 1. PRSCs improved aid processes
Enhanced country ownership
Eased conditionality
Better predictability
More pro-poor service delivery
2. Growth and poverty outcomes are unclear
Weak Results frameworks
Partial Support to Sectors
3. Other Policy Based Lending converged to a similar design

7. Evaluation Results Chain
Inputs
Predictable medium term resources
Aligned with country needs
Outputs
Implementation of PRSP
Improved accountability
Enhanced donor harmonization
Outcomes
Effective public administration
Improved climate for growth
Better pro-poor service delivery
Impact
Sustained growth
Reduction of poverty 7

8. PRSCs improved the aid process

9. PRSCs were expected to ease aid processes
Eased conditionality
Increased flexibility
Greater predictability in volume and frequency
Better alignment with client budget cycles
Improved vehicle for donor harmonization 9

10. Eased conditionality -
…conditionality declined in all policy lending
PRSC legal conditions
Non-PRSC legal conditions
PRSCs vs. other policy-based lending
PRSCs had fewer legally binding conditions from the outset
Conditionality in PRSCs was low from outset, subsequent reductions occurred mostly in program benchmarks, and misperceptions linger re: differences between legal conditions and benchmarks
Legally binding conditionality declined in all policy-based adjustment lending, decline began before the PRSC, and non-PRSC conditionality declined faster
Conditionality for subsequent operations was more flexible, through the introduction of triggers
Conditions in PRSC and non-PRSC loans now the same

11. Eased conditionality -
…conditionality declined in all policy lending
PRSC program benchmarks
Non-PRSC program benchmarks
PRSCs vs. other policy-based lending
PRSCs had fewer legally binding conditions from the outset
Conditionality in PRSCs was low from outset, subsequent reductions occurred mostly in program benchmarks, and misperceptions linger re: differences between legal conditions and benchmarks
Legally binding conditionality declined in all policy-based adjustment lending, decline began before the PRSC, and non-PRSC conditionality declined faster
Conditionality for subsequent operations was more flexible, through the introduction of triggers
Conditions in PRSC and non-PRSC loans now the same

12. More flexibility in interpreting conditionality…
PRSCs introduced ‘triggers’ -- indicative prior actions in place of legally binding tranche release conditions
Triggers between FY01 and FY08:
59% met
15% downgraded
9% amended
8% dropped
9% replaced/postponed
Sometimes new prior actions were included
Adjustments in Conditionality—Triggers and Subsequent Prior Actions
The Bank adopted a very different level of flexibility for PRSCs compared to former adjustment loans
Indicative triggers in PRSC operations may be compared with legally binding tranche release conditions in previous adjustment lending
Waivers for tranche release conditions were rare, but most PRSCs had modifications in some triggers
Some PRSCs included new “prior actions” that had not earlier been anticipated as triggers
Over time there was some reduction in the number of triggers modified 12

13. More lending for social services and public sector management…
Which countries received PRSCs?
Better (institutional) performers
Past performance & stability less important
Screening for reform commitment improved over time
Which sectors were emphasized?
Broader, less macro, more PFMP and pro-poor services
Reinforced but did not replace sectoral lending
Loss of depth, predictability in sectoral dialogue?
Less focus on macro adjustment than earlier policy-based lending
More public financial management and pro-poor social service delivery: health, education, and water supply and sanitation (increased over time)
Wider sectoral coverage than previous adjustment lending, especially in program benchmarks
All adjustment lending evolved in same direction
Despite expectations, PRSCs rarely replaced freestanding sector lending, rarely able to fully incorporate sectoral lending
PRSCs support sectoral objectives by reinforcing crosscutting and overarching issues
Some views that PRSCs lead to a loss of depth in sector dialogue and has not helped resource predictability to line agencies
as did other DPLs 13

14. More predictable resources …
Burkina Faso is a good example…
A steady volume of disbursements, in the same quarter per series…

15. Budget support through PRSCs complemented sector lending…
…Replacement was rare
Many tried to channel sector lending through the PRSC:
Of 15 CASs in health and education, only 2 achieved sustained results
Of 6 CASs in nutrition, water supply, agriculture or environmental management, 1 on a sustained basis

16. Weak but improving results frameworks
Need for:
Clearly defined indicators
Baseline data
Consistent over time
Intermediate milestones
Shortcomings due to:
Weak upstream PRSPs/ CASs
Multi-donor process differences
Modest M&E frameworks, often reflecting weak country statistical capacity
Baseline, intermediate, and end-of-series indicators have improved, but shortcomings remain in defining baselines, intermediate milestones, and indicators for tracking pro-poor outcomes
IEG findings are corroborated by information from other Bank studies

17. PRSCs improved donor harmonization
Sometimes as a focal point for donors
Often as member of a multi-donor group
Harmonized common donor matrices and alignment with the national plans
Reduced transaction costs for recipients
Provided Bank expertise to recipients and other donors
Bank harmonized more missions than other donors in PRSC as well as non-PRSC countries, especially weaker IDA countries
Harmonization without jointly negotiated PAF (e.g. Vietnam) Bank’s PRSC merged with the national development strategy over time, and Bank led donor process)
Harmonization with other budget support donors—the joint matrix
Multi-donor budget support groups most common for PRSCs, especially in Africa

18. Donor harmonization challenges remain
Limited integration of PRS reviews with the joint matrix (PAF) Initial perception of increased conditionality Increased transaction costs for Bank (e.g. Mozambique, Ghana) Some loss in Bank relevance alongside undue influence of small donors
Contributions to Aid Flows
: PRSCs are the sole source of budget support aid in some countries with short PRSC series and a limited donor process
Progress has been made in achieving harmonized matrices, but conditionality may initially increase to accommodate all donors
Progress is limited in harmonizing reviews of the PRS and integrating it with the joint matrix, harmonized results indicators, or reporting arrangements
In a large Budget Support Group, the Bank may lose the ability to incorporate substantive issues in the agenda
The Bank’s processing calendar may limit its voice in a joint process
Individual small donors can sometimes unduly influence the agenda
Recipients may prefer to leave major items off the agenda
Sector working groups have contributed little to harmonization
Reconciliation of Bank policy-based versus EU outcome-based aid is desirable
Harmonization has high transactions costs for Bank PRSC staff
Despite stagnant shares in budget support, PRSCs made effective contributions to donor harmonization
Achievements of PRSCs in a Multi-Donor Environment
Bank played pivotal role (and led the process) in donor harmonization in Lao PDR, Vietnam
Bank a reliable team member with deep technical ability in countries w/ large budget support
Common donor matrix process usually aligned with the national plans but not with process of review and reporting on the national plans
Variable performance of multi-donor sector groups, with limited support to PRSC process
Donors have begun to support separate sector funds
Harmonization toward a joint matrix may initially increase number of conditions
Sometimes, donor process limits Bank’s ability to bring substantive issues to PRSC agenda
Donor coordination has reduced transaction costs for recipients, but transaction costs for Bank has increased, with some loss in relevance
Better harmonized disbursements limited by differences between Bank and other donors
Coordination of capacity building?
Joint Missions and Joint Analytic Work
Bank harmonized more missions than other donors in PRSC and non- PRSC countries, especially weaker IDA countries
Much of analytic work was donor coordinated, especially by the Bank, but coordination was not higher in PRSC countries
Aid to PRSC countries was clearly channeled more through in-country systems
Views on Harmonization: Clients, Staff and Donors
Clients acknowledge Bank efforts in donor coordination
Clients believe that harmonization initially increased conditionality but improved predictability
Bank staff feel that the transaction costs of donor harmonization for Bank staff are not adequately recognized
Other donors also feel burdened by the high transaction costs of harmonization
Concrete examples of increased transactions costs from country case studies
Mozambique
3.21 It is not clear whether the harmonized framework has reduced overall transaction costs for government. Government officials repeatedly pointed out that the working group set up and semi-annual reviews require substantial time commitments, even if the overall processes are relatively well aligned with the government’s internal reporting and budget preparation processes. Similarly, the set up requires substantial time commitments on behalf of general budget support donors, including Bank staff. Bank staff feel that these efforts are not well recognized within the Bank and that the Bank provides little incentives to ensure close coordination with general budget support donors.
Ghana
As far as the Bank is concerned, there is undoubtedly an increase in transaction costs relative to carrying out the PRSC alone. There are monthly meetings of the donor coordination group and often time-consuming negotiations to achieve consensus. Donor representatives complain of the endless series of meetings needed to coordinate aid and the substantial added burden that this imposes. For some donors (as for the Bank) the Multi-Donor Budget Support may also represent a saving of the costs of going it alone with some of their project assistance. 18

19. PRSC Outcomes – Public Financial Management Easier objectives accomplished

20. Most PRSCs achieved their PFMP reform objectives, with minor shortcomings
Reforms well grounded in diagnostics led to well sequenced strategy agreed with donors Program achievements were in easier areas (e.g., budget classification reform) More difficult reforms show less success (e.g. bringing extra-budgetary funds and donor funds on budget; timely resource transfer to sector ministries)
PFPM Reforms: Diagnostic Work
Diagnostic tools used by PRSCs included a range of Bank instruments, such as Country Financial Accountability Assessments and Country Procurement Assessment Reports
HIPC indicators, PEFA assessments, and IMF Fiscal Transparency ROSCs have also been used
Minimum levels of PFMP quality at entry
Evaluative findings suggest generally adequate recent diagnostic work
Existence and quality of PFMP diagnostics
Links between the PRSC reform agenda and diagnostic work
PRSCs drew upon recent diagnostics and adequately acknowledged fiduciary risks
Most PRSCs also incorporated plans to further develop domestic financial management systems, beyond the minimal requirements for taking care of fiduciary risk
PFMP:
Results frameworks were a weak link in the design of PFMP components of PRSCs
Most PRSCs had an integrated action plan for PFMP with adequate donor support
Implementation delays occurred sometimes due to capacity or political economy factors
Capacity building needs
PFM Programs—Results Achieved
PFMP performance measured relative to benchmarks in four broad areas: budget formulation, execution, reporting, and procurement
Seven thematic indicators for budget formulation (e.g. standardized definitions, classifiers, inclusion of funds on-budget, integration of medium-term expenditures in budget cycle)
Yet improvement in reform indicators not clearly linked to PRSC reform conditions
ICRs show that most PRSCs achieved their PFMP objectives with only minor shortcomings
Improvement in performance as measured by Bank’s CPIA indicators
Bank’s task team leaders agree that PRSCs were broadly effective in improving PFM
Less success in some areas of public expenditure processes (e.g. timely transfer to sectoral ministries)
Seven country case studies show good progress in PFM reforms, but it less in procurement reform

21. PRSC Outcomes in Growth and Poverty Alleviation…
are difficult to establish

22. Attribution to the PRSC is difficult
PRSC countries grew faster in the
PRSC period…
but so did other countries
Per Capita GDP growth
PRSC countries
0.8
4.2
Better Performing Non-PRSC
0.5
3.3
All IDA countries
0.2
3.0
Notes: Data for individual PRSC countries’ growth rates are provided in Appendix Table A6.2
Non-PRSC countries are those which have never had a PRSC or not had one before 2005.
“Better Performing Non-PRSC countries” are those non PRSC countries with a CPIA of 3.0 or greater in This reduces the non-PRSC sample from 52 to 37 countries. Countries eliminated are: Angola, CAR, Chad, Comoros, Congo DR, Congo Rep., Cote d’Ivoire, Eritrea, Guinea-Bissau, Haiti, Liberia, Solomon Is., Sudan, Togo, Zimbabwe
Source: IEG estimates based on data from the World Development Indicators
Attribution to the PRSC is difficult 22

23. Better performing non-PRSC (24)*
PRSC countries had more income
poverty reduction…
but the decline began before the PRSC was introduced
Poverty Rates for PRSC and Non-PRSC Countries (% of population below $38 per month)
PRSC countries (20)
Better performing non-PRSC (24)*
Non-PRSC counties (36)
All IDA countries (56)
% change ( )
-16.2
-12.6
-2.1
-7.8
% change ( ) 
-19.3
-13.0
-10.8
-14.1
Evaluation Essentials/highlights
PRSC countries have better growth and macro indicators, but this began before PRSCs; non-PRSC countries have also improved
Most PRSCs lacked comprehensive growth strategies
PRSC countries had a better record in poverty reduction, but PRSCs paralleled sector projects in pro-poor service areas.
PRSC health and education components focused on better budget allocation, yet large proportions of resources remain off-budget
Objectives were fully met a third to a half of the time; a high proportion of service delivery components had modest achievements
Overall, PRSCs performed more satisfactorily than prior adjustment lending, but differences compared to all adjustment loans in the PRSC period are negligible
Tracking poverty outcomes is difficult due to limited indicators
Poverty Reduction: Creating a Growth Enabling Environment
PRSCs had better macroeconomic results than others—both in the PRSC period and before
Other countries improved their performance too, sometimes more than PRSC countries
PRSC countries were superior performers, but non-PRSC countries also improved their performance
PRSC countries improved their institutional environment, but others increased about as much
PRSC growth measures were not usually based on a comprehensive growth diagnostic
Economic Performance and Growth in PRSC Countries
PRSC countries show a marked reduction in income poverty even compared to control groups
PRSC countries do better on non-income measures of poverty as defined by the Millennium Development Goals
Most PRSCs included health and education but usually as a complement to other Bank lending
A high proportion of PRSC sectoral objectives pertained to budget and public finance issues
Measuring outcomes in pro- poor service delivery is hampered by a poor monitoring and evaluation framework
About 1/3 to 1/2 of monitorable indicators for health and education fully met; targets were somewhat met in another percent of projects
PRSC social sector objectives usually ancillary to core objectives; translation of objectives into specific measures was mixed
Helping Poverty Alleviation
Case studies find:
Overall results are modest
Efforts made to incorporate pro- poor focus into health components
Attribution of results difficult due to parallel sector projects—large shares of expenditures off-budget
Education not a substantial area of focus in any PRSC
Budget processes improved and funding increased, but less evidence of better outcomes
IEG Ratings and IEG Surveys
Overall outcomes of PRSCs better than previous adjustment lending but not noticeably different from other adjustment lending (today??)
PRSC countries had reasonably good CAS outcomes, which generally coincided with PRSC outcomes, despite some instances of disconnect
Overall findings suggest mixed achievements on outcomes, not better than parallel sector projects and not distinguishable from other adjustment lending 23

24. PRSC Countries had greater progress with Millennium Development Goals…
…and progress was faster than before the PRSC period
…and faster than all IDA countries in the PRSC period
PRSC and Other Countries: Millennium
Development Goal Achievement
Difference (%)
(% of population)
(1990/1–2000/1)
(2001–06)
Primary enrollment, net
PRSC
9.7
14.8
All IDA countries
11.6
9.1
Infant mortality (per 1000)
-19.0
-13.3
-14.5
-9.6
Access to safe water
20.2
7.3
12.6
4.8 24

25. Poverty rates declined in PRSC countries although attribution is difficult
Income poverty rates fell faster in PRSC countries, in the PRSC period, but also fell faster prior to the PRSC
In non-income measures of poverty PRSC countries did better, and improvement in the PRSC period was faster
Yet most PRSC programs do not trace links between actions and poverty outcomes
Parallel sector projects increase the difficulty of attribution 25

26. Evaluation Recommendations
Underpin PRSCs/DPLs with comprehensive pro-poor growth diagnostics
Strengthen results frameworks, link with underlying PRS; increase poverty focus
Focus sector content on high-level or crosscutting issues
Further simplify the language of conditionality and eliminate the term ‘triggers’
Synchronize Bank’s internal processing with country and donor processes to enable greater ‘voice’ for Bank in multi-donor budget framework
Phase out PRSC “brand name” or clarify when it is to be used
The evaluation recommends:
1 .Phase out PRSC as a separate brand name -- or clearly spell out these differences
Convergence in the design and content of PRSCs and other development policy lending in terms of conditionality and sector focus suggests limited rationale for separate existence of PRSC today. But implicit criteria backing the use of the PRSC label exists. If PRSC brandname’ still important, clear guidelines (which are currently lacking) and criteria for eligibility should be spelled out and applied.
2. Further simplifying the language of conditionality
Eliminate term “triggers” and transfer program benchmarks to monitoring framework
In line with its use of the term “prior actions,” the Bank could further simplify its lending framework by dispensing with the term “triggers” and substituting this with the term “indicative actions for future lending.” Lending then based simply on prior actions already achieved and indicative actions for future lending. This would exhibit greater flexibility and ease understanding.
To clearly delineate legally binding conditions from program benchmarks, which are still alluded to as binding and non-binding conditions by clients and others in the aid community, program benchmarks should be removed from the policy matrix/PAF and instead combined with program monitoring framework.
3. Synchronize Bank’s internal processing with country and donor processes to enable more effective participation of the Bank in a multi-donor budget support lending framework
At present, Bank commitments in a multi-donor framework must sometimes made before the Bank’s internal review of the PRSC. This can limit the Bank’s substantive contributions and comments on program content. Synchronizing the Bank’s internal processing timetable with country and donor group processes would ensure Bank input in PRSC/DPL formulation.
4. Underpin PRSCs/DPLs with comprehensive pro-poor growth diagnostics
PRSCs (and DPLs) should reflect country-specific growth diagnostics, which are undertaken based on analytic underpinnings that identify an overall growth strategy that reflects the linkages between growth, poverty reduction, and broader social development.
5. Strengthen PRSC/ DPL results frameworks, link them with the underlying PRS/national development strategy, and increase their poverty focus.
Results frameworks of PRSCs should be consistently linked to those in the PRS or national development strategy and its Annual Reviews and should be simplified to a small set of core outcomes. Adequate baseline and intermediate indicators and pro-poor results indicators should be required, built on country monitoring systems to the extent feasible.
6. Focus sector policy content in multi-sector policy based loans to high-level or cross-cutting issues, complemented with parallel sector lending.
PRSC/DPL sector content should focus on areas where it has been consistently effective: cross-sectoral or central ministry issues critical to facilitating key sectoral reforms and for strengthening sector budget processes. Complementary parallel sector lending, linked to PRSCs/DPLs, remains necessary to address detailed technical issues and facilitate program ownership by line ministries. 26

27. IEG INDEPENDENT EVALUATION GROUP
Thank You!