1. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/20151 Slide #1 DECEMBER 2011 The Pathfinder International Presentation on US Government Legislative and Policy Requirements for Family Planning

2. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/20152 Slide #2 DECEMBER 2011 Volunteerism and Informed Choice At Pathfinder, we believe volunteerism and informed choice are essential to our contraceptive programs. The US government (USG) also believes in volunteerism and informed choice and has put in place legislative and policy requirements to ensure that these values are adhered to in all USG funded programs.

3. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/20153 Slide #3 DECEMBER 2011 Characteristics of Requirements and Policies USG Requirements Mandated by the USG Generally relate to “volunteerism,” “informed choice,” or “abortion services” Apply to different kinds of assistance—some for family planning (FP) only and some for all foreign assistance If Pathfinder accepts funds for FP activities we are obligated to comply with the laws and policies applicable to the assistance. We are required to be knowledgeable about the policies and to ensure that all of our implementing partners and their service providers are knowledgeable about the requirements.

4. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/20154 Slide #4 DECEMBER 2011 RequirementGeneral TopicYear Enacted/Applicable Tiahrt AmendmentVolunteerism1999 – funds for FP activities Kemp-Kasten AmendmentVolunteerism1985 – all foreign assistance funds DeConcini AmendmentMethod Mix1985 – funds for FP activities Livingston AmendmentMethod Mix1986 – funds for FP activities Policy Determination 3 Voluntary Sterilization (VS) 1977 – direct support for VS services Helms AmendmentAbortion1973 – all foreign assistance funds Leahy AmendmentAbortion1994 – all foreign assistance funds Biden Amendment Abortion (biomedical research) 1981 – all foreign assistance funds Siljander AmendmentAbortion (lobbying)1981 – all foreign assistance funds Overview of Requirements

5. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/20155 Slide #5 DECEMBER 2011 Definitions of Volunteerism and Informed Choice Pathfinder and USG support the freedom of individuals to choose voluntarily the number and spacing of their children. Guiding principles for USG assistance: Volunteerism = making decisions independently, without the influence of any special incentives or forms of coercion Informed Choice = full access to information on contraceptive choices and to counseling, services, and supplies that allow a client to choose freely

6. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/20156 Slide #6 DECEMBER 2011 Tiahrt Amendment Overview 1.No targets or quotas for service providers or referral agents 2.No incentives or payment to clients or program personnel 3.No denial of benefits for not accepting FP 4.Comprehensible information required on the FP method chosen 5.Restriction on use of experimental FP methods

7. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/20157 Slide #7 DECEMBER 2011 Tiahrt Applicability To which kinds of “assistance” does Tiahrt apply? Any FP service delivery activity funded by USG More specifically: FP services that receive USG assistance FP assistance in the form of funds, technical assistance, FP commodities, and training To which entities does Tiahrt apply? It applies to US NGOs, foreign NGOs, and foreign governments.

8. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/20158 Slide #8 DECEMBER 2011 Requirement 1: No Targets or Quotas Service providers or referral agents may not implement or be subject to quotas or targets for total number of births, number of FP acceptors, or acceptors of a particular method of FP. Quantitative estimates or indicators for budgeting or planning purposes are permitted.

9. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/20159 Slide #9 DECEMBER 2011 Requirement 2: No Incentives or Financial Rewards No payment of incentives, bribes, gratuities, or financial rewards to: A.An individual in exchange for becoming an FP acceptor B.Program personnel for achieving a numerical target or quota of total number of births

10. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201510 Slide #10 DECEMBER 2011 Requirement 3: No Denial of Rights or Benefits No denial of rights or benefits as a consequence of an individual’s decision not to accept FP. Rights or benefits include access to participation in any general welfare program and the right of access to health care.

11. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201511 Slide #11 DECEMBER 2011 Requirement 4: Comprehensible Information Required FP acceptors must receive comprehensible information on the health benefits and risks of the FP method chosen. Comprehensible information can be provided in many forms (e.g. counseling, posters, brochures, flip charts, and package inserts).

12. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201512 Slide #12 DECEMBER 2011 Requirement 5: Experimental FP Methods Experimental contraceptive drugs, devices, and medical procedures may only be provided in the context of a scientific study in which participants are advised of potential risks and benefits. USG has regulations regarding research on human subjects. Support for any such research must be carried out in accordance with these regulations.

13. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201513 Slide #13 DECEMBER 2011 When Does Tiahrt Apply? Tiahrt applies to USG-funded FP service delivery projects (i.e. projects that deal directly with “acceptors”). Tiahrt applies to mobile clinics, private and government clinics, outreach clinics, services for internally displaced persons (IDPs) or refugees, and community-based services. Tiahrt applies when any kind of assistance (cash, technical assistance, FP commodities, or training) is provided to an FP service delivery project. Tiahrt applies when a project enhances the ability to provide FP services (e.g. systems strengthening or the ability to conduct surveys).

14. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201514 Slide #14 DECEMBER 2011 When does Tiahrt Not Apply? When assistance is for non-FP-related activities such as maternal health (even if FP is provided in same clinic) When assistance is for broad information campaigns, surveys or data collection, strategic planning, evaluation, research or publications When assistance is used to pay for a regional or international conference When assistance is used to pay for travel or per diem for a widely attended training conference When assistance funds mass media campaigns conducted by organizations that do not implement service delivery projects

15. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201515 Slide #15 DECEMBER 2011 The Tiahrt Amendment Permits: Free distribution of FP methods or selling methods at a reduced price Fee-for-service or per case payments to providers Non-financial small items provided to project personnel or individuals to acknowledge good performance (e.g. caps, aprons, backpacks, boots, umbrellas, etc.) Special training or promotions for project personnel who are considered good performers.

16. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201516 Slide #16 DECEMBER 2011 Specific Situations Targets are permitted if they are for planning purposes. Targets are permitted in social marketing programs where targets are set for manufacturers, distributors, and retailers. If FP commodities are paid for with USG funds and are donated to the country’s national supply, then Tiahrt applies to all service delivery sites that receive these supplies. If other donors supply FP commodities, Tiahrt applies unless the logistics system can identify clinics that only receive non-USG FP commodities. Performance-based financing mechanisms may incorporate FP indicators as long as individual service providers are not required to meet targets.

17. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201517 Slide #17 DECEMBER 2011 Frequently Asked Questions on Tiahrt Compliance 1.What kinds of projects are covered by the Tiahrt Amendment? 2.Are there some population activities funded by USG where Tiahrt does not apply? 3.Under Tiahrt, is a USG-funded implementing partner organization (IPO) allowed to set goals for FP in its clinics, for the clinic as a whole, or for individual service providers?

18. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201518 Slide #18 DECEMBER 2011 Frequently Asked Questions, continued 4.Does the Tiahrt incentive restriction prohibit payment on a per case or method basis? 5.Are items provided to project personnel (e.g. caps, work aprons, mugs, or backpacks) incentives that would be prohibited under the Tiahrt clause? 6.When does the provider need to obtain written consent for an FP method?

19. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201519 Slide #19 DECEMBER 2011 Additional Requirements Related to Volunteerism and Choice DeConcini Amendment: “Funds should be available only to voluntary FP projects which offer, either directly or through referral to, or information about a broad range of information and services.” Livingston Amendment: “In awarding grants for natural FP… no applicant shall be discriminated against because of such applicant’s religious or conscientious commitment to only offer natural FP.” Kemp-Kasten Amendment: No foreign assistance funds “may be available to any organization or program which, as determined by the President of the United States, supports or participates in the management of a program of coercive abortion or involuntary sterilization.”

20. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201520 Slide #20 DECEMBER 2011 Requirements on Voluntary Sterilization Policy Determination 3 (PD-3) is complementary to Tiahrt and has 3 key requirements: 1.Informed consent is required before a sterilization procedure and must be documented. 2.Incentive payments for sterilization are prohibited. 3.Compensation for service providers can be acceptable under certain circumstances.

21. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201521 Slide #21 DECEMBER 2011 PD-3 Guidance on Payments Payments cannot be used as an incentive to accept, provide, or refer clients for voluntary sterilization service. Certain payments to clients are not considered incentives, as long as they are reasonable (e.g. transportation to and from the procedure or food provided during confinement). Determination of what is a “reasonable” payment must be made by the USAID Mission based in-country and on a program-specific basis, using knowledge of social and economic circumstances.

22. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201522 Slide #22 DECEMBER 2011 MCP Rescinded The Mexico City Policy (MCP) has been rescinded. MCP was removed as a government policy by President Obama in 2009. We can now discuss all pregnancy options. X MCP

23. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201523 Slide #23 DECEMBER 2011 Currently there are 4 requirements that relate to abortion. Helms Amendment: Written in 1973 and states, “No foreign assistance funds may be used to perform or motivate or coerce people to practice abortions.” Leahy Amendment: Clarifies the Helms Amendment. Specifically, it clarifies the term “motivate.” Motivate does not prohibit the provision of information, counseling or referral for all pregnancy options including abortion when this is consistent with local laws in the country. Requirements on Abortion

24. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201524 Slide #24 DECEMBER 2011 The Biden Amendment: Prohibits using funds for any biomedical research that relates to abortion. The Siljander Amendment: States that “no funds may be used to lobby for or against abortion.” Requirements on Abortion, continued

25. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201525 Slide #25 DECEMBER 2011 Postabortion Care Postabortion care (PAC) is the treatment of complications, injuries or illness caused by legal or illegal abortion. PAC is not affected by USG policies related to abortion. USG supports the provision of PAC services. However, USG funds cannot be used to purchase manual vacuum aspiration (MVA) equipment. Equipment must be clearly separated from abortion services where both are offered. Equipment that can be used for multiple obstetric purposes (e.g. uterine sounds) must be labeled “for PAC only”.

26. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201526 Slide #26 DECEMBER 2011 Identifying Potential Vulnerabilities The first step towards ensuring compliance to USG policy and legislative requirements is to identify potential vulnerabilities in the country. Vulnerabilities may stem from various factors Abortion or menstrual regulation is legal or widely available. There is a movement to change the status or availability of abortion in the country. There is a history of targets or coercion in FP programs. The service package includes permanent methods.

27. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201527 Slide #27 DECEMBER 2011 Potential Vulnerabilities, continued Clients are compensated for costs associated with voluntary sterilization. There have been changes in the IPO or their staff. Local governments have significant autonomy in implementing FP programs. PAC and/or abortion are part of the IPO’s program. The IPO’s program has a social marketing component for FP. The program includes performance-based financing components. The program includes distribution of FP commodities to the national government.

28. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201528 Slide #28 DECEMBER 2011 Ensuring Compliance: HQ and Country Office 1.Standard Provisions related to the voluntary population policies are included in every cooperative agreement, contract, and sub- agreement. 2.All Pathfinder country office staff members have completed a yearly half-day training using the Pathfinder Training Guide on USG Legislative and Policy Requirements for FP. 3.All new staff members at the country, regional, state, and satellite offices have been briefed on Tiahrt and other USG legislative and policy requirements on family planning programs, during their orientation as new personnel.

29. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201529 Slide #29 DECEMBER 2011 Ensuring Compliance: HQ and Country Office, continued 4. Pathfinder country offices will conduct Tiahrt assessments, using Pathfinder’s compliance tools with all Pathfinder staff and IPOs. 5.Tiahrt questions will be included in standard monitoring visits. 6.Pathfinder will provide compliance tools to its staff and IPO staff to assess compliance with USG requirements. 7.Each Pathfinder country office will develop a compliance monitoring plan.

30. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201530 Slide #30 DECEMBER 2011 8. Each Pathfinder country office will maintain a compliance file which should include a record of all compliance activities: Ensuring Compliance: HQ and Country Office, continued Compliance monitoring plan Copy of the Pathfinder International Training Materials on USG Legislative & Policy Requirements for FP Notes on training sessions, including dates, attendance sheet signed by all participants, and a summary of key points Copies of presentations and handouts from training Correspondence, meeting minutes, and internal memos Questionnaires and monitoring forms used during field visits Reports on monitoring visits, including dates, sites visited, and a summary of results Documentation of any changes recommended and progress on their implementation Copy of procedures followed in investigating a suspected violation (if applicable)

31. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201531 Slide #31 DECEMBER 2011 Ensuring Compliance: IPO (NGO) 1.All IPO staff members have completed a yearly half-day training on USG legislative and policy requirements using the Pathfinder International Training Guide on USG Legislative and Policy Requirements for FP. 2. All NGO IPOs funded under the project have agreed (in writing) to comply with the Voluntary Population Activities Provision. 3.The IPO has conducted an annual half-day training for clinic- and community-level providers on Tiahrt and other USG legislative and policy requirements using the Pathfinder International Training Guide on USG Legislative and Policy Requirements for FP. 4.The IPO has a “Tiahrt poster” or equivalent poster providing comprehensible (i.e., clear and comprehensive) information on FP methods displayed on the wall of the office, or it has equivalent informational materials (e.g., flip charts or other counseling materials) describing the benefits and risks of different FP methods.

32. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201532 Slide #32 DECEMBER 2011 Ensuring Compliance: IPO (NGO), continued 5. Each IPO will maintain a compliance file which should include a record of all compliance activities: The compliance monitoring plan Copy of the Pathfinder International Reference Guide on USG Legislative & Policy Requirements for FP Notes on orientation sessions, including dates, attendance sheet signed by all participants in the training, and a summary of key points Copies of presentations and handouts Correspondence, meeting minutes, and internal memos Questionnaires and monitoring forms used during field visits Reports on monitoring visits, including dates, sites visited, and a summary of results Documentation of any changes recommended and progress on their implementation Copies of all signed agreements with sub-recipients

33. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201533 Slide #33 DECEMBER 2011 1.All IPO staff members have completed a yearly half-day training on Tiahrt and other USG legislative and policy requirements using the Pathfinder International Training Guide on USG Legislative and Policy Requirements for FP. (Pathfinder will conduct this training.) 2.Government IPOs should conduct joint monitoring visits with Pathfinder. Note: Government partners at all levels should be briefed about Tiahrt and all USG legislative and policy requirements. Records should be kept on personnel briefed and dates of briefings. Ensuring Compliance: IPO (government)

34. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201534 Slide #34 DECEMBER 2011 3. Each IPO will maintain a compliance file which should include a record of all compliance activities: –Copy of the Pathfinder International Reference Guide on USG Legislative and Policy Requirements for FP (translated into local languages where appropriate) –Questionnaires, checklists, and monitoring tools used during field visits, including the Pathfinder International Monitoring Tools for Compliance with USG Legislative and Policy Requirements FP –Reports on monitoring visits (including dates, sites visited, and a summary of results) –Completed compliance checklists and questionnaires from the Pathfinder International Monitoring Tools for Compliance with USG Legislative and Policy Requirements for FP from field visits Ensuring Compliance: IPO (Government)

35. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201535 Slide #35 DECEMBER 2011 Ensuring Compliance: Service Delivery Level Documentation and Systems: 1.The clinic has a copy of the Pathfinder International Reference Guide on USG Legislative and Policy Requirements for FP (in the local language where appropriate) in a folder, with a copy of the attendance sheet demonstrating that each service provider completed the half-day training. 2.A “Tiahrt poster” or equivalent poster providing comprehensible information on FP methods is displayed on the wall. 3.If the clinic performed voluntary sterilization services, client consent forms were reviewed. 4.A variety of FP methods are available to ensure that the client has a free choice of approved methods.

36. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201536 Slide #36 DECEMBER 2011 Ensuring Compliance: Service Delivery Level (cont’d.) Documentation and Systems (cont’d.): Where NGO clinics are involved the following apply: Staff contracts were reviewed to ensure that no bonus payments, targets, or quotas were given for attaining number of total births, numbers of FP acceptors, or numbers of acceptors of a particular FP method. The NGO clinic funded under the project has agreed (in writing) to comply with the Voluntary Population Policy Provisions.

37. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201537 Slide #37 DECEMBER 2011 Ensuring Compliance: Service Delivery Level (cont’d.) Service Providers: 1.Clinic staff members have completed a yearly half-day training on Tiahrt and other USG legislative and policy requirements using the Pathfinder International Training Guide on USG Legislative and Policy Requirements for FP. 2.Random interviews with service providers were conducted using the compliance tool to verify that they were giving comprehensible information on the different FP methods, and that clients were not pressured to accept a particular method. Results of these interviews were recorded. 3.Counseling on FP was observed to identify any informed choice issues 4.No “service providers” or “referral agents” are subject to or required to meet targets or quotas.

38. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201538 Slide #38 DECEMBER 2011 Ensuring Compliance: Service Delivery Level (cont’d.) Service Providers (cont’d.): 5.No program personnel receive bribes, gratuities, incentives, or financial rewards in exchange for achieving a quota or target. 6.Information about the health benefits and risks and known adverse side effects of the specific FP method being provided is available. 7.All providers are using the “Tiahrt poster” or equivalent informational materials to provide clients with information about the health benefits and risks and known adverse side effects of the specific FP method. 8.No USG funds are being used to fund abortion services or abortion equipment. 9.If experimental contraceptives or drugs are included as part of a scientific study, clients are advised of potential risks and benefits.

39. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201539 Slide #39 DECEMBER 2011 Ensuring Compliance: Service Delivery Level (cont’d.) Clients: 1.Random interviews with clients were conducted using the questionnaires in this compliance tool to verify that they were given comprehensible information on the FP method they selected, and were not pressured to accept a particular method. Results were recorded. 2.Clients are allowed to freely choose their FP method. 3.Clients are given an explanation of the risks and benefits of their chosen methods. 4.No clients receive incentives for accepting an FP method of any kind. 5.No clients are denied rights or benefits as a consequence of not accepting FP.

40. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201540 Slide #40 DECEMBER 2011 Investigation of a Suspected Violation There are 3 things to remember if a violation of USG policy is suspected: Inform Investigate Correct

41. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201541 Slide #41 DECEMBER 2011 In Case of a Suspected Violation Inform At the Pathfinder HQ or country office level If a concern or issue is raised during monitoring: 1.Inform the Project Manager 2.Project Manager informs Head of Operations (if none exists, then the Country Representative) 3.Country Representative informs Program Director at HQ who informs Program Systems Unit (PSU) Director at HQ 4.PSU Director notifies the Executive Team

42. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201542 Slide #42 DECEMBER 2011 In Case of a Suspected Violation Inform, (cont’d.) 5.Country office and Executive Team make a joint decision about whether the issue or concern might plausibly constitute a violation of a USG policy or legislative requirement. 6.If it is determined that a violation may have occurred, the Executive Team will inform the USAID PHN officer or the AOTR immediately about the suspected violation and the project’s plan to investigate the situation.

43. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201543 Slide #43 DECEMBER 2011 In Case of a Suspected Violation Investigate At the Country Office Level: Conduct a detailed investigation of the suspected violation. These basic questions must be addressed: Where? When? Who? How? Why?

44. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201544 Slide #44 DECEMBER 2011 In Case of a Suspected Violation Investigate, (cont’d.) Keep careful records of the investigation and corrective actions taken. Select a point person to track the process of the investigation. Examine the credibility/legitimacy of the allegation or report. Conduct interviews with IPO clinic and project staff. Determine the magnitude of the problem. Is the problem in more than one location? Investigate widely. Conduct a detailed review of clinic records and other clinic materials. If the suspected violation is related to incentives, conduct a community survey of acceptors and of staff who may have received incentives. Keep Pathfinder Program Director at HQ involved in the ongoing investigation.

45. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201545 Slide #45 DECEMBER 2011 In Case of a Suspected Violation Correct

46. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201546 Slide #46 DECEMBER 2011 As soon as a potential violation is discovered, take action to correct the problem. Resolving the situation may require systems strengthening, training, or changing the IPO’s policies. A serious violation may require the suspension of funds to the IPO. In Case of a Suspected Violation Correct, (cont’d.)

47. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201547 Slide #47 DECEMBER 2011 At the IPO Level Inform the Project Director and Country Representative immediately. Provide any assistance needed to correct the situation.

48. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201548 Slide #48 DECEMBER 2011 At the Clinic Level Inform the IPO senior staff. Inform the Pathfinder country office. If necessary, suspend suspected staff until the investigation is completed.

49. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201549 Slide #49 DECEMBER 2011 Pathfinder Monitoring Tools for Compliance The Pathfinder International Monitoring Tools for Compliance include: A summary of requirements and checklist of compliance requirements for the field office, IPO, clinic, clinic service provider, community-based worker, and hospital levels. Detailed monitoring tools to be used at Pathfinder – supported clinics, with clinic providers, community health workers, sterilization clients, and FP acceptors.

50. Click to edit Master title style Click to edit Master text styles – Second level Third level – Fourth level » Fifth level 8/28/201550 Slide #50 DECEMBER 2011 For more information, please email csolter@pathfind.org THANK YOU