The U.S. Agency for International Development (USAID) and the U.S. Department of State (State) are implementing a coordinated Partner Vetting System (PVS) pilot program that was congressionally mandated in the FY 2012 Appropriations Act. USAID is implementing the pilot program in Guatemala, Kenya, Lebanon, the Philippines, and Ukraine. USAID’s pilot program includes the vetting of U.S. and non-U.S. persons, and applies a risk-based approach. Under the pilot program, USAID will test vetting policies and procedures, evaluate the resources required for vetting, and seek input from implementing partners, Congress, and other stakeholders about the impact of vetting on USAID-funded delivery of foreign assistance. The FY 2012 Appropriations Act, and related acts, also requires a joint USAID/State report to Congress following completion of the pilot program that evaluates the estimated timeline and criteria for evaluating PVS for expansion.

Please find attached a link to both acquisition and assistance final rules as well as FAQs on the PVS Pilot. If you have any additional questions regarding Pilot Vetting at USAID please contact: pvspilothelpdesk@usaid.gov

Acquisitions Rule [PDF] | Assistance Rule [PDF]

Frequently Asked Questions

September 2015

1. What is the Partner Vetting System pilot program?

ANSWER: The U.S. Agency for International Development (USAID) and the U.S. Department of State (State) are implementing a coordinated Partner Vetting System (PVS) pilot program that was congressionally mandated in the FY 2012 Appropriations Act.  USAID is implementing the pilot program in Guatemala, Kenya, Lebanon, the Philippines, and Ukraine.  USAID’s pilot program includes the vetting of U.S. and non-U.S. persons, and applies a risk-based approach.  Under the pilot program, USAID will test vetting policies and procedures, evaluate the resources required for vetting, and seek input from implementing partners, Congress, and other stakeholders about the impact of vetting on USAID-funded delivery of foreign assistance.  The FY 2012 Appropriations Act, and related acts, also requires a joint USAID/State report to Congress following completion of the pilot program that evaluates the estimated timeline and criteria for evaluating PVS for expansion.

How did USAID choose the 5 pilot countries?

ANSWER:  State and USAID considered a range of factors during the selection of Guatemala, Kenya, Lebanon, Philippines, and Ukraine as the pilot countries, including the following:

• Geographic diversity;
• Range of terrorist threat levels; and
• Countries where State and USAID have comparable programs.

3. What lessons does USAID aim to gain from the pilot?

ANSWER:  The purpose of the PVS pilot program is to help assess the extent to which partner vetting adds value as a risk mitigation tool, and if so, under what circumstances should vetting occur. USAID’s objectives in establishing the PVS pilot program are as follows:

• Assess our risk-based approach to test certain assumptions related to levels of risk, types of awards, and the nature of proposed activities, vetting both U.S. and non-U.S. citizens;
• Evaluate the efficiency of the vetting process by assessing internal and external business processes; and
• Gather information regarding cost effectiveness of using partner vetting as an additional means to prevent the inadvertent funding of terrorism.

4. Has USAID decided to implement a worldwide partner vetting program?

ANSWER:  No. USAID has made no decision to implement partner vetting on a global basis.  USAID intends to complete the pilot, submit the joint report to Congress, and consult with Congress and Agency partners before assessing how the pilot findings should impact Agency vetting programs going forward.

5. Does USAID employ a clear definition of individuals to be vetted? 

ANSWER:  Yes.  “Key individual” is a term describing who will be vetted and is defined in the published final rules for Partner Vetting of USAID Acquisitions and Assistance. Under the PVS pilot program, key individuals of potential awardees and sub-awardees will be vetted.  Key individuals are defined as: (i) principal officers of the organization’s governing body (e.g., chairman, vice chairman, treasurer and secretary of the board of directors or board of trustees); (ii) the principal officer and deputy principal officer of the organization (e.g., executive director, deputy executive director, president, vice president); (iii) the program manager or chief of party for the USG-financed program; and (iv) any other person with significant responsibilities for administration of the USG-financed activities or resources.

6. What is the Risk-Based Assessment and how does it impact the pilot?

The PVS pilot Risk-Based Assessment (RBA) is a tool that establishes a risk profile for new USAID programs or activities to be implemented in a pilot country. Under the RBA, the pilot utilizes a risk-based approach to test certain assumptions. In order to test these assumptions against baseline data, generally all programs and activities will be vetted regardless of the RBA outcome. Procurement officials in the respective pilot Missions conduct the RBA at the program or activity level and document certain information, including the following:

• Program/activity location(s);
• Country risk rating provided by USAID’s Office of Security;
• Nature of the  assistance provided (e.g., emergency goods and services, food assistance, capital investment, cash-for-work, cash assistance, microfinance loans, scholarships, security services, training, technical assistance, health services, and commodities);
• Anticipated nationality of prime (U.S. or non-U.S.);
• Likelihood that sub-contractors or sub-grantees will be required to implement the program/activity;
• Anticipated monitoring and evaluation (M&E) of the program/activity (Offsite or Remote M&E, Third Party M&E, or Onsite M&E by USAID);
• Amount of proposed award ($150,000 or under; $150,001 to $25 million; or over $25 million);
• The Vetting Support Unit (VSU) may receive and review supplemental threat information, and/or any additional risk mitigation procedures above and beyond standard USAID anti-terrorism contracting and procedural controls that may reduce the risk of diversion.

In addition, USAID will provide implementing partners with the option to submit information that they believe may impact the risk profile of the program/activity.

7. Will USAID offer “direct vetting” as part of the PVS Pilot?

ANSWER:  Yes. USAID is offering a form of “direct vetting” as an option for acquisition and assistance awards under the PVS pilot program. Under the direct vetting approach, at the option of the prime awardee, USAID would communicate directly with the potential sub-awardee solely for the purposes of vetting, including the transmittal of eligibility and ineligibility notices. However, the prime would remain responsible for verifying that the information provided by its sub-prime organizations to USAID for the purposes of vetting is accurate and complete to the best of its knowledge. In evaluating the direct vetting approach, USAID will consider the extent to which the approach is utilized and analyze its impact on USAID and partner organizations.

Verification Language to be used with Direct Vetting

[Name of prime inserted by VSU] certifies that it has taken reasonable steps in accordance with sound business practices to verify the accuracy of the information contained in the attached Partner Information Form for [Name of key individual(s) inserted by VSU].

[Name of prime inserted by VSU] understands that the U.S. Government may rely on the accuracy of such information in processing this vetting request.

8. Can USAID clarify which beneficiaries will be vetted under the pilot?

ANSWER:  Yes. Clarification on which beneficiaries are vetted under the PVS pilot is provided as follows:

• USAID will vet individuals for whom the pilot Mission finances scholarships, fellowships, or other structured training, but only where the Mission specifically approves the individual participants and where (i) such scholarship, fellowship, or other training is in the U.S. or in third countries, or (ii) such other training in the pilot country lasts more than five consecutive work days.
• USAID will vet organizations that are direct recipients of cash or in-kind support (e.g., a hospital receiving pharmaceuticals, a company whose manufacturing will be repaired or replaced, or a Non-Governmental Organization whose recreational facilities will be renovated). Vetting is not required for persons or entities that benefit from such assistance indirectly (e.g., patients of the hospital, customers of the manufacturer, or users of the recreational facilities).
• Vetting is not required for individuals who receive jobs under employment generation activities, including incidental job training; or ultimate beneficiaries of cash or in-kind assistance, such as food, water, medical care, micro-enterprise loans, or shelter.
• Refugees and Internally Displaced Persons will not be vetted under the pilot. 
• Participant trainees who have obtained J-1 Visas in order to participate in U.S.-based training are exempt from vetting. 

USAID will notify potential awardees in the solicitation if the Agency intends to vet beneficiaries under that award. 

9. Will PEPFAR-funded activities be vetted under the pilot?

ANSWER:  Yes. USAID will vet PEPFAR-funded activities under the PVS pilot program.

10. Does the PVS pilot program take account of protections provided by the Privacy Act and due process considerations? 

ANSWER:  Yes. USAID’s PVS pilot vetting policies and procedures are in compliance with the Privacy Act. USAID has completed all appropriate regulatory steps and provides for notice and appeal in the event of denial of an award based on the outcome of the vetting process.  Personal identifying information (PII) collected by USAID under the pilot program is maintained in secure databases, and there are role-based limitations on USAID staff’s access to information in the Partner Vetting System.  Consistent with the Privacy Act, all information submitted to USAID on an individual will be available for that individual to request, review, or correct.

PII is required for proper identification of those vetted.  Retention of the information provides for appropriate audit and follow-up.  It also avoids individuals having to resubmit data or forms each and every time they apply for an award.  USAID plans to determine an appropriate retention cycle for the PII in the database through implementation of the pilot.

Throughout the design of the PVS pilot program, USAID has been committed to protecting national security while complying with all administrative requirements, and protecting privacy, civil liberties, and other rights, including due process, of partners and their employees.

11. Will USAID provide a categorical exemption of humanitarian assistance from vetting in the PVS pilot program?

ANSWER:  In order to prevent delays in the provision of urgently needed humanitarian assistance in PVS pilot countries, USAID does not require pre-award vetting of urgent humanitarian assistance in the pilot program.  USAID reserves the right to vet post award and once the immediate need has been addressed.

12. Who retains the personal identifying information that partners provide to USAID as a part of vetting in the pilot program, for what period of time, and subject to what safeguards?

ANSWER:  PII submitted by USAID partners applying for pilot acquisition or assistance awards that are subject to vetting in the pilot program is maintained by USAID in the vetting database that is utilized by the agency for processing, management and record-keeping.  As noted above, USAID plans to determine an appropriate retention cycle for the PII in the database through implementation of the pilot.  The PVS database resides behind the USAID firewall and meets Federal Information Security Management Act (FISMA) requirements for retention of such information.  Only USAID staff with specific duties related to screening and a need-to-know are provided access to the data.  In those instances in which a “match” occurs, additional identifying information may be submitted to the record that already exists in the non-public database.

13. Are organizations that are found ineligible barred from applying for USAID acquisition or assistance awards in the future?

ANSWER:  No. Entities or individuals found ineligible in the PVS pilot program may apply for new pilot funding opportunities, and each application for funding will be considered on its own merits.

14. What are some of the circumstances in which vetting will take place?

ANSWER:  In the PVS pilot program, vetting of an organization will occur at the appropriate point in the procurement process each time a potential awardee is in consideration for an award subject to vetting.  Recipients will still be required to submit a Partner Information Form any time key individuals change and before issuance of covered sub-awards but will not be required to resubmit the form annually if no information has changed or expired.