UNIT 3: AGENCY

FOCUS: Department
of Budget and
Management

USEC. RYAN L. ESTEVEZ, MARE, MPP

Overview:
– This Unit will focus on Government Budgeting System
particularly being implemented by the Department of Budget
and Management
– Through the government budgeting process, the student will be
able to appreciate the rigors of the budgeting process that it is
not as simple as it may seem, with all the complexities,
financial factors as well as political underpinnings in the
process.
Objectives:
– Identification of the critical areas of the budgeting
process
– Appreciation of the politics-administrative-
developmental interplay in the budgeting process
– Articulation of the priority sectors for funding and the
role of the citizens in helping government manage the
development process
Government
Budgeting
It is the process of designing,
implementing and operating
budgets. It is the managerial
process of budget planning and
preparation, budgetary control and
the related procedures. Budgeting is
the highest level of accounting in
terms of future which indicates a
definite course of action and not
merely reporting.

Budgeting
 
Budgetary
Governance
• It is the process of formulating
the annual budget, overseeing its
implementation and ensuring its
alignment with public goals.
Manage budgets within clear, credible and
predictable limits for fiscal policy.

Closely align budgets with the medium-term strategic

priorities of government.  

Design the capital budgeting framework in order to

10 Principles
meet national development needs in a cost-
effective and coherent manner. of Budgetary
Ensure that budget documents and data are open,
Governance
transparent and accessible.

Provide for an inclusive, participative and realistic debate on

budgetary choices.    
 Present a comprehensive, accurate and reliable account of the
public finances.

Actively plan, manage and monitor budget execution.

10 Principles Ensure that performance, evaluation and value for

of Budgetary money are integral to the budget process.

Governance Identify, assess and manage prudently longer-term sustainability

and other fiscal risks.

Promote the integrity and quality of budgetary forecasts,

fiscal plans and budgetary implementation through
rigorous quality assurance including independent audit.
 • It is the critical exercise of allocating

GOVERNMENT revenues and borrowed funds to attain

the economic and social goals of the

BUDGETING
country.
• It also entails the management of
government expenditures in such a way
that will create the most economic
impact from the production and
delivery of goods and services while
supporting a healthy fiscal position.
 Why is Government
Budgeting important?
• Government budgeting is important because it
enables the government to plan and manage its
financial resources to support the
implementation of various programs and projects
that best promote the development of the
country.
• Through the budget, the government can
prioritize and put into action its plants, programs
and policies within the constraints of its financial
capability as dictated by economic conditions.
THE BUDGET PROCESS
 • The Executive prepares the • The Congress
proposed National Budget. authorize the
General
Appropriations
Act.
Budget Budget

The Planning and

Preparation
Legislation/
Authorization

Budget
Cycle Budget
Accountability
Budget
Execution

• The executive monitor and • Agencies

evaluate the use of the budget utilize their
approved
budgets
Budget planning
and preparation
 Budget Planning and Preparation

BUDGET
PLANNING AND
PREPARATION
 1. BUDGET CALL
At the beginning of the budget preparation year, the
Department of Budget and Management (DBM) issues
the National Budget Call to all agencies (including state
universities and colleges) and a separate Corporate
Budget Call to all GOCCs and GFIs.

The budget Call contains budget parameters (including

macroeconomic and fiscal and agency budget ceilings)
as set beforehand by the Development Budget
Coordination Committee (DBCC); and policy guidelines
and procedures in the preparation and submission of
agency budget proposals.
 Budget Planning and Preparation

Under the Aquino Administration the DBM has

established a new tradition of beginning the
Budget Preparation phase earlier, to ensure that
the National Budget is enacted on time.

Early
Preparation Under the new Budget Preparation Calendar, the
Budget Call is issued in December (versus around
April in the past); and the submission of the
President’s budget a day after the State of the
Nation Address (in contrast to earlier practice
where it is submitted during the late in the 30-
day window that the Constitution prescribes)
2. Stakeholder’s
Engagement
A new feature in budget preparation which seeks to increase citizen
participation in the budget process, departments and agencies are
tasked to partner with civil society organizations (CSOs) and other
citizen-stakeholders as they prepare their agency budget proposals.

This new process, which was piloted in the preparations of the 2012
National Budget, is now being expanded towards
institutionalizations.
Departments and GOCCs Mandated to
Conduct CSO Consultations
 – For the first time in history, the National Budget for
2013 will be prepared using a breakthrough
“Bottom up” “bottom-up” approach. As opposed to the
conventional way of allocating resources from top to

Budgeting bottom, grassroots communities will be engaged in

designing the National Budget.
– The Cabinet Cluster on Human Development and
Poverty Reduction has identified 300 to 400 of the
poorest municipalities and will engage these in
crafting community-level poverty reduction and
empowerment plans. This initial salvo of “bottom-
up” budgeting will focus on rural development
programs and the conditional cash transfer program,
and will thus involve DA, DAR, DENR, DSWD, DepEd
and DoH. These agencies will then include the
community plans in their proposed budgets.
– This approach was adopted by the Duterte
Administration.
– It is a reform that restructures the current
budget by grouping activities and projects
Program
under major programs or key strategies. Expenditure
Through this innovation, the government will
be able to assign performance targets—both Classification
outputs and outcomes—at the level of
programs. This way, the direct link between (PREXC)
strategies, budgets and intended results will be
clearer and program monitoring and
evaluation can provide evidence-based
assessments
– PREXC was implemented in the proposed
Budget for 2018.
3. Technical Budget
Hearings
– These are conducted after departments and
agencies submit their Agency Budget Proposals to
the DBM. Here, agencies defend their proposed
budgets before a technical panel of DBM, based on
performance indicators on output targets and
absorptive capacity. DBM bureaus then review the
agency proposals and prepare recommendations.
4. Executive Review

– The recommendations are presented before an

Executive Review Board which is composed of the
DBM Secretary and senior officials.
– Deliberations here entail a careful prioritization of
programs and corresponding support, vis-à-vis the
priority agenda of the national government.
– Implementation issues are also discussed and
resolved.
5. Consolidation, Validation
and Confirmation
– DBM then consolidates the recommended agency
budgets and recommendations into a National
Expenditure Program and a Budget of Expenditures
and Sources of Financing (BESF).
– As part of the consolidating process, the
deliberations by the DBCC will determine the agency
and sectoral allocation of the approved total
expenditure ceiling, in line with the macroeconomic
and fiscal program. Heads of major departments are
invited to this meeting.
6. Presentation to
President and Cabinet
– The proposed budget is presented by DBM, together
with the DBCC, to the President and Cabinet for
further refinements or reprioritization. After the
President and Cabinet approve the proposed
National Expenditure Plan, the DBM prepares and
finalizes the budget documents to be submitted to
Congress.
7. The President’s
Budget
– The budget preparation phase ends with the
submission of the proposed national budget — the
“President’s Budget” — to Congress.
– The President’s Budget consists of the following
documents, which help legislators analyze the
contents of the proposed budget:
 President’s This is where the President explains the policy framework and priorities in
Budget Message the budget.
(PBM)

Budget of Mandated by the Constitution, this contains the macroeconomic

Expenditures assumptions, public sector context (including overviews of LGU and GOCC
and Sources of financial positions), breakdown of the expenditures and funding sources for
Financing (BESF) the fiscal year and the two previous years.
7. The National This contains the details of spending for each department and agency by

President’s
Expenditure program, activity or project, and is submitted in the form of a proposed
Program (NEP) General Appropriations Act.

Budget Details of
Selected
This contains a more detailed disaggregation of key programs, projects and
activities in the NEP, especially those in line with the national government’s
Programs and development plan.
Projects

Staffing This contains a summary of the staffing complement of each department and
Summary agency, including number of positions and amounts allocated for the same.
Budget
legislation
 BUDGET
LEGISLATION
– Alternatively called the
“Budget Authorization
phase,” this starts upon
the House Speaker’s
receipt of the President’s
Budget and ends with the
President’s enactment of
the General Appropriations
Act.
1. House Deliberations

– The House of Representatives, in plenary, assigns the President’s

Budget to the House Appropriations Committee. The Committee
and its Sub-Committees then schedule and conduct hearings on
the budgets of the departments and agencies and scrutinize their
respective programs and projects. It then crafts the General
Appropriations Bill (GAB).
– In plenary session, the GAB is sponsored, presented and defended
by the Appropriations Committee and Sub- Committee Chairmen.
As in all other laws, the GAB is approved on Second and Third
Reading before transmission to the Senate. (Note: In the First
Reading, the President’s Budget is assigned to the Appropriations
Committee.)
2. Senate Deliberations

– As in the House process, the Senate conducts its own

committee hearings and plenary deliberations on the
GAB. Budget deliberations in the Senate formally start
after the House of Representatives transmits the GAB.
For expediency, however, the Senate Finance
Committee and Sub-Committees usually start hearings
on the GAB even as House deliberations are ongoing.
– The Committee submits its proposed amendments to
the GAB to plenary only after it has been formally
transmitted by the House.
3. Bicameral
Deliberations
– Once both Houses of Congress have
finished their deliberations, they will each
constitute a panel to the Bicameral
Conference Committee. This committee will
then discuss and harmonize the conflicting
provisions of the House and Senate
Versions of the GAB. A Harmonized Version
of the GAB is thus produced.
4. Ratification and
Enrollment
– The Harmonized or “Bicam” Version
is then submitted to both Houses,
which will then vote to ratify the final
GAB for submission to the President.
Once submitted to the President for
his approval, the GAB is considered
enrolled.
5. The Veto Message
– The President and DBM then review the
GAB and prepare a Veto Message, where
budget items subjected to direct veto or
conditional implementation are identified,
and where general observations are made.
Under the Constitution, the GAB is the only
legislative measure where the President can
impose a line-veto (in all other cases, a law
is either approved or vetoed in full).
6. Enactment
– When the GAA is not enacted before the fiscal
year starts, the previous year’s GAA is
automatically re-enacted. This means that
agency budgets for programs, activities and
projects remain the same. Funding for
programs or projects that have already been
terminated is realigned for other expenditures.
Because re-enactments are tedious and prone
to abuse, the Aquino Administration—with the
support of Congress—has committed to ensure
the timely enactment of a new GAA every year.
 When the GAA is not enacted before the
fiscal year starts, the previous year’s GAA is
automatically reenacted. This means that
agency budgets for programs, activities and
projects remain the same.
Re-enacted
Budgets Funding for programs or projects that have
already been terminated is realigned for
other expenditures. Because reenactments
are tedious and prone to abuse, the
administration has committed to ensure the
timely enactment of a new GAA every year.
BUDGET
EXECUTION
BUDGET EXECUTION

– This is where the people’s

money is actually spent. As
soon as the GAA is
enacted, the government
can implement its priority
programs and projects.
1. Release of Guidelines
and Programs
– The budget execution phase
begins with DBM’s issuance
of guidelines on the release
and utilization of funds.
2. Budget Execution
Documents (BEDs)
– Agencies are required to submit their
BEDs at the start of budget execution.
These documents outline agency plans
and performance targets. These BEDs
include the physical and financial plan,
monthly cash program, estimate of
monthly income, and list of obligations
that are not yet due and demandable.
3. Allotment and Cash
Release Programming
– To ensure that releases fit the approved Fiscal
Program, the DBM prepares an Allotment Release
Program (ARP) to set a limit for allotments issued
to an agency and on the aggregate.
– The ARP of each agency corresponds to the total
amount of the agency- specific budget under the
GAA, as well as Automatic Appropriations. A Cash
Release Program (CRP) is also formulated alongside
that to set a guide for disbursement levels for the
year and for every month.
4. Allotment Release

– Allotments, which authorize an

agency to enter into an obligation,
are either released by DBM to all
agencies comprehensively through
the Agency Budget Matrix (ABM)
and individually via Special Allotment
Release Orders (SAROs).
4. Allotment Release
– Agency Budget Matrix (ABM)
– This document disaggregates all programmed
appropriations for each agency into two main
expenditure categories: “not needing clearance” and
“needing clearance.”
– The ABM is the comprehensive allotment release
document for appropriations which do not need
clearance, or those which have already been itemized
and fleshed out in the GAA.
4. Allotment Release
– Allotment Release Orders (SAROs)
– Items identified as “needing clearance” are those
which require the approval of the DBM or the
President, as the case may be (for instance, lump sum
funds and confidential and intelligence funds).
– For such items, an agency needs to submit a Special
Budget Request to the DBM with supporting
documents. Once approved, a SARO is issued.
5. Incurring Obligations

– In implementing programs, activities and projects,

agencies incur liabilities on behalf of the
government. Obligations are liabilities legally
incurred, which the government will pay for.
– There are various ways that an agency “obligates:”
for example, when it hires staff (an obligation to pay
salaries), receives billings for the use of utilities, or
enters into a contract with an entity for the supply of
goods or services.
6. Cash Allocation
– To authorize an agency to pay the obligations
it incurs, DBM issues a disbursement
authority.
– Most of the time, it takes the form of a Notice
of Cash Allocation (NCA); and in special cases,
the Non-Cash Availment Authority (NCAA)
and Cash Disbursement Ceiling (CDC).
6. Cash Allocation
– Notice of Cash Allocation (NCA)
– This is a cash authority issued periodically by the DBM to
the operating units of agencies to cover their cash
requirements.
– The NCA specifies the maximum amount of cash that can
be withdrawn from a government servicing bank for the
period indicated.
– The release of NCAs by DBM is based on an agency’s
submission of its Monthly Cash Program and other required
documents.
6. Cash Allocation
– Others Disbursement Authorities.
– In contrast to NCAs, Non-Cash Availment
Authority (NCAA) are issued to authorize non-
cash disbursements.
– Cash Disbursement Ceiling (CDC) are meanwhile
issued to departments with overseas operations,
allowing them to use income collected by their
foreign posts for their operating requirements.
7. Disbursement
– This is the final step of the budget execution
phase, where government monies are actually
spent. The Modified Disbursement Scheme is
mostly used, where disbursements of national
government agencies chargeable against the
Treasury are made through government servicing
banks, such as the Land Bank of the Philippines.
– The budget process, of course, does not end when
government agencies spend public funds: each
and every peso must be accounted for to ensure
that is used properly, contributing to the
achievement of socio-economic goals.
BUDGET
ACCOUNTABILITY
BUDGET ACCOUNTABILITY
– This phase happens alongside
the Budget Execution phase.
– Through Budget Accountability,
the DBM monitors the
efficiency of fund utilization,
assesses agency performance
and provides a vital basis for
reforms and new policies.
1. Performance and
Target Outcomes
– Agencies are held accountable not only for how these
use public funds ethically, but also on how these attain
performance targets and outcomes using available
resources.
– These performance measures are set alongside the
preparation of the National Budget; and these are
indicated in the OPIF Book of Outputs.
– Prior to the execution of the enacted National Budget,
these performance targets are firmed up during the
preparation of BEDs.
2. Budget Accountability
Reports
– Submitted by agencies on a monthly and
quarterly basis, BARs are required reports
that show how agencies used their funds and
identify their corresponding physical
accomplishments.
– These include quarterly physical and financial
reports of operations; quarterly income
reports, a monthly statement of allotments,
obligations and balances; and monthly report
of disbursements.
“No Report, No Release”
Policy
– Starting 2012, the DBM will be withholding certain fund releases
to agencies if these fail to submit their Budget Accountability
Reports. In particular, these will be funds from the
Miscellaneous Personnel Benefits Fund (MPBF) for
compensation adjustments under the Salary Standardization
Law, provisions for unfilled positions and employee clothing
allowances.
– These funds to be withheld are only limited to agencies’ MPBF
allotments so that only the agencies are penalized and that the
implementation of critical programs and projects will not be
disrupted. Errant and compliant agencies will also be posted
online for public scrutiny.
3. Review of Agency
Performance
– The DBM regularly reviews the financial and physical
performance of agencies. Actual utilization of funds and
physical accomplishments, as indicated in the agencies’
BARs, are evaluated against their targets as identified via
OPIF and in the agencies’ BEDs. Agency Performance
Reviews (APRs) are conducted quarterly or every semester,
as the case may be.
– An annual Budget Performance Assessment Review (BPAR)
is conducted to determine each agency’s accomplishments
and performance by the year-end. The DBM regularly
reports results to the President.
4. Audit
– Auditing is not within the DBM’s
jurisdiction, and is instead lodged under
the Commission on Audit (COA).
Nonetheless, auditing is critical in ensuring
agency accountability in the use of public
funds.
– The DBM uses COA’s audit reports in
confirming agency performance,
determining budgetary levels for agencies
and addressing issues in fund usage.
Performance-Based
Incentive System
– The Department of Budget and Management
(DBM) is also in the process of establishing a
performance-based incentive system — which will
recognize and reward good performance among
government employees — to help improve the
efficiency of service delivery across all government
institutions.
REFORMING
the Philippine
Budgeting
System
ANNUAL CASH-BASED APPROPRIATIONS

– It limits incurring obligations and disbursing payments for goods

delivered and services rendered, inspected, and accepted within
the fiscal year.
– In FY 2019, the national government will shift from an obligation-
based budget to annual cash-based appropriations.
– In annual cash-based appropriations, payments for contractual
obligations delivered until the end of the fiscal year may be settled
until the end of the Extended Payment Period (EPP) - the three-
month period following the end of the fiscal year.
WHAT ABOUT PROJECTS THAT WILL
REQUIRE MORE THAN ONE YEAR
TO IMPLEMENT?
– For projects with an implementation period of more than 12 months,
agencies must obtain a Multi-Year Obligational Authority (MYOA) from the
DBM.
– A MYOA is issued for projects that will be undertaken by agencies for a
period of more than one fiscal year and exceeding 12 months.
– Likewise, Government-Owned and/ or -Controlled Corporations (GOCCs)
that will implement multi-year projects (MYP) need to obtain an equivalent
authority of multi-year support from their governing board.
– Contracts with implementation periods of 12 months or less should not
spill over to the next fiscal year as they cannot be covered by a MYOA.
WHAT ABOUT PROJECTS THAT
WILL REQUIRE MORE THAN ONE
YEAR TO IMPLEMENT?
– A MYOA (or any other equivalent authority) is a commitment by the
implementing agency or GOCC that the annual funding requirements for the
multi-year projects shall be included in its budget proposals or corporate
operating budget (COB) for the covered years, consistent with the provided
implementation schedule. Subsequent budget items under a MYOA will be
given priority consideration when evaluating proposals.
– The MYOA should show the schedule of the annual cash requirements of the
multi-year project. The annual funding requirement of the multi-year project
will be appropriated annually.
– In addition, in accordance with the Administrative Code, the Certificate of
Availability of Funds (CAF) should be issued annually for multi-year projects,
based on the approved budget in the General Appropriations Act (GAA) and
allotments received for the purpose.
FREQUENTLY ASKED
QUESTIONS
– What will be the cost of a multi-year project?
– Pursuant to Sections 5.b and 7.6 of the 2016 Revised
Implementing Rules and Regulations (IRR) of Republic
Act No. 9184, or the Government Procurement Act,
the Approved Budget for the Contract (ABC) shall be
the total project cost of a multi-year project as
reflected in the MYOA.
FREQUENTLY ASKED
QUESTIONS
– When is the Certificate of Availability of Funds (CAF) required?
– Pursuant to Presidential Decree No. 1445 (Government Auditing Code of the
Philippines), the CAF is only required prior to awarding of a contract. Consistent with
Section 20.1.c(i) of the 2016 Revised IRR of RA No. 9184, either (a) the approved
Annual Procurement Plan (APP) consistent with the General Appropriations Act
(GAA), or (b) the indicative APP consistent with the NEP for Early Procurement, is
sufficient for the purpose of commencing procurement, including undertaking pre
procurement conferences and publishing invitations to bid.
– For multi-year projects, a MYOA should be secured from the DBM prior to
commencing procurement activities.
– For multi-year projects, when is the CAF issued?
– The CAF should be issued annually based on the allotments released for the
purpose.
HOW WILL UNPAID OBLIGATIONS
BE SETTLED? (2018)

– Unpaid obligations (accounts payable and not-yet-due-and-demandable obligations) as of the

end of Fiscal Year 2018 will be prioritized, paid, and issued Notices of Cash Allocation(NCAs),
subject to validation by the DBM, even after FY 2018. These unpaid obligations will have the
first allocation from the Total Cash Budget Ceiling to determine the Fiscal Space available for
items to be included in the annual cash-based General Appropriations Act.
– Agencies should wind down their accounts payable and ensure prompt delivery, acceptance,
and payment for the not-yet-due-and-demandable obligations.
– In accordance with Section 98 of PD 1445, the Commission on Audit (COA) may revert to the
unappropriated surplus of the general fundany unliquidated balance of accounts payable in
the books of the national government, which has been outstanding for two years or more.
HOW WILL UNPAID OBLIGATIONS
BE SETTLED? (2019)

– From 2019 onwards, agencies have up to three months, during the Extended Payment Period
(EPP), to pay their booked accounts payable by the end of the fiscal year. Payments for
accounts payable during the EPP will be charged against the previous year’s appropriations.
– For example, the EPP of Fiscal Year 2019 is from January to March 2020. Payments of FY 2019
accounts payable (i.e.,goods and services delivered and accepted by agencies) during the EPP
will be charged against the FY 2019 Budget.
– In an annual cash-based budget, all obligations should be delivered, inspected, and accepted by
the end of the fiscal year. There should be no booked not-yet due-and-demandable obligations
by the end of the year.
– Payments done during the EPP will be part of the performance of the prior fiscal year’s budget.
For accounting and fiscal programming purposes, however, these will be booked in the current
fiscal year’s financial reports.
How could agencies successfully
transition to a cash -based budget?

– A multi-year planning perspective is even more significant now

that the time horizon of the national budget has shortened.
Program managers should have a clear plan on their targets in
the medium term and the necessary resources to attain these.
In addition, agencies are encouraged to practice an increased
discipline in managing their budgetary resources, and to carry
out forward planning and risk management in proposing and
implementing an annual cash-based budget. This includes
plotting timelines that are based on the implementation
capacity of the agency.
How could agencies successfully
transition to a cash -based budget?

– Agencies should only propose projects that are “shovel-

ready” and can be fully implemented, delivered, and
paid for within the fiscal year. Agencies are urged to
complete preparatory works early such as conducting
feasibility studies and detailed engineering, and
obtaining necessary clearances from local government
units and other agencies. If the project is not yet
implementation-ready, the proposal should only
include expenditures for these preparatory activities.
How could agencies successfully
transition to a cash -based budget?

– In order to deliver a 12-month contract within

the fiscal year, agencies should prepare budget
proposals with a clear intent to conduct Early
Procurement after the Executive has submitted
the National Expenditure Program (NEP) to
Congress.
– This way, 12-month contracts can be awarded
within January of the fiscal year.
How could agencies successfully
transition to a cash -based budget?

– Shifting from an obligation-based budget to an annual

cash-based budget requires the re-engineering of
processes like procurement and payment. Thus, agencies
should formulate a procurement strategy for every
category of goods and services that they plan to procure.
– This also entails properly scoping the market and
assessing the requirements of end-users as early as the
period of preparation of budget proposals. This ensures
that failure of bidding is minimized.
HOW ARE NG TRANSFERS TO
GOCCs AND LGUs DONE IN AN
ANNUAL CASH-BASED BUDGET?

– In an annual cash-based budget, budgetary support to

GOCCs should be disbursed within the fiscal year. Likewise,
program/ project transfers to Local Government Units (LGUs)
from agencies, such as the Department of Health’s Health
Facilities Enhancement Program (HFEP) and the Department
of Agriculture’s Farm-to-Market Road (FMR) projects, should
be disbursed within the fiscal year.
– For transfers of financial assistance and other support to
LGUs (in the Local Government Support Fund), LGUs have
until the end of the following fiscal year to utilize the
transfer.
HOW ARE NG TRANSFERS TO
GOCCs AND LGUs DONE IN AN
ANNUAL CASH-BASED BUDGET?

– Similar to budgets of the national government, any

unspent appropriations after the end of the validity
period will lapse. Unexpended balances of funds
transferred to GOCCs and LGUs will revert to the National
Treasury.
– On the other hand, the Internal Revenue Allotment and
the Special Shares of LGUs from the Proceeds of National
Taxes and Fees will have no such limitation. These
statutory shares will be valid until fully expended as these
are their lawful shares in the NG revenue collections.
REFERENCES
– www.dbm.gov.ph
– www.gov.ph
– www.oecd.org
–“A BUDGET IS MORE THAN
JUST A SERIES OF NUMBERS ON
A PAGE; IT IS AN EMBODIMENT
OF OUR VALUES” – -BARRACK OBAMA
Additional reading materials:
– Briones, Leonor M. (2013). What the People Should Know About
the National Budget. Social Watch Philippines
Activities/Assessment:

Make a critique paper on the government’s plan to move from

the annual obligations-based budgeting system to the annual
cash-based budgeting system. Citing possible advantages or
disadvantages of such policy reform in the planning,
implementation as well as the auditing stages. Make your own
recommendations, if any.