Implementing, managing risks and monitoring

1Targeting and registration

• Clear vulnerability criteria, known to the community (for example female-headed households, persons with disabilities, lack of income).
• Combined methods: socio-economic criteria, household verification visits, involvement of community committees, with checks to prevent favouritism.
• Digital registration with informed consent, data minimisation and protection of personal data (restricted access, encryption, controlled sharing).
• Prevent duplication and coordinate lists with other organisations through the cash working group.

2Payments

• Choose the financial service provider (mobile money operator, bank, money transfer agent) after competitive bidding and due diligence.
• Plan solutions for people without a phone or without identity documents.
• Reconcile payments: the list paid by the provider must match the approved list; discrepancies are explained.
• Security: avoid predictable and visible cash distributions, inform people about scams (no one should ask for part of the money), protect PINs.
• Communicate clearly: amount, date, duration, how to complain.

3Monitoring and accountability

• Post-distribution monitoring (PDM): was the money received, in full? How was it spent? What problems arose (hidden fees, pressure, tensions)?
• Market and price monitoring to detect inflation and adjust the transfer value.
• An accessible complaints mechanism, including for sensitive complaints (requests for money or favours in exchange for registration).
• Common indicators: percentage of households that received the full amount on time, Food Consumption Score, negative coping strategies, share of expenditure covered.

4Designing and conducting targeting: methods, errors and quality control

Targeting is the part of the programme most exposed to community criticism, pressure from local authorities and errors. There is no perfect method: every method produces inclusion errors (households that do not meet the criteria receive assistance) and exclusion errors (eligible households do not receive it). In humanitarian settings, exclusion errors are generally considered more serious, because they deprive people of life-saving assistance; but visible inclusion errors destroy trust and fuel tensions.

Methods and their uses

In practice, two or three methods are often combined: geographic targeting to delimit the area, categorical criteria or a vulnerability score to select households, community validation to correct obvious errors, and a complaints mechanism to address cases of exclusion.

The step-by-step process

1. Define the criteria (one week): based on the needs analysis, identify the variables that genuinely distinguish households in difficulty. The criteria are discussed in the CWG to harmonise them with other organisations.
2. Test the criteria on existing data: apply the score to a dataset of households already surveyed (for example the MSNA) and check what proportion of households with poor food consumption is actually selected. If fewer than 70% of households in severe difficulty are selected, the model must be revised.
3. Inform communities before any data collection: objectives, criteria, timeline, the impossibility of serving everyone, the existence of a complaints mechanism. This step considerably reduces later tensions.
4. Collect data: door-to-door surveys are preferable to lists provided by third parties, which are only one source among others.
5. Calculate the scores and draw up the provisional list, with random verification of 5 to 10% of households by a team different from the one that collected the data.
6. Validate: post or present the provisional list in ways that do not put people at risk (no public posting of names if status is sensitive), with a complaints period of 7 to 10 days.
7. Handle complaints and revisit contested households, then finalise the list, signed by the programme manager and sent to the person responsible for payments through a secure channel.

Building a simple vulnerability score

The eligibility threshold (for example 7 points out of 14) is set according to the number of households that can be funded and tested on the dataset. The FCS thresholds mentioned are those used by WFP for standard contexts; they are raised (28 and 42) where consumption of sugar and oil is high.

A criterion that the community does not understand will be perceived as arbitrary. A criterion known to everyone but impossible to verify will be manipulated. Good criteria are both explainable and verifiable.

5Registration, identity verification and responsible data management

Registration turns a list of households into a database that will be used for payments, monitoring and often coordination between organisations. It is also the moment when the organisation takes the greatest risks for people: every piece of data collected may one day be lost, stolen or demanded by an authority. The IASC Operational Guidance on Data Responsibility in Humanitarian Action and the ICRC Handbook on Data Protection in Humanitarian Action set the framework.

Data to collect, and data to avoid

The registration procedure

1. Prepare: tested digital form, unique household codes, training of enumerators (at least two days, including consent and how to respond to requests for favours), data collection plan by area.
2. Explain and obtain consent: why the data are being collected, who will have access to them (including the payment service provider), how long they will be kept, how to exercise one's rights. Consent is valid only if refusing does not deprive the person of assistance; otherwise, another legitimate basis is used (vital interest or public interest mission, depending on the organisation's policy) and documented.
3. Collect: enumerators working in pairs, ideally mixed-gender; photo of the identity document only if necessary.
4. Check quality every day: missing data, invalid numbers, duplicates, abnormally short interview durations, clusters of identical phone numbers.
5. De-duplicate: internally (same name, same phone, same document), then across organisations according to the CWG protocol, preferably by exchanging transformed (hashed) identifiers rather than named lists.
6. Verify: phone call-back or random visit to at least 5% of registered households, by a different team.

Protecting data in practice

• Data protection impact assessment before launch: data flows, actors, risks, measures.
• Written data sharing agreements with the provider and partners: data transmitted (the strict minimum), purpose, prohibition of commercial reuse, security, retention period, destruction at the end of the contract.
• Role-based access control: the monitoring team does not need identity document numbers; finance does not need vulnerability data.
• Encrypted transmission of payment lists, never via personal messaging apps or unencrypted USB sticks.
• Limited retention: period defined by the organisation's policy and the donor's contractual audit obligations, followed by documented destruction.

Retention obligations for audit purposes (often several years after the end of the project) apply to financial supporting documents. They do not justify keeping all household vulnerability data: separate what must be kept for audit from what can be destroyed.

6Selecting, contracting and managing the payment service provider

The financial service provider (mobile money operator, bank, microfinance institution, money transfer operator, payment agent) becomes a central link in the programme. Choosing it badly, or contracting too quickly, creates risks that the programme team will not be able to correct.

Mapping and assessing the options

Provider mapping is ideally carried out by the CWG and updated every year. For each provider, it records: geographic coverage, the number of active agents in the area, agents' liquidity capacity, know-your-customer requirements, fees, experience with humanitarian organisations, reporting capacity and regulatory compliance.

The procurement process

1. Statement of requirements: number of households, values, frequency, areas, timeline, data requirements, expected services (SIM card registration, account opening, phone distribution, helpline).
2. Tender according to the thresholds in the organisation's and the donor's procurement policies. Many organisations have framework agreements signed during preparedness, which saves several weeks in an emergency.
3. Due diligence: licences, financial situation, ownership, screening against applicable sanctions lists (United Nations, European Union and, depending on the donor, other lists), data protection policies, references.
4. Evaluation by a committee, using a weighted grid announced in the tender.
5. Pilot test with a few hundred households before full roll-out, when the timeline allows.

Essential contract clauses

• Completely free of charge for the household: no cash-out fees, no obligation to buy from the agent; penalties if deductions are found.
• Timelines: transfer within a defined period after receipt of the payment instruction; transaction report within 48 to 72 hours.
• Management of uncollected funds: withdrawal period (for example 30 days), return of unclaimed funds to the organisation's account, detailed report.
• Data protection: exclusive purpose, prohibition of targeted marketing, security, incident notification, destruction at the end of the contract.
• Code of conduct applicable to agents, including the prohibition of sexual exploitation and abuse and cooperation with investigations.
• Right of audit for the organisation and the donor.

Reconciliation: principle and segregation of duties

Reconciliation compares three lists: the approved list (programmes), the payment instruction sent (finance) and the provider's transaction report. Every discrepancy must be explained and documented before the next payment. Segregation of duties is essential: the person who draws up the list of households must not be the one who sends the payment instruction, nor the one who carries out the reconciliation.

7Worked example: a mobile money payment cycle in Tamoro, from list to reconciliation

Fictional context: the NGO "Entraide Tamoro" is implementing a multipurpose cash assistance programme for 3,000 households in two rural communes of the fictional district of Tamoro, affected by floods. The transfer value is USD 120 per month for four months. The provider is a mobile money operator selected through a tender, with fees of 1.8% of the value disbursed, cash-out included. This example follows the second payment cycle.

Cycle timeline (working days)

Step 1: preparing the list

The first-cycle list contained 3,000 households. Analysis of complaints and cross-checking with the CWG database identified 14 duplicates (households registered both by Entraide Tamoro and by another organisation, or twice under different spellings) and 6 households that had left the area or whose recipient had died without a declared alternate. These 20 households are removed; the last 6 are visited to register a new recipient if the household is still present. The second-cycle list contains 2,980 households, and the payment instruction amounts to 2,980 multiplied by 120, i.e. USD 357,600.

Step 2: provider report and reconciliation

Check: 355,440 + 1,320 + 840 = 357,600. The reconciliation balances in terms of amounts. The USD 2,160 from failed transfers remains in the provider's account and will be offset against the catch-up payment; the USD 3,720 not withdrawn is returned to the organisation in accordance with the contract.

Step 3: analysis of anomalies

• Analysis of the transaction file shows that 9 phone numbers each received two transfers. After verification, 7 correspond to households that share a phone with a neighbour, a situation declared at registration; 2 correspond to the same community worker who had provided his own number for two households without phones. The households concerned are contacted, actual receipt is verified, and the practice is prohibited for the next cycle, with an alternative solution (cash payment by the provider's agent upon presentation of an identity document).
• The complaints hotline received 4 reports of a 10% fee being deducted by one of the provider's agents in the commune of Bassi. The provider is notified in writing, the agent is suspended by the operator after an investigation, and the households concerned are reimbursed by the provider in accordance with the contract. A reminder that the service is free of charge is sent to all households in the commune.
• The withdrawal rate within three days is only 61% in the village of Kéla, compared with 88% elsewhere: the local agent lacked liquidity. For the next cycle, the provider undertakes to deploy a mobile agent with sufficient liquidity during the first three days.

Step 4: cycle report

The cycle report, one to two pages long, presents the reconciliation, the anomalies and corrective actions, the timeliness and coverage indicators (99.4% of transfers successful on day D, i.e. 2,962 out of 2,980; 98.4% of households having withdrawn their transfer by D+30, i.e. 2,931 out of 2,980, before catch-up payments), and the complaints received and handled. It is signed by finance and programmes, archived with the supporting documents, and serves as the basis for donor monitoring.

A reconciliation that balances in terms of amounts does not prove that the right people received the money. It must be complemented by an analysis of anomalies in the transactions, verification calls and post-distribution monitoring.

8Post-distribution monitoring and accountability: sampling, indicators and complaints mechanism

Post-distribution monitoring (PDM) answers three sets of questions: did the process work (receipt, amount, timeliness, fees, safety); how was the money used; what effects are observed on consumption, coping strategies and access to services? It is combined with market monitoring and complaints analysis to form a coherent system.

Timeline and method

• Baseline survey before the first transfer, on outcome indicators, using the same questionnaire as subsequent surveys.
• Process PDM two to four weeks after each payment (or after each of the first two payments, then every other payment): households' memories are still fresh and problems can be corrected in the next cycle.
• Outcome PDM at mid-term and at the end, or even three months after the end to observe sustainability.
• Data collection mode: face-to-face or telephone interviews. Telephone is less costly and suited to remote management, but it excludes households without phones and is poorly suited to sensitive questions; plan a face-to-face sub-sample.

Calculating the sample size

To estimate a proportion with a 95% confidence level and a margin of error of 5 points, in the absence of prior information (assumed proportion of 50%), the formula gives 384 households for a large population. With a finite population correction for 2,962 households, the result is 384 divided by (1 + 383 / 2,962), i.e. about 340 households. Adding 10% for non-response gives about 375 households. If results representative of each of the two communes are required, the sample must be calculated for each commune (about 300 households each for a population of 1,500), which almost doubles the cost: the decision should be based on how the results will actually be used. Households are drawn at random from the list of paid households, stratified by commune and, if possible, by sex of the recipient.

Key indicators and benchmarks

The complaints and feedback mechanism

• Multiple channels: toll-free hotline, help desks, suggestion boxes, feedback gathered during visits; at least one channel accessible to people who cannot read and to those without a phone.
• Categorisation: request for information, payment problem, targeting dispute, conduct of staff or an agent, sensitive complaint (fraud, sexual exploitation and abuse). Sensitive complaints follow a confidential procedure and are referred without delay to the designated focal point.
• Set and monitored response times (for example acknowledgement of receipt within 48 hours, response within 7 days for a standard complaint).
• Feedback loop: every complaint receives a response; trends are analysed every month and presented to the team and the CWG; the adjustments decided are communicated to communities.

A mechanism that receives no complaints is not a sign of a perfect programme: it is almost always a sign of a mechanism that is unknown, inaccessible, or that people do not believe will make any difference.

9Contextual variations, common mistakes and auditors' checkpoints

Adapting implementation

Common mistakes

• Using a list provided by the authorities or leaders as the final list: it must always be verified against the programme criteria.
• Entrusting targeting, registration and verification to the same team: this is the configuration in which fraud is easiest to commit and hardest to detect.
• Not providing for an alternate recipient: illness, travel or death lead to avoidable exclusion.
• Collecting too much data because "it might come in useful": every unnecessary piece of data is a risk with no benefit.
• Allowing the provider to charge households fees, even small ones: households receive less than the intended value and abuses spread.
• Conducting PDM too late or not using it: the results arrive when the programme has ended.
• Not disaggregating results by sex, age and disability: access problems specific to certain groups remain invisible.

What auditors and donors check

For donors, proof of receipt by the household is the central issue: electronic transaction reports are generally accepted as supporting documents, provided they are accompanied by the approved list and the reconciliation. Direct cash distributions require distribution lists that are signed or thumbprinted, and stronger controls.

10Interview questions and key references

Interview questions

1. "How do you limit inclusion and exclusion errors in targeting?"

A good answer combines several methods and explains testing the criteria on existing data, informing communities beforehand, random verification by a separate team, the validation period and the complaints mechanism. It acknowledges that exclusion errors are often more serious in humanitarian settings and proposes ways to correct them.

2. "Describe a payment reconciliation."

The candidate cites the three lists (approved list, payment instruction, provider report), line-by-line matching, documented explanation of each discrepancy, the handling of failed transfers and uncollected funds, segregation of duties and the link with PDM. They specify that balancing the amounts is not enough and mention the analysis of anomalies.

3. "A ministry asks for the list of beneficiaries with their phone numbers. What do you do?"

A strong answer draws on the organisation's data protection policy, the analysis of risks to people, the data minimisation principle and the need for a data sharing agreement, and proposes alternatives (aggregated data, transformed identifiers). It mentions escalation to senior management and coordination with the CWG and other organisations.

4. "You discover that the provider's agents are charging fees on withdrawals. What do you do?"

The candidate describes verifying the facts (complaints, verification calls), written notification to the provider in accordance with the contract, protection of complainants, reimbursement of households, information on the free-of-charge nature of the service and follow-up of the measures taken. They mention the possible obligation to report the incident to the donor.

5. "Which indicators would you use for a multipurpose cash assistance programme?"

A good answer distinguishes process indicators (full and timely receipt, fees, safety, awareness of the complaints mechanism) from outcome indicators (FCS, rCSI, livelihood coping strategies, economic capacity to meet essential needs), explains how they are calculated and disaggregated, and discusses PDM sampling.

Key references

• CALP Network: Programme Quality Toolbox (targeting, registration, providers, monitoring), guidance on protecting beneficiary data.
• IASC Operational Guidance on Data Responsibility in Humanitarian Action.
• ICRC: Handbook on Data Protection in Humanitarian Action.
• WFP: technical guidance on the food consumption score, the reduced coping strategies index, livelihood coping strategies and the CARI approach.
• Recommended outcome indicators for multipurpose cash assistance (work by the Grand Bargain and the CALP Network).
• Core Humanitarian Standard (CHS), commitments on accountability, feedback and complaints.
• Inter-Agency Standing Committee (IASC): principles on protection from sexual exploitation and abuse.
• Financial Action Task Force (FATF) Recommendations on customer due diligence, useful for understanding providers' requirements.