Independence, Programme Boundaries and an Adverse Finding
Your firm has assessed Prakash Foundation's livelihood programme for three consecutive years. The engagement now generates INR 42 lakh a year, which is 55% of your firm's total revenue. Your firm also designed the foundation's management information system and its indicator set, and provides quarterly monitoring and evaluation support under a separate contract. For this year's assessment the foundation's chief financial officer proposes that you carry forward last year's assumptions on the basis that there has been "no material change", which would halve the fieldwork. During fieldwork you find that a resettlement site linked to the programme's irrigation component displaced 40 families, of whom 26 have received no compensation and 9 have no written record of their land claim. The programme boundary in the terms of reference covers only "programme participants", and the 40 families are not participants. The CFO asks you to leave the finding out because it is "outside the boundary" and asks you to sign before the financial audit closes in three weeks.
1. Should your firm accept this year's assessment at all? Set out the independence analysis and any safeguards.
Read the worked answer
There are four threats, and collectively they are serious.
- Self-review. Your firm designed the MIS and the indicator set. Assessing performance against indicators you chose is self-review; the finding that the indicators are adequate is not independently reached.
- Fee dependence. 55% of firm revenue from one client creates an intimidation and self-interest threat. A single client at that share can effectively determine whether the firm's staff are paid.
- Tenure. Three consecutive years with the same team reduces scepticism and produces assumption carry-forward of exactly the kind the CFO is now proposing.
- Multiple services. M&E support means your firm is part of programme management, not external to it.
Safeguards that could make acceptance defensible: a completely separate assessment team with no M&E role, an engagement quality review by a partner unconnected to the client, written acknowledgement that the firm's M&E work is itself subject to criticism in the report, and a fee that is not contingent on the outcome. Given the fee concentration, the cleanest answer is to resign from the M&E contract before accepting the assessment, or to rotate the assessment to another firm. Independence that exists only on paper is not independence.
2. Is the resettlement finding inside or outside the assessment boundary? How do you handle it?
Read the worked answer
It is inside. The programme boundary is a matter of impact, not of contract drafting. A programme that physically displaces households has affected those households, whether or not they are enrolled participants. Defining the boundary to exclude them would exclude the negative impact while retaining the positive ones - a one-sided account.
Positive and negative impacts should be assessed on the same basis. If the irrigation component generates attributed benefits for participating farmers, then the displacement it caused is part of the same causal chain and must be reported with the same rigour.
Practically:
- Record the finding with evidence - a household list, compensation status per family, and the documentary gaps for the nine claims.
- Report it as an adverse finding, distinct from the programme's positive results, with a description of the mitigation the foundation has committed to and the timeline.
- Note the discrepancy between the terms of reference and the impact boundary in the report itself, so readers see that the scope was widened and why.
- Where an entity's own grievance mechanism exists, check whether the 26 families used it and what response they received.
Recommending that the foundation commission an independent land and compensation review is appropriate; deleting the finding is not.
3. The CFO wants sign-off in three weeks and proposes carrying forward last year's assumptions. How do you respond?
Read the worked answer
Both requests go to the same point: signing on the basis of evidence you have not gathered.
On carry-forward: prior-year assumptions can be used as a starting hypothesis but must be re-tested. Document what has changed - new sites, changes in staff, rainfall and crop patterns, price inflation affecting the income proxy, any shift in the beneficiary profile. If fieldwork is genuinely reduced, the report must say so, and the assurance given must be narrowed accordingly: a limited scope, not a full assessment presented as equivalent to previous years.
On the deadline: the financial audit timetable is the foundation's constraint, not a reason to shorten verification. Offer the alternatives - an interim report with clearly stated limitations and a final report after fieldwork, or a phased sign-off covering the components that are complete.
Also address the sequencing risk directly: signing before the financial audit closes means programme expenditure figures may change afterwards, and any cost-per-beneficiary or value-for-money statement in your report would then be wrong.
If the foundation insists on a full sign-off without the fieldwork and with the resettlement finding removed, decline the engagement. Record the request and your refusal in the file, and inform the board or audit committee rather than only the CFO.