{"id":4523,"date":"2016-02-11T09:33:26","date_gmt":"2016-02-11T14:33:26","guid":{"rendered":"https:\/\/charityandsecurity.org\/?p=4523"},"modified":"2019-10-09T07:00:06","modified_gmt":"2019-10-09T11:00:06","slug":"pvs_summary_and_analysis","status":"publish","type":"post","link":"https:\/\/charityandsecurity.org\/analysis\/pvs_summary_and_analysis\/","title":{"rendered":"Partner Vetting System: Summary and Analysis"},"content":{"rendered":"

The Partner Vetting System (PVS) is a pilot program created to vet individuals in nongovernmental organizations (NGOs) and for-profit entities who apply for United States Agency for International Development (USAID) contracts and grants, to ensure that USAID-funded activities are not inadvertently providing support to entities associated with terrorism. Under the PVS pilot program, the U.S. government requires many grant applicants to submit detailed personal information on key employees and subcontractors to USAID for comparison with intelligence databases.<\/p>\n

The PVS pilot program operates pursuant to two rules\u2014one for acquisitions and another for assistance. The acquisitions rule (48 CFR Parts 704, 713-16, 744 and 752), part of USAID\u2019s procurement regulation, and the assistance rule (2 CFR Part 701) are similar. They require vetting of key personnel (both U.S. and non-U.S. persons) of potential awardees and sub-awardees. The PVS program applies to non-federal entities, nonprofit organizations, for-profit entities and foreign organizations that apply for USAID contracts, grants, cooperative agreements or other funding.<\/p>\n

The pilot, implemented by USAID and the U.S. State Department, is operated in Guatemala, Kenya, Lebanon, the Philippines and Ukraine. However, USAID\u2019s authority is not limited to these five countries. The agency has the legal authority to conduct vetting outside the pilot program \u201cwhere a risk assessment indicates that vetting is an appropriate higher level safeguard that is needed to protect U.S. taxpayer resources in high-risk environments like Afghanistan,\u201d according to the most recent PVS final rule (80 FR 36693, June 26, 2015).<\/p>\n

USAID applies a risk-based assessment to determine if a particular award is subject to vetting. This involves a number of factors, including the operating environment, nature of the program or activity, geographic locations of the proposed program or activity, and the amount of the award.<\/p>\n

At the same time, the U.S. State Department runs a parallel program known as Risk Analysis and Management (RAM). Direct recipients of State Department funds under Bureau of Population, Refugees and Migration solicitations in the same five pilot countries must undergo pre-award vetting. The State Department uses USAID’s PVS database to collect and store information on partner organizations and their key individuals, although the RAM information is accessible only to State Department employees. Few additional details on RAM are available.<\/p>\n<\/div>