Chapter 11: Accountability in Supporting the Emergency Response to a Crisis: Lessons from COVID-19 Funds
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Mr. Richard I Allen
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Fazeer Sheik Rahim
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Abstract

When a country’s system is inefficient and ill prepared, the need to respond quickly to a national emergency can create significant governance vulnerabilities. This chapter considers an approach taken by some countries during the COVID-19 pandemic to acelerate the execution of emergency spending by creating a dedicated fund outside the budget to support the emergency spending. The chapter discusses the benefits of this approach and warns against the risks. Drawing from the experience of these funds, the chapter offers some guiding principles for the creation and operation of special funds, and broader lessons for strengthening PFM systems.

Abstract

When a country’s system is inefficient and ill prepared, the need to respond quickly to a national emergency can create significant governance vulnerabilities. This chapter considers an approach taken by some countries during the COVID-19 pandemic to acelerate the execution of emergency spending by creating a dedicated fund outside the budget to support the emergency spending. The chapter discusses the benefits of this approach and warns against the risks. Drawing from the experience of these funds, the chapter offers some guiding principles for the creation and operation of special funds, and broader lessons for strengthening PFM systems.

Introduction

During a pandemic, governments are faced with immediate demands to take action to save lives, protect livelihoods, and support the economy. These demands for action include calls for fast- tracking expenditure on health and containment measures, for the continuation of essential public services, and for assistance to support affected households and businesses. To meet these demands, governments must quickly reprioritize their existing budget allocations and secure additional resources both domestically and externally. Once the situation is more controlled, governments are expected to scale up their efforts to support aggregate demand, while standing ready to respond to future waves of the pandemic.

A country’s PFM system is typically geared to meet its budgetary needs in normal times. Its authorities make policy decisions— and allocate resources for their implementation— as part of an annual or multiannual budget process, in which various entities (parliament, the cabinet, the ministry of finance, and line ministries) have well- defined roles. Regular checks and controls are employed during budget execution, and public procurement processes, reporting frameworks, and external oversight arrangements are aligned with the annual budget cycle.

A PFM system may not be prepared to deal with an exceptional situation like a pandemic, which can also expose many of its weaknesses. An effective response may require new forms of coordination and collaboration across the government. For example, close coordination among sectors that do not typically work together, such as health, social services, police, and customs agencies, is critical during a lockdown. The typical processes behind the planning and execution of the budget, including procedures for procurement, necessary in normal times, may constrain the speedy deployment of resources in an emergency. In the absence of specific institutions and processes to deal with emergencies (whether officially in place or informally practiced), the authorities may need to create new ones as they respond to the crisis. In situations when prior controls are relaxed, there is a need for compensating improvements in the monitoring and audit of emergency spending or which existing capacities are typically weak in developing countries. These weaknesses, coupled with the scale of the response, can create significant exposure to corruption and other governance vulnerabilities.

This chapter reviews some of the governance vulnerabilities that can occur during a crisis and considers ways in which countries have addressed these vulnerabilities during the COVID- 19 pandemic. It examines the benefits of setting up an extrabudgetary fund to support transparency and accountability while still facilitating the overall response to a crisis, and it warns against the inherent risks. The chapter draws from lessons emerging from the experiences of the many countries that set up dedicated funds during the COVID-19 pandemic, and from these lessons identifies good practices for managing these funds and for strengthening PFM systems in general.

Governance Vulnerabilities During a Crisis and Ways to Address Them

The Main Vulnerabilities

The main governance vulnerabilities of a PFM system that emerge during a crisis will depend on the nature of the country’s response and the inherent weaknesses of its PFM system. Emergency responses to a pandemic take various forms, which include (1) public procurement— for health- related spending at the peak of the pandemic and for infrastructure spending during the recovery phase; (2) policing and border controls to enforce lockdowns; (3) cash transfers to poor citizens and vulnerable groups; (4) schemes to support companies in financial difficulty; and (5) unemployment benefits and other support for employees. Each of these types of support may give rise to vulnerabilities and corruption risks, which the weaknesses in its PFM system, discussed in the introduction to this chapter. Consider the following examples:

  • Public procurement: Figure 11.1 illustrates the various stages of the public procurement cycle. Vulnerabilities can arise at every stage. Rigorous needs assessment and planning are needed to ensure that the appropriate projects are selected and that they are competitively priced. Ensuring that the request for bids is widely advertised, and that the tender process is fair and competitive, will help to encourage competition, prevent overpricing, and discourage the delivery of goods of inferior quality. The screening of bids is required to identify signs of collusion among bidders. Transparency on beneficial ownership is needed to provide confidence in the process. Technical audits will allow officials responsible for overseeing the procurement process to perform due diligence and identify irregularities.

  • Cash transfers to vulnerable groups: Much needed during a pandemic, cash transfers have proved challenging to implement and are vulnerable to abuse (Una and others 2020a). Key governance vulnerabilities include the absence of (1) clear, transparent, and objective criteria to define beneficiaries; (2) mechanisms to authenticate and validate beneficiaries’ applications for support and to cross- check data; (3) reliable and context- specific cash distribution systems, such as commercial banks, money transfer operators, and so on; (4) robust monitoring and evaluation systems that can be established in collaboration with NGOs; (5) procedures for disclosing the policy objectives of the cash transfer programs— their design, beneficiaries, budgets, delivery mechanisms, and so on; (6) timely and reliable recording of payments in the budget to permit robust internal controls and reporting; and (7) ex-post inspections or audits, ideally carried out on a real- time or monthly basis by a country’s supreme audit institution (SAI) or a reputable external audit firm.

Figure 11.1.
Figure 11.1.

Stages in the Public Procurement Process and Sources of Vulnerability

Source: Based on UNODC (2020).

The Ebola crisis of 2014–2016 provides a good example of PFM weaknesses and governance vulnerabilities. In Sierra Leone, the office of the auditor-general reported many sources of irregularities in the management of the Ebola funds (see also Chapter 12). These irregularities included undocumented payments for supplies, disregarded or misapplied procurement procedures, bribes paid to circumvent security protocols, suspicious payments to parliamentarians and NGOs, and undocumented loans. Many of these irregularities arose from weaknesses in the country’s PFM system, especially its internal controls— or lack thereof— including inadequate management of payroll, inefficient data collection and record- keeping, and poor tracking of foreign aid and emergency spending (Audit Services of Sierra Leone 2014).

Better Transparency and Accountability

During the COVID- 19 pandemic, many governments have been transparent in formulating, budgeting for, and reporting on their emergency response. In many countries, specific policies to mitigate the impact of the pandemic have been prepared, costed, and approved by the parliament as part of supplementary budgets. Countries with good programmatic budget frameworks, such as Armenia and France, have introduced special COVID- 19 programs that cut across spending agencies for better visibility and tracking, and facilitate impact assessment. Countries with a comprehensive financial management information system (FMIS) and a well- defined chart of accounts, such as Rwanda, have prepared specific COVID- 19 codes to support tracking along the spending chain. Some countries (for example, Uganda) have prepared dedicated reports on their COVID- 19 responses. Some have increased the frequency of their financial reporting (for example, from a quarterly to a weekly cycle in the Maldives). Other countries, such as Brazil, Colombia, France, Honduras, Peru, and the Philippines, have created dedicated transparency portals to provide both an overall picture of their COVID-19 related support and ready access to information on procurement processes and beneficiaries.

Some countries have also supplemented standard external scrutiny procedures to improve accountability. For more timely accountability, the SAIs in Sierra Leone and South Africa have undertaken interim audits (see Chapter 9). These exercises are meant to complement audits of emergency spending and the regular end- of- year audits that these SAIs will perform at a later stage. The example of South Africa (see Box 11.1) shows how interim audits have improved the government’s accountability. In Latin America, the SAIs in Honduras and Peru have undertaken concurrent controls of emergency payments and procurements to check the validity of these transactions.

To centralize their response to the pandemic and keep an audit trail, many countries have created dedicated COVID- 19 funds. The next sections examine the benefits and risks associated with this approach.

Role of Extrabudgetary Funds

Even before the onset of COVID- 19, extrabudgetary entities (EBEs), which are outside the control of the budget, were widely used in countries at all levels of development. An EBE can be defined as a set of accounts or a government entity engaged in “financial transactions, often with separate banking and institutional arrangements, that are not included in the annual state budget law” (Allen and Radev 2006, p. 4). Excluding social security and health funds, EBEs account for about 15 percent of central government expenditure across a range of advanced, middle- income, and low- income economies, or close to 50 percent if social security and health funds are included.1 Examples include special- purpose funds (of which COVID- 19 funds are an example), development funds, savings funds, trading funds, and investment funds.

South Africa: The Use of Interim Audits during COVID-19

The auditor-general of South Africa has undertaken two audits and published two reports (in September 2020 and November 2020, respectively) on the financial management of the country’s COVID- 19 response. These reports cover real- time audits of payments, procurements, and deliveries as they occur.

Audience: The reports were ultimately intended for Parliament: prior to submitting them, the auditor-general shared the findings with the accounting officers in implementing agencies to enable them to deal with any shortcomings immediately and tighten controls to prevent recurrence.

Audit team: The audit exercises have been unique in bringing together financial auditors, fraud examiners, IT specialists, and sector- specific experts to provide insights into COVID-19 spending management.

Scope: The first report focused on (1) the payment of benefits and grants to relieve economic and social distress; (2) the procurement of personal protective equipment; and (3) the frontline initiatives to protect against and manage the impact of COVID- 19. The second report had a similar focus, extending its reach to spending by provincial governments and municipalities and assessing the progress made since the first report.

Findings: The first report found instances of benefits and grants directed to unintended beneficiaries, including government officials. The government’s IT systems were slow to respond and failed to share data across various government platforms to enable reconciliation and cross- verification. The report also provided evidence of overpricing, unfair processes, and potential fraud, as well as of instances in which supply chain management legislation was sidestepped.

Sources: Auditor-General of South Africa (2020a; 2020b).

EBEs have traditionally been created to facilitate coordination among government agencies and to promote efficiency. Stronger- than- usual coordination may be needed to implement policy decisions that cut across many public agencies, whether in normal times or in emergency situations (as with the COVID- 19 pandemic). An EBE, with well- organized management structures and accountability arrangements, can also be created to simulate private market conditions and ensure the efficient delivery of certain public services (Allen and Radev 2006; Allen 2013). Another motivation for the creation of an EBE can be to address the consistent underfunding of some activities that are generally overlooked during budget negotiations because they are politically unattractive. A classic example is the maintenance of public infrastructure, often neglected in favor of investment in new assets. An EBE with earmarked resources— such as for roads or other public infrastructure— can potentially bring benefits in terms of the predictability of financing and accountability, an argument often used to justify the existence of extrabudgetary road funds (Potter 2005).

The creation of EBEs is often justified as a temporary and second- best solution to address structural weaknesses in existing budget systems. PFM practitioners generally agree that the best budget practice is one in which (1) the budget process is unified and includes all areas of public spending within a single framework; and (2) the central budget authority exerts strong oversight over the spending decisions of implementing entities. The aim is to avoid fragmentation of policy-making, enforce top- down fiscal discipline, and prevent a dilution of accountability and a weakening of fiscal control by entities with independent fiscal authority. In the real world, budget systems may be far from perfect, especially in low-income countries. Cumbersome processes (often manual and paper-based) may lead to delays and rigidities; weak checks and controls of line ministries and subnational governments often lead to poor budget execution and create corruption vulnerabilities; and decisions on budget allocations may be dominated by political considerations. An EBE with a clear mandate and well- defined PFM processes, subject to heightened standards of accountability, can be a way to circumvent these weaknesses, especially in a situation of crisis and fiscal stress (Allen and Radev 2006).

In the context of the COVID- 19 pandemic, many of these issues have gained prominence. Governments have responded by adopting measures that allow funds to be programmed and disbursed more quickly than would be possible under the conventional budget process, with simplified execution and procurement procedures.2 As noted, the budget system, especially in many low- income countries, faces the challenges of low capacity and governance vulnerabilities, both of which may be better addressed by an EBE with heightened standards of transparency and accountability. With many COVID- 19 funds set up to receive voluntary contributions from the private sector and development partners, governments are under pressure to manage these funds efficiently and effectively, which may require separate arrangements. Finally, COVID- 19-related interventions span several areas, such as health, social services, internal and border security, and local governments, which requires strong coordination, as noted earlier.

As of February 2021, more than 45 countries around the world (27 in sub-Saharan Africa) have set up COVID- 19 funds since the beginning of the pandemic (Rahim and others 2020). These funds usually take the form of EBEs.3 The list spans countries with different administrative and PFM traditions (including both Anglophone and Francophone countries, among others), legal frameworks, and income levels (see Figure 11.2).

Several reasons have been advanced for the creation of these funds. First, there was a need to establish high- level political control of COVID- 19 policies (for example, under the president’s office in Kenya and Sierra Leone) and bring together different sectors and entities affected by the crisis to facilitate implementation of these policies. Second, some countries decided to centralize their funding by pooling together public and private resources, which their standard budget practices may not have allowed. Delays in implementing PFM processes have also motivated some countries to start afresh with streamlined budgeting, payment, and procurement processes within a new structure to speed up their response. Finally, as mentioned earlier, many countries preferred the creation of a separate channel for COVID- 19 spending to enhance transparency and accountability and create a clearly defined audit trail.

Figure 11.2.
Figure 11.2.

COVID-19 Funds around the World

Sources: © 2020 Mapbox. © OpenStreetMap.Note: The classication of PFM traditions is based on Pattanayak (2016). Disclaimer: The boundaries, colors, denominations, and any other information shown on the maps do not imply, on the part of the International Monetary Fund, any judgment on the legal status of any territory or any endorsement or acceptance of such boundaries.

The Risks

EBEs may also create significant risks that need to be balanced against their potential benefits. Their freedom to take independent actions may bypass normal budgetary and expenditure controls, especially when these controls are weak and ineffective. The insulation of EBEs from the budgetary process can, in the absence of full and timely information, distort a finance ministry’s picture of public finances. For both reasons, EBEs are often regarded— particularly in countries where administrative capacity is limited and challenges in reporting and fiscal consolidation exist— as potential sources of financial malpractice and corruption, and are often referred to as “little empires” of limited accountability and as silos for financing political operations (Allen 2013).

The context of the COVID- 19 crisis heightens many of these risks. The need for governments to respond swiftly, under high public pressure, has often led to the relaxation of ex-ante financial controls and standard procurement processes without any safeguards being put in place. While such policies can effectively accelerate spending in some contexts, they can also create significant governance vulnerabilities, particularly when the funds (1) operate outside government systems; (2) are managed by officials not familiar with good principles of PFM; or (3) are not subject to robust transparency and reporting standards. Finally, the very availability of COVID- 19 funds carries with it the risk that some governments may seek to broaden the operational mandate of these funds and to extend their use well after the pandemic has ended.

As discussed below, it is possible for these risks to be managed, and they should be balanced against the inherent weaknesses and corruption vulnerabilities in the budget systems of many low- income countries. Overall, a COVID- 19 fund, backed by strong safeguards, can be a pragmatic approach when PFM systems are weak (for example, where key processes and controls are not automated). These safeguards include a strong legal backing, a clear sunset clause, well- defined PFM processes, and robust accounting, reporting, and audit procedures.

Lessons Drawn from Covid-19 Funds

Countries have followed diverse approaches in setting up their COVID- 19 funds. While some of the funds have drawn mainly from budgetary resources, most have pooled private donations, public resources, and external sources of finance (Rahim and others 2020). Some funds are fully integrated into countries’ existing PFM systems and processes (for example, Francophone countries such as Chad, Morocco, and Senegal), but most operate through separate banking, financial management, and reporting arrangements, outside the regular channels of PFM. While all funds have an explicit mandate to collect resources, some have broad responsibility for coordinating policy responses to the crisis (for example, Sierra Leone), while others have a more restricted role, limited to executing pandemic-related spending. In addition, some (but not all) funds have been set up with a strong legal backing, with their scope and mandate well defined (Rahim and others 2020). This diversity of approaches provides valuable lessons on what constitutes good practice in establishing such funds.

A Clear and Strong Legal Mandate

A clear legal mandate is essential to clarify the purpose of the fund and its sources of finance, its management and oversight structure, its business processes and reporting standards, and the accounting and auditing requirements it is expected to fulfil. Early in the crisis, some countries that operate within the British Commonwealth tradition of public administration, such as Botswana, Ghana, Kenya, and Mauritius,4 created COVID-19 funds through government-issued regulations under their general budget law. Other countries took longer to provide a legal basis for their funds. In Sierra Leone, for example, the fund operated in a legal vacuum for around four months, before regulations were finally issued in August 2020. The country’s SAI noted that this gap had an impact on the soundness of the fiduciary management of the fund (see Audit Services of Sierra Leone 2020).

A Single Fund with a Well- Defined Mandate

To avoid duplication, limit fragmentation, and ensure coordination across activities, a single fund is generally preferable. The areas of the fund’s operations and revenue sources should be defined in some level of detail, which should be done in consultation with relevant government ministries and other stakeholders to ensure that the fund’s mandate is commensurate with the resources at its disposal. Most countries have resorted to creating a single COVID- 19 fund in line with good practice, with rare exceptions (Côte d’Ivoire, for example, has established five funds). The law in Botswana describes in detail the various areas where fund interventions are permissible, such as for wage subsidies, loan guarantees, and citizen evacuation, and for building up stockpiles of strategic grain reserves, and medical supplies and equipment. In Ghana, on the other hand, the fund’s mandate has been defined more loosely in terms of “activities that complement the efforts of the government to combat the pandemic.” ( COVID- 19 National Trust Fund Act 2020)

A Well-Defined Sunset Clause

To ensure that these funds do not outlive their purpose, the law should stipulate a sunset clause and a mechanism for determining how any remaining financial balances should be used. In cases where the funds are expected to continue during the recovery phase of COVID- 19—for example, to ensure continued support from external partners— the conditions under which they will operate should be clearly stipulated.

The COVID- 19 fund regulations in Kenya stipulate that the fund shall be terminated when the president declares that the pandemic no longer poses a threat to the country, but they do not specify the use of any remaining balances. On the other hand, the regulations in Mauritius do not establish any sunset clause but require that the remaining balances of the fund accrue to the country’s consolidated fund. More loosely, in Côte d’Ivoire, the establishing decree requires that after the fund’s dissolution its net assets should be remitted to “any structure assigned to continue its mission or to a major public financial corporation.” (Projets de loi – Fonds de riposte au COVID- 19)

Management and Oversight

A sound management structure for a COVID- 19 fund could be composed of an independent and high- level executive board responsible for making strategic decisions and a chief administrator responsible for managing the fund’s day- to- day activities. A technical team of specialists in health, national security, and other relevant areas could assist the board on policy and operational issues, while a fiduciary team of specialist financial managers, accountants, procurement experts, and internal auditors could assist the administrator. Ideally, the ministry of finance should also have a strong oversight role, through representation on the executive board, for example, and by staffing the fiduciary team.

The management structure of the COVID- 19 fund in Sierra Leone contains some of these key elements. An administrator manages the fund, supported by teams of experts that guide operations and policy across six pillars of interventions, and a fiduciary team that manages the fund’s finances. The fund, however, does not have an independent board, and oversight by the country’s ministry of finance is weak. By contrast, in Botswana, Kenya, and Mauritius the ministry of finance plays a leading role in either the administration of these countries’ respective funds or in their oversight through representation on the executive board.

Clearly Defined PFM Processes

Efficient delivery of emergency relief measures depends on how swiftly interventions can be rolled out on the ground, while ensuring full transparency and accountability. In some countries, the COVID- 19 funds utilize elements of the regular budget and PFM process. In countries where these channels are bypassed, standards of operational practice (SOPs) should be prepared and published, and should include (1) the submission of a proposal to provide emergency funding; (2) the approval of the proposal; (3) the execution of spending and procurement process; and (4) reporting requirements. These published standards should also clarify the role and responsibilities of the fund itself, its chief officers, the finance ministry, and implementing agencies, such as health and internal security. The standards should also prevent potential duplication of approvals and controls, and hence the risk of delays.

Ghana provides a good example of a governance system where the main elements of sound financial management processes have been incorporated into the operations of the COVID- 19 fund. The fund receives both private and public funding (private funds are collected through a separate bank account). The resources are then transferred to the Coronavirus Alleviation Programme, which is managed by the Treasury Department of the Ministry of Finance. Similarly, in Francophone countries, such as Chad, Morocco, and Senegal, while resources for the fund are earmarked through special accounts (comptes d’affectation spéciale), the treasury still manages the spending, albeit through simplified, lighter- than-usual authorization procedures.

Making Use of Electronic Transactions

E-transactions and e- procurement will lend speed and accuracy to the delivery of emergency services, simplify records management, and reduce operating costs. The funds should be granted access to relevant government databases (for example, financial management, tax administration, social security, health care, and public procurement). The COVID- 19 Solidarity Fund in Mauritius requires that all potential beneficiaries make their applications online. The fund uses the databases and payment system of the Mauritius Revenue Authority and the country’s social services agencies to means- test and pay eligible beneficiaries.

High Standards of Transparency

To offset the potential risks of diluted accountability and corruption risks created by an EBE, there is a need for enhanced reporting standards, including the disclosure of detailed information on procurement tenders and contracts. It is good practice for governments to disclose the existence of COVID- 19 funds on their website and describe these funds’ legal mandate, objectives, and policy rationale; sources of revenue, governance, and management arrangements; and operating rules and procedures. Ideally, the revenue and expenditures of the funds should be reported monthly or quarterly on a gross basis.

The regulations in Kenya require the COVID-19 fund’s administrator to submit a report of its activities every quarter. In Ghana and Sierra Leone, on the other hand, the funds are only required to report annually. The Solidarity Fund in South Africa has been set up as an independent charity under private law and is subject to the same reporting requirements as other nonprofit (“public benefit”) organizations. In Honduras, a dedicated portal provides comprehensive information on COVID- 19-related spending, including the activities of an EBE that accounts for around half of this spending.

Transparency requires putting in place a tracking mechanism to monitor the activities and transactions of these funds. While some of their operations may be captured in the government’s FMIS, others, such as in-kind donations, may fall outside of it. Benin and Pakistan have each complemented their FMIS with other information systems to monitor their COVID- 19 funds’ activities and spending.

Effective Audit during and after the Pandemic

Strengthening ex post controls during and after a pandemic is particularly important when ex ante and upstream controls are streamlined for rapid response. Countries should ensure that their SAIs have a clear mandate for auditing COVID-19 funds and undertake and publish these audits in a timely manner. To the extent possible, interim audits (in addition to the regular annual financial audits) should be encouraged. The successful audits done in Sierra Leone during the Ebola crisis and the COVID- 19 pandemic are good examples.

Conclusion

The lessons from COVID- 19 funds can help shape future emergency responses, whether to pandemics or natural disasters. When there is a strong need to coordinate activities across sectors, to bring together public and private resources, and to work around existing PFM weaknesses, there is a case for setting up a special fund outside the regular budget process. The potential risks, however, need to be carefully mitigated. This could be done by (1) setting up a sound legal framework that defines the mandate of the EBE, its governance structure, and its accounting and reporting requirements; (2) resourcing adequately the EBE with staff that have relevant finance skills and experience in managing complex organizations; and (3) enforcing higher- than- usual standards of transparency and external scrutiny (Rahim and others 2020).

The experience gained from countries’ use of COVID- 19 funds also sheds light on the reforms needed to strengthen budget and PFM systems. The proliferation of these funds indicates that PFM systems in many developing countries are not doing a good job in managing resources efficiently and nimbly. Lessons learned from the governance and transparency challenges experienced by the COVID- 19 funds, as described in this chapter, could be applied to strengthen core PFM systems in these countries.

Going forward, digital solutions have a role to play to ensure effective service delivery in normal times and in emergency situations. Such digital solutions include FMISs, the use of e- transactions and e- payments, fiscal transparency portals, and procurement platforms. Two IMF notes provide guidance on how PFM systems can leverage digital solutions to support emergency responses (see Una and others 2020a; 2020b). In some countries, the measures recommended in this chapter could be implemented relatively rapidly to streamline spending and control processes embedded in their information systems, enhance FMIS functionalities for cash management, and improve transparency of emergency responses through digital solutions. They should also be an integral part of PFM modernization programs in the future, a welcome if unexpected spinoff of the COVID-19 crisis.

In conclusion, while an EBE provides a solution to address the immediate needs of a national emergency such as the COVID- 19 pandemic, PFM systems need to be strengthened to improve service delivery in normal times and enable countries to respond quickly and effectively to future crises. Important safeguards should be put in place to minimize some of the risks inherent in establishing an EBE.

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1

Figures are derived from IMF (2018, p. 14).

2

This is further discussed in Barroy (2020) and Barroy and others (2020).

3

The term “extrabudgetary fund” is often used in the literature, but “EBE” is a broader and more appropriate concept because it includes the government agencies and entities used to manage emergency financing, as well as the accounts and funds set up for receiving revenue and making payments.

4

Mauritius’s COVID Solidarity Fund is relatively small. The majority of the pandemic spending in Mauritius is through the central government, special funds, or the Mauritius Investment Corporation, a special- purpose vehicle fully owned by the central bank.

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