POLICY AND PRACTICE ISSUES FOR REFORM

This brief is an outcome of a year-long participatory research and advocacy project conducted by the Centre for Policy Analysis (CEPA), with support from the Uganda Governance, Accountability, Participation and Performance (GAPP) program funded by USAID and DFID.

The research analyzed the obstacles that undermine the effective and timely consideration of the Office of the Auditor General (OAG) reports by the Public Accounts Committee (PAC), the Local Government Accounts Committee (LGAC), and the Committee on Statutory Authorities and State Enterprises (COSASE); and propose reforms to address the gaps identified.

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EXECUTIVE SUMMARY

This brief is an outcome of a year-long participatory research and advocacy project conducted by the Centre for Policy Analysis (CEPA), with support from the Uganda Governance, Accountability, Participation and Performance (GAPP) program funded by USAID and DFID. The research analyzed the obstacles that undermine the effective and timely consideration of the Office of the Auditor General (OAG) reports by the Public Accounts Committee (PAC), the Local Government Accounts Committee (LGAC), and the Committee on Statutory Authorities and State Enterprises (COSASE); and propose reforms to address the gaps identified. This process culminated in the 2014 CEPA report Strengthening the Oversight Function of Parliament: An Assessment of Accountability Committees.

The methodology used in conducting the research included in-depth interviews with over 40 key stakeholders, including the Speaker of Parliament and her deputy, committee chairpersons, selected committee members, committee technical staff, Parliamentary administrative staff and OAG liaison officers to Parliament. This was complemented with the review of secondary literature and analysis of committee proceedings and reports produced to establish the timeliness of consideration, debate and adoption of reports by Parliament.

The report’s findings revealed a number of major obstacles including: a heavy backlog in the three accountability committees that review the OAG reports, due to slow consideration and production of the reports, which delays debate and adoption among other administrative and political challenges. CEPA spearheaded advocacy initiatives with accountability cycle stakeholders including

Parliament, OAG, the Ministry of Finance and the Ministry of Local Government. At these meetings, CEPA proposed the identified policy issues for reform necessary for improving the oversight function of Parliament and the timely consideration of the OAG reports by the accountability committees are adopted and implemented.

This brief highlights key emerging reform issues around which there has been wide stakeholder consensus, and those that have not been fully explored by the stakeholders that can improve Parliament’s oversight.

The proposed reforms covers both the practices and policies that, if adopted by the Parliament, will improve the timely consideration of the OAG reports and have Parliament meet its constitutional mandate of considering and adopting the OAG reports within six months. This will allow the stakeholders on accountability issues, especially the Secretary to Treasury, the DPP, the IGG, and the Police to deal with corruption issues in a timely manner, hence improving accountability and service delivery.

The reforms would also assist Parliament to reduce the endemic backlog in accountability committees. For example, the report recommends that reports in all the accountability committees be combined and the resulting omnibus report be presented on the floor of Parliament. This will allow the accountability committees to allocate more time to the current reports of the OAG.

CEPA will continue to engage with and encourage all relevant stakeholders, especially the OAG, MoFPED and Parliament, to adopt and implement all the proposed reforms.

INTRODUCTION

The three accountability committees in Parliament that review the annual OAG reports (PAC, LGAC and COSASE) have made significant contributions to the accountability sector in Uganda through their high profile public hearing sessions that have brought to light a number of financial mismanagement cases such as those within the Office of the Prime Minister and the pension sector.

This brief has been developed to document the process and status of policy reforms in Parliament towards strengthening the institution’s oversight role. Having held a number of advocacy meetings with key stake holders, this brief documents key recommendations made by CEPA that have been adopted and how they have improved practices of the accountability committees. Adopting the report’s recommendation, PAC presented a report to the house based on the opinion of the AG for the FY2013 within one year, which has been difficult since 2009.

The pre meetings preparations have also allowed the PAC committee to spend and organize their hearings with the Accounting officers more efficiently. Given the success of proposals already adopted, therefore, other similar reforms could likely help address the remaining obstacles in order to improve the oversight function of Parliament.

The report lays out 14 areas necessary for reforms that are broadly categorised into two broad categories: practice and policy. While there are reforms that only require changes in practice and mode of operation of the committees, there is a second category of reforms that require changes to either the rules of procedure of Parliament, policies or laws of Uganda

CHAPTER 1: PRACTICE ISSUES REQUIRING A CHANGE IN ACCOUNTABILITY COMMITTEES

1. (A) PRACTICE ISSUES REQUIRING A CHANGE IN ACCOUNTABILITY COMMITTEE

ISSUE 1: BACKLOG OF OUTSTANDING OAG REPORTS IN PARLIAMENT

One of the major challenges the accountability committees face is the delay in consideration of reports the Auditor General presents. This has resulted in a backlog of outstanding reports.

Parliament is yet to debate and adopt any annual OAG report on Central Government or Local Governments since the reports from the 2004/5 Fiscal Year. This means that no Treasury Memoranda have been issued on annual reports since the ones corresponding to the 2004/5 Fiscal Year reports.

Instead, they have adopted Special Investigation Reports and two LGAC reports; 2008/9 that covers 36 districts and 2009/10 that covers 41 districts, as well as the Treasury Memoranda for the two reports.

At the level of producing reports, PAC has not produced final reports on the Auditor General’s annual reports from the FY 2008/9 to 2011/12, but has produced the reports based on the opinion of the AG for the FY 2012/13 (Disclaimer and Unqualified). The LGAC has not produced a final report on any year since their partial report for the FYs 2008/9 and 2009/10.

Suggested Solution

  • Develop consensus on considering current reports first, then considering previous

years’ reports through an omnibus report (not year by year) to clear all backlog without sacrificing the prompt consideration of current reports.

  • Scale back the extent to which LGAC hears AG reports on LGs from scratch considering that the District Local Government Accounts Committees (DPACs) are mandated by the LGA and Parliamentary rules of procedure to hear those reports initially.
  • Set up a separate committee to address Value for Money Audit reports, to scale down the work of accountability committees. This will ensure that VfM Audit reports are considered expeditiously.

Benefits and Justification

An omnibus report will enable Parliament to clear the backlog and allow Parliament to handle the current issues, rather than looking at queries that were raised 10 years ago and are no longer relevant. Reviewing the DPACs reports will enable Parliament to reduce the workload, and will be in line with the Local Government Act 1997 and the Parliamentary Rules of Procedure.

A separate committee to handle the VfM reports will reduce the backlog in the committees and also allow the committee to give the VfM the audience it requires since the nature of the VfM report is different from that of the Financial Audits. VfM reports are comprehensive researched reports which require the committees to handle them according to how they are presented to Parliament.

ISSUE 2: PARLIAMENTARY PROCEDURES FOR HEARINGS AND REPORT WRITING

There are a number of gaps in the way accountability meetings are organized. Their agenda and structure for meetings are inadequate, meaning that timing and organizing meetings is difficult. Sometimes, there are no briefs prepared; such briefs could be helpful in determining a short list of outstanding items to be discussed and how they would be discussed. Also, there is no established procedure for report writing, meaning that in many cases the accountability committee reports just mirror the AG’s reports, rather than summarizing the report and focusing on outstanding questions.

Suggested Solution

Promote the input of the technical staff in ways that can simplify the committee’s consideration of the complicated financial management issues such as:

  • The pre meetings preparations be made mandatory for committees
  • Establishing a procedure/ report writing manuals for the accountability committees.
  • Preparation of briefs / summarization of key issues in the AG’s reports Benefits and Justification Pre meeting preparations will allow committees consider the key outstanding issues.

Benefits and Justification

Pre meeting preparations will allow committees consider the key outstanding issues. The report writing manuals will make the committee’s reports more precise, user friendly and easily accessible in plenary as opposed to being mirror images of the AG’s report

ISSUE 3: INEFFICIENT METHODS OF WORK

One of the crucial factors identified as causing delays in consideration of AG’s reports was the method of work of the committees.

MPs are frequently unprepared for committee meetings, and the committee often proceeds without a clear strategy for how to address issues raised in the AG’s report. The audit report conducted by CEPA in 2014 found out that committees spent excessive time discussing each query raised in the AG’s report, including those that had already been resolved by the AG. Similarly, MPs tend to raise policy issues such as levels of funding, incomplete staffing, and other issues that are outside the scope of assessing the efficacy of policy implementation.

Suggested Solutions

Develop a handbook for accountability committees to guide them on how to review the OAG reports more efficiently. This handbook should address issues like; focusing on outstanding issues rather than considering every query, limiting the number of witnesses heard to a small sample of potential witnesses, and restricting the committee business to the consideration of the AG reports and producing the accountability reports basing on the opinion of the Auditor General. This handbook should also clearly state the stages where technical staff input is needed to support committee work.

Benefits and Justification

The suggested solutions will help committees consider the AG reports in timely manner through increased technical input and concise guidance laid out in the Handbook. This will also allow the committees to handle queries when they are well informed and use less time, since they will not have to go through all the queries.

ISSUE 4: LGAC HOLDING MEETINGS IN DISTRICTS PRESENTS LOGISTICAL CHALLENGES.

The question of logistics is particularly important for the LGAC, which carries out its hearings in districts. LGAC frequently faces challenges in arranging travel, because its members have scheduling conflicts with Parliament plenary sessions when they are supposed to travel to districts for hearings. Further on, Officials may often not be available on the days when the Committee is scheduled to travel to the districts.

Suggested Solution

Scale back the extent to which LGAC hears AG reports on local governments from scratch since the vast number of local governments renders this process unsustainable. Instead LGAC should hear only a small sample of AG’s reports, including ones that contain outstanding issues after the DPACs have finished their consideration in accordance with rule 170 of the Parliamentary rules of Procedures and Local Government Act 1997.

Benefits and Justification

This practice will be in accordance with the Laws governing the Local Government Act and it will reduce the backlog in the LGAC committee, because the committee will be looking at the report of the GPACs and the AG reports. They will have to conduct hearings at the district level for only the matters/queries that were not resolved by the GPACs.

Public Accounts Committee (PAC) meeting with the Kampala City Council Authority (KCCA)

Public Accounts Committee (PAC) meeting with Kampala City Coucil Authority (KCCA)

ISSUE 5: NO FIXED SCHEDULE FOR CONSIDERING ACCOUNTABILITY COMMITTEE REPORTS

The lack of a guaranteed scheduled time to consider accountability committee reports on the Parliamentary calendar also contributes to low priority status for the accountability committee reports, especially compared to other parts of the budgeting process.

This is not helped by the infrequent meetings of the business committee that leaves little opportunity for committee chairpersons to lobby for the inclusion of their reports in the business to follow and the order paper.

Suggested Solution

  • Include the constitutionally allocated time, which is six months after being tabled by the AG, for considering OAG reports in the official parliamentary calendar, as is done for other parts of the budget process. This would provide for a fixed window of time in which accountability committee reports will be tabled, debated and adopted.
  • Hold quarterly meetings of the Business Committee to ensure that accountability committee reports receive their due consideration in the plenary. Also ensure that any outstanding accountability committee reports, which have been tabled but not debated, are saved as parliamentary business to be considered in the subsequent Parliament.
  • Reorganize the schedule of plenary sessions to allow more time for debate of reports, including accountability committee reports.

Benefits and Justification

Specific deadlines will act as motivation to complete consideration of the OAG reports. This will institute a higher standard than the general provision of the Rules that they are required to report to the House twice a year. E.g Rule 170 (2) for the Local Government Accounts committee and Rule 169(2) for COSASE.

The quarterly Business Committee meetings will help put pressure on members of the committees to make sure they finish the work within the time provided for by Article 163(5) of the Constitution of the Republic of Uganda which is to the effect that “Parliament shall, within six months after the submission of the report referred to in clause (4) of this article, debate and consider the report and take appropriate action.”

ISSUE 6: WORK NOT CARRIED OVER FROM ONE LEADERSHIP OF THE COMMITTEE TO THE NEXT

What work is done or prioritised in the committee is largely left to the discretion of the chairperson of that committee, which affects continuity in instances where the new leadership doesn’t follow up on business conducted under the previous chairperson. In the long run this has affected the output of the committees and the follow up of the accountability cycle.

For example, the LGAC under Chairperson Hon. Ekanya presented one report (for 2000-2001) and left four draft reports (for the years 2001/2, 2002/3, 2003/4, and 2004/5). The LGAC under Chairperson Hon. Katuntu presented Ekanya’s draft reports and also left five reports in draft form, including the years 2005/6-2007/8; the Special Audit Report on Lands (KCC), and the Special Audit on Markets for Kawempe Division. The LGAC under Chairperson Hon. Jack Sabiiti did not table Chairperson Hon. Abdu Katuntu’s draft reports, but presented the reports for 36 and 41 districts for the years 2008/9 and 2009/10. Therefore, since FY 2004/05 the LGAC has not laid any other annual report.

Suggested Solution

Put in place a proper handover process by designating a set date for this so that the new composition of committees can take over unfinished work.

Benefits and Justification

The proper handover will help the institution bridge the output gap and have the accountability cycle continued and completed. This will result in new chairpersons taking on leadership with clear targets and objectives with regard to order of business,

1. (B) OTHER PRACTICES FOR ACCOUNTABILITY COMMITTEES

ISSUE 9: SUBCOMMITTEE TO REVIEW THE RESPONSES OF THE ACCOUNTING OFFICERS

Procedurally when the committee receives the AG report, the secretariat schedules meeting for the MDAs they intend to meet in a specified period, the secretariat then sends letters of notice of the public meeting to the MDAs they have scheduled to meet. In addition, each MDA is required to submit responses to the queries raised in the AG to the committee before the Public hearing. Often times the accounting officers submit their responses late, and sometimes the committees go through the responses in the public hearing and this makes the committee spend more time looking through the queries and responses.

Suggested Solution

The secretariat should write letters to all Accounting Officers to send their responses two weeks before the public hearings. The accountability committees then constitute subcommittees to look through all the responses from the accounting officers and report to the main committee on MDAs, Districts and statutory entities with satisfactory responses on the queries be dropped and those with unsatisfactory responses be called to appear before the committees for public hearings.

Benefits and Justification

This will allow the accountability committees to save time since they will only be meeting a few accounting officers with issues that require further investigations. It will also allow the secretariat to prepare their report in time. The committees will also meet their constitutional mandate of considering the AG’s reports in six months

ISSUE 7: NEED FOR MORE TECHNICAL SUPPORT FOR COMMITTEES

While committees have research and legal personnel, most of the day-to-day technical work is the responsibility of the clerk to the committee. This tends to affect the speed of production of committee reports.

Suggested Solution

The Parliamentary staff structure should be adjusted to provide for two clerks for Accountability Committees so as to ensure efficient completion of reports. Benefits and Justification This will reduce the workload of technical staff in the committees.

Benefits and Justification

This will reduce the workload of technical staff in the committees.

ISSUE 8: INADEQUATE CAPACITY OF COMMITTEE MEMBERS TO HANDLE ACCOUNTABILITY ISSUES

The capacity of some MPs to address accountability issues requires enhancement. There is a tendency to appoint chairpersons and vice chairpersons to committees by political parties based on loyalty, regional balance or other criteria—with no consideration on their capability to effectively interrogate and efficiently handle the technical issues required of them during hearings.

Suggested Solution

Provide capacity building through mentoring on the job. There is need for training and guidance to technical staff and committee members to increase their expertise on financial management issues, to ease their speedy consideration of reports. There is evidence that Parliament receives lots of training, even of the same type, and hence, linkage between training and adaptation should be ensured. However, mentoring has been seen to bring results, as seen in PAC through recent proposals and mentorships by CEPA.

Benefits and Justification

The training will help any member who becomes a leader of the committee to handle the issues objectively with or without an accounting background.

ISSUE 10: PUBLICATION/ ANNOUNCEMENT OF THE PUBLIC HEARING DATES

The accountability committees meetings/ Public hearings are open to the public, but only those aware of them show up for the meetings. The secretariat only informs the accounting officers on the dates they are scheduled to appear before the committee. This leaves out most stakeholders who would be interested in the committee proceedings.

Suggested Solution

After the submission of a sub-committee report to the main committee, the committee should identify the accounting officers that have to appear for the public hearing and writes to them. The press release includes the dates that MDA will appear before the committee and where the public hearing will take place. This should by both print and electronic media to allow the message reach most of the stakeholders.

Benefits and Justification

This will allow the public/ stakeholders be part of the proceedings and understand the contribution of the accountability committees of Parliament in the fight against corruption.

CHAPTER 2: POLICY ISSUES REQUIRING A CHANGE IN THE RULES OF PROCEDURE, POLICIES OR LAWS

ISSUE 11: SLOW CONSIDERATION OF AG’S REPORTS AND PRODUCTION OF REPORTS BY ACCOUNTABILITY COMMITTEES

The slow consideration of the AG reports by accountability committees leads to significant delays in the production of committee reports. This in turn affects the implementation of recommendations made by the Executive, because often times the recommendations come out many years after the responsible Accounting Officers have moved from their posts. Or the the Executive has more current issues to follow up, and lets these recommendations pass without taking any action. In some cases, recommendations are over taken by events and yet the committee continues to uses logistics/resources while considering the OAG report, therefore wasting resources. For instance, the COSASE report on the Uganda Revenue Authority, had most of recommendations over taken by events, and the report was not adopted by the House.

Suggested solutions

Amend the Rules of Procedure to include the fixed time frame of 6 months for consideration, presentation, debate and adoption of the AG’s report by Parliament as provided for by Article 163(5) of the Constitution of the Republic of Uganda.

Suggested Amendment

The Rules of Procedure be amended to include the 6 months’ time frame as provided by the Constitution.

Recommendation; Amend Rule 162(3) from “The Chairperson of the Public Accounts Committee shall, upon receipt of the Auditor General’s report under sub rule (2), lay the report on the Table for purposes of debate by House under clause (5) of Article 163 of the Constitution.” To read “the Chairperson of the Public Accounts Committee shall within six months, upon receipt of the Auditor General’s report under sub rule (2), lay the report on the Table for purposes of debate by House under clause (5) of Article 163 of the Constitution.”

The same should apply for LGAC and COSASE

  • The Rules be amended to cite the Handbook for Accountability committees issued by the office of the Clerk to Parliament.

Benefits and Justification

The inclusion of the 6 months in the Rules will remind Members of their constitutional mandate to consider debate and adopt the AG’s reports in the specified time. The Handbook will help members to consider the AG’s reports in a timely manner since it will show how to handle queries and report writing

ISSUE 13: CONFLICTING AND INADEQUATE REGULATION OF THE TREASURY MEMORANDUM

At the very final stage of the accountability process, is the return of the Treasury Memoranda to the House. There have been a number of Treasury Memoranda presented in the House (Treasury Memorandum for the year ended 30th June 2000 and Treasury Memorandum for the year ended 30th June 2001 for PAC) on 1st April 2008, (Treasury Memoranda for the Financial Year ended June 30th 2002, 30th June 2003 and 30th June 2005 for PAC), (Treasury Memoranda for the Financial Year ended June 30th 2002, 30th June 2003, 30th June 2004 and 30th June 2005, 30th June 2009 and 30th June 2010 for LGAC) on 5th July 2011 and 30th April 2015 respectively and were referred to their respective committees to study and help the House debate.

The major obstacle in the final stage of the accountability cycle is whether the Treasury memoranda are to be audited by the AG and then the committee; or should the committee scrutinize the Treasury memoranda before the AG? Does PAC follows up on the audit of the Treasury memoranda? Secondly, whether the plenary finds time to consider what the AG and PAC/LGAC have discovered regarding the response is still unclear.

Suggested Solution

Parliament should pass a law that puts the Treasury Memoranda in place, plus gives a time line to the Minister of Finance to ensure that the Treasury Memoranda are produced, a timeline for the consideration of the Memoranda by the Auditor General, and a timeline for the accountability committees to consider the already audited Memoranda by the AG, in order for the accountability cycle to have a clear definition of the time spent by the respective parties.

* Section 53 of the Public Finance Management Act 2015 provides for the Treasury Memoranda and the timeframe of 6 months from the date Parliament sends their report to the Ministry. This is inconsistent with S.13 (11) (b), which requires that a TM be presented by 1st April when the next budget is being presented to Parliament. Amendments are needed to harmonise the Public Finance Management Act and the National Audit Act?

Suggested Amendment

  • Amend the Rules of Procedure by introducing a specific rule that provides for referral of the Treasury Memorandum laid on Table by the Minister of Finance to the Auditor General for audit. Also explain clearly the procedure of the accountability cycle—with the Treasury Memoranda being referred to the AG as provided for by the National Audit Act 2008 section 13(1)(f) ‘audit the treasury memoranda’ as one the functions of the Auditor General.
  •  The consideration of the audited Treasury Memoranda by the accountability committees and the final stage of the audit cycle.
  • Amend the National Audit Act 2008 by inserting a new clause that will provide for the time frame for the Auditor General to Audit the Treasury Memoranda from the date of submission to Parliament by the Ministry of Finance in accordance with section 53 of the Public Finance Management Act 2015.

Benefits and Justification

This would ensure that the accountability cycle is concluded and make the committee reports more relevant. It will also lead to improving the financial management of public expenditure, reducing corruption and improving accountability.

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Public Account Committee (PAC) meets Minister of Karamoja Affairs, Hon. Janet Museveni over misappropriation of funds in the Office of the Prime Minister

ISSUE 12: LACK OF A CLEAR TIMELINE FOR THE DPAC TO CONSIDER THE REPORTS OF THE AG AND THE MINISTER OF LOCAL GOVERNMENT LAYING THEM IN PARLIAMENT

The Local Government Act 1997 requires the local government public accounts committees to submit their reports to councils, and for the Minister responsible for local governments to lay the reports before Parliament. The Rules of procedure further mandate the Parliamentary Local Government Accounts Committee, after consideration of the AG’s report and the reports laid before Parliament, to lay their report on Table of the House under clause (5) of Article 163 of the Constitution.

Lack of a clear timeline for the DPACs to consider the report of the AG has resulted into reports not being submitted. As a result, LGAC has taken the DPAC work on considering the AG reports, hence going against the laws in place that governs the accountability cycle and also increasing the backlog in the accountability committee of Parliament.

Suggested Solution

The six months period stipulated for Parliament to consider the AG report should be divided to have 4 months for the DPACs to consider the AG’s reports, 2 months for Parliament to look through the DPACs and the AG reports as provided for by the Rules of Procedure and report to Parliament by amending the Local Government Act 1997 and the Rules of Procedure to include the timeline.

  • Section 88(8), which provides for the local government public accounts committee to submit its report to the council and to the Minister responsible for local governments, who shall lay the report before Parliament, should be amended to read; “The local government public accounts committee shall, in four months after receiving the Auditor General’s report, submit its report to the council and to the Minister responsible for local governments who shall lay the report before Parliament.”

Rule 170(4), which provides that the Chairperson of the committee on Local Government Accounts shall, after consideration of the AG’s report and the reports laid before Parliament under subsection (2) lay the report on the Table of the House under clause (5) of article 163 of the Constitution should be amended to read; “The Chairperson of the committee on Local Government Accounts shall, in two months, consider the AG’s report and the reports laid before Parliament under subsection (2), and lay their report on the Table of the House under clause (5) of article 163 of the Constitution”

Benefits and Justification:

This would ensure that the accountability cycle is concluded within the time provided for by the Constitution and all stakeholders will know exactly what they are required to do within a specific timeframe.

ISSUE 14: REPORTS NOT CARRIED OVER FROM ONE PARLIAMENT TO ANOTHER.

Some business that is still pending is not carried over from one Parliament to another. In the 8th Parliament, several annual reports were tabled by the Chairperson of PAC on the last day of Parliament. There was no resolution of Parliament to carry these reports over into the 9th Parliament, and to date Parliament has not considered these tabled reports, meaning that the PAC reports from the 2006-2009 Fiscal Year reports have not been debated or adopted by Parliament.

Suggested Solution

Ensure that any outstanding accountability committee reports, which have been tabled but not debated, are saved as Parliamentary business to be considered in the next Parliament. This should be included in the Rules of Procedure.

Suggested Amendment

Amend the current /future Parliamentary Rules of Procedure to include a provision for saving the work lapsed in one Parliament for both Plenary and Committees.

Benefits and Justification

Saving all the Business lapsed rather than Bills only will help Parliament keep track of business. It will ensure that the accountability cycle will not be affected by the lapse of one Parliament, since it is the same institution with the constitutional mandate to consider the business

CONCLUSION

The work of CEPA as supported by GAPP has been fundamental in identifying the primary challenges that undermine the effectiveness of parliament especially in its mandate to consider debate and adopt the report of the AG.

The recommendations in the report if adopted will continue to improve the performance of parliamentary accountability committees for effective oversight and better service delivery. More targeted engagements with parliament and other key stakeholders will be necessary to ensure the adoption and implementation of all the highlighted recommendations.

This study is made possible by the support of the United States Agency for International Development (USAID) and the UK Department for International Development (DFID) through the Governance, Accountability, Participation and Performance (GAPP) Program contract. The contents of this study are the sole responsibility of Centre for Policy Analysis and do not necessarily reflect the views of USAID, DFID and or the Government of Uganda.