How to protect against school fee fraud?


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Keeping girls and young women in school not only makes them less vulnerable to HIV infection, it helps them grow into healthy, educated, financially autonomous citizens. With the Global Fund committing significant sums towards funding educational incentive programs, OIG Senior Investigator Mykola Martynov assesses how we can ensure funds reach their intended beneficiaries.


One of the Global Fund’s strategic objectives for 2017-2022 is to reduce HIV incidence among adolescent girls and young women. During 2016-2017, the Global Fund budgeted US$15 million to fund educational incentive programs in Tanzania, Malawi, Zambia, Haiti, Mozambique, and Uganda. The money is used to provide training to healthcare service providers, teachers and medical students; to cover school tuition fees and school materials for orphans and vulnerable children; and to provide meals, health care, books, equipment and accommodation.

Looking more widely, the Global Fund has allocated US$122 million to support interventions across 12 countries in Southern and East Africa which are geared towards reducing new HIV infections among adolescent girls and young women. This includes US$33 million allocated specifically for Social Protection Interventions covering

– Cash transfer programs

– Keeping girls in school through education subsidy

– Livelihood support and economic empowerment

The Global Fund’s Office of the Inspector General is always on the alert for allegations of fraud and abuse. While our investigations have found no major wrongdoing in connection with educational incentives, we were keen to learn how to prevent program weaknesses being potentially exploited. In February 2018 our team went to Zambia, where the Churches Health Association of Zambia (CHAZ), the country’s largest non-government health provider, runs a successful Adolescent Girls Accessing Prevention and Education (AGAPE) project in 16 secondary schools, aimed at empowering girls living in extremely poor households.

During our trip, we were able to talk to school management, staff involved in project implementation and beneficiaries, and to examine school records. Combining what we learnt in Zambia with what we know from our previous investigative work, we can identify the major fraudulent schemes associated with educational incentive programs, along with their root causes.

These schemes include:

‘Ghost’ students – when program beneficiary students can’t be physically verified, or there’s no documentary evidence to support their enrollment as students, despite grant funds being provided to schools to cover their tuition and school needs.

Non-eligible students receiving funds – when schools or implementers select ineligible beneficiaries (e.g. friends, relations, school administrative staff) to receive program-funded scholarships. As well as being fraudulent, this prevents genuine beneficiaries from receiving support, hurting our grants’ impact.

Double-billing – when schools receive funding for scholarships, tuition fees or other school-related expenditures, and additionally collect funds for the same purpose from the beneficiaries. We have seen cases of schools soliciting funds from various donors for the same students, obviously without telling the donors or beneficiaries.

Overcharging – when schools charge the Global Fund fees for beneficiary students that are higher than the fees paid by regular students. Schools may also overcharge students and implementers for items such as uniforms or stationery.


These schemes are possible for a variety of reasons:

– Inadequate or inconsistent guidance – when educational programs are launched without clarifying expectations for scholarship provisions, e.g. program duration, the number of eligible students and the duration of their eligibility, the components of fees to be paid through grant funds.

– Delayed disbursements of grant funds – if implementers launch a program before they receive funding, they cannot perform the necessary checks. This can also lead to schools asking scholarship-eligible students to pay fees themselves, which may not be reimbursed once the grant funds become available.

– Poor program design – Students may be required to pay school examination fees at the beginning of the school year while implementers have budgeted to disburse them to schools later in the year. Or various implementers, using different accounting approaches or incompatible tools, may work on the same program. Or insufficient resources may be allocated to monitoring program delivery, facilitating the enrollment of fraudulent or ineligible students.

– Vague eligibility criteria – beneficiaries may only be asked to provide self-produced eligibility applications, rather than needing to provide third party supporting documents or verification.

– Lack of transparency – when school fee structures are not clear, students may be unaware of all program benefits and end up paying for components which are supposed to be covered by grant funds.

– Improper procurement – rather than supplying schools with program materials and supplies, schools may be given money to buy them themselves, creating the risk of overpricing and collusion between suppliers and school administrations.


How can we stop wrongdoing before it happens? CHAZ does a number of things well in its AGAPE project and these could all usefully be adopted by other implementers of educational incentive programs:

Thorough, wide-ranging initial guidance and training

CHAZ has designed comprehensive Orphans and Vulnerable Children guidelines that detail the processes of pupil selection and validation, Monitoring and Evaluation, financial oversight and potential fiduciary risks. A CHAZ team conducts an introductory mission to each school and trains school staff on project implementation, as well as organizing a meeting with school, parent and pupil representatives to introduce the project and to communicate details of the scholarship and its components.

Transparent criteria for selecting beneficiaries

CHAZ has designed clear eligibility criteria and selection guidelines. These require schools to document the process of candidate evaluation, which becomes a part of the pupil’s file. The guidelines stipulate that school staff, pupils and community representatives must be included as members of the beneficiary selection committee. Prospective beneficiaries must provide third party supporting documents, such as a letter from their church, alongside their scholarship application.

Good communication

During the initial program introduction, CHAZ teams provide guidance to school staff, emphasizing the need for strict project accountability, and setting the right “Tone from the Top”. CHAZ supplies schools with portable electronic devices (tablets) to monitor beneficiaries in real time. CHAZ uses an AGAPE WhatsApp group to provide schools with regular updates and to encourage teachers to share ideas and practices.

Regular monitoring of program implementation

To avoid possible funding stream duplication, CHAZ conducts detailed checks on the school fees paid by newly enrolled AGAPE project pupils, documenting the findings. CHAZ also conducts regular Monitoring and Evaluation visits to schools. The CHAZ teams, which include both programmatic and financial specialists, collect original copies of school and exam fees payment slips, and stipend acquittal sheets. The fee structure in each school is checked to make sure that the AGAPE project pupils are being charged appropriately. As well as reviewing beneficiaries’ files and school records, CHAZ teams interview pupils, to make sure they are receiving the services they are supposed to, and to capture any complaints.


Educational incentive programs are a critical component in the fight against AIDS, malaria and tuberculosis. Investing effort into safeguarding these programs against wrongdoing is well worth it!