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Compact Implementation Guidance

Policy on Program Closure

September 7, 2023


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Annex I: Outline of the Program Closure Plan (PCP)

Program Administration Closure

  1. Accountable Entity Status: Each Program Closure Plan must include a description of the post-Compact treatment of the Accountable Entity.
    If the Accountable Entity will be closed upon the Closure Date, the Program Closure Plan must include the following:
    1. Accountable Entity and other key personnel (per section 5.5):
      • A plan for release or termination of staff, including any financial obligations incurred by the Accountable Entity to affect the plan.
      • A plan for which staff will be retained for part or all the Closure Period, as well as a brief justification of why the selected staff are required for closure tasks. Include any special arrangements to retain key staff during the Closure Period. MCC may require modifications to existing staff contracts to include closeout related tasks to ensure payment for only those services/tasks that were completed.
    2. Asset Disposition: A brief description of the intended disposition of Fixed and Program Assets the Accountable Entity. This section should include the proposed timeline for asset disposition, to ensure adequate documentation of the process and timely disposition of assets. The description should include use of any third-party agents or Government entities to assist in the disposition of assets.
    3. Website: This section should describe how the Accountable Entity will ensure that the website will be publicly available for one year after the Compact End Date.
    4. Treatment of Sensitive Information: A brief description of how the Accountable Entity will ensure that reasonable steps to safeguard or remove sensitive data and information are taken for all relevant Program Assets prior to transfer, as specifically described in this policy.
    If the Accountable Entity will continue operations beyond the Closure Date through sources of funding other than MCC Funding (per section 5.5.1), the Program Closure Plan must include a description of the funding and proposed operations, as well as documentation supporting commitment of such other sources’ funding. The Program Closure Plan should also include any plans to use the Accountable Entity name and logo beyond the closure date.
  2. Project Closure: For each Project, the Program Closure Plan must include the following components:
    1. A brief description of the closure strategy for the Project. If applicable, the Program Closure Plan for the Project should include detail at the Activity and sub-activity level.
    2. Identification of completion risks and sustainability risks for the Project/Activity, including how the Accountable Entity plans to address these risks, and contingency plans for how to respond if these risks materialize. These risks should be presented by Sub activity, and by contract. An example of a completion risk includes: if construction of works does not begin by a certain date, the works will be terminated and appropriate stakeholders will be informed, or sources of funding other than MCC Funding have been mobilized to support any construction beyond the closure date, should the schedule experience any delays. Completion risks should be treated in detail, including a plan for how to monitor these risks during the last year of the Compact and the Closure Period. Sustainability risks should be addressed through the development of sustainability plans for major project activities. The PCP should outline when the plan will be completed, how it will be approved and implemented, and describe the mechanism for ongoing monitoring post-CED.
    3. Clear definition of standards for the taking over of works, and the institutional coordination required.
    4. Any environmental, social (including resettlement), health, safety, gender or inclusion risk mitigation or closure activities and how these will be managed during the last year of the Compact, the Closure Period, or beyond.
    5. Plans to manage contingency amounts for the Project/Activity through the last year of the Compact and the Closure Period (when contingency funds will be released, how those funds will be utilized, etc.).
    6. A brief description of the intended disposition of all forms of applicable Program Assets by Activity and asset category (e.g. equipment, vehicles, furniture). This section should include the proposed timeline for disposition of assets, to ensure adequate documentation of the process and timely disposition of assets. Disposition of Financial Assets as described in section and Guarantees and Retention Monies Securing Contractor Obligations as described in section are particularly complex issues and should be treated in detail in the Program Closure Plan.
    7. An inventory, description, and timeline for the closure and/or assignment of each contract, grant, and Implementing Entity Agreement related to the Project.
    8. For any works and/or DNPs continuing post-CED, a description of the plans newly assigned Owners will execute for oversight, including engagement with and management of the Engineer.
    9. Plans to hand over to MCC the project documentation necessary to complete post-compact monitoring and evaluation activities, the geo-coordinates of investment locations, engineering as-built drawings, final project status reports and final written deliverables from any Accountable Entity contractors, and final detailed costs of investments.
  3. Financial Management:
    1. Closure Budget. The Program Closure Plan should include a budget for the Closure Period, with a description of how the issues described in section 5.6 have been addressed, including any anticipated reallocation of funds.
    2. New commitments. This section should include a description of any commitments anticipated during the Closure Period, as well as plans for a contingency amount to cover unexpected Closure Expenses (if applicable).
    3. Taxes: This section should indicate how any outstanding (not yet reimbursed) tax amounts will be reimbursed by no later than 60 days after the Compact End Date (per section 5.10.7).
    4. Country Contributions. This section will include a report on the status of country contributions, with a description of any actions that may need to be taken to ensure that all contributions are received prior to Compact End Date.
  4. Procurement:
    1. The Program Closure Plan should include a template tracking tool to be approved as part of the PCP.
    2. This section shall include a deadline for all procurement actions to begin and that shall be at least 30 days before the Compact End Date.
    3. This section shall include a deadline for the publication of the Final Procurement Notice, a deadline to carry out Contractor Past Performance Evaluations (CPPRS) and a deadline to finalize the Final Procurement Performance Report (PPR).
  5. Grants:
    1. The Program Closure Plan should include a template for a grants tracking tool to be approved as part of the Program Closure Plan.
    2. The Program Closure Plan should include a deadline to receive all deliverables and a deadline by which any new grants are to be signed.
    3. This section should include the closure strategy for all grants.
  6. Monitoring and Evaluation:
    1. This section should provide a brief overview of the closure strategy for M&E disaggregated by Project and Activity as structured in the M&E plan. The closure strategy should: a) highlight any ongoing activities, such as data collection, evaluations, or other M&E-funded efforts that are at risk of not being completed by the Compact End Date; and b) include a description of all M&E activities that are planned to be conducted after the Compact End Date and before the Closure Date as agreed by MCC.
    2. This section should describe the data and documentation to be provided as electronic copies to MCC (or to the independent evaluator, where appropriate, according to MCC’s Transparent, Reproducible and Ethical Data and Documentation Guidelines (TREDD), including: (a) all MCC-funded survey data sets and supporting materials for all MCC-funded data collection, such as questionnaires or qualitative protocols, enumerator field guides, data entry manuals, data dictionaries, meta data and final reports; (b) other analyses, evaluations, data quality reviews and/or special studies that were funded out of the M&E budget within the Compact, and (c) supporting documentation not previously provided for data reported in the ITTs and for any new or updated data. This section should describe how all submissions will comply with MCC’s TREDD Guidelines
    3. This section will (a) identify designated representatives that will serve as the primary points of contact for any M&E-related obligations of the Government that extend beyond the Closure Date and indicate who will serve as the central point of contact; (b) identify the actions these representatives are required to take to fulfill the Government’s obligations, including whether a separate agreement with MCC must be established and by when; (c) detail the process and timeline for incorporating the Government’s post-Compact responsibilities into the M&E plan and getting signature of the Acknowledgement and Acceptance of the M&E plan; and (d) detail the process and timeline for submission of the final ITT no later than 70 days after the Compact End Date.
    4. If the individual serving in an M&E capacity will continue operations beyond the Closure Date through funding provided either by the Government or other sources, the Program Closure Plan should include a description and supporting documentation of the commitment from those funding sources. This section should similarly describe any other Government funding or in-kind support to be provided for post-Compact M&E and/or dissemination activities.
  7. Marking and Communications with Stakeholders: The Program Closure Plan should include a brief description of how the results of the Program will be communicated to stakeholders, including the board of the Accountable Entity, the Implementing Entities, the Accountable Entity personnel, Project stakeholder groups, contractors, and the public. This section should also address how the Accountable Entity will ensure compliance with the Standards for Global Marking as described in section 5.12.
  8. Legal Requirements: This section should describe any modifications to legal agreements that may be required to effectively execute the Program Closure Plan, following the review described in section 5.9.2.
  9. Ongoing Government Responsibilities: This section should identify the Principal Representative for the Government, if this will change during the Closure Period, and any Additional Representatives that will be the primary points of contact for any obligations of the Government that extend beyond the Compact End Date.
  10. Retention and Safekeeping of Records:
    1. This section should describe how the Accountable Entity will ensure that relevant records are provided to MCC, as necessary, prior to the Closure Date, and remain accessible beyond the Closure Date as required.
    2. This section should include an indicative list of the types of records, as well as a description of the process and timeline for finalizing these lists.


There may be many annexes associated with the Closure Plan. Examples include:

Legal Opinion: a draft opinion from legal counsel engaged by either the Accountable Entity or the Government confirming that the Program Closure Plan is in accordance with the provisions of the Compact and supplemental agreements and complies with applicable laws and regulations of the country.

Procurement/Contracts List and Procurement Tracking Tool: a comprehensive list of contracts and their characteristics used to close contracts and evaluate action steps to be taken.

Pro-forma Closure Budget: a budget specifically formulated to cover necessary closure expenses; it does not contain programmatic activities.

Sample forms, e.g. Asset Transfer Agreement forms: various forms which will be needed during closure activities.

ESP Closure Checklist: a tool to track environmental, health and safety and/or social hazards which require closure by CED.

Annex II: Guidance on Certain Compensation Arrangements

The goal of special compensation or other arrangements proposed to retain staff through the Compact End Date (referred to herein as “Retention Incentive Payments”) is to ensure that certain Accountable Entity staff members whose jobs are deemed critical to the smooth administrative closing of the Compact remain with the Accountable Entity as long as needed. Such payments represent an incentive to remain at the Accountable Entity until a date that is determined through developing the Program Closure Plan for each accountable entity.  Staffing planning is an important part of the program closure process. Each compact situation has unique issues related to staff employment and local labor laws. Notwithstanding these particulars as well as the need to respect the sensitivity of individual employment arrangements, it is critical that the formulation of accountable entity staffing during the program closure period is completed with the rest of the overall program closure planning process, with notification of staff as well as employment agreement amendments implemented as soon as possible after approval of the overall program closure plan.

To retain the critical staff through project conclusion, MCA will have a special program closure retention incentive payment for staff whose jobs are deemed critical to the smooth administrative closing of the Compact remain with the Accountable Entity as long as needed.

As part of the Program Closure Plan, each MCA must perform an assessment of the staffing needed to successfully and responsibly close the program. This assessment must be based on project work plans and the timing of closure tasks. The final assessment must be realistic and be intended to identify only those staff who must be retained until the Compact End Date or through some or all of the Closure Period to ensure a successful program closure, and who must be incentivized to remain because the real costs to the program of replacing them and/or training replacement staff outweigh the costs associated with the retention incentive payment. MCA staff of all pay bands are potentially eligible for a retention incentive payment but must meet both of these criteria per MCA’s assessment and MCC’s No Objection. This assessment must also identify the date through which the service of each employee is required (e.g. – Compact End Date, Compact End Date + 30 days, Closure Date, etc.).

If determined to be eligible through the staffing needs assessment the retention incentive payment is structured as a growing amount based upon time in service, but vesting only upon staff separation at the closing of the project at a rate of five percent of annual base salary as of CED per year of service. MCA staff who depart (either voluntarily or are removed from their position) prior to the date previously identified and approved as critical for them to remain employed by MCA are not eligible for any part of the planned retention incentive payment.

The maximum retention incentive payment, regardless of total MCA service, will be capped at twenty-five percent of annual base salary as of CED in total for those staff who serve a total of five years or more from start date to separation date at or after CED as defined by the Program Closure Plan. This structure differentiates the experience level of staff who joined later and, with an accruing benefit, creates a strong, yet variable retention incentive for the most experienced staff.

An individual who has been subject to any of the following disciplinary measures shall not be eligible for a retention incentive payment:

  • Suspension without pay for more than two working days;
  • Fine; or
  • Demotion.

Annex III: Outline of Records Retention

The purpose of this annex is to elaborate on section 5.11 regarding Government’s responsibility to store and safely maintain important Records for a period of five years after the Compact End Date. This annex provides an indicative list of the types of materials that should be maintained. The Accountable Entity’s Program Closure Plan must include a specific list of Records and the related storage arrangements for each.

Records Category Document Type
Accountable Entity Management and Administration Board materials and minutes
Governing Documents – legislation, relevant statues, regulatory notes, etc.
General correspondence (including all email of all Accountable Entity staff– see below)
Legal documents- court filings, correspondence related to contractor disputes, etc.
Conventions and agreements (IEAs, MOUs)
Audit reports and responses
Vehicle logs
Physical inventory reports
Human Resources List of all Accountable Entity staff from establishment, including names, positions, dates of employment, personal email addresses, and personal phone numbers
Staff employment contracts
Performance management system
Human resources manual
Training materials
Travel orders and trip reports
Financial Management Financial records
Fiscal agent records
Payment invoices
Interim payment certificates
Worksheets associated with calculation of advances, retentions, etc.
Bank statements
Fiscal agent periodic reports
Backup of accounting software
Fixed assets registers
Guarantees of all types (advance, performance, retention)
Asset Transfer Agreement forms
Transfer agreements
Titles (e.g. vehicles)
Tax exemption/refund documentation
Procurement Procurement agent files
Procurement plans/amendments and general procurement notices
Documents related to bid challenges and resolutions
Bid challenge system
Contracts and contract-related documents (amendments and modifications, cure and notification letters)
Contract closeout forms
Notifications to vendors
Procurement Operations Manual
Procurement Performance Reports
Project Management Contractor deliverables (studies, site reports, design documents, completion certificates and defects lists, etc.)
Geo-coordinates of investment locations
Engineering as-built drawings
Final detailed costs of investments
Work plans
Resettlement compensation documentation
Final Approved ESIA and any amendments
Final approved RAPs
Documents concerning serious health and safety incidents
Final records of livelihood restoration activities
Environmental audit reports
Grants Grant Operations Manual (GOM)
Grantee selection reports
Grant agreements and related documents (including modifications)
Requests for reconsideration and related documents
Monitoring and Evaluation Studies (including evaluations, program reviews, data quality reviews, and other analysis)
Indicator data and related documentation
Communications Communications materials (brochures, videos, etc.)
Workshop materials
Stakeholder committee meeting minutes
Documents related to media and public outreach
Website snapshot
Intellectual property
Copyrights and patents

Accountable Entities should also establish an indexing system for the records in sufficient detail that any given record could be located quickly from its storage area. Electronic records of any type (e.g., email correspondence) must also be stored or archived in a commonly used searchable format. More details on email retention are below.

Email Retention Guidance

Email Retention Each Accountable Entity should archive all emails during the life cycle of the Compact, and for a period of five years after the Compact End Date.All archived emails should be protected by encryption and password.
Access Control Restrictions to access emails should include a unique identification element (username) and a unique authentication element (password).Accounts holders should maintain their authentication element confidential and protected from unauthorized access.Electronic authentication elements should be encrypted using AES 256 encryption algorithm.
Encryption All emails retained in a removable storage device; for example, a USB flash drive or removable hard drive, must be encrypted using an encryption algorithm of AES 256, or stronger.Electronically stored passwords should be encrypted at rest with an encryption algorithm of AES 256, or stronger.
Passwords All passwords should be at least twelve characters and should utilize upper case, lower case characters, numbers, and special characters. Passwords should never be dictionary words in any language.
Email Archiving Procedures and Annual Testing The Accountable Entity should devise written archiving instructions. Archiving and retrieval should be tested annually. Testing should include all operational requirements to retrieve emails.
System Logging and Auditing All email access should be logged and audited. Logs should indicate the user accessing the email; the date and time of access; and the actions the user took (e.g., read, write, or delete). Audit logs should be protected from alteration.
Separation of Duties The Accountable Entity should separate duties of personnel that have the ability to make changes to the information technology system and personnel that oversee their security and auditing functions to reduce the risk of unauthorized system or data changes/alteration.

Annex IV

Download Annex IV: MCC Policy on Program Closure Ex-Ante Waiver Request Form

  • 1. This policy has been prepared based on the assumption that a procurement agent has been selected to perform all procurement activities of the Compact. In case the program does not include a procurement agent, all references to procurement agents must be substituted by the Accountable Entity procurement director or procurement unit, whichever is appropriate.

  • 2. In accordance with entitlements set forth in the Resettlement Action Plan and/or Livelihood Restoration Plan

  • 3. Punch list items may be completed after Compact End Date. However, new costs related to the remedy of punch list items, such as those associated with engineer oversight and verification of work, are not allowable.

  • 4. As defined in MCC’s Country Contributions Policy.

  • 5. In-kind contributions managed by the Government outside of the Accountable Entity are not eligible for reimbursement.

  • 6. Found at:

  • 7. This assumes a standard program, with 20 quarters. If a program is terminated early or, conversely is extended, references to “quarter 19” and “quarter 20” should be replaced with “the second to last program quarter” and “final program quarter,” respectively.

  • 8. The unique circumstances associated with each Compact – and each contract – may necessitate additional steps or requirements beyond those outlined in this section. In all circumstances, the new party to whom the contract is assigned must possess the requisite skillset to successfully administer the entire range of activities associated with the contract.