How Many Foreign NGOs Are Subject to the Expanded Mexico City Policy?


Using data obtained from USAID,1 we identified NGO prime recipients of U.S. global health assistance in the most recent three-year period for which such data were available (FY 2013 – FY 2015).2 We categorized them into U.S. and foreign3 NGOs. We included bilateral global health funding obligated by USAID (including funding that had been transferred to USAID from the Department of State) through grants, cooperative agreements, and contracts. We then analyzed data from to identify NGO sub-recipients of the top NGO prime recipients of U.S. global health assistance over the same period. This allowed us to create a database of foreign NGOs that would have been subject to the expanded MCP if the policy had been in effect during that three-year period, as well as U.S. NGOs that would have been required to ensure that their foreign NGO sub-recipients were in compliance. We also quantified the effect of expanding the policy beyond its prior conditions on the number of affected NGOs.

Our findings should be considered a minimum estimate since we only looked at sub-recipients of the top prime recipients of funding (and not all prime recipients report sub-recipient data).4 In addition, we did not include NGOs that received global health funding transferred from State or other agencies to the Department of Health and Human Services in this analysis (although such funding is subject to the policy).

Funding totals shown in this report represent net obligations. We only included funding subject to the policy and for health activities in program areas subject to the policy.5 Funding that is exempted from the policy (e.g., funding provided to international organizations, such as the Global Fund to Fight AIDS, Tuberculosis and Malaria, certain water and sanitation activities, the American Schools and Hospitals Abroad (ASHA) program, the Food for Peace (FFP) program, and humanitarian assistance) was not included. The exceptions were funding provided to entities that are government-run hospitals6 and entities that qualify for a “commercial exemption”7 under the current policy.

For prime recipients, we used information in the data on health program area, responsible office, and activity descriptions to identify funding amounts subject to the policy, which was available for most but not all recipients. For sub-recipients, we used information in the data on the funded agreement and activity, as well as related additional research, to identify funding amounts subject to the policy. The funded agreement must have been included in and identified as “health,” at least in part, in the prime recipient data for the funding to have been considered subject to the policy at the sub-recipient level.

NGOs are defined by USAID as “any non-governmental organization or entity, whether non-profit or profit-making, receiving or providing USAID-funded assistance under an assistance instrument or contract.”8 This includes institutions of higher education,9 hospitals, non-profit non-governmental organizations, and commercial organizations.10,11 For prime recipients, we used information in the data on organization type and country of origin to assign organizations into these categories; where information was not available, we did additional research. For sub-recipients, we conducted additional research to categorize organizations as NGOs and used information in the data on country of origin to assign them to the U.S. or foreign category.

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