Attachment J.1 - Market Systems & Partnerships SOO .pdf

SECTION J.1 – STATEMENT OF OBJECTIVES (SOO) FOR FEED THE FUTURE MARKET

SYSTEMS & PARTNERSHIPS (MSP) PROCUREMENT

1. INTRODUCTION

The Feed The Future Market Systems & Partnerships (MSP) activity is designed by USAID’s Bureau for

Food Security (BFS) to provide USAID/Washington, USAID Missions, and other U.S Government

(USG) operating units and their implementing partners, international and local, with the evidence, capacity, tools, technical assistance, and/or services required to design, implement, monitor, and/or evaluate market systems and private sector engagement activities that lead to inclusive and resilient agricultural-led economic growth, improved food security and nutrition, and/or increased incomes for the poor. MSP seeks to improve the effectiveness of Feed the Future, USAID, and other USG programs, leading to sustained development outcomes at scale. MSP activities shall support the Feed the Future initiative in alignment with the U.S Government Global Food Security Strategy (GFSS) and the USAID

Private Sector Engagement Policy

Feed the Future is the U.S. Government’s global hunger and food security initiative. This interagency initiative is guided by the GFSS, led by the USAID Bureau for Food Security, and backed by the efforts of eleven (11) U.S. departments and agencies, partner governments around the world, global organizations and leading American businesses, non-profits, universities and research institutions. Feed the Future’s programming is targeted in twelve (12) focus countries but includes efforts in many other countries.

The Bureau for Food Security (BFS) is one of USAID’s technical pillar bureaus, based in Washington, D.C, with approximately 160 staff. BFS leads the implementation of Feed the Future. Although BFS and

Feed the Future are not the same entity, the vast majority of BFS-funded programming falls under the heading of Feed the Future.

2. BACKGROUND

Technical and Strategic Context

Through its leadership of the U.S. Government's Feed the Future initiative, BFS strives to reduce poverty, fight hunger, increase smallholder incomes, and improve nutrition through a portfolio of activities that accelerates responsible private investment, improves access to finance, enhances risk management, builds the capacity of smallholder producers and agribusinesses, strengthens the business environment for making investments, and explores constraints and opportunities to making the agriculture market system more competitive, inclusive, and resilient. BFS recognizes that inclusive and resilient ag-led growth must be advanced via multiple pathways. This includes through explicitly targeting the poor and otherwise marginalized groups to engage in markets as well as through activities that, by working at a higher level of business or markets, create indirect opportunities for the poor.

USAID has a long history of private sector engagement and working through partnerships and more recently has adopted the market systems approach as an evolution of learning from the value chain

USAID Food Security Strategy: https://www.usaid.gov/what-we-do/agriculture-and-food-security/us-government-global-food-security-strategy PSE: https://www.usaid.gov/work-usaid/private-sector-engagement/policy https://www.usaid.gov/what-we-do/agriculture-and-food-security/us-government-global-food-security-strategy https://www.usaid.gov/what-we-do/agriculture-and-food-security/us-government-global-food-security-strategy https://www.usaid.gov/work-usaid/private-sector-engagement/policy approach and from learning that narrow focus can miss opportunities for durable systemic changes by ignoring cross-market functions and the broader enabling environment.

Without a dynamic agriculture and food market system that engages a variety of actors, sustainable poverty reduction cannot be realized. The agriculture and food market system is also foundational in achieving nutrition and resilience objectives by providing consistent availability of and access to high quality goods and services for all. Achieving Feed the Future goals through a market systems approach will create sustainable solutions to challenges that are embedded in the local context.

Therefore, USAID seeks to facilitate changes in agriculture and food systems such that market actors, including private sector, public sector, and civil society, shift behaviors in a catalytic way to promote competitiveness, inclusiveness, and resilience for the broader market system. As USAID expands its use of the market systems facilitation approach to achieve Feed the Future objectives, it is critical to also expand understanding of good practice and evidence around the approach.

A core principle of the Feed the Future strategy is to engage and partner with the private sector to achieve food security development objectives. Feed the Future partners with U.S.-based as well as multinational and local businesses to promote inclusive agriculture led growth in new markets, and increase investment in research, dissemination, and scale of agriculture technologies that help meet agricultural potential, as well as reduce the need for future publicly-funded development assistance. In December 2018, USAID released the Private Sector Engagement Policy, which signals an intentional shift to pursue market-based approaches and mobilize private investment as a means to accelerate countries’ progress in achieving economic growth and prosperity.

Furthermore, USAID seeks to advance the commercialization and scaling of agricultural technologies and services through private sector engagement, catalyzing commercial investment, and partnerships with agriculture and food system enterprises in Feed the Future and other developing countries. Private sector investment in the commercialization of agricultural technologies and services is crucial for the competitiveness and productive capacity of producers and others in the market system.

Previous Related USAID Investments

MSP builds on the work of two prior USAID investments, described below. While MSP is expected to continue to advance knowledge and practice from these investments, it will go a step further in bringing together the learning from from market systems and private sector engagement approaches to help push

USAID interventions from transactional to transformative (i.e., catalyze systemic change).

In support of USAID’s adoption of the market systems approach, the Leveraging Economic

Opportunities (LEO) contract (2013-2016) supported programming that fostered inclusive growth through markets. LEO's learning agenda focused on inclusion and a systems approach to markets, advancing research and practice in inclusive market development.

Feed the Future Partnering for Innovation (FTF-P4I) helps the private sector scale and market agricultural technologies for smallholder farmers through investing in technology commercialization and knowledge exchange. The program improves productivity and profitability for smallholders by (1) commercializing agricultural technologies; (2) assisting USAID Missions in Feed the Future and other

Cross-market functions are not specific to a single commodity including inputs, finance, information, logistics etc.

Local systems framework: https://www.usaid.gov/policy/local-systems-framework

Market systems framework: https://www.marketlinks.org/library/framework-inclusive-market-systemdevelopment

LEO products: https://www.marketlinks.org/collections/leveraging-economic-opportunities-leo

FTF-P4I: https://www.partneringforinnovation.org/ https://www.usaid.gov/sites/default/files/documents/1865/usaid_psepolicy_final.pdf https://www.usaid.gov/policy/local-systems-framework https://www.marketlinks.org/library/framework-inclusive-market-systemdevelopment https://www.marketlinks.org/collections/leveraging-economic-opportunities-leo https://www.partneringforinnovation.org/ countries to engage directly and effectively with private sector partners; (3) showcasing successful and replicable public private models; and (4) capturing and exchanging pertinent information and best practices in technology development, adaptation, and distribution to the smallholder market.

3. PROBLEM STATEMENT AND THEORY OF CHANGE

As noted earlier in the Technical and Strategic Context section, Feed the Future and USAID have made two significant technical shifts:

From a value chain concept to a market systems development approach

Deepened private sector engagement approaches and commitments

Accordingly, USAID/Washington and Missions need support to execute this transition, not only for

Agency staff, but for our partner community. This transition must build upon 1) the extensive value chain and emergent market systems experience of USAID to date, as well as the Making Market Systems Work

Better for the Poor (M4P) and market systems experience of others and 2) the long track record of USAID engagement as well as direct partnerships with the private sector. While these are two distinct, albeit interrelated, approaches, efforts under these approaches will be best advanced, and better sustained, by seeing their connections and distinctions more clearly. Therefore, BFS is merging them in the MSP activity. How to best operationalize this merger will require strong collaboration, learning, and adaptive management.

Moreover, USAID needs to ensure that neither its market systems development nor private sector engagement work at the field level is simply buying short-term results by subsidizing investors or other market actors to do things that are not sustainable - even if they do show short-term results. Rather, USAID wants to use these two complementary approaches to identify the most effective leverage points where facilitative assistance or private sector action can push beyond the transactional to the transformative; deepening and accelerating inclusive and resilient ag-led growth, improved food security and nutrition, and/or increased incomes for the poor.

Current capacity to deliver these types of programs is unevenly spread and learning from adopters experimenting with new ideas and methods is not being well captured, analyzed, and communicated.

USAID Missions and other development actors seeking to employ these approaches need tactical guidance, evidence, analytics, updated tools, and other types of practical support.

4. PURPOSE AND OBJECTIVES

4.1 Purpose

The purpose of the requirement is to acquire Contractor services in the support of Feed the Future's use of private sector engagement and market systems development approaches, including but not limited to 1) partnership development services and partnership management services, 2) various market research and analytics, monitoring support services, and evaluation services, 3) research studies and data collection and analytics, and 4) training development, training delivery, and event management services.

The objective of MSP is to advance learning and good practice on market systems development and private sector engagement within USAID (Washington and Missions), USAID partners, and beyond by

Market systems development as described in A Framework for Inclusive Market Systems Development and in the

Global Food Security Strategy technical guidance.https://www.marketlinks.org/library/framework-inclusive-market-system-development https://www.marketlinks.org/library/framework-inclusive-market-system-development https://www.marketlinks.org/library/framework-inclusive-market-system-development providing and improving upon the evidence, capacity, tools, technical assistance, and/or services required to design, implement, monitor, and/or evaluate activities that lead to inclusive and resilient agriculture-led economic growth, improved food security and nutrition, and increased incomes for the poor.

As a result of MSP, USAID expects to advance knowledge on and explore new areas around market systems development and private sector engagement as a means to achieving more competitive, inclusive, and resilient market systems. USAID also expects to engage directly with private sector partners to commercialize and scale agriculture technologies and services as well as catalyze commercial investment in agriculture.

This activity will contribute to achieving the Global Food Security Strategy (GFSS) Results Framework

Objective 1: Inclusive and sustainable agriculture-led economic growth. It will also assist with GFSS

Objective 2: focused on resilience and GFSS Objective 3: focused on nutrition, especially for women and children by advancing private sector engagement and strengthened markets for related goods and services.

MSP will also contribute to advancing the development objectives of USAID Missions and Operating

Units, subject to buy-in.

4.2. Activity Objectives

While market systems development and private sector engagement provide the technical parameters for the scope of this activity, the activity objectives have a functional focus. The MSP objectives fall into two broad categories:

Field support functions with the potential for “buy-ins” to conduct discreet activities that are within MSP’s technical and functional scope, and

Global leadership functions focused on advancing global goods with central funding. While the functional objectives lend themselves predominantly to one or the other of these categories there may be instances when, for example, a mission wants to buy-in for a specific capacity building activity.

Field Support Functions:

Objective #1: To support effective private sector partnership development and management.

With over 90 percent of capital flows into the developing world coming from private sources, USAID’s official development assistance should play a catalytic role in developing economies to help direct and guide private capital flows to bottom of the pyramid markets. USAID would like to strengthen existing and co-create new, long-term relationships with key agribusinesses and other commercial firms in the agri-food sector to support USAID Mission food security programs.

USAID’s relationship with the private sector focuses on building mutual, long-term and strategic relationships, making systematic efforts to use a wide range of flexible forms of support to achieve development results while advancing business opportunities. Engagement and partnerships will speak to the “shared value creation” between USAID and private sector actors i.e. aligning core business interests https://www.feedthefuture.gov/wpcontent/uploads/2018/03/GFSS_TechnicalGuidance_MarketSystemsValueChains.

pdf Private sector engagement as described in the latest USAID private sector engagement policy https://www.usaid.gov/work-usaid/private-sector-engagement/policy https://www.feedthefuture.gov/wpcontent/uploads/2018/03/GFSS_TechnicalGuidance_MarketSystemsValueChains.pdf https://www.feedthefuture.gov/wpcontent/uploads/2018/03/GFSS_TechnicalGuidance_MarketSystemsValueChains.pdf https://www.usaid.gov/work-usaid/private-sector-engagement/policy of commercial firms while achieving USAID’s development objectives.

Private sector engagement and partnerships often require a great deal of nurturing and investment both upfront and throughout in order to benefit concerned parties. MSP will assist USAID Missions and

Operating Units operationalize USAID’s private sector engagement policy and advance their development objectives on an on-demand basis in ways that could include:

Building and strengthening relationships with local and/or multinational enterprises of all sizes.

Co-creating and co-investing in new, innovative and inclusive private sector partnerships that create sustainable impact that might not occur without public investments to address otherwise binding constraints.

Developing and managing new partnerships that utilize a pay-for-results approach

Supporting USAID Missions and Operating Units in directly engaging with private sector partners to commercialize and scale agriculture technologies and services as well as catalyze commercial investment in agriculture.

Providing technical assistance to donors, businesses and investors, identifying promising inclusive business models, and evaluating market conditions.

Utilizing effective and/or innovative mechanisms for private sector engagement including, but not limited to Grants under Contract (GUC), deliverable-based sub-contracts

, and other results-based financing mechanisms. The inclusion of the GUC component in the SOO is pending internal USAID approval.

Objective #2: To provide analytical and other services in support of design, implementation, monitoring, and evaluation of market systems and private sector engagement activities.

The analytic and other services needed throughout the program cycle to effectively deploy market systems development and private sector engagement (beyond partnerships as articulated under Objective

#1 above) activities can be extensive and beyond the capacity of USAID staff to execute themselves.

MSP shall provide on-demand support to meet specific needs of USAID Missions or Operating Units.

Sometimes Missions may require a full team including local experts; sometimes they may need an individual to join a pre-existing team to bring additional expertise and bandwidth. These services may include, among others:

Business model development

Value chain, sector, or market analysis

Organizational network analysis

Enabling environment analysis

Evaluation

Systems monitoring development

Market resilience assessment

Market inclusion assessment

Strategic review

Stakeholder or private sector landscaping or convening

Feasibility assessment

Public Private Partnership structuring

For more info see: Global Food Security Strategy Technical Guidance for Private Sector Engagement https://feedthefuture.gov/sites/default/files/resource/files/GFSS_TechnicalGuidance_Private%20Sector%20Engage ment.pdf https://www.usaid.gov/sites/default/files/documents/1865/Pay_for_Performance_Primer_Final.pdf https://usaidlearninglab.org/program-cycle-overview-page https://www.usaid.gov/sites/default/files/documents/1865/Pay_for_Performance_Primer_Final.pdf

Global Leadership Functions

Objective #3: To generate knowledge on both market systems development and private sector engagement.

MSP will generate knowledge and collate evidence on cutting-edge market systems development and private sector engagement learning questions. Some of this will support the elaboration and testing of theories of change that are required for quality project and activity designs. For example, through literature reviews, meta-analyses, syntheses of evaluations, and primary research, MSP will bring together evidence on topics that are central to USAID programming, private sector engagement, and market systems development - where there are gaps and where there is demand for such evidence.

In addition to supporting theory, USAID also seeks practical knowledge on tactical approaches for the day-to-day front line work involved in adopting and implementing both of these approaches. This is important from the perspective of activities designed with either approach as well as activities trying to pivot to these approaches.

This objective shall directly support the Feed the Future Learning Agenda, as appropriate and technically relevant. In addition, MSP shall develop more nuanced learning agendas for each technical approach.

USAID desires an expanded evidence base on both approaches individually, as well as where that evidence overlaps across the two, and also where it does not. USAID anticipates that the MSP learning agenda will evolve over time. Illustrative areas of inquiry include:

How to best utilize and incorporate pay-for-results approaches

How to assess and monitor unintended consequences and/or market distortions

What methods best measure indirect impacts without excessive added burden

How does implementation practice need to shift in thin markets or areas of recurrent crisis

What are the pathways from market shifts to household benefit

How to integrate shock-responsive and flexible approaches

How to best engage “target” groups for inclusion through indirect approaches

How can the unintended consequences of women’s increased economic roles be mitigated within the market systems framework

Success in this objective will require the ability to craft action research in partnership with donor and implementing partner staff, to provide academic rigor as necessary, and to be creative given imperfect research conditions and data gaps.

Objective #4: To build capacity to design, implement, monitor, evaluate, and learn from market systems and private sector engagement activities.

USAID and its partner community are quite extensive and decentralized, and USAID’s strategic shifts around market systems development and private sector engagement are relatively recent. As a result, enabling ongoing capacity development is necessary to fully execute the shift to the effective utilization of these two approaches throughout the program cycle. USAID seeks to build capacity for high quality use of these approaches rather than just renaming old tactics.

Capacity development can take many forms and may address different facets of development programming. MSP will meet the needs of USAID, USG, and/or the partner community through a variety of methods that may include training, guidance notes, embedding mission staff on analytical teams, etc.

One example would be to support an activity already in implementation to pivot their approach - requiring capacity development across a range of functions within the activity and perhaps would include meeting individual needs for learning among both implementing partner and USAID staff.

In addition to building technical capacity and support for the two approaches, this objective considers collaborating, learning, and adapting (CLA) to be essential capacities for success in deploying both market systems and private sector engagement approaches. Inherent in these two technical approaches is the ability to work effectively with a variety of market actors who have varying incentives, and to learn continuously about each context and its underlying market dynamics. Activities must also possess agility to effectively adapt as contexts change or as new evidence and/or opportunities emerge. Therefore, to advance use of these approaches that depend on CLA, MSP must simultaneously advance the ability of development actors and USAID staff to manage and embed CLA into activities using these approaches, and into their internal processes. This includes facilitating Mission-to-Mission learning about these approaches for more rapid field application, while still feeding that learning back to BFS to serve as a global good.

USAID recognizes that the MSP functional objectives are not mutually exclusive and they have the potential to feed into one another. Indeed, MSP should be deliberate about pulling learning from field support into global leadership and vice versa. These objectives can and will intersect across specific work assignments. For example, new knowledge (MSP Obj 3) should feed into capacity development efforts

(MSP Obj 4), or learning from field support (MSP Obj 1-2) could spur new knowledge (MSP Obj 3), and so forth.

5. GUIDING PRINCIPLES & IMPLEMENTATION CONSTRAITS

MSP will be implemented under conditions where various challenges including limitations related to laws, rules, regulations, standards, technology, and other constraints that must be successfully navigated.

In addition to addressing the development challenges and achieving performance objectives, the proposal must address and integrate each of the following requirements throughout:

Facilitation: Market systems development and private sector engagement seek to catalyze change in markets through market actors themselves, as opposed to having implementing partners directly deliver services that attempt to bridge market failures (e.g., extension services). Direct delivery impacts are difficult to sustain post-intervention and can displace market actors who should serve that market function. Therefore, MSP will emphasize the importance of using facilitation practices whenever possible. This may require supporting a mindset shift for those accustomed to thinking about direct outcomes and ownership of activities rather than indirect ripple effects and market-driven actions.

CLA: Just as supporting CLA within USAID’s portfolio is an objective, CLA must be embedded within the day-to-day work and operations of MSP. There are specific known activities for collaboration on technical work (e.g., Advancing Women’s Empowerment

) as well as to support dissemination of learning (e.g., Agrilinks, Marketlinks, BEAM Exchange). Over time specific collaborators may change.

Learning foci might shift as new priorities emerge. MSP needs to be well connected to find opportunities within the development community and flexible to engage in a variety of ways and in different areas as needed. Further, USAID anticipates a close, collaborative working style between MSP and Activity

Managers.

Competitiveness: Competitiveness is a foundational concept to sustainable development impacts driven by market systems development and private sector engagement. MSP must stay cognizant of how to advance these approaches steeped in the business case for behavior change and with an eye to how the use of subsidies within activities using these approaches can be catalytic or anti-competitive.

See https://usaidlearninglab.org/cla-toolkit

Advancing Women’s Empowerment Program: https://www.agrilinks.org/activities/awe#tab-1-1 https://usaidlearninglab.org/cla-toolkit https://www.agrilinks.org/activities/awe#tab-1-1

Inclusion: MSP will embed the ethos of inclusion throughout its work. Whether building on prior women’s economic empowerment theory and evidence or engaging youth or persons with disabilities in meaningful and creative ways, the technical products will integrate inclusive agricultural development 15,16

. In addition, MSP operations and methods on the ground should incorporate the capacity and tools to identify and address the factors that underlie marginalization. USAID recognizes that sometimes this means direct engagement with marginalized groups, but other times inclusion impacts may be created indirectly, with care to monitor actual results. USAID takes a broad view to inclusion and specific groups of interest can and should vary and intersect depending on context, including the extreme poor, women, youth, people with disabilities, ethnic and religious minorities, indigenous peoples, LGBTQI persons (lesbian, gay, bisexual, transgender, queer and intersex)

, widows and orphans, and other marginalized groups.

Resilience: As a mechanism designed to further market-led interventions in pursuit of sustainability, resilience must be a lens put on each task under MSP. Resilience in USAID is defined as the ability of people, households, communities, countries, and systems to mitigate, adapt to, and recover from shocks and stresses in a manner that reduces chronic vulnerability and facilitates inclusive growth.

This is important for all GFSS beneficiaries through GFSS Objective 2: Strengthened Resilience Among People and Systems

, but it is especially critical in areas of recurrent humanitarian crisis, where shocks and stresses compound and contribute to poverty backsliding for many of the world’s poorest people and some of the most marginalized. Risk and its mitigation and management should be explicitly considered in all MSP work streams.

Shared Value

: A management strategy in which companies find business opportunities and create economic value in addressing social issues. This contrasts with corporate philanthropy and social responsibility efforts that focus more on the license to operate, “giving back,” or minimizing the harmful impacts of a business. Focusing on shared value enhances the competitiveness of a company while simultaneously advancing the economic and social conditions in the communities in which it occurs.

Pay-for-Results (PfR) and Results-Based Funding: MSP will prioritize partnerships that utilize approaches that pay upon the accomplishment of predetermined results, rather than efforts to accomplish those results. In PfR, the funder sets financial or other incentives for an entity to deliver predefined outcomes, and rewards achievement of the results upon verification. In addition, MSP will advance learning on how pay-for-results approaches can be optimized and scaled across USAID and partner programming.

Please see the GFSS technical guidance for Advancing Gender Equality and Female Empowerment https://www.feedthefuture.gov/wp-content/uploads/2018/03/GFSS_TechnicalGuidance_Gender.pdf

Please see the GFSS Objective 1 Technical Guidance for more on Inclusive Agricultural Development.

https://drive.google.com/file/d/1ILpX8JBnhP2QhgM3qMRM27A2ivNQ5ZG9/view

When working for the inclusion of LBGTQI persons, the concept of ‘Do No Harm’ is critical to their safety. See

USAID LBGT Vision for Action, p. 8 for more.

https://www.usaid.gov/sites/default/files/documents/1874/LGBT_Vision.pdf https://www.usaid.gov/resilience

Global Food Security Strategy Technical Guidance Objective 2: Strengthened Resilience Among People and

Systems, https://drive.google.com/file/d/1LWqjleCU_W38FzbjNaXgGlbYIwHMU5NJ/view, and GFSS Technical

Guidance - Diversifying Livelihoods, Resilience, and Pathways Out of Poverty, https://drive.google.com/file/d/1n-iFmovzJHsPrW6DIGkAz4tX-zzXy9S9/view.

“Creating Shared Value-How to reinvent capitalism—and unleash a wave of innovation and growth,” Michael

Porter and Mark Kramer. Harvard Business Review. February 2011 https://www.feedthefuture.gov/wp-content/uploads/2018/03/GFSS_TechnicalGuidance_Gender.pdf https://drive.google.com/file/d/1ILpX8JBnhP2QhgM3qMRM27A2ivNQ5ZG9/view https://drive.google.com/file/d/1ILpX8JBnhP2QhgM3qMRM27A2ivNQ5ZG9/view https://www.usaid.gov/sites/default/files/documents/1874/LGBT_Vision.pdf https://www.usaid.gov/resilience https://drive.google.com/file/d/1LWqjleCU_W38FzbjNaXgGlbYIwHMU5NJ/view https://drive.google.com/file/d/1n-iFmovzJHsPrW6DIGkAz4tX-zzXy9S9/view https://drive.google.com/file/d/1n-iFmovzJHsPrW6DIGkAz4tX-zzXy9S9/view

6. MONITORING, EVALUATION, AND LEARNING

The purpose of MSP is to advance learning and practice in the fields of market system development and private sector engagement, contributing to the ongoing research and implementation experience. The activity’s Monitoring, Evaluation, and Learning (MEL) achievements will center around progress in the four objectives with annual workplans and targets, building upon previous year accomplishments. The

MEL Plan must take into consideration the measurable and verifiable set of deliverables that will be developed under each objective. Usage of indicator-based monitoring is not required and USAID encourages innovative approaches to monitoring and evaluating activity achievements as part of the proposal. The MEL Plan will cover one year of programming and be reviewed, updated, and expanded each year as annual workplans are developed.

The contents of the MEL Plan will be proposed by the contractor in collaboration with the COR and

Activity Managers. The COR and Activity Managers will have authority to determine the appropriate format of the MEL Plan and the Contractor must coordinate with the COR and Activity Managers prior to drafting the MEL Plan. If revisions to the MEL Plan are necessary or desirable within a fiscal year, the

Contractor must report any suggested significant MEL Plan changes or revisions to the USAID COR and

Activity Managers, and must obtain the USAID COR’s approval prior to implementing or undertaking such changes or revisions. MEL Plans should not be submitted to USAID’s DEC.