December 2009
Reform Priorities in the
For more information,
please contact:
Linda Poteat
Director, Disaster Response
InterAction
lpoteat@interaction.org
Natalie Eisenbarth
Legislative Associate for
Humanitarian Affairs
InterAction
neisenbarth@interaction.org
www.InterAction.org
1400 16th Street, NW
Suite 210
Washington, DC 20036
202-667-8227
Humanitarian Sector
The community of American non-governmental organizations (NGOs) commends the U.S.
government’s consistent support for international humanitarian assistance, and recognizes
this as a long-standing strength of U.S. foreign assistance policy. Since the post-World War
II period, NGOs have leveraged our extensive staff capacity and deep field presence in coun-
tries experiencing emergencies to partner with the U.S. government as an integral part of our
nation’s humanitarian response capacity. Beyond our operational strengths, NGOs bring to
this partnership both substantial private resources and the ability to galvanize the interest
and commitment of the American public in addressing the needs of the world’s most vulner-
able. In 2006, InterAction members raised nearly $6 billion from private and non-USG sources,
complementing $2.7 billion in U.S. government contributions. The American people’s con-
tributions to NGOs and their support for the U.S. government’s humanitarian aid programs
reflect the best traditions of American generosity.
Stengths and Weaknesses in the Current System
As U.S. policymakers begin to review, reform, and modernize U.S. development and foreign
assistance policy, it is important to highlight the strengths in the current system:
• Robust budget levels for high profile crises, supported by many strong allies on Capitol
Hill.
• A strong humanitarian field presence, via State/Bureau of Population, Refugees and
Migration’s (PRM) Refugee Coordinators, Office of U.S. Foreign Disaster Assistance’s
(OFDA) six regional teams, and USAID/Disaster Assistance Response Teams (DART).
This gives the U.S. an unmatched capacity to rapidly deploy to an emergency, assess
needs, and fund appropriate programs in a responsive and strategic manner.
• Strong partnerships with NGOs and UN agencies, with good communication, a frank
exchange of perspectives, and a collaborative approach to program strategy.
• Strong support for UN humanitarian action; the USG is the largest global donor to UN
High Commission for Refugees (UNHCR), World Food Program (WFP), UN Children’s
Fund (UNICEF), and to UN Consolidated Appeals.
• Responsive, flexible and rapid bilateral grant-making procedures.
• Absence of hard budgetary earmarks, enabling the USG to allocate humanitarian
funding towards holistic and context-driven program strategies.
Notwithstanding these strengths, a number of systemic inconsistencies, inefficiencies, and
disconnects have also developed as the USG’s humanitarian architecture has evolved over
the years. As longstanding partners of the USG in humanitarian action, we wish to highlight
priority areas where reform is needed:
Falling Short on Needs-Based Assistance
While the U.S. is a signatory to the Good Humanitarian Donorship1 principles, it often falls
short in implementing them. The overarching purpose of U.S. humanitarian assistance is to
save lives, alleviate suffering, maintain dignity, and uphold the rights of extremely vulnerable
people. Yet U.S. humanitarian response policy is at times unduly influenced by consider-
1
The standards represent the consensus of all major countries on best donor practices in humanitarian response set-
tings, and can be found here: http://www.goodhumanitariandonorship.org/
 ations beyond humanitarian need:
• The large differences between U.S. assistance to
refugees versus that provided to internally displaced
persons (IDPs) and conflict-affected communities
are difficult to justify given the often broadly simi-
lar needs of these groups.2 U.S. refugee assistance
spans the full life cycle of a crisis, from emergency
relief to durable solutions, using UNHCR3 , SPHERE4,
and INEE5 standards as benchmarks. IDP and com-
munity-level assistance is far less comprehensive
across sectors, and funding levels are much lower
even when needs are comparable. U.S. refugee pro-
grams also address protection issues far more com-
prehensively than other U.S. humanitarian response
programs.
• While U.S. contributions of in-kind food aid com-
modities are generous in scale, U.S. emergency food
programs need to become more flexible and respon-
sive to local needs. In particular, use of emergency
food assistance tools that address immediate food
consumption needs in line with market conditions
– such as local and regional procurement programs
and voucher approaches – is improving but remains
limited. This lack of flexibility increases the likeli-
hood that U.S. food assistance may be unnecessarily
delayed through procurement and shipping delays
and may also result in food being diverted to other
uses, such as sale on the open market. The admin-
istration’s new Global Food Security Initiative will
provide an excellent opportunity to address these
challenges.
Budget and Structural Challenges
U.S. humanitarian budget structures contribute to short-
comings in the quality and quantity of aid:
• There is a growing disconnect between USAID/
OFDA’s multiple mandates and its resources. As
OFDA engages more in protracted crisis response,
it faces challenges balancing its budget between
anticipated needs and unforeseen new emergen-
cies. Unlike State/PRM, whose main budget comes
from the Migration and Refugee Assistance (MRA)
account and can draw down from the Emergency
Refugee and Migration Account (ERMA) for unantici-
pated needs, OFDA has only a single account – Inter-
national Disaster Assistance (IDA). Lacking a con-
tingency drawdown fund, OFDA must use its main
account as both a general budget and a contingency
fund for unanticipated emergencies. This greatly
complicates its ability to allocate funds at the start of
the fiscal year and restricts its ability to support a full
2
For example, PRM funds education activities for refugees while OFDA generally does not do so
for IDPs.
2 3
UNHCR Handbook for Emergencies: http://www.unhcr.org/home/PUBL/3bb2fa26b.pdf
range of aid to protracted crises.
• The reliance in recent years on supplemental bud-
gets to fund anticipated and recurring humanitarian
response programs has created political uncertain-
ties and delays in developing and financing pro-
grams. This has made it particularly hard to fund
assistance to protracted crises at an appropriate
level.
• There is a disconnect between funding timelines
and the actual dynamics of humanitarian response.
U.S. humanitarian programs use 6-12 month funding
cycles, which can be ill-suited to humanitarian crises
that often endure for 5-10 years.
Post Crisis and Transitional Assistance Gaps
Post-emergency transition and recovery efforts lay a criti-
cal foundation for a country’s stability and long-term devel-
opment. Transition planning should begin at the outset of
an emergency response; such efforts become particularly
important when emergencies reach a “protracted” phase
– when the acute emergency recedes and a crisis-affected
population begins to stabilize (even while a conflict is ongo-
ing). Transitional contexts in fragile states now constitute
a large policy priority for the U.S., yet the structure of U.S.
assistance still reflects an outmoded dichotomy between
“relief” and “development”, with effective coordination and
handover between these poles oft-discussed but rarely
executed. The chronic under-funding of disaster risk reduc-
tion activities – which support communities to assess their
vulnerability to threats such as drought or floods and work
to reduce their future exposure to those threats – is a closely
related challenge.
The Office of Transition Initiatives (OTI) has the transitional
mandate in theory, but in practice has focused on a limited
scope of interventions, leaving major gaps in transitional
assistance. OFDA tends to be drawn into de facto transi-
tional development assistance, but without a clear man-
date and appropriate tools to do so. OFDA’s short funding
cycles impede medium to long-term strategic planning,
complicate efforts to build program ownership and capac-
ity among the affected populations, and prolong the use of
expensive relief-oriented program strategies. The bottom
line is that until transitional development assistance priori-
ties are backed with appropriate authorities and resources,
the U.S. will continue to underperform in this area.
Unclear Leadership
The lack of a clear humanitarian “lead” in the USG com-
plicates interagency coordination and impedes coherent
engagement with international partners and mechanisms.
4
SPHERE Minimum Standards for Disaster Response: http://www.sphereproject.org/
5
Inter-Agency Network for Education in Emergencies (INEE), INEE Minimum Standards for Education
in Emergencies, Chronic Crises and Early Reconstruction, 2004, available at: http://www.ineesite.org/
 This creates problems in several ways:
• The lack of a formal lead actor for humanitarian
response can lead to ineffective ad hoc arrange-
ments, such as the military leadership during the
2008 Georgia response.
• The dilution of U.S. humanitarian leadership means
that the U.S. punches below its weight on interna-
tional reform and coordination processes. The UN
Humanitarian Reform process is altering the archi-
tecture of humanitarian action, but the U.S. has been
less influential than European donors in shaping this
important process.
• Likewise, the U.S. gives a great deal of resource sup-
port to international organizations (UNHCR, UN
Development Program, WFP, International Commit-
tee of the Red Cross, International Organization for
Migration, etc.) but does so through so many differ-
ent offices and funding spigots that it is difficult to
coherently and effectively leverage USG humanitar-
ian engagement with these organizations.6 These
international organizations’ decisions on policy
issues can significantly impact how U.S. resources are
targeted and expended; yet the lack of a clear U.S.
humanitarian lead impedes effective oversight of
these decisions. This is a particular concern on IDP
issues because, despite USAID’s lead on IDP policy,
a significant proportion of USG resources for IDPs is
controlled by State/PRM through its contributions to
UNHCR and ICRC.
Militarization of Humanitarian Assistance
The civil-military relationship in humanitarian response
is shifting as the Department of Defense (DoD) and civil-
ian leaders come to view assistance as a useful tool of U.S.
security policy. Congress has simultaneously proved willing
to appropriate assistance funds to DoD (i.e. Commander’s
Emergency Response Program, 1207/1210) with far greater
flexibility, far less oversight, and inadequate impact moni-
toring relative to similar funding to USAID. The USAID
“Civilian-Military Cooperation Policy”, released in 2008,
focuses on how USAID will work in sync with the military
but does little to concretely delineate USAID’s prerogatives
and capacities as the U.S. government’s lead actor on devel-
opment policy. These trends have caused the U.S. military’s
humanitarian remit – traditionally limited to large-scale
logistical assistance – to expand (in Iraq, Afghanistan, Geor-
gia, and increasingly in Africa) into more traditional forms of
humanitarian and stabilization/transitional assistance.
The military’s increasingly visible role as a major face of U.S.
assistance impedes effective partnership between NGOs
and the USG. NGO assistance methodologies and security
models are premised on our ability to serve as impartial
actors, providing assistance based on need rather than pur-
suing security or political agendas. In places like Afghani-
stan, the explicit linkages between USAID assistance and
military counterinsurgency (COIN) strategies can thus cre-
ate serious risks to NGO safety and operations. Efforts to
begin addressing some of these challenges are underway –
for example, the NGO community and DoD have produced
joint guidelines for civ-mil interaction in the field, and NGOs
have been gratified to see these guidelines integrated into
military doctrine and training regimes.7 But the military
remains free to disregard these guidelines, implementation
at field level has been inconsistent, and even when imple-
mented, these guidelines address only a subset of the wider
problem of the militarization of aid.
Policy Reform Recommendations
1. State explicitly in law that the purpose of U.S.
humanitarian assistance is to save lives, alleviate
suffering, maintain dignity, and protect and uphold the
rights of extremely vulnerable people. In accordance
with this purpose, formulate clear, government-
wide principles8 governing the prioritization and
administration of U.S. humanitarian assistance.
2. Establish and apply, based on these principles, a
framework of basic needs and protection standards
that is balanced, comprehensive, and equally
applicable to refugees, IDPs, and conflict-affected
individuals and communities. Ensure that this
framework is operationalized across all government
organs with responsibility for humanitarian assistance
activities.
3. U.S. food aid programs should aim for increased
flexibility through greater use of local and regional
procurement mechanisms and voucher programs,
among other approaches, where market conditions
permit. Thorough market and food needs analyses
and “Do No Harm” assessments should accompany
the use of such tools. Where use of in-kind U.S.
commodities is preferred, commodity distribution
should be accompanied by diet and recipe education
and supplemented with complementary local foods
when possible.
4. Reform the USAID humanitarian accounts to prevent
new emergencies from undermining U.S. support to
protracted crises and disaster risk reduction. OFDA
should be given a general account, in parallel to PRM’s
MRA account, to fund foreseeable programming
expenses in a consistent, sustained manner over
multi-year timeframes.

6
This challenge is discussed in detail in the report of the U.S. Task Force on the United Nations: http:// 8
The NGO community submitted a document on humanitarian principles to the House Foreign

www.usip.org/files/file/usip_un_report.pdf Affairs Committee in February 2009; it is included as an annex to this document.

7
http://www.usip.org/files/resources/guidelines_pamphlet.pdf 3
 5. Via the aforementioned account, increase OFDA’s
overall funding to enable it to more comprehensively
address protracted emergency, disaster risk
reduction, and early recovery needs, especially in
relation to IDPs and conflict-affected individuals and
host communities. Provide OFDA and PRM with the
capacity, authority and resources to provide multi-
year funding in appropriate settings.
6. Create a new “transition” contingency account to
enable rapid funding of recovery and transitional
development assistance in post-crisis and post-
conflict settings without cutting into existing
emergency response budgets. This should be put at
the disposal of the USAID Administrator and used to
support joint transitional program efforts between
USAID/DCHA and the in-country USAID Missions. In
order to enable satisfactory congressional oversight,
the transition account could be structured as an
ERMA-style replenishable drawdown account. Ensure
that U.S. transition activities include strong emphases
on conflict mitigation and disaster risk reduction.
7. Legally designate a humanitarian response “lead”
within the USG with full authority to coordinate all
of the USG’s humanitarian and recovery programs
including those carried out by the military. This
individual should serve as the principal USG policy
voice in international humanitarian fora and have
principal responsibility for humanitarian policy
engagement with fellow donor governments,
recipient governments, the UN system, NGOs, and
other international institutions.
8. Engage and show leadership in UN humanitarian
reform initiatives. The USG should seek to shape and
influence these initiatives, leveraging its extensive
field presence (via USAID/OFDA regional teams
and DART teams and PRM Refugee Coordinators)
to ensure that UN reform processes yield tangible
improvements for beneficiary populations. In
particular, the USG should promote the use of
dedicated UN Humanitarian Coordinators in crisis
situations, push for improved cluster coordination
performance, and closely monitor the efficiency and
effectiveness of pooled funding mechanisms.
9. DoD involvement in humanitarian, transitional and
development assistance activities should occur as a
last resort and only where the military brings unique
capacities that are demonstrably lacking among
civilian actors (e.g. heavy lift capacity). The ongoing
administration review of civil-military authorities
provides an important opportunity to rectify those
areas in which the military’s expanding mandate for
humanitarian and transitional assistance exceeds its
unique capacities or comparative advantages. This
review process should include a revision of the USAID
4
Civilian-Military Cooperation Policy to more clearly
delineate the appropriate roles of DoD and USAID.
10. To ensure a better civilian-military balance in
humanitarian and post-conflict assistance, military
engagement in such activities should be contingent
upon certification by the Secretary of State that
civilian actors lack the requisite capacity to respond.
In such instances, the military’s assistance activities
should be held to the same impact measurement
standards as non-military aid.
List of Endorsing Organizations (in alphabetical
order):
• Africare
• Agency for Technical Cooperation and Development
(ACTED)
• The American Refugee Committee
• AMREF USA
• AMURT
• CARE
• Church World Service
• Hands On Disaster Response
• International Medical Corps
• International Rescue Committee
• Jesuit Refugee Service/USA
• Life for Relief and Development
• Mercy Corps
• Oxfam America
• Plan USA
• Refugees International
• Relief International
• Resolve Uganda
• Women’s Refugee Commission
• World Vision US
5
Annex: Principles for U.S. Humanitarian Assistance • T he U.S. should work to ensure that its assistance programs
Humanitarian crises present a moral challenge to the United States. operate harmoniously with those of other countries and mul-
A robust and coordinated response to humanitarian emergencies tilateral institutions.
should be an obligation and a foreign policy priority. U.S. humani- • The U.S. should strive to maintain accountability and to learn
tarian assistance should have clearly stated goals for its operation, from its experience. Independent government agencies
established principles for how assistance should be administered, should review and evaluate programs on a regular basis to
and priorities that help identify where assistance and protection ensure that best practices are being followed and that pro-
are most needed. grams are effective and transparent, in keeping with humani-
tarian principles.
Principles for Humanitarian Assistance
• Assistance should be based on and allocated in proportion List of endorsing organizations (in alphabetical order):
to humanitarian need. • American Joint Distribution Committee
• Assistance should be provided impartially without regard to • American Red Cross International Services
the political views, national origin or religious affiliation of • American Refugee Committee
the beneficiaries. • AMREF
• U.S. humanitarian funding should be consistent with inter- • Brother’s Brother Foundation
national protection standards and in furtherance of interna- • CARE
tional humanitarian law, refugee law, and the protection of • Christian Children’s Fund
human rights. • Church World Service
• In keeping with the humanitarian imperative, the U.S. should • Food for the Hungry
use its leverage to assist humanitarian agencies in obtaining • Hebrew Immigrant Aid Society
secure, unfettered access to survivors in crisis situations. • Helen Keller International
• While the distribution of humanitarian aid is authorized • International Medical Corps
through the Foreign Assistance Act, administration of such • International Rescue Committee
aid should be governed by international treaties and agree- • Islamic Relief USA
ments to which the U.S. is a signatory. • Jesuit Refugee Service USA
• U.S. policy should require that humanitarian assistance • Liberty in North Korea
programs strive to abide by internationally agreed upon • Mercy Corps
standards, including Inter-Agency Standing Committee • Operation USA
guidelines, the Sphere Standards, and the Principles of Good • Oxfam America
Humanitarian Donorship. • Pan American Development Foundation
• The U.S. should ensure that non-humanitarian U.S. foreign • Pathfinder International
aid, including foreign aid programs administered by depart- • Plan USA
ments other than State, complements U.S. humanitarian • Refugees International
assistance programs, and that all aid meets international • Relief International
humanitarian law and human rights standards. • Save the Children
• U.S. humanitarian assistance programs should be imple- • Women’s Refugee Commission
mented by inter-governmental and non-governmental • World Vision
international humanitarian organizations. When the mili-
tary is required to support a humanitarian response, civilian
agencies should be in the lead and have the requisite capac-
ity to perform this leadership role.
• Assistance should be provided quickly and efficiently.
• Funds for humanitarian response should be appropriated
annually at a sufficient level to assure an overall U.S. response
commensurate with the need, including for protracted
emergencies. An emergency draw down fund should be
supported to ensure that capacity for rapid response to
emergencies is maintained at all times.
• Humanitarian, recovery, and development programs should
be coordinated and planned to address post-conflict and
post-disaster relief to development transitions. Funding
mechanisms should ensure continuity of life-sustaining ser-
vices during transition phases.
6