(By Funding Institution, NPMO and RPMO)

OBJECTIVES:
Understand the prior review requirements to the issuance of NOL

To facilitate the NOL processing and submittal to RPMO/NPMO

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Presentation Coverage
Why prior-review?

Prior Review

Requirements No Objection Letter (NOL) Thresholds, methods, category Procedures Timeline

Relationship of technical documents

Prior-review

Project mechanism to ensure that procurement policies and guidelines are complied;

Prior-review refers to the comprehensive review of procurement documents and requirements before a contract is awarded;
The review covers Procurement Plan; pre-procurement to evaluation and draft contract preparation; Review may warrant issuance of No Objection Letter (NOL) or Objection Letter (OL)

Prior Review Requirements

1. Review will be done by the RPMO, NPMO or MCA-P/WB, depending on the threshold, upon submission by the BSPMC of the request of No Objection Letter (NOL) together with the attached documents specified in the NOL review report.
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Thresholds
Category Goods RPMO a)Single Contract/PO 500,000.00 up to One Million NPMO WB/MCA-P a)Single a)Single Contract Contract above 2.5M above 1.0 M to 2.5M Single Contract above 2.5M

Works

a)Single Contract a)Single 500,000.00 Contract up to 1.25M 1.25M to 2.5M

Aggregate contracts > 1.0 M but less than P2.5M within a municipality regardless of category

Aggregate contract 2.5M within a municipality regardless of category

Prior Review Requirements

2. Any NOL issued by the RPMO is presumed to be thoroughly reviewed. Any contract/purchase order perfected without prior review and without issuance of NOL will be declared mis-procured. The amount covered in the misprocurement will be deducted from the cost of the grant fund.
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NOL General Procedure

1. With the assistance of ACT/MCT,

BSPMC prepares NOL request addressed to the NPM through the RPM; including complete procurement requirements/ documents; 2. Endorse NOL request to RPMO for review and issuance of NOL (if RPMO threshold); 3. RPMO review and endorse to NPMO for NPMO and WB/MCAP threshold; 4. For donors prior-review, NPMO review, issue corresponding actions, endorse to WB/MCA-P for

BSPMC NOL Request

ACT/MCT review

RPMO
RPMO NOL issuance
Feedback Mechanism
If within the Threshold of NPMO/WB/MCA-P NOL

RPMO review RPMO Transmittal to NPMO

WB/MCA-P NOL issuance

WB/MCA-P/ NPMO Issuance of Findings or OL

NPMO
If Not
NPMO Review

If OK If Not
WB/MCA-P Review

If OK
Transmittal to WB/MCA-P
If within the Threshold of WB/MCA-P NOL

WB/MCA-P

NPMO NOL issuance

Prior Review Requirements

3. For MCC-funded project/s: Contracts below PhP 2,500,000 generally do not need prior approval by the MCA-Philippines but during each Kalahi-CIDSS cycle, fifty (50) randomly-chosen community-based procurement contracts in part or whole area of coverage, regardless of amount, shall be subject to MCA-Ps review proceedings.
The PT should therefore make sure that all supporting documents of every contract are properly filed.
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Prior Review Requirements

4. All contracts requiring the donor and NPMO NOLs must be prioritized for review at the BSPMC, A/MCT and at the RPMO since it will require longer period for the issuance of NOL : 14 days is allotted for the review A/MCT (2-days) RPMO (5 days) NPMO (5-days) And 2 days for transmission.
In cases of deficiencies, compliance to such defects or clarification must be given priority and immediate action.
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Timeline
REVIEW UNIT
WB/MCA-P NPMO

TIMELINE
15 days 5 days

KEY ACTIONS
Review and Issue NOL or OL Request clarification prior to NOL Review and endorse to WB/MCA-P NOL requests Issue NPMO NOL Request clarification prior to NOL

RPMO

5 days

Review and endorse to NPMO NOL requests Issue RMO NOL Request clarification prior to NOL
Prepare NOL requests including the complete attachment Endorse to NOL request to RPMO

BSPMC & M/ACT

- 2 days @ M/ACT - 3 days @ BSPMC

Guides in Filling up NOL Review Form

1. Indicate what are the technical, financial and legal

documents submitted by the bidder in reference to the checklist of documents for NPMO/MCA-P NOL 2. Complete all the needed information to facilitate the RPMO,NPMO and WB/MCA-P review 3. Extract from the minutes of the activities all the useful information such as; agreements ,TWG/DAC conclusions on the proceedings 4. For the OBSERVATION/s part: Indicate the KEY reason for the recommendation either for issuance of NOL or OL.
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Implications to SPI if without Prior Review/or issuance of NOL

1. Delayed implementation;
Procurement

conducted fails or ineligible for NOL; Rebidding;

2. Possible mis-procurement;

Activity: Workshop on NOL review

Evaluate the sample Procurement Documents using the KC NOL Review Checklist. 2. Enumerate all comments and recommendations 3. Reporting of workshop out-puts 4. Critiquing
1.

Possible Comments & Recommendations

I.

Part I
a.
1. 2.

Invitation to Bid: Validity of Bid = 60 days Surety Bond is not allowed Acknowledgement Receipt: Receipt after the Pre-bid Instruction to Bidders Surety Bond is not allowed Bank Guarantee for Bid Security = 2% Validity of Bid = 60 days Inconsistencies of the date of Pre-bid Minutes of Pre-bid Conference Date was re-scheduled without a Bid Bulletin The use of ABC in KC we use Estimated Budget for the Package (EBP) The TA that exceeding the EBP will mean automatic disqualification

b.
1.

c.
1. 2. 3. 4.

d.
1. 2. 3.

Possible Comments & Recommendations

II.

Part 2
a.
1. 2.

Minutes of Opening of Bids The BAC allowed the bidder to provide additional amount for bid security The BAC disregarded the lacking bid security of Php. 1.00 Form of Bid: The date was after the Opening of Bids No amount of bid indicated Bank Guarantee Lacking of Php.1.00 Dated after the Opening of Bids Procurement of Works Evaluation Form The indicated Remarks Disqualified due to above ABC Signatures were not properly labeled No date

b.
1. 2.

c.
1. 2.

d.
1. 2. 3.

Possible Comments & Recommendations

II.

Part 2 a. Resolution to Award 1. No entry in the amount 2. No date

III. Over-all recommendations: a. The Brgy. Treasurer is not allowed to become a BAC Chairman
b.

Recommended for re-bidding because all bidders were disqualified

Overview of Region V NOL Issuance 20

17 5 1 NOL documents received with issued NOL NOL issued by MCA-P NOL issued by WB

11 NOL issued by NPMO 1 1 1

OL issued by NPMO/recommended for rebidding (Palaspas, Del Gallego)

with comments/awaiting compliance (Poblacion IV, Garchitorena) pending at MCAP (Bantugan, Presentacion)

COMMON OBSERVATIONS
1. Incomplete documents e.g. POW, PCPP, post-qua report, AR and MOV of Bid Security, minutes of

meetings and other documents in the checklist 2. Minutes of meeting/bid opening and evaluation does not reflect critical basis of decisions and agreements; 3. Recommended award is higher than the Estimated Budget for the Package (EBP) (note: Not ABC); no supporting documents for the additional fund for the award. 4. Use of SPA with absolute authority to the Atty Infact;

COMMON OBSERVATIONS
5. Inconsistency of dates from the ITB, pre-bid and bid opening/evaluation; schedule moved without

bulletin and explanation. 6. Inconsistency of quantities and cost in the POW, ITB and PCPP; 7. Un-prescribed bid security (form i.e. cash and bank guarantee, percentage i.e. old manual provision); Cash bid security was acknowledged after the bid opening; 8. Estimated budget for the package was disclosed; bid documents sold instead of free (as stipulated in the enhanced manual)

COMMON OBSERVATIONS
9. The same contractors bidding in various subprojects; in one SP, complete requirements

complied and win the bid but in the other Barangay/SP incomplete requirement particularly insufficient or no bid security, did not attached contractors license, others 10. Some bid were not examined to check correct calculations; some bids increased/decreased due to arithmetic recalculation (Qty)(U-cost); 11. No analysis and report on the failed biddings; 12. Packaging/splitting

COMMON OBSERVATIONS
13. Bid document served to more than three suppliers/contractors (3-7) but only one or two

submit a bid and in some cases, one was disqualified due to incomplete document or insufficient or no bid security 14. Evaluation report / lacks analysis 15. Negotiated Procurement due to two failed bidding 16. ITB served after and during pre-bid conference;

CONSOLIDATED

Procurement Benchmark
Subproject procurement matrix that serves

as database, reference in managing and reviewing procurement transactions;

Ideally prepared during pre-implementation

stage (based on PCPP) and updated during award, implementation and completion of contracts to reflect the actual start & finish, and the name of suppliers/contractors;

PROCUREMENT TRACKING / BENCHMARKS

D A T E S

Municipality & Province

Name of Supplier / Contractor

Post Qualification

Pre-Procurement

NOL issued by (RPMO, NPMO, World Bank)

Canvass/Bid Evaluation

Canvass / Bid Opening

Mode of Procure ment (Shoppi ng, Bidding or Direct Contract ing)

Serving of Canvass Pre-bid / or posting Contrac of Invitation tor's Conf. to Quote/Bid (For Shoppin g Works / Bidding Goods & Start End Works

Status (ongoin Aging g from delivery, ACT ongoing to implem RPM entation O of (Days contract ) or complet ed)

Amount of Contract (Pesos)

Name of Sub-project

Barangay

Date at RPMO

Package

Date at MCT

COMMON OBSERVATIONS
1. No regional consolidated Procurement Benchmark in most of the regions; lack analysis
a. Prior review, NOL b. Single contract

Aggregated Contract d. Status of contract execution, duration,

c.

2. Municipal Procurement Benchmark are directly forwarded to the NPMO 3. Some procurement transactions did not reflect the dates of planned start and end; actual duration; contract amount, mode of procurement, Name of Suppliers/contractor 4. The same supplier but different names

Meaning of Fiduciary
noun. from the Latin fiducia, meaning "trust," a

person (or a business like a bank or stock brokerage) who has the power and obligation to act for another (often called the beneficiary) under circumstances which require total trust, good faith and honesty.
fiduciary noun agent, caretaker, custodian,

guardian, one who handles property for another, one who transacts business for another, person entrusted with property of another, trustee

I. OBJECTIVES
Generally the objective of the ex-post fiduciary workshop is to review procurement transactions to assess compliance to the community procurement manual. Specifically, it aims to aid the Facilitators in providing guidance to the participants on the following:
Check consistency of data from the pre-procurement to the

completion of procurement activities including payment; Scrutinize responsiveness of procurement documents and activities conducted in every milestone; Derive good and best practices that may be adopted in other areas; Determine areas of enhancements to improve the conduct of fiduciary workshop; Provide technical assistance to participants on how fiduciary review is conducted; Come up with action plan in addressing and monitoring actions to recommendations

II. EXPECTED OUTPUT

After the workshop, it is expected to attain the following:
1. Procurement requirements, procedures and processes were

2. 3.

4.
5.

reviewed and analyzed whether such are compliant and responsive to the community procurement manual (i.e. PAP, PCPP, Benchmarks and detailed procurement documentation) Issues and concerns were clarified; agreements reached and provided with recommendations Participants gained knowledge and information on how to better conduct fiduciary review and mitigate occurrences of deficiencies in the actual conduct of procurement activities Derived available procurement good practices Action plan prepared to address agreements and recommendations

III. GUIDE
1. During the workshop, the facilitator should clearly share the

objectives and rationale of the activity to properly put into context and level-off expectations and outputs. 2. It is expected that preparatory requirements and activities were conducted. 3. Before proceeding to the detailed review of documents attached to the disbursement vouchers (DV) or folder of procurement documents:

Verify if the procurement transaction under consideration is consistent with the schedules; meaning, timeline, threshold and appropriate NOL as may be applicable. Procurement Action Plan (PAP), PCPP and Procurement Benchmarks should be checked to validate consistency and responsiveness of compliance.

III. GUIDE
a.

Is the conduct of procurement within the timeline per procurement action plan (PAP)? Particularly;

The PAP lays down the time frame and other procurement activities. Check if the actual procurement activities are complied within the timeline set in the PAP.
If the conduct deviates from the action plan, what are the possible factors or reasons? Check if there are justifications provided. Analyze whether the reason/s justifies the deviation.

III. GUIDE
Are

there no other ways to mitigate such factors of deviation? What is the effect of deviation to the schedules and delivery of outputs? The cause and effect should be presented taking note that delays in the timeline will affect or cause further delay in the succeeding activities,

Follow the above procedure in the evaluation of every milestone in the procurement phase.

III. GUIDE
b. Verifying the Planned Community Procurement

Package (PCPP).

Check if the threshold and procurement method is consistent with the PCPP.
Check

the cost of actual contract/PO if there is an increase or decrease in the package amount in the PCPP.

III. GUIDE

Should there be difference in the amount whether higher or lower than the PCPP:
Analyze

the factor/s. Check the unit costs of the item of works Check the time elapsed on the planned period of procurement which may have affected the increase (as the case may be);

If there is an increase or decrease in the package amount,

Does

this affect the procurement method? Check if prior review requirement (request of NOL) applicable.

III. GUIDE

It is also important to check the costs in the item of works whether no front loading or unbalance quotations/bids.
Be

reminded that there are contracts abandoned or incurred too much delays as a result of frontloading.

Compare the period of contract/PO implementation if conform to the PAP and PCPP.

III. GUIDE
c. Procurement benchmarks. Based on threshold, is

no objection letter (NOL) applicable?

Or based on the procurement benchmarks, is the procurement transaction under review part of an aggregated contracts that requires NOL? Take note that in the consolidated procurement benchmarks in the region or municipality, actual and planned schedules should be reflected. The basis of request for NOL is the thresholds in the PCPP, not the actual contracts.

III. GUIDE

A presentation of analysis of the procurement benchmarks should be prepared by the RPMO engineers for presentation to the participants. It is recommended that it will be presented prior to the workshop to demonstrate the use of benchmarks.

In the procurement benchmarks, present what common procurement method usually used. In the analysis:
Are

the methods used appropriate based on thresholds? Are the thresholds based on packages require prior review, thus, NOL is issued.

III. GUIDE

Based on the period of procurement,

Are

there aggregate contracts requiring NOL? In cases of aggregated contract/P.O., is the contract/PO that reached the aggregate threshold issued with NOL?

III. GUIDE
4. Determining fiduciary good or best practices. The RPMOs and

ACTs or even the BSPMCs may innovate systems of reviews which may further enhance or facilitate the attainment of the fiduciary objectives. Such practice should be properly documented and shared to the other areas (Municipality or Region) should it be found effective.
5. Enhance ex-post fiduciary review tool. The detail of

procurement requirements in every milestone is provided in this tool. The reviewer/facilitator should remind the group or participants that each document should be evaluated to assess the responsiveness of the procurement requirement.

III. GUIDE
6. Reporting of observations and findings.

In the workshop, aside from the written report, presentation of observations and findings should be a must requirement.

This is where sharing of idea and learning shall be facilitated among participants. This is also the venue to critique the output of the workshop.

III. GUIDE
6. Reporting of observations and findings. (cont)

Documentation should include the minutes of the workshop. A monthly report should be submitted to the NPMO; for regional fiduciary activity and consolidated municipal fiduciary reviews conducted.

In the report, the common observations and findings likewise the recommendations should be clearly reflected. This shall also be the basis of monitoring actions or compliance to the recommendations in the succeeding month.

III. GUIDE
6. Reporting of observations and findings.

It is emphasized that in the succeeding fiduciary review, deficiencies and findings observed in the previous fiduciary review are expected to have been minimized if not eliminated.

7. Action planning. Part of the outputs of the activity is the

Individual action plan and Workshop action plan. These shall be used in monitoring the compliance of recommendations and agreements during the activity; likewise, the individual subproject procurement.

I. OBJECTIVES
This aims to review procurement and financial transactions conducted in the implementation of KALAHI-CIDSS community subprojects; and ensure to provide recommendations and actions to issues and observations. Specifically, reviews the following:
Proper conduct of procurement in the following phases: pre-

procurement, procurement proper (Posting of ITB, submission of bids/quotations, evaluation and awarding) contracting and implementation, and payment. methods and No Objection Letters (NOLs);

Procurement planning, appropriate packaging, threshold, Procurement benchmarks Disbursement and complete attachment

II. COVERAGE
Completed or ongoing (at least 50% complete or

evaluation stage) procurement transactions regardless of procurement method; Local Bidding, Local Shopping, Negotiated Procurement.

III. WHO CAN USE THIS TOOL?

All Project stakeholders can use this tool. Primarily,

Field Offices including the Area Coordinating Teams / Municipal Coordinating Teams (ACT/MCT), partner LGUs and Barangay Subproject Management Committees (BSPMCs).

IV. GUIDE
1. PREPARATION Preparation will depend on how the review is planned to be conducted. In some cases, unannounced or announced review may be conducted depending on the specific review objective.
For

purposive review by the FOs for specific procurement transactions due to some issues or concerns of irregularities, The un-announced (not to specify the fiduciary review) may be made but coordinate the visit to the concerned ACT/MCT to ensure that BSPMC and community volunteers will be available.

IV. GUIDE
2. RESPONSIBLE PERSONS
Regional

Community Infrastructure Specialist (RCIS) - overall in-charge ACTs/MCTs At the community level the Deputy Area Coordinator (DAC) together with the other team members should also conduct orientation and capability development to community volunteers for them to be able to conduct the fiduciary review.

IV. GUIDE
3. METHODS OF FIDUCIARY REVIEW
A. Purposive fiduciary review

Procurement transactions are purposively selected for review. Objectives of review may include validating some issues or irregularity; also, more appropriate to procurement transactions with more complex considerations i.e. local bidding for works. Out of all procurement transactions, randomly pick any transaction for review. This is used when volume of procurement transactions cannot be managed during the review period. A 10% representative sample size may be determined. All procurement transaction will be reviewed

B. Random

C. Complete

IV. GUIDE
4. PROCESS
Planning

the conduct and setting the specific objectives of the review is very important, likewise, communication/coordination to the ACT/MCT and BSPMC in the preparation. At the community, it is always important to carefully inform the community volunteers of the objectives of the review; that such is conducted to determine possible areas of procurement that need to be strengthened. Observing the principles in procurement will benefit the quality and responsiveness of subproject implementation at the same time an antidote to corruption. Document review of procurement shall be made first. Check if all documents and process conducted

IV. GUIDE
5. FILLING-UP THE FORM Provide the basic information pertaining to the subproject and procurement transaction under consideration.
The form contains the key milestones and

respective activities. Succeeding steps, under column (a), scrutinize the procurement milestones/stages and its corresponding activities; rating (explained below) and filling-up the comments, observations and findings.

IV. GUIDE
5. FILLING-UP THE FORM (cont.)
There are activities/indicators or milestones that are

not applicable to the procurement transaction under review just indicate in the remarks column to be N/A or not applicable. review should look into the responsiveness of the documents;

In evaluating the indicators, the one conducting the

Are the documents/activities conducted in accordance

with the community procurement manual? Are the information provided properly; e.g. dates, signatories, etc. The documents should not serve as checklist requirement but shall be reviewed with utmost consideration of its purpose.

6. RATING MATRIX
Numerical

V. GUIDE
1

2 3 NUMERICAL

Considerations in rating the milestones / indicator Deficient activities and documents e.g. minutes of procurement conference does not capture important agreements; documents not signed; no attached required documents Minor deficiencies observed; e.g. incomplete signatories, minutes of procurement meetings did not fully capture discussions and agreements Procurement activities and document are compliant to the community based procurement manual ADJECTIVAL
In the analysis of the performance of the procurement transaction, it can be determined what procurement stage or milestone is weak or what needed more assistance to the community; e.g. preprocurement, procurement proper, contract implementation and so on.

Below 2.0 2 2.60 2.61 3.0

Unsatisfactory Satisfactory Very Satisfactory

IV. GUIDE
7. FIDUCIARY FEEDBACK
After the activity/evaluation, it is important to present the observation and findings to the community volunteers or BSPMC concerned. They can present or discuss what possible causes or issues that led to the observations/findings. At the end of the presentation, issues should be clarified and recommendations should be made.

IV. GUIDE
7. FIDUCIARY FEEDBACK (cont.)
An action plan may be prepared to guide the community in responding to the recommendations. At the RPMO and NPMO level, result of the fiduciary review should be consolidated and analyzed to provide the management whatever enhancement that need to be made.

V. REVIEW FORM
EX-POST FIDUCIARY REVIEW FORM
Name of Sub-project Location (Brgy,Mun.,Regn.) : : __________________________________________ __________________________________________ : _________________ PERIOD OF PROCUREMENT: : _____ Goods; _____Works; ________ Service/s ____________

PROCUREMENT METHOD CATEGORY

PACKAGE NUMBER: ______________ DISBURSEMENT VOUCHER (DV) NUMBER: _______________

PROCUREMENT MILESTONE / ACTIVITIES/INDICATORS

I. PRE-PROCUREMENT PHASE
1. Pre-procurement conference/s minutes stating or discussing this procurement, items to be procured, method and timeline 2. Procurement Action Plan Duly signed and attached to the procurement/DV folder 3. Plan Community Procurement Packages (PCPP) duly signed and attached to the procurement/DV folder; if revisions were made the actual PCPP should be the one attached. 4. Program of works (POW) and Detailed Estimates attached to the procurement/DV folder; entries in the POW should be consistent with the PCPP. 5. Duly accomplished and signed Procurement forms, applicable to this procurement (Canvass, Quotation, Bidding documents); complete with the necessary information/instructions such as dates, quantity, specifications, others 6.

RATING

REMARKS (Comments, Notes)

V. REVIEW FORM
II. PROCUREMENT PHASE
1. Post / issue invitation to Bid (LB); Issue Quotations/Canvass for Local Shopping (LS) - proof posting must be attached; - Is the bid document complete? Duly signed? - Acknowledgement receipt attached in the folder 2. Conduct Pre-bid conference (for LB) - Minutes attached , agreements and discussions are captured - Dates of submission and evaluation of bids clearly indicated 3. Issue Bid Bulletin (if necessary) - Posted or issued to bidders 4. Solicit/Receive quotations/bids - With acknowledgement receipts or listed in the logbook? With date and time of receipt - Canvass/Quotations/Bids sealed and put in the drop box before deadline? 5. Opening of Bids/Quotation/Canvass - Opening conducted at the time stipulated in the invitation to bid or Quotation/Canvas - BAC has a quorum? - Bids/Quotation/canvass envelopes are sealed? - Envelopes/Bids taken from the bid box - Minutes of opening of quotation/bid prepared and signed after the opening 6. Evaluation of Bids/Quotation/Canvass - Canvass/Bids scrutinized and initialed by the BAC - Erasures are initialed - Specifications conform to the requirements - Abstract of quotation/bids prepared - Prices/amount within the budget 7. Post-qualification - Are all documents and information provided in the quotation /canvass/bid authentic/true? - Minutes of post-qualification prepared and signed by members of TWG and BAC 8. Prepare Abstract of bids/quotations - Abstract of quotations/bids prepared and signed by members of the TWG and BAC - Responsive Quotations/bids were ranked from lowest to highest 9. BAC resolution recommending award or failure - Award was recommended to the lowest calculated and responsive supplier/bidder

V. REVIEW FORM
III. CONTRACT/P.O. AWARDING PHASE
1. Issued Notice of Award 2. Prepared/served/ Approved /execute Contract / Purchase Order (PO); Contract/P.O. 3. P.O. received; Contract signed 4. Notice to Proceed (for LB/LS for works) issued to the winning supplier/bidder

IV. CONTRACT/P.O. IMPLEMENTATION PHASE

1. 1. NOL issued (for contracts/PO with NOL) 2. PO prepared and conform by the supplier within 15 days from receipt of NOL or after evaluation of canvass 3. PO/Contract prepared within 21 days from issuance of Notice to Award 4. Delivery/Contract completion within the approved duration 5. Delivery/Accomplishments with complete documentation and conform to specifications e.g. Delivery/Official receipt for goods, Accomplishment reports prepared and signed for works; certificate of inspection; completion;

V. PROCUREMENT TIMELINE
Issuance of P.O. and Notice Proceed is within the below prescribed timeline LOCAL SHOPPING Goods: 7 to 9 Calendar Days Works: 27 to 45 Calendar Days LOCAL BIDDING Goods: 35 to 53 Calendar Days Works: 41 to 61 Calendar Days

VI. PROCUREMENT BENCHMARKS

1. The Procurement transaction being reviewed is included in the procurement benchmark matrix in the ACT/RPMO. 2. The procurement conducted with appropriate threshold, packaging, method; NOL issued as appropriate 3.

VII. PAYMENT PHASE

1. 2. 3. or Disbursement vouchers signed/acknowledge; DVs with complete attachment Check prepared and signed by authorized signatory DVs and attachments are properly filed in a folder and secured to a filing cabinet Box Numerical FINAL RATING Adjectival

ANALYSIS:

Conducted by: __________________________ ____________________________________