Subject: RE: POM and related questions
From: Maddalena Honorati <[email-masked]>
To: Nino Kvernadze <[email-masked]>, Volkan Cetinkaya <[email-masked]>
Cc: Tamar Gabunia <[email-masked]>, Tamar Barkalaia <[email-masked]>, Mehek Marwaha <[email-masked]>, "Nino V. Moroshkina" <[email-masked]>, Natalie Godziashvili <[email-masked]>, Djamshid Iriskulov <[email-masked]>, Lia Tavadze <[email-masked]>, Nino Gvenetadze <[email-masked]>, Nino Veltauri <[email-masked]>, Lika Klimiashvili <[email-masked]>, "Alicia C. Marguerie" <[email-masked]>
Date: Mon, 03 Aug 2020 15:32:27 +0000

Dear Nino,

Many thanks for submitting the revised POM and for clarifying our questions in the email below.

The revised POM has addressed some comments and was enriched with new information. We have deleted the addressed comments and left the comments that require elaboration in the write-up. In addition, for your consideration we had edited
in track change to add information as per our knowledge based on the several amendments of Resolution #286.

Nonetheless, the verification protocols for the disbursement of the cash transfers - especially the new ones (unemployment benefit and one off benefits) - need to be clearly defined in the POM as well as the PIU’s random checks and the
required evidence to be provided while submitting the reimbursement applications. There are guiding questions that may hep you fill the missing information.

As previously offered, Nino Moroskina and Djamshid are available to help you complete the draft by helping gather the information to address all the comments. They can also check the POM before iit is submitted to TTLs to confirm that all
comments are elaborated in the text.

Regarding the internal audits, while it was agreed during the negotiations that the Project will be included in the annual audit plan of internal audit department of MoILHSA, we had not received confirmation. The internal audit are crucial
for ensuring controls over flow of funds.

Kind regards,

Maddalena

From: Nino Kvernadze

Sent: Thursday, July 30, 2020 7:08 PM

To: Maddalena Honorati ; Volkan Cetinkaya

Cc: Tamar Gabunia ; Tamar Barkalaia ; Mehek Marwaha ; Nino V. Moroshkina ; Natalie Godziashvili ; Djamshid Iriskulov ;
Lia Tavadze ; Nino Gvenetadze ; Nino Veltauri ; Lika Klimiashvili

Subject: RE: POM and related questions

[External]

Dear Maddalena,

Good evening. When I saw your question, I was trying to find the chart N2 (p19) in POM which explains the compensation process of  informal and formal workers and I accidently found out that I have sent the morning version (july 29)of POM,
the dates were the same, However this was the wrong version.

If you compare you will find out the chart I am refereeing to is missing from the previous version.

I am truly sorry for that and please use currently enclosed one.

As for the question, there are three basic information an applicant should upload: the Name, Personal ID number and a bank account. Meaning that everybody who wants get temporary assistance must have a bank account during the application
submission process.

If your question is more on human rights side, even if a person feels ill and is unable to go to the bank and open an account, there is a special service, which is absolutely free and the Bank’s  staff can visit this person at home and
help to open an account, if requested.

Hope that I could answer your question.

Best regards,

Nino

From: Maddalena Honorati <[email-masked]>

Sent: Thursday, July 30, 2020 9:48 AM

To: Nino Kvernadze <[email-masked]>; Volkan Cetinkaya <[email-masked]>

Cc: Tamar Gabunia <[email-masked]>; Tamar Barkalaia <[email-masked]>; Mehek Marwaha <[email-masked]>;
Nino V. Moroshkina <[email-masked]>; Natalie Godziashvili <[email-masked]>; Djamshid Iriskulov <[email-masked]>;
Lia Tavadze <[email-masked]>; Nino Gvenetadze <[email-masked]>

Subject: RE: POM and related questions

Dear Nino,

Many thanks for the revised POM and for clarifying and responding to our questions below. We will start the review right away and get back to you the sooner.

Related to bank accounts, it is good practice to pay benefits through bank accounts and we understand it is pretty simple and cheap to open a bank account in Georgia. We understand also that the majority (95%) of formal workers have bank
accounts (with remaining 5% without) and that TSA is paid mostly through post offices.  Are there alternative payment mechanisms in case informal workers who apply for the one off benefits do not have a bank account and/or formal workers laid off do not have
a bank account? Have you encountered such cases so far?

Kind regards,

Maddalena

From: Nino Kvernadze <[email-masked]>

Sent: Wednesday, July 29, 2020 10:15 PM

To: Maddalena Honorati <[email-masked]>; Volkan Cetinkaya <[email-masked]>

Cc: Tamar Gabunia <[email-masked]>; Tamar Barkalaia <[email-masked]>; Mehek Marwaha <[email-masked]>;
Nino V. Moroshkina <[email-masked]>; Natalie Godziashvili <[email-masked]>; Djamshid Iriskulov <[email-masked]>;
Lia Tavadze <[email-masked]>; Nino Gvenetadze <[email-masked]>

Subject: POM and related questions

[External]

Dear Maddlena,

Dear Volkan,

This is to inform you that we have tried to respond to all your questions and fill the document  with information as much as we could.  Since the process from your side might still feel difficult
to understand, because there are many supporting documents (resolutions, amendments, instructions, orders, etc ) which describes the whole process separately, we suggest to have a call with involved parties and finalize the POM together.

the Annex D was very long, we made it as separate document.  Please also find answers to your questions below. However it is better to see the document first, since you might get better understanding
of the process.

Best regards,

Nino

Questions:

Please clarify what it means for a self-employed to “registered with Revenue Service”: does it people registered for corporate/business taxes ? does it mean individuals
being in the taxpayer database.

Yes  (please refer to the process chart, POM)

We understand there are two cases identified in the online registration system, self employed who are registered and the others We saw indeed separate data monitoring
provided in SSA administrative database (downloaded from the ministry website). However, it seems that the transfer has been made only to self-employed registered. Why? When are the unregistered self-employed receive the transfer?

SSA does not undertint the question. Please refer to the process chart of the POM.

We understand that registration for the one-off benefit was only allowed up to July 1st . Please confirm if this is the case and whether there are plans to extend
the window for application.

Extended until August 1st.

Grateful if you could please provide information on the registration process for self-employed (in particular whether help was provided for opening bank accounts
to those who do not have one, and whether the information campaign made it clear that informal workers should not be worried to register).

Self-employee submits an application while registering, to the RS. If its formal. If informal, no registration at RS is needed. For example nannys, they do not pay taxes,
hence if they lost their job because of the covid 19, they would need only a contract as an evidence and this information should be submitted to SESA, not the RS. The special commission will discuss the evidence and within 10 days the compensation will be
paid.

As for the bank accounts, there is established experience that all state allowances are transferred through bank transfers. In addition, there is an instruction available
and widely spread information how to register in the system and that everyone needs a bank account. In case of need, people are assisted to open a bank account.

It remains unclear how the final status of “specified status” people (self employed who provided documents, but the documents are not clear enough to decide whether
they are eligible or not) is decided.

Specified statuses are given to those, when for example the dates are missing, or terms.

Commission makes decisions in accordance with the criteria’s defined in the Res. N 286

In case the applicant is not in the taxpayers database and bank account info is correct –  is he required to register and pay taxes? The question
relates to what was written on the registration process in one of the manuals you sent us  “ii. If the bank account is correct, a message will be issued, please register the type of economic activity for registration and upload the documents proving self-employment.
Then click the Finish button”

This is for informal workers, meaning that this person will register economic activity as it was and the commission will make a decision whether this
activity is eligible.  This type of applicant does not need registration in RS. They only need accurate evidence.

Temporary benefit for vulnerable households (with score between 65,000 and 100,000)

Please confirm  whether the temporary benefits is only for households with score between the 65,001 and 100,000 who were in the SSA database before May 1st or it
is also for  households  that have registered in the database after May 1st  and are assessed with score in that range (we understand it takes a month to compute and verify the score) –  yes, but also families who are under 100001 and have three or more children
between 0-16 ages.

If  who register after May 1st are eligible to the temporary benefit, please clearly define the eligibility window: for example, as for the one-off benefit, would
families who register before July 1st and are subsequently assessed with eligible score be eligible to the temporary benefit?

The time has extended until August 1st.

Unemployment benefit

We noted from the data monitoring table in SSA administrative database (downloaded from the ministry’s website) that about 150,000 forma employees have been laid
off in May and June. This is a pretty high number corresponding to about 9% of the labor force in Georgia. Are these numbers confirmed by Revenue Service? Do you have more information on the sector of the employer and size of employer/firm.

This is a question to the revenue service. As for the numbers, this is a recent figure 146,287

As above, please clarify/confirm the eligibility criteria: are only workers laid off between May 4th and July 1, 2020 eligible to the benefits?

Eligible: April, May,June

o
Is yes, is there a plan to extend the window of eligibility?

The Ministry does not know yet.

From: Maddalena Honorati <[email-masked]>

Sent: Tuesday, July 28, 2020 4:38 PM

To: Nino Kvernadze <[email-masked]>

Cc: Volkan Cetinkaya <[email-masked]>; Mehek Marwaha <[email-masked]>; Nino V. Moroshkina <[email-masked]>

Subject: RE: Meeting on July 15th at 2PM Tbs time

Dear Nino,

I hope this email finds you well.

We look forward to receiving the revised POM and appreciate an update on it and questions raised.

Thanks in advance

Maddalena

From: Nino Kvernadze <[email-masked]>

Sent: Thursday, July 23, 2020 7:42 PM

To: Maddalena Honorati <[email-masked]>

Cc: Volkan Cetinkaya <[email-masked]>; Mehek Marwaha <[email-masked]>; Nino V. Moroshkina <[email-masked]>

Subject: RE: Meeting on July 15th at 2PM Tbs time

[External]

Dear Maddalena,

I understand your concerns. The problem is that the group which was working on data covenants in SESA and SSA is the same group who should send us the description of the FM structure in POM. It has been a tough
week for all of us, documents and questions, and indications back and forth. Plus the project procurement  and  FM. Unbelievable number of information and documents was shared and processed.  I have just received the first draft of the WP on data covenant.
Will review and send it for translation, just to make sure you receive it on Monday. As for the POM, we of course can send you it tomorrow, but from my point of view, if we give them this weekend, together with Nata, they will  analyze the FM process well,
and I am sure we  will have better document on Monday.

In addition I have received  ESMF + LMP as well. SEP is under review. We have tried to involve everyone who should be reviewing these documents.  Both deputy ministers are assisting us in the project implementation
and I believe we will finalize all the documents really soon and move to the next step.

Give me tomorrow and will inform you during a day on POM and the questions you have raised in your previous email.

Best regards,

Nino

From: Maddalena Honorati [mailto:[email-masked]]

Sent: Thursday, July 23, 2020 7:38 PM

To: Nino Kvernadze <[email-masked]>

Cc: Volkan Cetinkaya <[email-masked]>; Mehek Marwaha <[email-masked]>; Nino V. Moroshkina <[email-masked]>

Subject: FW: Meeting on July 15th at 2PM Tbs time

Importance: High

Dear Nino,

Just a quick check in as we are unclear on several aspects of the design and verification processes of benefits under the SP components (some questions in the email below, others in the last version of the POM sent). We understand you are
working hard to clarify those in the POM, and look forward to the revised draft tomorrow.

We may need to raise these questions with Tamila and Tamar if we do not get answers by tomorrow.

Looking forward to hearing from you,

Maddalena

From: Maddalena Honorati

Sent: Tuesday, July 21, 2020 7:15 PM

To: Nino Kvernadze <[email-masked]>; Tamar Barkalaia <[email-masked]>

Cc: Lela Ghongadze <[email-masked]>; Alicia C. Marguerie <[email-masked]>; Djamshid Iriskulov <[email-masked]>;
Natalie Godziashvili <[email-masked]>; Lia Tavadze <[email-masked]>; Volkan Cetinkaya <[email-masked]>;
[email-masked]

Subject: RE: Meeting on July 15th at 2PM Tbs time

Dear Nino,

Many thanks. These are excellent news. We look forward to both revised POM and first draft of the Action Plan.

We had reviewed the documents Nino M. sent and we have still some clarification questions ( some  of the questions are included in the draft POM also and we hope are addressed in the revised POM you are working on).  I copy DM Barkalaia
for her information and inputs.

One-off benefit / informal workers and self-employed:

Please clarify what it means for a self-employed to “registered with Revenue Service”: does it people registered for corporate/business taxes ? does it mean individuals being in the taxpayer database.

We understand there are two cases identified in the online registration system, self employed who are registered and the others (informal selfemployed or informal workers). We saw indeed separate data monitoring
provided in SSA administrative database (downloaded from the ministry website). However it seems that the transfer has been made
only to self-employed registered. Why? When are the unregistered selfemployed receive the transfer?

We understand that registration for the one-off benefit was only allowed up to July 1st . Please confirm if this is the case and whether there are plans to extend the window for application.

Grateful if you could please provide information on the registration process for self-employed (in particular whether help was provided for opening bank accounts to those who do not have one, and whether
the information campaign made it clear that informal workers should not be worried to register).

It remains unclear how the final status of “specified status” people (self employed who provided documents, but the documents are not clear enough to decide whether they are eligible or not) is decided.

In case the applicant is not in the taxpayers database and bank account info is correct –  is he required to register and pay taxes? The question relates to what was written on the registration
process in one of the manuals you sent us  “ii. If the bank account is correct, a message will be issued, please register the type of economic activity for registration and upload the documents proving self-employment. Then click the Finish button”.

Temporary benefit for vulnerable households (with score between 65,000 and 100,000)

Please confirm  whether the temporary benefits is only for households with score between the 65,001 and 100,000 who were in the SSA database before May 1st or it is also for  households  that
have registered in the database after May 1st  and are assessed with score in that range (we understand it takes a month to compute and verify the score).

If hh who register after May 1st are eligible to the temporary benefit, please clearly define the eligibility window: for example, as for the one-off benefit, would families who register before
July 1st and are subsequently assessed with eligible score be eligible to the temporary benefit?

Unemployment benefit

We noted from the data monitoring table in SSA administrative database (downloaded from the ministry’s website) that about 150,000 forma employees have been laid off in May and June. This
is a pretty high number corresponding to about 9% of the labor force in Georgia. Are these numbers confirmed by Revenue Service? Do you have more information on the sector of the employer and size of employer/firm.

As above, please clarify/confirm the eligibility criteria: are only workers laid off between May 4th and July 1, 2020 eligible to the benefits?

Is yes, is there a plan to extend the window of eligibility?

Looking forward to hearing from you,

Maddalena

From: Nino Kvernadze <[email-masked]>

Sent: Tuesday, July 21, 2020 2:06 PM

To: Maddalena Honorati <[email-masked]>; Volkan Cetinkaya <[email-masked]>;
[email-masked]

Cc: Lela Ghongadze <[email-masked]>; Alicia C. Marguerie <[email-masked]>; Djamshid Iriskulov <[email-masked]>;
Natalie Godziashvili <[email-masked]>; Lia Tavadze <[email-masked]>

Subject: RE: Meeting on July 15th at 2PM Tbs time

[External]

Dear Maddalena,

We are working within the Ministry to finalize the financial process description of POM. Not sure with the exact deadline, but Friday is the latest. However it can be tomorrow as well, depending on the availability
of time of our colleagues.

As for the data covenants, we had a very fruitful meeting and the first draft of the Action Plan,  which is in Georgian yet, is already prepared. It is under internal  review now. As you know PIU is facilitating
the process. The tentative deadline is as follows: Finalization of the first draft – Thursday 23,

Translation – Friday -24, Submission to the WB  – Monday 27.

Hope this response is useful at this stage.

Best regards,

Nino

From: Maddalena Honorati <[email-masked]>

Sent: Tuesday, July 21, 2020 3:51 PM

To: Nino Kvernadze <[email-masked]>; Volkan Cetinkaya <[email-masked]>;
[email-masked]

Cc: Lela Ghongadze <[email-masked]>; Alicia C. Marguerie <[email-masked]>; Djamshid Iriskulov <[email-masked]>;
Natalie Godziashvili <[email-masked]>; Lia Tavadze <[email-masked]>

Subject: RE: Meeting on July 15th at 2PM Tbs time

Dear Nino,

Following up on the meeting last week, could you please update us on the status of the revised POM and when you will be able to share the final one addressing all our comments?

Also please let us know if the WB on the personal data protection met last week and which are the next steps and timeline.

Looking forward to hearing from you,

Maddalena

From: Nino Moroshkina <[email-masked]>

Sent: Tuesday, July 14, 2020 9:43 AM

To: Maddalena Honorati <[email-masked]>; Volkan Cetinkaya <[email-masked]>

Cc: Lela Ghongadze <[email-masked]>; Alicia C. Marguerie <[email-masked]>; Nino Kvernadze <[email-masked]>;
Djamshid Iriskulov <[email-masked]>; Natalie Godziashvili <[email-masked]>; Lia Tavadze <[email-masked]>

Subject: Meeting on July 15th at 2PM Tbs time

[External]

Dear Colleagues,

As agreed, we will be having the meeting tomorrow, July 15th at 2 PM Tbs time.

There are two main topics to discuss:

1. Finalization of the POM

2. The Global Reimbursement Manual

I will be going to the ministry.

Lela will send us the Webex invite shortly.

Please feel free to expand the list of participants for the meeting.

Best regards, Nino