4.4.2.2 Administrative Procedures and Internal Organizational Processes

In addition to the above-mentioned challenges, NGOs also encounter other barriers to implementing disability-inclusive programming. Like United Nations agencies, they struggle with an extremely high staff turnover and respondents confirmed that this had a negative impact on the overall success of their consortia projects, including those with disability-focused organizations. Time and time again, new managers would join and quickly leave their jobs, and technical experts from disability-focused organizations constantly had to work with new staff members. This means that they had to provide ongoing awareness and capacity-building to new staff on disability and disability-inclusive programming. Simultaneously, newly employed technical experts from disability-focused organizations, who were not at all familiar with the terms and conditions of the various projects, had to provide technical support to the various project partners in the field.43 This obviously delayed the implementation of several activities.44 Clearly, these issues could have been avoided if project managers and technical experts stayed in the field for the entire duration of the projects, which, as mentioned in the previous section, currently do not last longer than a year.45 However, sometimes collaboration and implementation issues also stem from the challenge of getting all responsible managers in one room at the same time.46

Even if they stay in Cox’s Bazar for a substantial amount of time, expatriates are regularly on rest and recuperation (R&R)47 and are therefore unable to attend all important project meetings, despite often holding key management positions:

Focus group discussion with an INGO.

So there […] was a requirement that each organization has to develop an action plan to mainstream disability into their current programme. But, actually, only officers participated and I think that they came up with something. Yet, I think that it should have come from the management and not from the officers.

Some respondents also complained that many humanitarian workers were too busy to follow up on e-mails in a timely manner.48 Moreover, it is not easy to secure a long-term visa, and therefore, many positions in the NGOs are vacant, leading those employed in Cox’s Bazar to juggle two or more jobs at the same time. This makes it difficult to coordinate activities, schedule training and develop strategic visions of how to include persons with disabilities in programmes and organizational structures.49 In one consortium project, training for field staff on how to collect disaggregated data with the WG-SS only took place months after the start of the project. The data collected with this tool were only used for reporting purposes and therefore did not inform project-related activities.50

Another factor that prevents disability mainstreaming is the fact that NGOs fail to share their experiences across different departments. Field staff complained about the lack of cohesion within the organizations and claimed that "unless you were forced to work with other sectors, it would not really happen".51 Consortia projects only focus on specific sectors and hence only target specific staff in the organizations. This means that practices to include persons with disabilities may improve in one specific sector of the organization but not within another. Clearly, it is impossible for disability-focused organizations to provide training and technical support to all sectors. Instead of working in silos, the management therefore needs to ensure that experiences are shared across different levels and organizational departments. This requires structured and regular exchange, which may be difficult to achieve in such a dynamic environment. Sometimes the consortia projects themselves do not function well and there is little collaboration between consortia members. Some interlocutors explained that organizations that have the same donor failed to establish a common monitoring framework and continue working independently from the other members. This makes it difficult to mainstream disability throughout the consortia. Instead, disability-focused organizations provide a few individual members with technical support on disability-inclusive humanitarian action on an individual basis.

Finally, NGOs also face some bureaucratic hurdles that can result in institutional barriers to disability inclusion. As stated, most INGOs increasingly face difficulties in securing long-term visas for their expatriate staff and many organizations had staff working remotely from their official places of residence outside of Bangladesh.52 This implies that these employees cannot physically participate in consortia meetings, training and other relevant activities to foster the inclusion of persons with disabilities. Moreover, regulations for the NGO community create a high administrative workload for the organizations and limit their ability to improve disability-inclusive practices, including reaching out to persons with disabilities.

One respondent mentioned that:

Interview 31, representative of an INGO.

Every six months you have to get a new approval for your activities. And you also have to report every month on these activities to the Government. Moreover, you have to submit a completion report after the six months, in addition to all your other reporting, so it is a lot of administrative work. And if you have a project that is longer than six months, let’s say you have a nine-month project, you have to re-apply for permission after six months, even though it is for nine months of funding.53

Since February 2020, the NGO community also have to apply for official RRRC ID cards to access the camps and register their vehicles when entering and leaving the camp areas. There has been considerable miscommunication about the procedures and the application process is time-consuming.54 Although there is no direct connection to the inclusion of persons with disabilities, it is clear that such regulations and their concomitant administrative workload take up time that could be spent on capacity-building, technical support, development of disability-inclusive action plans and related activities.

Sometimes NGOs also experience delays in the approval of their interventions, which can cause implementation to be delayed and work to be rushed. In the process, inclusion is sometimes overlooked. This also affects consortium projects with disability-focused NGOs.

One interview partner elaborated:

Interview 10, representative of an INGO.

Officially, the consortium project was supposed to start in April. But in reality, it started in June. However, only one INGO managed to start in June. The other organizations of the consortium struggled with government approval issues and started implementing activities in October/November last year. One INGO is still not on board due to not having government approval [...]. So right now, they participate in the working group meetings and steering committee meetings and take part in decision-making, but they will only start field level implementation, I think, by the end of January.

It is therefore crucial that all NGOs are well prepared and submit their application form as soon as possible so that their projects can be approved on time.55

This overview of government regulations for NGOs is by no means exhaustive and, as mentioned, with the outbreak of the COVID-19 pandemic in early 2020, many humanitarian and human rights organizations have criticized the Government of Bangladesh for restricting humanitarian activities in the camps (Human Rights Watch 2020a; Human Rights Watch 2020b; Reliefweb 2020). These administrative procedures and regulations hamper ongoing activities and limit the time that NGOs can invest in capacity-building of their staff and developing inclusive action plans that can be applied across all their operations.

Overall, NGOs in Cox’s Bazar recognize the importance of including persons with disabilities in humanitarian action. All respondents were positive about the cooperation with HI, CBM or CDD and the technical support they received within the framework of the consortia projects. However, this section shows that NGOs encounter many obstacles that prevent them from systematically including persons with disabilities in their programmes and organizational structures. While NGOs started collecting disaggregated data, made efforts to build accessible latrines and service points, and even developed action plans for specific sectors, they continue to lack a clear vision of how they will become inclusive. The reasons are manifold but the lack of time due to short funding cycles and a high administrative workload, as well as considerable turnover of international staff at management level, represent the biggest obstacles for a strategic approach. This also applies to disability-focused organizations, which also struggle with visa applications, recruitment of qualified staff and limited time and resources. Problems in disability-inclusive humanitarian action will persist until these structural issues are resolved.