This post discusses a set of issues with Evidence Action’s No Lean Season program. No Lean Season is a former GiveWell top charity and GiveWell Incubation Grant recipient. It is now shutting down. Evidence Action discusses its decision in this blog post.

Here, we share a significant amount of detail about this decision and the factors that contributed. Proactively sharing detailed information about a charity’s shortcomings may be unusual, but it is core to GiveWell’s mission. We are dedicated to transparency about our recommendations—the good and the bad.

Evidence Action has reviewed this post, and we’ve discussed our thinking at length with its senior leadership; however, the views expressed are our own. We have been impressed with Evidence Action’s commitment to transparency and continue to support its other work. These updates have not substantially changed our view of Evidence Action; we expect large programs to experience problems, to a certain extent. We believe Evidence Action responded to these problems responsibly, although we have several open questions.

Summary

Evidence Action is shutting down No Lean Season, a former GiveWell top charity that distributed no-interest subsidies to support seasonal migration in Bangladesh.

As we have discussed previously, a study of the No Lean Season program in 2017 found disappointing results; this led to our removal of No Lean Season, in agreement with Evidence Action, from our list of top charities.

In early 2019, Evidence Action’s senior leadership received allegations that a junior employee of the government agency in Bangladesh responsible for approving the No Lean Season program allegedly forged the government approval, allegedly in collaboration with an employee of the program’s implementing partner. The government agency allegedly later asked the implementing partner for a bribe to grant approval of the program. Senior leadership at Evidence Action then began an investigation that was largely unsuccessful in its attempts to learn more due to lack of full cooperation from the implementing partner. Evidence Action terminated its relationship with the implementing partner as a result. Evidence Action’s senior leadership also found that some Evidence Action program staff who worked directly with the partner did not fully cooperate with its investigation and had violated internal Evidence Action policy.

Evidence Action decided to shut down No Lean Season because the cost of finding and supporting a new implementing partner was too high, given the disappointing 2017 study results.

Separately, Evidence Action also informed us of a tragic accident involving migrants from households that had received No Lean Season subsidies. We do not believe this contributed to the decision to shut down No Lean Season, but we are sharing it in this post as the investigation into this accident recently concluded.

We will provide additional information on the following in this blog post:

• We outline below the factors contributing to Evidence Action’s decision to shut down its No Lean Season program (More):
  • The disappointing 2017 study of the program at scale. (More)
  • Evidence Action’s termination of its partnership earlier this year with the organization implementing the program in Bangladesh. After learning of the alleged improprieties (referenced above) in February 2019, senior leadership at Evidence Action began an investigation, conducted by external, independent legal counsel. Given the seriousness of the original allegations, Evidence Action also terminated its contract with the partner. The implementing partner largely refused to cooperate with the investigation, and as a result Evidence Action will not reengage with this partner in the future. (More)
• In the course of its investigation, senior leadership at Evidence Action found evidence of an approximately $400 payment by an Evidence Action program staff member that violated its internal policies, as well as contradictory and potentially misleading statements made by some program staff members to investigators. This finding was not material in the decision to shut down the program, as the implementing partner’s lack of cooperation was already known at that point. (More)
• We summarize the findings of the investigation into the accident involving migrants whose families had received subsidies from the program. (More)
• We do not see any of the above issues as a significant update on Evidence Action as an organization. We expect challenges when working in international development, and think senior leadership at Evidence Action responded responsibly to address these challenges. We do retain open questions about Evidence Action’s selection of implementing partners and its process for hiring and evaluating staff. Finally, we and Evidence Action agree that it should continue to strengthen its financial controls going forward. (More)
• Evidence Action expects No Lean Season to have some funding remaining after the program fully closes out. We expect to ask Evidence Action to redirect the remaining funding it received from GiveWell for No Lean Season to Evidence Action’s Deworm the World Initiative, a GiveWell top charity. We (and Evidence Action) will also take into account donors’ preferences for reallocating this funding; we provide instructions for donors who supported No Lean Season to communicate their preferences to us below. (More)

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