Introducing Olga Wall: Lost in Regulation
Olga Wall is Chief of Compliance and Contract Administration at Palladium, where she oversees an annual budget of around $165 million across diverse international procurement and assistance portfolios. Her conversation with Humentum was a chance to get to know the person behind the “Lost in Regulation” blog, which Olga began over a decade ago, and which you can find today on LinkedIn. Her aim is to explore compliance and best practices for USAID grantees and contractors. In the first part of this interview, below, Olga shares her story, including early work for the BBC and as a USAID program manager in both Afghanistan and Iraq.
HUMENTUM: Olga’s career began in TV as a line producer and translator from her native Russian on a BBC natural history documentary series, The Realms of the Russian Bear.
OLGA WALL: It focused on different parts of the former Soviet Union, the animals and the plants, but with a focus on different bears that lived throughout the Soviet Union. I had a very fortunate experience of joining that crew as a line producer.
HUMENTUM: Though filming bears may seem to have little in common with her current role, Olga sees a common thread in terms of being aware of the wider world, sharing knowledge, and exercising empathy. A few years after that TV experience, she found herself engaging her analytical skills as part of a new venture from KPMG subsidiary, the Barons Group.
OLGA WALL: This was the time when European bank reconstruction was coming upand all these foreign donors and national financial institutions that were pouring money into the former Soviet Union and then into Eastern Europe and Central Europe to try to do privatization in different projects, and so they decided to open the office in London because they wanted to deal with European donors (they have already been working with USAID). So to me, I was looking for the next thing and that just sounded amazing, and so that was a lot of fun, that was basically creating an office and bringing in a lot of American development experts who wanted to bid on projects with EBRD and UNCLEAR.
HUMENTUM: I guess a lot of people find the regulations a headache, something they’re afraid of, they only engage with it [them] when they absolutely have to with gritted teeth. But you clearly take a sort of—is it an intellectual pleasure, is it seeing the big picture and how it fits in, is it something about your mindset?
OLGA WALL: It may be partially because of the experiences and where I came from, where I grew up, you know I’ve seen a lot of bad regulations. I’ve seen a lot of regulations that don’t apply to everyone, that apply selectively to people, and they don’t really make sense because they’re not there to make sense.
I find the regulations that are applied to foreign aid, for example, if you actually research the ‘why,’ it actually starts to make a lot of sense. It starts being fun because you get to research where something came from, why somebody decided it was a good idea, and why so many other people sign onto the decision. I find it intellectually stimulating. I also find it—it’s fun for me to break it down, and take it down to the basic level, because a lot of people see it at the end. They see it as the 2800 pages of federal acquisition regulations and they think, ‘well, this is ludicrous, why would we have to comply with this.’ But if you find out why they’re there, a lot of the regulations actually end up making a lot of sense in terms of fiscal responsibility and accountability to the taxpayers, and maybe favoring some of the smaller business and socioeconomic programs, and they’re really representing the best practices our countries have in managing taxpayer funding.
Mind you, not all of the regulations out there make sense. I think there are a lot of things that are outdated, that just no longer apply.
HUMENTUM: Do you see the USAID regulation system as being necessary complexity given the complexity of the different models?
OLGA WALL: AIDAR (USAID Acquisition Regulation) hasn’t been rewritten since 1984, so I do think it’s a little outdated. It was written for a different time, there was a very different agency that was dealing with those regulations, and they had very different acquisition and assistance staff, the contracting and agreement officers, and it was a very different community on the other side, it was a much smaller community, and the contracts were not nearly as huge as we have now. You know, if you got a $1 million contract 20 years ago, this was a huge win for anybody dealing with USAID. Now, you know, people don’t get out of bed for less than $100 million, which, you know, it’s just this sign of times.
So, I do think they need to be re-hauled, they need to be simplified, they need to be streamlined. Some of stuff that’s there, it’s good, it does address some of the parameters under which the foreign aid is being provided. It’s also forcing the contractors to exhibit best practices of the American business, if you will, this is how I look at it.
HUMENTUM: You had a number of years working as a USAID program manager, which involved spending time in Afghanistan and Iraq, and for that kind of engagement on the ground, how did that change or develop you as a professional and as a person?
OLGA WALL: It was one of those things, actually that is quite relevant now and people talk about it. I’d just had my baby, my first baby, in 2002, and I was on maternity leave and looking to re-engage, you know I had taken the year off and nobody really wanted me, and so I was looking to re-engage and try to go back into the workforce. I started writing little articles here and there and trying to help people understand some of the regulations and I had a lot of time to just sit and read, and so that prompted me to reach out to my former employers and my former colleagues and exchange ideas, you know, this was pre-blog time, so we were just doing it via email.
Then, one of my former colleagues asked me to join this program, which was providing mission support services for the USAID of Iraq, this was when there was no embassy and there was no mission yet, and so I jumped at the opportunity, I had a four month old baby but I thought I mean, why not[CH4] ? This is incredible, this is an incredible opportunity to work inside the agency, being a contractor but working within the agency, and to understand how the agency operates and how they field personnel and what those people go through in managing the programs that we implement.
So this was an incredible experience from that standpoint—it gave me that 360 understanding of how the programs are managed and what challenges people on the government side go through in managing the programs.
HUMENTUM: That period was the period when very large sums of money were beginning to be spent by the US in both Iraq and Afghanistan. That, and the volatility of the situation, did they really accentuate the challenges?
OLGA WALL: This is what a lot of the relief agencies deal with all the time, you know, they don’t go into nice, stable, middle-class countries to help, they go where there is conflict or hunger or disease, whatever. So, this is normal operation mode for a lot of the relief agencies. It does test some of the systems and frameworks and regulations that we do have, because a lot of them, at least in the United States, are really aimed at peacetime, and US companies working.
They don’t take into consideration working in the remote village in Afghanistan, and so you have these regulations that are implemented you have to comply with, but you’re presented with a completely different reality in which you have to comply with. You cannot fill out your timesheet when you’re hiding behind an armored car during an explosion, it’s not a possibility. You’re frightened, and people are not going to do it. This is amplified, and just a microcosm of the challenges, but so I think the regulations need to be flexible in that way. I think other agencies do it better, they may not do the volume that USAID does and so it may not be as challenging, but you know, certainly in the US, I have once called OMB asking them how we would apply regulation in the aid context, and they said ‘well, we never think about aid, you’re sort of an outlier agency, and we write those, we don’t think about you.’ ‘Yes, but we have to comply with it, so please help me, how would you comply with it if you were in this situation?’ They couldn’t answer. They think there’s no need for them to think about those things. AID does have their own regulation, they have AIDR and they have codification of the grant regulations, but I do think they need to really spend time matching it to their realities.
In part II, we’ll discuss Olga’s blog “Lost in Regulation,” her thoughts on USAID compliance systems, and the bigger picture evolution of global regulation.