MHA’s emails for COVID19 response from NGOs

Since the last few days there has been some anxiety within the voluntary sector over a couple of emails received by some NGOs from the Ministry of Home Affairs (FCRA) seeking their (NGOs) assistance in supplementing the government’s efforts in providing relief and rehabilitation to those affected by COVID-19.

Background

First came a letter dated April 1, 2020 signed by the Additional Secretary (Ministry of Home Affairs) addressing recipients as ‘Dear Friend’. This was a very pleasant and refreshing change from earlier communications from the department.

It was even more heartening to read: “It is understood that your association has been making valuable contributions to benefit society in many ways and in the event of outbreak of this pandemic, your outreach and assistance in society may complement government’s endeavours.”

The letter indicated broad areas where NGOs could aid and supplement the efforts of Government and local administration such as, supporting the local administration in setting up community kitchens, particularly for the migrant and homeless population, provide shelter to homeless daily wage workers and poor families without jobs, etc.

The letter has suggested that NGOs should contact local authorities and offer their (NGOs) support to them.

The second letter dated April 7, 2020 is signed by the Director, Ministry of Home Affairs and again addressed to the NGOs as ‘Dear Friend’. We do love and appreciate this friendly approach towards the voluntary sector.

However, in this letter NGOs are “requested” (note the term used is ‘requested’) to provide information regarding their association’s COVID-19 response directly in the online COVID-19 Response Format which can now be accessed on the FCRA login Portal under the tab “Services under FCRA”.

The letter of 1^st April had requested the response by email. However, the email of 7^th April now requests resubmission in the online format.

Questions

There are several questions which have not been made clear by MHA and it would be good if MHA could issue clarifications:

• Why is it that only some NGOs have received these request letters?
• NGOs which have not received these letters and have tried to fill their response online have received a popup stating: “You are not required to fill this form”. This of course came as a relief to those not involved or active in any COVID-19 related activity. But what if the organization is involved or active in any COVID-19 related activity and gets this pop up?
• Are only associations registered or having prior permission under FCRA required to provide this response?

These are questions which require immediate answers.

Where to ask?

Perhaps one way to find out would be by contacting MHA.

In fact the letter of 1^st April 2020 specifically states that the office of Additional Secretary (Ministry of Home Affairs) can be contacted for any consultation or clarification on email jsf@mha.gov.in or dirfcra-mha@gov.in

Coordination or compliance?

NGOs are also keen to know whether this is an exercise in coordinating the effort of the government with the voluntary sector (in the response to COVID-19) or a compliance requirement? It would seem more of the former rather than the latter.

The Government of India has set up a coordinating group for COVID-19 related activities. This group is headed by the CEO of NITI Aayog which is soliciting support of all voluntary organisations, including those registered under FCRA. The two letters from MHA appear to have been sent with a view to request NGOs registered under FCRA to share information regarding how they are addressing or proposing to address this pandemic and help the Government of India.

Next Steps

1. If your organisations has received the letter please file your response online and submit the same by the 15^th of each month starting with the month of April;
2. If you get a popup message stating: “You are not required to fill this form”, do nothing further. Take a screenshot and keep it for the record;
3. If you feel you want to respond despite the popup, you may contact MHA for clarification or support;
4. In response to the email of 1^st April 2020, some NGOs have already emailed the form as requested earlier. These NGOs should now fill up the online form and submit the same before 15^th April and update the form every month with cumulative support provided till the date of submission;
5. It is not clear whether NGOs should report only for FCRA funds or also the local funds;
6.  It would seem NGOs have the choice to report only for FCRA funds or FCRA and local funds. However, while reporting it should be made clear whether the NGO is reporting support from FCRA funds only or both FCRA and local;
7. It would seem that filing this form to report your NGOs spending on COVID-19 is voluntary and not mandatory;
8. However, filing this form could have two possible advantages: a) Letting the government of India know what your NGO and the voluntary sector is collectively doing in terms of helping the government in it’s battle against COVID-19 and b) your NGO could be scoring brownie points before applying for renewal of your FCRA registration;
9. Not filling this form is not likely to invoke any punitive action from MHA