USAIM — Seasonal Migration from Haiti

A beneficiary of the International Organization for Migration (IOM), USAIM’s implementing partner, works on a soil conservation project in the Vallee de Jacmel area in Haiti. (Photo courtesy of IOM)
Award Date 
7/2014
Grant Amount 
$1,490,505
Purpose 
To support a pilot project to facilitate Haitian access to legal seasonal work in the U.S.
Topic (focus area) 

First published August 2014; updates below.

International Organization for Migration (IOM) staff reviewed this page prior to publication.

Note: This page was created using content published by Good Ventures and GiveWell, the organizations that created the Open Philanthropy Project, before this website was launched. Uses of “we” and “our” on this page may therefore refer to Good Ventures or GiveWell, but they still represent the work of the Open Philanthropy Project.

A proposal submitted by the International Organization for Migration (IOM) and the U.S Association for International Migration (USAIM) describes the proposed grant, which would involve a pilot program to give Haitians access to seasonal work visas in the U.S. The total amount requested is $1,490,505 over 14 months.

Temporary seasonal workers in the U.S. earn far more money than unskilled workers in Haiti, so giving Haitians access to U.S. labor markets could substantially increase their income. After being removed from eligibility for H-2 (lower-skill, seasonal work) visas in 2009 due to widespread abuse, Haiti was reinstated in 2012. However, few legitimate U.S. employers have recruited Haitians to use H-2 visas since then. The project aims to to recruit employers for a pilot with 100 Haitian workers, to facilitate the workers’ access to H-2 visas, and to ensure compliance with H-2 visa terms so the visa access will be sustainable. The project also includes the first rigorous evaluation of a U.S. labor facilitation program. Our understanding is that employers for the 100 Haitian workers are likely to be found and they are likely to be able to receive H-2 visas, but we have less confidence that the program will be sustainable beyond the pilot stage or that compliance with visa terms will be high enough to ensure Haiti’s continued access.1 We see the possibility that the program results in many Haitians being able to take advantage of H-2 visas in the coming years, in addition to the benefits of the evaluation and our learning benefits, as sufficient to justify the grant.

Based on these considerations, Good Ventures decided to grant a first tranche of $450,655, and to conditionally commit a second tranche of $1,039,849 (depending on employers being identified for the pilot group of 100 Haitian workers and evidence that they will be able to obtain H-2 visas).

Proposal summary

The following summary is based on documents that the IOM shared with us in the process of proposing this grant, including:

Due to widespread abuse, Haiti was removed from the list of countries eligible for H-2 visas, which are the main mechanisms allowing lower-skill temporary workers legal access to the U.S. labor market, in 2009.4 In 2012, partly as a result of advocacy by the Center for Global Development, the U.S. government once again included Haiti in the list of eligible countries.5 However, very few H-2 visas have since been issued to Haiti—just 59 in 2012 and 14 in 2013.6 Legitimate employers have expressed very low demand for H-2 workers from Haiti, and there have been concerns about illegitimate use of the visa, which would increase the exploitation risk for migrants and the administrative burden on US consular staff and immigration officers.7 The goal of the proposed work is to pilot a program that familiarizes US employers with Haitian workers and ensures sustainable and legitimate uptake of the visa.

The proposed work involves collaboration between five groups:8

  • The U.S. Association for International Migration (USAIM), a registered 501(c)(3) nonprofit organization in the United States that supports the IOM, which will officially administer the grant.
  • The International Organization for Migration (IOM), which will lead the project in Haiti. The IOM is a large international organization with a long track record training migrants.9
  • The Center for Global Development (CGD), which will conduct an evaluation of the program to assess its impact.
  • Protect the People (PTP), a contractor that will lead efforts to recruit employers and to monitor the seasonal workers while they are in the U.S.
  • Haiti’s National Office for Migration (ONM), an implementing agency within Haiti’s Ministry of Social Affairs and Labor (MAST), which will be responsible for authorizing recruiters and potentially continuing the program beyond the pilot phase.

The project aims to recruit U.S. employers for an initial group of 100 Haitians to use H-2 visas for seasonal work in the U.S. and ensure that they comply with their visa requirements so that other Haitians can continue to use H-2 visas in the future. The project also includes an evaluation of the impact of participation on the Haitian workers and their families, and a number of other elements.10 Work is divided into three phases:11

  1. Preparation: coordinating between actors, recruiting employers and recruiting potential employees.
  2. Seasonal migration: orientation for workers, travel to the U.S., monitoring, return to Haiti.
  3. Follow up: impact evaluation, community development projects.

Funding is expected to flow in two tranches:12

  1. $450,655 to cover the preparation phase of work, estimated to take 4 months. This total includes roughly $150K for IOM staff and office costs in Haiti; roughly ~$110K for PTP for recruiting employers; roughly $90K for IOM for a stakeholder workshop, sensitization campaign (about the dangers of irregular migration), and vehicles and drivers; roughly $50K for CGD for initial evaluation costs; and roughly $50K for IOM and USAIM overhead.
  2. $1,039,849 for the seasonal migration and follow up work, estimated to take 10 months. This tranche of funding is conditional on the successful completion of the preparation work, in particular the identification of U.S. employers planning to hire 100 Haitian workers and evidence that the workers will be able to obtain H-2 visas. This total includes roughly $380K for IOM staff and office costs in Haiti; roughly $190K for PTP for monitoring and travel; roughly $200K for IOM for training of ONM staff, vehicles and drivers, and monitoring of sending communities; roughly $50K for CGD for final evaluation costs; roughly $140K for IOM for community projects and monitoring costs upon return; and roughly $80K for IOM and USAIM overhead.

To ensure that H-2 visa holders comply with the terms of their visas, the project will feature a number of efforts, including:13

  • a pre-selection process for workers that engages “local community leaders” who know their families.
  • a “community rotation scheme” in which members of a community are allowed continued access to the H-2 program only if previous members of the community have complied with their visa terms.
  • regular monitoring visits by ONM officials to the families of workers who are in the U.S.
  • support for community-based projects and small businesses for returning migrants who complied with visa terms.

By demonstrating high rates of compliance with visa requirements, the project aims to ensure sustainable Haitian access to H-2 visas.

Rationale for making the grant

Background

We have identified labor mobility as a priority cause, and as such have prioritized it for possible “learning grants”. As part of our search for potential grant opportunities, we spoke with Michael Clemens at the Center for Global Development, the most prominent advocate for this cause that we know of. Dr. Clemens suggested that we support this project, and put us in touch with IOM representatives.


Case for this grant

The gains to a Haitian worker from receiving an H-2 visa appear to be quite large: unskilled agricultural workers in Haiti make around $1,000 a year, while H-2A visa holders in the U.S. make around $20,000 per year.14 However, Haitians who come for the project are unlikely to stay for a full year, and they seem likely to bear some additional costs in the U.S. Net of costs, we might expect a Haitian worker who is able to come to the U.S. on an H-2 visa to make about $10,000 more than they would in Haiti.15 Accordingly, if the project succeeds in its initial goal of getting 100 Haitians H-2 visas and jobs, the additional income to Haitians in the first year would be about $1 million.

The project also seems to have considerable upside. If overstaying and abuse of H-2 visas are limited and Haiti continues to have access to H-2 visas, many more Haitians may be able to take advantage of the H-2 program in the future. Haiti sent roughly 500 people to the U.S. on H-2 visas in 2008 and 2009 (before it was removed from program eligibility), suggesting that that may be a realistic level to expect if legitimate employers begin using the program.16 500 is also roughly the mean annual number of H-2 users from countries in the Americas in 2012 that had at least one user (excluding Mexico, which is a substantial outlier).17 If 500 Haitians per year were able to use H-2 visas, their total income gains over a 10 year period would be around $50 million. While we think it is relatively unlikely that the project will result in such long-run gains, the benefits if it does appear substantial.

That said, it is not at all clear how to weigh the wages earned by Haitian H-2 visa holders. It seems fairly likely that at the margin Haitian H-2 visa holders are displacing irregular immigrants or H-2 visa holders from other countries, either of which would likely considerably undercut the social benefits of increasing access to the H-2 program and make “wages earned by Haitian H-2 workers above what they would have earned in Haiti” a poor proxy for “net transfers to low-income people.” Although it is difficult to understand the appropriate counterfactual (i.e. what would happen in the absence of Haitian workers using H-2 visas), Haiti is the poorest country in the Western hemisphere, with a GDP per capita in purchasing power parity terms 1/10th of Mexico’s and more than half of the population below the $1/day poverty line in 2001.18 This suggests that to the extent that Haitians are replacing other workers, the result is a progressive transfer (i.e. the wage gains from H-2 access are transferred to a population that was poorer than the counterfactual recipients were prior to receiving them). Additionally, Haitian H-2 visa holders might be expected to remit a larger portion of their earnings to poor compatriots.19 Our current best guess is that Haitian H-2 workers would mostly displace irregular immigrants or H-2 visa holders from other countries, but that ensuring continued Haitian use of the H-2 visa could eventually lead to a (very small) net increase in the population working in the U.S.

While we see the wages paid to H-2 workers (and potentially remitted) as the main benefit of this project, there may be others. CGD is planning to conduct an evaluation, which we believe would be the first rigorous evaluation of a U.S. labor facilitation program, and one of only a handful of such evaluations globally. The evaluation could plausibly influence other policymakers in the future, and accordingly may account for a substantial portion of the expected value of the project.20 Unlike the benefits from a stream of income and remittances, the benefits of the evaluation do not strictly depend on Haitians’ continuing to be allowed access to the H-2 program after the pilot.

The first tranche of funding will cover the initial efforts to get the program started and to identify one or more employers to hire the 100 pilot program workers. Conditioning the second tranche of funding on the the identification of employers planning to take 100 Haitian workers and evidence that they will be able to obtain H-2 visas limits some of the downside risk, though notably not the risk that the program is unsustainable after the pilot ends.

Because it is a fairly short-term pilot, this project also offers opportunities for learning: we expect to know whether visas will be granted and employers are found within about 6 months, and the sustainability of the program and the results of the evaluation within a year from that.

Room for more funding and fungibility

We believe that this project is unlikely to receive funding from another source—or take place without outside funding—if we do not support it. IOM and CGD staff have approached multiple bilateral and multilateral funders since Haiti was added to the list of countries eligible for access to H-2 visas in 2012, and have not found interest in supporting a migration facilitation project.21 We believe this project was only fully fleshed out and formalized because we expressed an interest in potentially supporting it.

Risks to the success of the grant

We see several potential risks to the success of the grant:

  • The project could fail to find one or more U.S. employers that are interested in hiring 100 Haitians to work on H-2 visas. It is difficult to assess this probability in advance, but in the event of failure, only the first tranche of funding would have been committed.
  • The U.S. government could decide not to grant H-2 visas to the workers in the pilot. Our understanding is that this is unlikely, but we do not expect to know for sure until after the first tranche of funding is disbursed.
  • Even if the pilot project succeeds in ensuring that H-2 visa holders comply with the terms of their stay, it is not clear that the program (and high compliance rates) will be sustainable after the pilot funding ends.22 If compliance with visa terms degrade after the pilot ends, Haiti could be removed again from the list of countries eligible for H-2 visas (as it was in 2009). More prosaically, even if Haiti continues to be eligible for H-2 access, legitimate U.S. employers may not pursue many Haitian workers, so the stream of Haitians using H-2 visas in the future may be quite small.23
  • We generally see this as an ambitious project working in a complex environment, and expect that it could fall short of our expectations in any number of unanticipated ways. Our contact on the IOM Haiti staff has changed twice during the course of our consideration of this grant, and a government reshuffle in Haiti led to the replacement of the previous Director General of the National Office for Migration (ONM).24 We had not anticipated these obstacles to the project prior to their occurrence, and we would guess that there are other important potential obstacles that have not occurred to us.
  • We would not say that we fully share IOM’s vision for the project, so it seems possible that in response to an unanticipated barrier, they would respond differently than we would like. For instance, the metrics described in the proposal are not the main ones we expect to use to assess the project’s success, and the proposal characterizes the goals of the project somewhat differently than we would, e.g. by focusing more on the immediate impact on the communities of the pilot workers, and less on the potential sustainability of the program or access to H-2 visas, than we would.25 That said, we believe that we have a reasonable level of shared understanding about the specific work proposed.

We see a fairly high probability of being able to find out which of these risks end up occurring, which is unusual relative to many of our other grants.

Conclusion

We see the main rationale for this grant as the possibility that it will eventually lead to many Haitians using H-2 visas for temporary work in the U.S. We see this scenario as relatively unlikely, but we believe that the possibility, in addition to the benefits of the evaluation and our learning benefits, justify the cost. We also see this as a useful test for a broader potential “migration facilitation” focus area within labor mobility and as a further opportunity to express our interest in the cause.

Plans for learning and follow-up

Key questions for follow-up

Questions we hope to eventually answer include:

  1. Is the project able to find employment opportunities for 100 Haitian H-2 visa holders? Is there evidence that they will be able to obtain H-2 visas? We expect to be able to answer both of these questions within 6 months of making the grant, and before disbursing the second tranche of funding.
  2. Is the program sustainable after the pilot stage? How do H-2 usage numbers change over time? Does Haiti continue to have access to H-2 visas in the future? We expect to have an initial answer to this question within a year of the second tranche of funding being disbursed, and then to be able to track H-2 usage at roughly annual intervals.
  3. What are the results of the evaluation? Does it have a discernible impact on policy or the academic literature?

Follow-up expectations

We expect to have phone calls with IOM and/or other program staff roughly every 3 months for the duration of the grant, with public notes if the conversation warrants it. We will disburse the second tranche of funding and post an update after employers are identified and we receive evidence that the workers will be able to receive H-2 visas, or, if those conditions are not met, we will publicly discuss what happened.

Towards the end of the duration of the grant (i.e. after the pilot workers have returned), we plan to attempt a more holistic evaluation of the project’s performance, aiming to answer questions #2 and #3 above. We may continue to check in on the status of Haitian H-2 visa usage (which the U.S. State Department publicly discloses) and the evaluation on a roughly annual basis for an indefinite period.

We may abandon either or both of these follow-up expectations if labor mobility ceases to be a focus area.

Our process

We approached Michael Clemens of CGD looking for funding opportunities in labor mobility in November 2013. He suggested we speak with IOM Haiti staff about a migration facilitation mechanism and we began to do so starting in December 2013. After a few more conversations with IOM staff and feedback on an earlier draft, a final proposal was submitted in June 2014.

We shared a draft version of this page with IOM and CGD staff, and incorporated some of their suggestions, prior to the grant being finalized.

Updates

In December 2014, we published our first update on the progress of this grant to date and decided to grant the second tranche of funds.

In March 2015, we received the following documents from IOM:

At IOM’s request, we redacted the names of specific farmers and consultants in the interim report and are not posting Annex 1, which contains the agenda and participant list for the November 2014 stakeholder meeting.

Sources

Document Source
Clemens 2011 Source (archive)
Clemens 2012 Source (archive)
Email from Dmitry Poletayev (IOM) on April 16, 2014 Unpublished
IOM Comments on Draft Grant Writeup Unpublished
IOM Project Budget Source
IOM Project Proposal Source
Notes from a conversation with Michael Clemens on December 10, 2013 Unpublished
Notes from a conversation with Michael Clemens on January 21, 2014 Unpublished
U.S. Visa Data Spreadsheet Source (archive)
  • 1.

    IOM notes in response to a draft version of this document: “Please note that IOM has put in place all possible measures, including incentives, to increase the likelihood of sustainability through improving visa compliance rates:

    • ONM agents will go through on-the-job training, retaining the lessons learned and act as a clearing house/filter for H2 applicants;
    • Migrant workers will undergo pre-departure briefings that will emphasize that upon return they will be eligible to participate in subsequent H2 opportunities.
    • Haitian Consular staff visits will be supported by the project, enabling direct contact and reinforcement of H2 regulations.
    • PTP will reinforce this same message to employers regarding visa compliance.”

    IOM Comments on Draft Grant Writeup

  • 2.

    IOM Project Proposal

  • 3.

    IOM Project Budget

  • 4.

    “In 2012 the United States Government (USG) included Haiti in the list of countries whose citizens are eligible for the H-2 visa for lower skilled temporary/seasonal workers. Haiti was previously excluded from this list in 2009 due to wide-spread fraud of both applicants and soliciting employers. On the side of the migrants the main issue was visa overstaying and fraudulent declarations.” IOM Project Proposal

  • 5.

    Clemens 2012

  • 6.

    U.S. Visa Data Spreadsheet

  • 7.

    Notes from a conversation with Michael Clemens on January 21, 2014

  • 8.

    IOM Project Proposal

  • 9.

    “The project will be led by the International Organization for Migration. Established in 1951, with 155 current Member States and UN Observer Status, IOM is the leading international organization focused on migration. IOM has been present in Haiti since 1994, focused initially on assisted voluntary return and reintegration (AVRR), including livelihood reintegration support. Beginning in 1996, IOM supported the GoH through Disarmament, Demobilization and Reintegration (DDR) programming and a communal governance program providing support, capacity building and technical assistance to local communities and municipalities. These activities aimed at reducing migration push factors driving irregular migration flows departing from Haiti.

    IOM has significant experience in offering pre-consular services to circular labor migrants, migrant training, recruitment services, and government capacity building. IOM has, among others, supported Canada, Italy, Libya, Portugal and Spain in the recruitment of temporary migrant workers from countries such as Colombia, El Salvador, Guatemala, Honduras, Mauritius, Sri Lanka and Ukraine. IOM has worked in agreement with concerned governments in countries of origin and destination, as well as directly with private employers and/or employer associations….

    IOM has over 50 years’ experience in migrant training in general, including curriculum development, language training, and training of trainers to support and complement a comprehensive package of employment-related services. To date, IOM has assisted well over 500,000 migrants through its migrant training activities. Migrant training is one of IOM’s core programmes, and has been in existence since the early 1950’s. Traditionally, participants in IOM’s migrant training programs have been refugees accepted for resettlement in a third country. During the last two decades, however, IOM has widened its scope by also offering training to migrant workers, including skilled and non-skilled labour migrants, and immi­grants and their family members. All IOM training activities for temporary migrant workers will be conducted by trained IOM trainers or specialized training consultants. Training beneficiaries may also include members of migrants’ families.” IOM Project Proposal

  • 10.

    “A rigorous impact evaluation of this intervention will be commissioned. The most feasible research design in this setting would be the propensity score-matched differences-in-differences method used by David McKenzie of the World Bank to evaluate the impacts of New Zealand’s guest worker visa on participant families in Vanuatu. He used a panel survey of participant and similar nonparticipant households, with a baseline survey before the start of the program and a second round after the program.
    This model could be feasibly replicated in Haiti to determine the impacts of temporary labour migration on Haitian households. The project will support a similar survey of participants and non- participants to identify differences in key outcomes between participant and non-participant households and in turn, attribute those differences to the circular labor migration scheme. The outcomes of interest could include measures of development such as household income, indebtedness, health-seeking behavior, child welfare (school enrollment), entrepreneurship, and savings among others.
    A rigorous evaluation of this program will quantify the impacts of temporary labour migration on household welfare, and enable a more precise estimation of the multiplier effects that temporary migration can have on communities of origin. This would help identify the impact and cost effectiveness of scaling up this program in Haiti or expanding this type of migration support project to other areas as part of a post-disaster recovery or development assistance program.” IOM Project Proposal

  • 11.

    “To produce these outcomes USAIM in agreement with the IOM/ONM/PTP/CGD project team proposes the implementation of the following activities, divided into three phases corresponding to the above outlined outcomes:
    Phase 1 (Month 1- 4):

    • PTP team of technical experts to work with agents & employers in the US
    • IOM to host a workshop bringing together key experts & stakeholders in PaP or Miami
    • IOM and ONM put together recruiting mechanism in communities of origin
    • Outcome: Workers and employers identified for the pilot group

    Phase 2 (Month 5 – 11):

    • Cooperation established b/w ONM and US embassy PaP on worker interviews
    • Haitian seasonal workers are received in the US
    • Monitoring visits by Haitian consulates, including a reception for the arrival and departure of workers according to visa timeframes

    Phase 3 (Month 11 – 14):

    • Initial group of workers return to Haiti
    • Tracking of remittance flows
    • Economic impact evaluation”

    IOM Project Proposal

  • 12.

    IOM Project Budget

  • 13.

    “Four social responsibility tools will be used in order to maximize the rate of workers’ return:
    (1) a pre-selection process facilitated by the agents of DOL-certified employers and local community leaders with a thorough knowledge of the families targeted;
    (2) a comprehensive migrant pre-departure training/orientation program to better prepare workers for employer’s expectations and the logistics of seasonal agricultural work in the US;
    (3) a community rotation scheme, subject to the return of the previous caseload. Twenty-five (25) workers from each community will be sent to the US with the following group of 25 sent upon the initial group’s return;
    (4) regular monitoring visits of the beneficiary families.
    Furthermore, by matching visa candidates with jobs in the US that are relevant to their livelihoods in Haiti, the visa system can be leveraged as a training program to facilitate skills transfer and as a means to raise awareness amongst Haitians regarding labour rights and labour relations. In support of this notion, the project team will seek to design, in cooperation with ONM a framework for transparent and ethical recruitment of Haitian workers from communities with high irregular migration rates, based on the principles of the International Recruitment Integrity System (IRIS)7.
    Ultimately in order to encourage compliance with USA visa requirements and particularly with the obligation of return by visa expiration date, the project will create an additional incentive structure by funding small community-based projects and small-businesses for the returning beneficiaries.
    In order to mitigate the risk of fraud and visa overstay, IOM proposes to reinforce the role of the National Office for Migration (ONM) through the deployment of four field ONM agents in the targeted communities to carry out regular follow-up monitoring visits to the beneficiary families. Regular government monitoring has been documented as a reason for high return rates in countries (e.g. Jamaica) where circular migration schemes are successfully implemented. Additionally, the Directorate for Immigration and Emigration (DIE), local authorities in the targeted communities, the US Embassy in Haiti, as well Haitian consulates in the US are seen as critical actors in the success of the proposed intervention.” IOM Project Proposal

  • 14.

    Clemens 2011

  • 15.

    This is somewhat more conservative than Clemens 2011’s figure because we assume that migrants may bear some additional costs in the U.S. and will stay for less than a full year.

  • 16.

    U.S. Visa Data Spreadsheet, “Master” sheet, M229.

  • 17.

    U.S. Visa Data Spreadsheet, “Master” sheet, Q253.

  • 18.

    “Haiti is the poorest country in the Western Hemisphere with more than half of the population living on $1 or less a day in 2001.” IOM Project Proposal

  • 19.

    “Roughly 30-40% of H-2 workers’ income would be sent to Haiti. Haitians now in the U.S. who send money to Haiti, most of whom are quite different from temporary low-skill agricultural workers, send home roughly 20% of their incomes in remittances, repatriated savings, and expenditures during home visits.6 Haitian H-2 workers would likely remit a much larger fraction of income. Comparable Mexican seasonal low-skill agricultural workers (H-2, non H-2, and unauthorized together) send home more than 1/3 of income as remittances or repatriated savings.7 And Haitian H-2 workers would likely send even more, because they would all be authorized (unauthorized workers send less, among other reasons, due to lower earnings and to high smuggling fees) and because many H-2 employers are required to provide housing and meals lowering those workers’ cost of living.” Clemens 2011

  • 20.

    Notes from a conversation with Michael Clemens on January 21, 2014

  • 21.

    Notes from a conversation with Michael Clemens on December 10, 2013

  • 22.

    IOM notes in response to a draft version of this document: “Please note that IOM has put in place all possible measures, including incentives, to increase the likelihood of sustainability through improving visa compliance rates:

    • ONM agents will go through on-the-job training, retaining the lessons learned and act as a clearing house/filter for H2 applicants;
    • Migrant workers will undergo pre-departure briefings that will emphasize that upon return they will be eligible to participate in subsequent H2 opportunities.
    • Haitian Consular staff visits will be supported by the project, enabling direct contact and reinforcement of H2 regulations.
    • PTP will reinforce this same message to employers regarding visa compliance.”

    IOM Comments on Draft Grant Writeup

  • 23.

    IOM notes in response to a draft version of this document: “One of the aims of the pilot is to introduce Haitian workers to legitimate employers. A successful exercise should result in maintained interest among employers. It is also anticipated that employers will visit Haiti and see for themselves the value of hiring Haitian migrants.” IOM Comments on Draft Grant Writeup

  • 24.

    Email from Dmitry Poletayev (IOM) on April 16, 2014. IOM notes in response to a draft version of this document: “IOM Haiti works in a post-emergency context, in a changing political environment. That said, the project-based structure ensures that the Organization maintains strong internal controls guaranteeing that, regardless of staff turnover, internal memory is passed on and projects are brought to completion.
    Regarding the change in ONM management, IOM views this as a positive step.” IOM Comments on Draft Grant Writeup

  • 25.

    IOM notes in response to a draft version of this document: “IOM has a balanced approach to this – we do value direct and immediate impact to migrants and their families and communities, but we have also put in place all necessary measures to ensure that the project has strong chance of becoming sustainable beyond the pilot phase.” IOM Comments on Draft Grant Writeup