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IPS175 Pietro Gennari et al.
                  and validation mechanisms at national level and to build the capacity of NSOs
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                  to fulfil their role as coordinators of national monitoring in practice .
                  b.  Specific provisions of the Guidelines that are not often followed in practice.
                     The Guidelines contain other provisions that are not overtly controversial,
                  but  may  become  challenging  when  countries  and/or  custodian  agencies
                  attempt to implement them. One such provision is 22.k), which describes the
                  situation where a  custodian agency has contacted the designated national
                  focal point but no response has been provided within a reasonable timeframe.
                  In such a case, a non-response “will be taken as agreement with the statistics
                  shared by the custodian agency”. Many countries, however, take issue with this
                  provision,  which  is  perceived  by  them  as  a  way  for a  custodian  agency  to
                  bypass the authority of the NSO. Despite the explicit provision therefore, a
                  number  of  countries  have  transmitted  formal  complaints  to  custodian
                  agencies about this practice, which has led many organizations to self-censor
                  themselves  publishing  only  the  estimates  of  those  countries  that  have
                  explicitly validated them. The consequence is a significant drop in the country
                  coverage for the indicator.
                  c.  The absence of a specific mechanism for data validation
                     The Guidelines may have several inherent shortcomings in their various
                  provisions,  but  one  of  the  key  challenges  that  countries  and  custodian
                  agencies have faced in recent years is the absence of a specific mechanism for
                  data validation. This was, and still is, a major constraint, despite the fact that
                  two additional supporting documents on “criteria for implementation” as well
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                  as “best practices” were subsequently produced  to facilitate implementation.
                  Neither the Guidelines nor any of these supporting documents attempt in any
                  way  to  suggest  particular  modalities  for  how  parties  should  go  about  the
                  procedure. As a result, different custodian agencies have hitherto had to “go
                  it alone”, effectively improvising new procedures and tools. This creates two
                  types  of  inefficiencies:  unnecessary  multiplication  of  work  as  different
                  custodian  agencies  try  to  resolve  the  same  problem;  and  increased
                  bewilderment and confusion among recipient countries, who are confronted
                  with varying approaches depending on the custodian agency. There is clearly
                  a need to find pragmatic solutions, as data validation is a resource-demanding
                  exercise for both countries and custodian agencies. At the same time, finding
                  a more efficient mechanism for data validation could improve data quality as
                  well as provide an opportunity to find solutions to the decades’ old problem



                    Another symptom of NSOs’ struggle with assuming a coordinating role is that less than 60
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                  percent have identified an SDG focal point, “expected to respond to requests from custodian
                  agencies in a timely manner and facilitate the coordination of data transmission within the NSSs
                  for global reporting on the SDGs”.
                  12  Op. cit., 4
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