PAI provides its feedback and specific recommendations to strengthen the Operational Framework draft put forth by Every Woman Every Child. PAI is concerned that the current draft: (1) Could provide clearer guidance to countries around reproductive health aspects of the Global Strategy; (2) Relies too heavily on the troubled Country Platform and Investment Case model of the GFF; and (3) Fails to provide adequate provisions for accountability at the country level. This document goes into further detail about these concerns.