Elevate Berkshire ESIF Workshop 5 th October 2015 Ecorys has - - PowerPoint PPT Presentation

Elevate Berkshire

ESIF Workshop

5th October 2015

Ecorys has longstanding experience of ensuring compliance with EU and ESF

• ESF Equal
• Pan London Objective 3 ESF
• UK National Agency for Erasmus + with British

Council

• Advisors on ESF to Big Lottery Fund BBO

Our Experience of ESIF

• Manage and deliver EU programmes
• Provide support to potential applicants,

applicants and grant holders (lead partners)

• Helpline on ESIF rules and regulations,

roadshows, webinars, templates and guidance

• Help organisations manage risk of clawback in

terms of specific partnerships and projects

Today

• Refresher on ESIF requirements
• Discussion around implications for Elevate

Berkshire

• Questions as we go

– Finances – Procurement – Participant Data and Outcomes – State Aid – Publicity – Cross-cutting Themes

ESF Key Principles

• Co- financing
• Non profit
• Non retrospective
• Non cumulative

Actual costs

• Do not complete claim from original budget

(unless agreed advance payment)

• All costs paid by ESF must be actual costs

incurred and defrayed (paid) by projects

• Partners are paid for their expenditure, not

day rates or fees.

Staff Costs

• 100% time – JD, letter of appointment, payroll
• Part time – Timesheets, payroll, evidence of

work carried out

• Indirect staff costs – proportion of general

admin and support staff if relevant

Participant Costs

• Everything claimed by participants needs to be supported by

evidence

– Travel – Childcare – Expenses

• Get this evidence from beneficiaries before you pay them
• Participant allowances, benefits or incentives

– Likely to affect the level of benefits the participant may be entitled to, which you’ll need to discuss with the local Jobcentre Plus office – Need to conform to HM Revenue and Customs rules on taxable income.

Other Costs

• Staff Expenses (linked to project)
• Consumables (linked to project)
• Venue Hire/lease or rent of buildings (linked to project)
• Equipment Hire
• Depreciation (if on items solely used by project)
• Small items < £1,000
• Consultants/suppliers/ agency staff
• Overheads (apportioned)

European Court of Auditors

• Overall approx. 3% of payments thought to be

incorrect (of €14bn )

• 93% of errors on EU audits of ESF were to do with

ineligible expenditure (including ineligible participants)

• 7% on procurement failings

ESIF Expenditure Errors

• Overcharging of overheads (23%)
• Lack of a robust and transparent method
• Differences between formula at bid and delivery stage/ miscalculations
• Inflation of rents compared to market average
• Over-declaration of personnel costs (8%)
• E.g. a school in Portugal charged the head teacher’s whole salary to ESF when
• nly a small part of his work was ESF related
• Other examples where ESF funded staff were on 5 x the salary of equivalent non

ESF funded

• Inadequate timesheets
• Incorrectly allocated costs (14%)
• Things charged to the project but not directly linked to delivery e.g. including

general catering in overheads

• Other ineligible items (48%)
• Ineligible participants or activities
• Expenditure on items not required for delivery or at unsuitable times
• Notional costs (e.g. internal recharge)

Match Funding

Unacceptable

ESF funding Match funding

Budget item 1 Budget item 2 Budget item 3 budget item 4 PROJECT COSTS

Acceptable

ESF Funding Match funding Budget item 1 Budget item 2 Budget item 3 budget item 4 PROJECT COSTS

Match Funding

Aligning Funding Sources

? ?

ESIF

?

CO

?

Other sources

?

Partners or Contractors?

Partners:

• Shared aims and priorities
• Stake in the project as a whole
• Local knowledge and influence
• Paid on actual costs
• Deliver most project services
• Consulted, not told
• Sign SLA
• Named in bid / DWP contract
• Running start in delivery

Partners or Contractors?

Contractors

• Usually deliver only small, specialist elements e.g.

LMI or ICT support

• Limited interest in wider objectives
• Told, not consulted
• Paid fee/output basis
• Procured through market
• Managed via contract
• Will take time to procure

Procurement

• Principles of transparency, non-discrimination,

equal treatment and proportionality

• ESIF does not have its own procurement rules,

just brings a high degree of scrutiny

• Education and training services to the person

are “Part B”

• 1. Consider and define all parties by role
• 2. Discuss with DWP- name all delivery partners and role

in contract/grant agreement

• 3. Consideration at each LA of its Elevate supply chain
• 4. Possible procurement audit of all proposed

partners/suppliers

• 5. Project procurement plan

– What you need to procure – When and how – Who procures – exceptions

Suggested Steps

Partner Payments

• Safest approach is to apply same method of

payment to partners as MA is applying to

• verall grant.

Actual expenditure Profile and reconciliation Unit pricing Incentives

Thresholds

Current OJEU threshold for Part B (total contract value) Services £111,676 (€134,000) Any procurement above that threshold must go on OJEU DON’T SPLIT ITEMS TO FALL BELOW THRESHOLD- e.g. tendering for separate 2 x 1 year contracts

Common Procurement Failings

• Inadequate time limits
• Unclear evaluation criteria
• Insufficient profile or description of service
• Process not documented
• Procurement “in the field”, not by experts

• Be very wary of “re-engineering” existing contracts or services
• Any new suppliers/services must be procured correctly (LMI?)
• Procurement related clawback can be 100%
• Balance your desire to move quickly with compliance and

transparency

• ESIF does not have its own procurement rules, just brings a high

degree of scrutiny and possible challenge

Elevate Procurement Risks

Participant Eligibility

• Participants must be legally resident in the UK

and able to take paid employment in European Union member states and unemployed or economically inactive.

• https://www.gov.uk/legal-right-work-uk/y
• Support must be additional
• Must not be counted twice

Participant Data

• Projects need to capture, evidence and report
• approx. 30 characteristics of each participant
• Track and evidence each participant through all

activity, results and outcomes

• E.g. recruitment/assessment
• Learning and support
• Qualification
• Job/Progression

Participant Outputs

• Unemployed including long-term unemployed
• Economically inactive including NEET
• At risk of NEET
• Single parents
• Participants with disabilities
• Youth offenders

Participant Results

– Education and training – Offer or take-up? Minimum hours? Within 4 weeks or 6 months? – Securing a job – offer or take-up? Proof of starting? Minimum hours? Internship? Zero hours? – Commencing job search – how to evidence?

Participant Evidence Trip Hazards

• Lack of participant signatures
• Inadequate evidence of eligibility
• Gaps in participant files
• Using generic data collection forms
• Reported outcomes and results not

backed up by evidence

State Aid - 4 Tests

1) The assistance is granted by the state or through state resources. 2) It favours certain undertakings or the production

• f certain goods

3) It distorts or threatens to distort competition 4) It affects trade between Member States

State Aid- General

• For 2007 – 2013 programme ESF Priorities 1 and 3

were not in scope for State Aid

• Most ESF activity is addressing market failure
• Employment support to disadvantaged people is a

specific SA exemption under GBER

• De-minimis threshold is €200,000 over rolling 3 years

State Aid- Elevate

Work placements: Could be considered an indirect subsidy to employers so should be costed and tracked if unwaged

Publicity

• ESF must be acknowledged as source of funding on all

materials, eg:

– job adverts and descriptions – procurement materials – internal records and paperwork – social media

• Prescriptive branding rules
• News stories and case studies to DWP; hosting visits

from ministers or representatives of EC

Cross Cutting Themes

• Sustainable Development

– All partners must have policies and an implementation plan that demonstrates:

a) commitment to promoting sustainable development and complying with relevant EU and domestic environmental legislation b) how the commitment will be turned into action at project level.

Cross Cutting Themes

• Non discrimination

– Providers required to meet individual needs – Design and delivery to enable minorities of all kinds to access, participate and succeed within the project – Activities to be fully accessible to disabled people – Actively enabling more women to take part in the programme, including disadvantaged women – Part of ongoing review and evaluation

Next Steps

• Detailed planning and troubleshooting
• Transferring ESF knowledge to delivery

partners

• “ESF-ify” paperwork, systems and processes
• DWP approval