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FINANCIAL REQUIREMENTS ...and other usefull things to know for your IVB Project Utrecht, 15 January 2013 Financial Requirements The Basics Table of contents The Lead Partner principle Audit and Control Eligibility of Expenditure


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FINANCIAL REQUIREMENTS

...and other usefull things to know for your IVB Project

Utrecht, 15 January 2013

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Table of contents

  • The Lead Partner principle
  • Audit and Control
  • Eligibility of Expenditure
  • The Payment Procedure
  • Project Modifications

Financial Requirements

The Basics

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The LP Principle

Financial Requirements

The Basics

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The Lead Partner Principle (LP principle)

Compulsory For the 2007-2013 programming period

Financial Requirements

The Basics

The Lead Partner is the administrative link between the programme and the project. As such, they bear responsibility for ensuring the project’s

  • implementation. However, each partner bears full responsibility for

their own actions.

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The Lead Partner Principle (LP principle)

Compulsory For the 2007-2013 programming period

Financial Requirements

The Basics

The LP

  • drafts the Partnership Agreement, setting mutual rights,
  • bligations and duties among project partners.
  • ensures that expenditure is eligible, even if partners remain

liable for their own actions and related expenditure

  • is responsible for reporting and other administrative actions

to the JTS

  • distributes ERDF to partners
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The Lead Partner Principle (LPP)

Financial Requirements

The Basics

Lead Partner Principle Partnership Agreement

Overall responsibility

  • n project

implementation: content of the project + finance management

Responsibility for Project Management

  • Signature of Subsidy Contract
  • Transfer of received ERDF

funds to partners

  • Organisation of audit of all

expenditure

Contact with JTS

Submission of progress reports, payment claims, audit reports, project modifications…

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Audit and Control

Financial Requirements

The Basics

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What is the audit trail?

Financial Requirements

The Basics

The audit trail is a comprehensive set of documents which provide a complete history of a project and provide evidence that proper procedures were apllied and outcomes achieved. What documents do you need?

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Financial Requirements

The Basics

  • Approved Application Form, Subsidy Contract, Partnership

Agreement (in copy at partner level)

  • Relevant project correspondence (financial and contractual)
  • Progress Reports, Payment Claims, Partners controllers’

confirmations (and checklists/control reports)

  • Bank account statements proving the reception and the transfer of

ERDF

  • Invoices of all expenditure declared in the Payment claims
  • Bank account statements / proof of payment for each invoice
  • Method used by all partners outside the EURO-zone for converting

national currency into EUR

  • Staff costs: information on actual annual working hours, labour

contracts, payroll documents and time records of personnel working for the project

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Financial Requirements

The Basics

  • List of subcontracts and copies of all contracts with external

experts and/or service providers

  • Calculation of administrative costs, proof and records of costs

included in overheads

  • Documents relating to public procurement, information and

publicity

  • Public procurement notes, terms of reference, offers/quotes,

evaluation, order forms, contracts

  • Proof of delivery of services and goods: studies, brochures,

newsletters, minutes of meetings, translated letters, participant lists, travel tickets, etc.)

  • Record of assets, physical availability of equipment

purchased in the context of the project.

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Financial Requirements

The Basics

In what form? Original documents (at partner level), but also photocopies (at Lead Partner level), microfiches or electronic versions

  • f original documents.

Where? The Lead Partner is responsible for storing all relevant documentation for all partners and all sub-partners. They must be filed separately, even if this leads to a dual treatment of accounts. Importance of Partnership Agreement ! How long? It is essential that all documents and accounting records be kept available for a period of three years following the closure of the Programme, that is 31st December 2021. Projects that cannot provide sufficient documentation risk losing their ERDF grant.

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Financial Requirements

The Basics

  • When to control? Example:

Closure of accounts at partner level: end July Documents to the project controller: end August Documents to the LP (controller): end September Documents to the JTS: end October

  • > Maximum for the whole process : 3 months (Article 16 of

1080/2006)

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On the spot checks by the FLC

Financial Requirements

The Basics

  • Commission Regulation 1828/2006 was updated in 2009. Article 13

says now that verifications by the controllers shall include on-the-spot verifications.

  • What is the added value for going on the spot?
  • See the reality of investments and the project as a whole
  • Check that the EU Logo is printed on brochures, that

commemorative plaques have been installed.

  • What do you check if a project has no investments?
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Financial Requirements

The Basics

The Commission verifies that the FLC have checked the follwing community rules:

  • Gender equality
  • Environment
  • Publicity
  • State Aid
  • Public Procurement

For help please take a look at the COCOF “Guidance document on management verifications to be carried out by Member States on

  • perations co-financed by the Structural Funds and the Cohesion

Fund for the 2007 – 2013 programming period”.

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Most common mistakes/problems at JTS level:

Financial Requirements

The Basics

  • Calculation of staff costs
  • Administration costs had no project relation
  • Wrong signatures of FLC
  • Modified controller‘s declarations, empty declarations
  • FLC findings should be cut already before the claim is

presented to the JTS

  • The comment boxes are not used enough (for external expert

rates or hotel stays)

  • Frequent problems with data protection
  • Public Procurement mistakes not detected by the FLC
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Financial Requirements

The Basics

Findings of Second Level Control:

  • Mistakes in timesheets
  • Usage of wrong budget line
  • Missing original documents and bad quality
  • No project relation
  • Breach of public procurement
  • Administration costs had no project relation
  • FLC comments in checklist did not correspond to

payment claim

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Financial Requirements

The Basics

Mistakes found by DG Regio during their audit in Germany

  • Staff cost calculation was based on average hours worked, time

sheets did not exist.

  • Controllers did not document their work sufficiently (checklist and

controller‘s declaration are the minimum requirements).

  • Public procurement procedures for contracts below 21.000€ were

not documented transparently. One explanation for an in house tender procedure was not accepted by the Commission.  The conclusion was an interruption of payment to all German partners as of August 2012.

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Eligibility of Expenditure

Financial Requirements

The Basics

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Eligibility period

Financial Requirements

The Basics

Start date: All costs are eligible one year prior to the closure of the call for proposals as long as the actions are not completed before that date. End date: The end date indicated in the Application Form is the date by which the final report should be submitted to the Secretariat. Project expenditure can be eligible until 31 December 2015. Any expenditure (including costs linked to the project closure) incurred, invoiced or paid after the official project end date is ineligible.

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NWE Budget Lines:

Financial Requirements

The Basics

1 Partner Staff 2 External Experts & Consultants 3 Travel and Acommodation 4 Meetings and Seminars 5 Publicity 6 Equipment 7 Investment 8 Audit costs 9 Administration Costs 10 Revenues

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Partner staff (1)

Financial Requirements

The Basics

Staff costs are the costs of the actual time (no averages) worked by the persons directly carrying out the work under the project and directly employed by the partners. All staff costs must be based on real costs, supported by proper documentation (payslips and timesheets) and calculated on the following basis: Remuneration costs (taken from payroll) = total gross remuneration + employer’s portion of social charges. Remuneration costs must be calculated individually for each employee and must be based on the monthly payslip.

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Partner staff (2)

Financial Requirements

The Basics

Working time must be recorded (eg. timesheets) throughout the duration of the action. The records should be certified at least once a month and signed by the employee and the supervisor. Estimates of hours/days worked are not acceptable. Employees working full time on the project, do not need to fill in time sheets.

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External Experts & Consultants

Financial Requirements

The Basics

Work done by independent consultants must be essential to the project and reasonably priced. Pay attention to:

  • Costs must be paid on the basis of contracts and against invoices.
  • Maximum rate for a senior consultant is €800 per day (excluding VAT).
  • Public procurement rules apply.
  • Travel and accommodation expenses belong in this budget line
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Travel costs

Financial Requirements

The Basics

Are eligible for partner staff, all tickets, invoices and receipts must be kept by partners so that their eligibility can be checked and audited. Copies should be sent to the Lead Partner. Costs must be directly related to, and essential for, the effective delivery of the project and cover economy class travel on public transport. Recommendation for maximum daily subsistence allowances are based on the Commission subsistence allowances paid to experts on assignments requiring an overnight stay. For more information see our Guidance Notes.

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Meetings & seminars

Financial Requirements

The Basics

Costs related to the organisation of meetings and events (renting of premises and equipment, meals, etc), participation in meetings and seminars related specifically to the project are eligible under this budget line. Related travel costs and external expert costs must not be budgeted under this budget line (external expert, communication).

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Publicity

Financial Requirements

The Basics

Expenditure with the main aim of promoting the project should be part of this cost category. This includes website, promotional material and printed publications. Public procurement rules must be observed in selecting company or individual who will carry out the assignment. Pleas be sure that you follow the publicity requirements of the European Commission and use the flag all project documents and commemorative plaques wherever needed.

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Equipment vs. Investment

Financial Requirements

The Basics

A clear distinction must be made between what is included in the investment budget line (where the total cost is eligible) and the equipment budget line (where depreciation should be the rule). The purchase of land is eligible in an investment if it does not exceed 10% of the total eligible costs for the operation concerned. All eligible expenditure must be fully described in the approved Application Form.

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Administration costs

Financial Requirements

The Basics

Administration costs include items such as office rent, maintenance and furniture, electricity, heating, water, insurances, telephone, fax, internet, stationary and other administrative structure costs. The NWE Programme has decided to use a 11% flat rate on staff costs for all projects that have been approved after June 2011. This flatrate is the same for all projects and cannot be adjusted. No documents need to be kept as proof.

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Revenue

Financial Requirements

The Basics

The Lead Partner must keep separate accounts for the project so that all expenditure (costs) and all revenue (receipts) can be posted and audited, and detailed summary reports drawn up. All revenue generated from sales, rentals, subscriptions, fees

  • r other equivalent sources must be reported and must be

deducted from the eligible costs. In case of a revenue-generating projects, the current value of the net revenue from the investment must be estimated over a specific reference period. Where it is not possible to estimate the revenue in advance, the revenue generated within 5 years following project closure must be reported (article 55 of EU regulation No 1083/2006).

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Expenditure outside eligible area

Financial Requirements

The Basics

For partners from the NWE area, any expenditure incurred outside the eligible area (for example, costs of a meeting or conference held outside the area) must be justified in full and a clear need for the expenditure to be incurred outside the area must be demonstrated. Projects must get formal approval from the Secretariat before incurring expenditure outside of the NWE area.

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Ineligible costs

Financial Requirements

The Basics

(non-exhaustive list)

  • National banking charges
  • VAT unless it is genuinely and definitively borne by the final

beneficiary

  • Fines, financial penalties and expenditure on legal disputes
  • Interest on debt
  • Decommissioning of nuclear power stations
  • Housing
  • Exchange rate loss (or gain)

Further Information: General Regulation (EC) No 1083/2006 - article 56 ERDF Regulation (EC) No 1080/2006 - articles 7 and 13 Implementation Regulation (EC) No 1828/2006 - articles 48-53

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Eligibility of expenditure: preparation costs

Financial Requirements

The Basics

Costs related to project development and application are eligible if:

  • The activities show a direct, demonstrable connection to the

development of the project.

  • Costs were incurred up to one year prior to the closure date of

the call. They may include staff, external experts, travel and subsistence, meetings, publicity. Preparations costs have to be claimed all at once for the whole partnership They are subject to a ceiling of €100,000 total eligible cost (max €50,000 ERDF).

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Coordination costs

Financial Requirements

The Basics

Costs related to coordination and the management of the project must be recorded under the partner who will incur the expenditure. Partners can contribute financially to the coordination costs but this should not be mentioned neither in the budget, nor in the Payment Claim.

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The Payment Procedure

Financial Requirements

The Basics

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Payment procedure

Financial Requirements

The Basics

Joint Technical Secretariat Assesses the Progress Report and the Payment Claim received Prepares the payment request to the Certifying Authority Certifying Authority Programme Bank Account Project Lead Partner Submits a Progress Report and a Payment Claim: end April - full version and end October - light version Reimburses the other project partners according to their expenditure Payment Claim Project Partner Project Partner Payment Claim Flow Money Flow

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Deadlines and reports

Financial Requirements

The Basics

What and when? 30 April and 31 October

  • Payment claim
  • Progress report (short in October, long in April)
  • Verification sheets
  • Checklist (sent only to the Lead Partner)

!! Are necessary beforehand:

  • signed Subsidy Contract and Partnership Agreement
  • Approved first level controllers
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Project Modifications

Financial Requirements

The Basics

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Project modifications

Financial Requirements

The Basics

Request for changes are allowed 3 times in total, no later than 6 months before the end date of the project and only upon formal request and approval by the Secretariat or the Programme’s Steering Committee – depending on the significance of the changes. The “request for changes” form must be used. The Secretariat should be notified of minor changes as soon as possible by official letter from the Lead Partner. This would be, for example, a change of bank account, a new contact person, a change

  • f address, etc.

To receive the request for changes form an email needs to be sent to the JTS Officers in charge of your project.

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Project changes: budget/finances

Financial Requirements

The Basics

Budget Line Modifications (BLM) Projects can overspent an individual budget by a maximum of 20%. Increases of more than 20% on individual budget lines must be submitted and duly justified to the Secretariat using the request for changes form. The project will receive formal approval from the Secretariat if appropriate. Other financial changes Ex: a reduction of grant rate at partner level or a decrease in the overall budget -> use the request for changes form.

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Thank you very much for your attention!

VoE

Financial Requirements

The Basics