project handbook guidelines for administrative and financial … · 2015. 3. 10. · epale national...
TRANSCRIPT
ERASMUS + PROGRAMME
Project Handbook
Guidelines for Administrative and Financial
Management and Reporting
Selection 2014
EPALE National Support Services (EPALE-NSS)
1st version March 2015
2
Table of Contents
Introduction .................................................................................................................................... 3
1. Overview Project Life Cycle (from the signature of your project until audit) ..................... 4
1.1. Your project in the lifecycle of the Erasmus + Programme .................................................. 5
2. Monitoring of the actions by the Agency ................................................................................. 6
2.1 Purpose ................................................................................................................................... 6
2.2 What kind of monitoring ........................................................................................................ 6
3. Reporting .................................................................................................................................... 6
3.1 Structure of the Final Report .................................................................................................. 7
3.2 Structure of the Public Report ................................................................................................ 7
3.3 Structure of Confidential Report ............................................................................................ 8
3.4 How to send the Reports ........................................................................................................ 9
3.5 Processing the Reports ......................................................................................................... 10
3.5.1. Incompleteness of a report ............................................................................................ 10
3.5.2. Rejection of a report ..................................................................................................... 10
4. Financial rules .......................................................................................................................... 11
4.1 General Provisions on Eligibility of Costs ........................................................................... 11
4.2 Principles applied to the different categories of expenditures.............................................. 13
4.2.1 Staff costs ....................................................................................................................... 13
4.2.2 Travel and subsistence costs .......................................................................................... 14
4.2.3 Costs related to equipment and materials ...................................................................... 15
4.2.4 Subcontracting costs ...................................................................................................... 15
4.2.5 Other Costs .................................................................................................................... 16
4.2.6 Indirect costs .................................................................................................................. 17
4.3 Calculation of the final grant amount and supporting documents ........................................ 18
4.4 Checks and Audits ................................................................................................................ 20
4.5 Claims/Appeals .................................................................................................................... 21
5. Amendments ............................................................................................................................. 22
5.1. Introduction ......................................................................................................................... 22
5.2 Cases where the amendment request form is not required ................................................... 22
5.2.1 Changes via the Participation Portal .............................................................................. 22
5.2.2 Change of legal representative of the beneficiary organisation ..................................... 23
5.2.3 Change of project coordinator ....................................................................................... 23
5.2.4 Change to the budget breakdown................................................................................... 23
6. Recognition of Commission funding and use of Erasmus + logo ......................................... 23
3
Introduction
Purpose of the Handbook This Handbook applies to grants awarded in 2014 under the Erasmus+ Programme for the action:
EPALE National Support Services, hereinafter EPALE-NSS.
Its principal aims are to:
− help beneficiaries to manage their project and run them efficiently;
− clarify matters arising from the grant agreement and its annexes;
− provide practical information that may be referred to throughout the project's life;
− provide guidance on how to handle the financial side of projects in such a way that
financial statement can be readily drawn up;
− promote the sound financial management of a project and ensure that the best
results/products are delivered at reasonable cost;
− encourage smooth relations between the parties involved by setting out an operational
framework for the project.
Other Documents
This document should be read in conjunction with your Grant Agreement, the Call for
Proposals 2014 (EACEA/14/2014) and the Instructions for completing the Application
Package, in particular section "Completing the attachments to the e-form".
For further information
For further information or clarifications on the content of this handbook, please contact us via
the functional mailbox for this action:
4
5
1.1. Your project in the lifecycle of the Erasmus + Programme
Policy
The Erasmus + Programme is implemented via Calls for proposals and it is expected that
your project will contribute to the policy priorities of this programme. Check the web pages
of DG EAC (Directorate General for Education and Culture), CEDEFOP (European Centre
for the Development of Vocational Training), DG EMPL (Directorate General for
Employment, Social Affairs & Inclusion) and other relevant bodies regularly in order to keep
your project in line with the latest policy development in the field and priority your project is
linked to. Eligibility of costs and guarantee
The Agency co-finances the costs of the project activities from the beginning until the end
of the eligibility period. Any project activities occurring outside of the eligibility period are
not eligible for funding. Depending on the evaluation of the financial capacity of the beneficiary organisation, the
Agency may seek a financial guarantee before the pre-financing payment(s) are made. At the beginning of the project the Agency transfers to you a first pre-financing payment
which amounts to the percentage of the European Union's contribution to the project costs
set out in the grant agreement. At the end of the project and after approval of the project
results, analysis and approval of the costs incurred, the Agency will execute the final
payment which is made up of the contractual percentage of the total eligible actual costs
less the payments already made less the interests earned on the pre-financing payments. Monitoring and reports
To enable the Agency to monitor and assess the achievements of your project, you are
required to submit a final report. The Agency uses external expertise to assess the progress
of your project. As part of the monitoring activity, the Agency may organise a meeting with
the key people on your project (in Brussels or at your premises). Changes
If during the project's lifetime the need for changes to the grant agreement arises, you must
request an amendment to the Agency PRIOR to the change(s). (See Section "Amendment
request"). Keeping documents
After the project's closure, independently of the report on factual findings made by an
auditor to be transmitted with the final report, the Agency reserves the right to launch an
audit to verify the accounts. The grant agreement includes a specific requirement to keep
records (accounts and all supporting documents) for 5 years after the final payment is
transferred to the beneficiary's account.
These areas are now presented in more detail.
6
2. Monitoring of the actions by the Agency
2.1 Purpose
The main purpose of the monitoring is to provide support for each project, to offer guidance
and advice which can be integrated by the project team as it endeavours to achieve a
successful outcome. Monitoring also ensures that projects fulfil their stated objectives and
allows the identification of good practices and lessons learned so that others may benefit from
them.
2.2 What kind of monitoring
A performance oriented monitoring is more relevant in the first half of the project and
will target more at the way the project is being managed, the partnership is cooperating, and
how activities are developing as compared to initial plans. A result oriented approach is
more relevant in the second half of project implementation and will focus more on the
actual implementation of the project activities as laid out in the approved work programme..
The Agency's monitoring may cover operational and/or financial aspects and may be
performed through face to face meetings or remotely1. Monitoring can be performed
through different means:
► Agency's desk monitoring: through the review of reports
► Agency's monitoring visits: monitoring visits are normally organised around an event
organised by the project. However, they may also consist of a visit by Agency’s
representatives or experts to the premises of the beneficiary (in situ visit);
► Meeting with a project at the Agency's premises: a visit by project representatives to the
Agency; or invitations of project representatives to participate in an event organised by the
Agency or the European Commission.
The above list is not exhaustive – additional project monitoring methods may be developed.
3. Reporting
The Agency is currently revising its reporting procedure and is moving towards an
eReporting system. This section of the Handbook will be updated as soon as the new
rules for submitting reports are in place. Meanwhile, please refer to the currently
available documents for preparing the reports as the information required will not be
modified, only the procedure for submitting reports.
A Final Report, covering the reporting for the entire project duration must be submitted two
months after the end of the project.
In order to provide a practical and structured means for a project to report its achievements,
the Agency has report templates – including a financial reporting table – accompanied by
instructions on how to complete them. The templates can be found at the following link:
7
http://eacea.ec.europa.eu/erasmus-plus/beneficiaries-space_en
(Chose Key Action 2 > Cooperation for innovation and exchange of good practices > EPALE-NSS)
The Final Report contains information about the execution of individual activities, the
management of the project, the project finances, and any supplementary information the
beneficiary would like to communicate to the Executive Agency/Commission (DG EAC and
DG EMPL). The legal representative of the EPALE National Support Service (NSS) must
confirm that the data and information contained in the report are accurate and in accordance
with the facts.
Please note: the report should offer the complete picture of a project thus enabling it to be
fully evaluated.
A complete financial analysis of the project's expenses will be done at the submission of the
Final Report.
3.1 Structure of the Final Report
The Final Report consists of two parts:
► a Public Part;
► a Confidential Part.
The Public Part presents a summary of the content of the project and its achievements. It is a
document intended for the general public, including people who are not familiar with the area
the project addresses.
The Confidential Part contains information about the execution of individual activities, the
management of the project, the project finances, and any supplementary information the
beneficiary would like to communicate to the Agency. The legal representative of the
beneficiary organisation must confirm that the data and information contained in the report
are accurate and in accordance with the facts. If there is any information or issue that the
beneficiary wishes to raise but is not considered as suitable for external communication then it
should be included in the Confidential Part.
Please note: the Public and Confidential Parts of the report when put together should offer the
complete picture of a project thus enabling it to be fully evaluated. However, the two parts
should not contain the same information.
A complete financial analysis of the project's expenses will be done only at the submission of
the Final Report.
3.2 Structure of the Public Report
The public report should include information on the 4 following headings:
1. Description of the Project:
Please provide a brief description of the main aims, activities and achievements of
your NSS also giving a brief overview of your priorities and the target groups you
addressed.
8
2. Project Methodology:
Please briefly outline your methodology for achieving the specific objectives set out in
the call for proposals. This could for instance include your national communication
strategy as well as your strategies for animating the portal and online communities, for
contributing development of the platform's contents and for supporting
multilingualism on the platform.
3. Project outcomes and results:
Please briefly describe the achievements and results of your main activities as well as
your main outputs, results and/or products.
4. Plans for the future:
Please provide a brief description of your plans or suggestions for continuing,
amplifying and/or improving your activities with the EU grant received. Please
highlight your suggestions for ensuring sustainability of your achievements.
The public report style and language should be suitable for a general public. Copying content
from the original application does not suit the external communication purpose of the Public
Part and is to be avoided. The use of EU project-related terminology is not recommended. Use
instead the actual titles and names of the various deliverables and products.
The report should include details of all products/results produced within the reporting period
in accordance with the approved work programme. It may contain diagrams and pictures
illustrating the work of the project. It should be of a quality that allows it to be published
without further revision or editing.
3.3 Structure of Confidential Report
The Confidential Part of the Final Reports includes the following parts:
Section 1 Declaration of honour by the Beneficiary
Formal declaration of the accuracy of the information provided in your report.
Make sure that the declaration is signed by the legal representative (the same person who signed
the grant agreement). If the declaration page is signed by the wrong person, the Agency will not be
in a position to accept the report, which would delay the due payment.
Section 2 Implementation of the work programme and project management
2.1 Implementation of Work programme Activities:
Describe the implementation of the activities in your work programme, including the list of all
deliverables/ achievements for each work package:
− Compulsory activities (E)
− National communication strategy (WP 1)
− Identifying stakeholders at local, regional and national level (WP 2)
− Cooperation with Erasmus+ National Agencies and the National Coordinators for the
European Agenda for Adult Learning (WP 3)
− Animating online communities and interactive/social sections of the EPALE platform
(WP 4)
− Identifying adult education content/resources (WP 5)
− Motivating users to contribute editorial content (WP 6)
− Providing support to multilingualism and translations (WP 7)
9
Please refer to performance indicators and report to which extend they have been achieved.
In case of problems encountered describe the solutions that have been implemented.
Please copy the table provided as required for each work package and respective activities.
2.2 Overall project Management
Explain the methodology put in place to manage the project, the coordination with the
different stakeholders and the implementation of quality assurance tools. Report on any
particular difficulty the project encountered related to the management.
Section 3 Other Supplementary Information (optional)
In this section you should include information or issue you do not consider suitable for
Sections 2 and 3 but that you wish to communicate to the EACEA/DG EAC.
You should attach to the Confidential Part any document produced within the project that
provides useful information for the assessment of the project performance. For instance,
examples of dissemination material you have produced, any further products (publications,
multimedia products, promotional material, articles published, etc.).
Section 4 Financial Reporting Table
The financial reporting for your project must be carried out using the Excel workbook that has
been provided by the Agency for that purpose and is available from the following webpage:
http://eacea.ec.europa.eu/erasmus-plus/beneficiaries-space_en.
More information is given on the financial reporting in part 4. Financial Rules of this
Handbook.
3.4 How to send the Reports
The complete report should be sent in the following way2:
- 1 original copy of the final report on PAPER (report drafted on the template). This
original copy has the signature of the legal representative. No supporting documents
(results) or financial report (excel sheets) should be attached.
- 2 electronic storage devices (eg. 2 USB sticks) containing the complete final report
(public and confidential part), the financial reporting tables (excel sheets) and all the
results (publications, presentations and agendas of meetings and conferences, folders
…). For supporting documents on the financial report, please consult the section
Calculation of the final grant amount and supporting documents. Please send 2
separate devices. One of them needs to be sent to an external expert.
10
The address is:
Education, Audiovisual and Culture Executive Agency
Erasmus+: Vocational Training, Adult Education, Platforms
Office: BOU2 02/145
Av. du Bourget 1
BE - 1049 Brussels
3.5 Processing the Reports
Each report must be submitted to the Agency by the deadline indicated in the grant
agreement. Late submission may considerably delay the process of analysing and assessing
the report.
In general, the Agency uses external experts to help with the analysis of the report, the
evaluation of the quality of the work accomplished and the formulation of an overall
assessment.
The experts engaged by the Agency are obliged to declare in advance that no conflict of
interest exists in relation to the projects they will assess.
3.5.1. Incompleteness of a report
If a report is incomplete (for instance, some parts are missing or incorrect), the Agency may
request that further information be supplied and provided through the submission of a new,
updated version of the report. The submission of a new version of the report is especially
important if the Public Part is not of sufficient quality for its publication. However, if the
missing or incomplete information relates to the Confidential Part, the Agency may decide
that the additional information can be submitted separately e.g. without the project having to
submit a new version of the report. The Agency will specify the form in which the additional
information should be submitted. In these cases, the period foreseen in the contract for
payment will be suspended until the additional information has been received by the Agency.
3.5.2. Rejection of a report
In addition, there are a number of elements that are indispensable for the Agency to carry out
an analysis of the report. The absence of any of these elements would render the Agency
unable to assess the report and would thus lead to a rejection of the report until the missing
information had been provided.
Reasons for rejecting reports:
− no original version of the report is received;
− the original signature of the legal representative is missing (the signature of a person
other than the legal representative cannot be accepted);
− the Public or the Confidential Part is missing;
− the financial report (electronic version) is missing or the amounts presented are not in
accordance with the initially agreed budget;
− the report, including the financial report, has been submitted using wrong templates
(excel reporting tool);
− the report has been submitted in a language other than English, French or German.
11
Based on the experts' assessment and their recommendations, the Agency takes a final
decision with regard to the payment of the due part of the grant. In case that a report is not
complete and additional information needs to be submitted, the related payment is likely to be
delayed.
Once the assessment is complete, the Agency will inform the project of the final evaluation
e.g. its decision and feedback on the project's progress and achievements.
4. Financial rules
4.1 General Provisions on Eligibility of Costs
Eligible costs
The general context, nature and amount of expenditure will be considered when assessing
eligibility.
To be considered as eligible project costs, costs must satisfy the following general criteria:
− they must relate to activities involving the eligible countries in the action "EPALE
National Support Services (NSS)".
− they must be incurred by the legal entity mentioned in the agreement;
− they must be connected with the project (i.e. relevant for the action and be directly
connected with execution of the project in accordance with the activity plan);
− they must be foreseen in the estimated overall budget of the project. Should the
Beneficiary anticipate incurring costs that were not foreseen in the estimated budget,
the prior approval of the Agency should be sought before incurring these costs. In
some specific cases an amendment will be necessary (see section 5);
− they must be necessary for the performance of the project;
− they must be reasonable and justified and they must be in accordance with the
principles of sound financial management3, in particular in terms of value for money
and cost-effectiveness;
− they must be generated during the contractual lifetime of the project4
as defined in
the Agreement;
− they must be actually incurred by the beneficiary and be recorded in its accounts in
accordance with the applicable accounting principles and be declared in accordance
with the requirements of the applicable tax and social legislation; Costs which are not
paid yet at the time of submission of the report cannot be recorded in the final
financial statement.
− they must be identifiable and verifiable and determined according to the applicable
accounting standards of the country where the beneficiary is established and
according to the usual cost-accounting practices of the beneficiary.
3 Costs shall be defined in accordance with the principle of sound financial management, namely with the principles of economy,
efficiency and effectiveness. The principle of economy requires that costs shall be defined in due time, in appropriate quantity and quality and at the best price. The principle of efficiency is concerned with the best relationship between resources employed and results achieved.
The principle of effectiveness is concerned with attaining the specific objectives set and achieving the intended results.
4 e.g. generated by an activity that takes place during the lifetime (legal duration) of the project / action. Activities taking place before or after
the period specified in a grant agreement are not eligible for funding.
12
The beneficiary's internal accounting and auditing procedures must allow direct reconciliation
of the costs and revenue declared in respect of the project with the corresponding accounting
statements and supporting documents.
Where national taxation and accounting rules do not require an invoice, an accounting
document of equivalent value means any document produced in order to prove that the
accounting entry is accurate and complies with the applicable accounting law.
The beneficiary must keep all supporting documents relating to the project.
Unjustified costs will not be considered as eligible by the Agency and/or by the
auditors.
Non-eligible costs
The following items of costs are not eligible and should therefore not be included under any
headings in the Budget:
− contributions in kind;
− return on capital;
− debt and debt service charges;
− provisions for losses or potential future liabilities (provisions for contractual and moral
obligations, fines, financial penalties and legal costs);
− interest owed;
− doubtful debts;
− exchange losses;
− VAT5;
− costs declared by the applicant and covered by another action or work programme
receiving an EU grant;
− excessive or reckless expenditure;
− purchase of capital assets;
− in the case of rental or leasing of equipment, the cost of any buy-out option at the end
of the lease or rental period;
− costs associated with the preparation of the application, including participation in
Infodays;
− costs of opening and operating bank accounts (costs of transferring funds are eligible);
In particular, if the EPALE National Support Service (NSS) is a National Agency, it will take
care to avoid dual funding, i.e. both as an activity of the National Agency concerned
supported under the Delegation Agreement or under any other operating grant, and as an
activity supported under the present call.
Similarly, there may be no duplicate funding of staff costs already covered by the Delegation
Agreement of the National Agency or by any other operating grant.
Costs which could be considered as eligible according to the criteria detailed under section
4.1 become ineligible if they are not supported by adequate supporting accounting
documents.
In addition, internal invoices will not be accepted as valid supporting documents.
For more information regarding costs linked to bank transfers, please read article II.24.11 of
the Grant agreement.
5 The VAT paid by public bodies that cannot be recovered according to national legislation is an eligible costs
13
Timely recording of costs
Expenses must be recorded in the accounting system on the basis of adequate supporting
documents at the time the costs were incurred. Documents created after the period in which
the costs were incurred, will be declared ineligible (e.g. declaration of costs incurred in
2013, created / dated in 2015).
4.2 Principles applied to the different categories of expenditures
4.2.1 Staff costs
Costs relating to the following categories of staff are considered:
− Statutory staff, having either a permanent or a temporary employment contract with
the contracting organisation or equivalent appointing act;
− The cost for temporary staff, recruited through a specialised external agency, is also
eligible.
− other types of contracts as far as the national labour law assimilates them to
employment contracts/staff.
Learners/Trainees, volunteers and persons working through subcontracting (e.g. freelancers,
self-employed person, sole traders) cannot be considered as staff member.
Staff costs must be broken down into four categories:
− Staff category 1 Manager
− Staff category 2 Researcher, Teacher, Trainer
− Staff category 3 Technical
− Staff category 4 Administrative
Beneficiaries should report staff costs based on real daily staff cost rates, corresponding to
the beneficiary's usual policy on remuneration, comprising actual salaries plus social security
charges and other statutory costs included in the remuneration, respecting the non-profit
making principle which applies to EU grants.
Non-statutory costs like bonuses, lease car, expense account schemes, incentive payments or
profit-sharing schemes are excluded. Salary policy shall be the same for all staff no matter if
they work or not in the project: the use of grid of salary for staff working in the frame of
beneficiary activities in parallel with different rates for staff working on an EU project is not
acceptable. In case of ad-hoc staff daily rates on EU projects this one will be considered
ineligible. The veracity of these costs may be the subject of an audit.
Staff costs should be claimed on the basis of the actual daily salary/fees of the
employee/interim staff based multiplied by the number of days spent on the project.
i.e.:
Please note that the work outside regular working hours (like weekends), a substantial
increase of the number of working days and/or a significant shift between the categories in
the final report in comparison to the initial budget must be duly justified.
14
Staff members of the beneficiary are not allowed to operate in a subcontracting capacity for
the action. Costs related to persons working through subcontracting shall be included under
the appropriate category.
4.2.2 Travel and subsistence costs
4.2.2.1 Travel costs
− Travel costs for staff taking part in the action are considered eligible, provided that they are in
line with the beneficiary organisation 's usual practices on travel costs;
− Costs may be claimed only for journeys directly connected to specific and clearly identifiable
project-related activities. For information on charging Travel Costs for non-staff members
please refer to sections below ('Other direct costs’ and ‘Costs of subcontracting, consultancy
and other external services’);
− Reimbursement is based on real costs, independent of the means of travel chosen (rail, bus,
taxi, plane, private car). The beneficiaries are required to use the cheapest means of travel (e.g.
use economic class tickets bought well in advance for air travel and take advantage of reduced
fares, where this is not the case then a full explanation should be provided);
− The travel cost for a journey should include all costs and all means for travel from the point of
origin to the point of destination (and vice versa) and may include visa fees, travel insurance
and cancellation costs;
− Expenses for private car travel (personal or company cars), where substantiated and where the
price is not excessive, will be refunded as follows (whichever is the cheapest):
− either a rate per km in accordance with the internal rules of the organisation concerned up
to a max of EUR 0.22;
− or price of a rail, bus or plane ticket shall be reimbursed, independently of the number of
people travelling in the same vehicle.
− For hired cars (maximum category B or equivalent) or taxis: the actual cost will be considered
eligible where this is not excessive compared with other means of travel (also taking account
of any influencing factors e.g. time, excessive luggage).
Travel costs incurred outside the countries participating in this action of the Eramus+
programme are not eligible, unless explicit written prior authorisation is granted by the
Executive Agency.
4.2.2.2 Subsistence costs
− Subsistence costs for staff taking part in the project/action are eligible under this
budget heading;
− Costs may be claimed only for journeys directly connected to specific and clearly
identifiable project-related activities. For information on charging Subsistence Costs
for non-staff members please refer to Section ‘Other direct costs’ and ‘Subcontracting
costs’;
− Subsistence rates cover accommodation, meals and all local travel costs (but not local
travel costs incurred to travel from point of origin to point of destination,).
− The maximum number of days that can be claimed is the number of
event/conference/meeting days + 1 (this additional day is eligible in case of prior
arrival or late departure due to flight/train/means of transports schedule). A full day
normally includes an overnight stay. In duly substantiated cases, a full day’s
allowance without an overnight stay may be allowed with a pro rata reduction for
accommodation (costs limited to 50% of the maximum rate)..
15
− A pro-rata reduction must be applied if accommodation, meals and local travel costs
are provided for by a third party;
− In either case, proof of attendance and overnight accommodation may be required to
substantiate the costs declared.
Within these limits, subsistence expenses may be reimbursed on an actual or daily allowance
basis as per beneficiaries' usual practices on subsistence
Subsistence policy should be the same for all staff no matter if they work or not in the project:
the use of a grid of subsistence for staff working in the frame of beneficiary activities in
parallel with different rates for staff working on an EU project is not acceptable. Ad-hoc
subsistence rates on EU projects will be considered ineligible. The veracity of these costs may
be the subject of an audit.
4.2.3 Costs related to equipment and materials Purchase, rent or lease of equipment (new or second-hand), including the installation,
maintenance and insurance costs, are considered eligible costs:
− only when specific and necessary for achieving the goals of the project/action.
Proposed equipment costs must always be duly justified. The rules for procurement
defined in the Grant agreement apply;
− provided that it is written off in accordance with the tax and accounting rules
applicable to the beneficiary organisation and generally accepted for items of the same
kind. Only the portion of the equipment's depreciation corresponding to the duration
of the action and the rate of actual use for the purposes of the action may be taken into
account. If the nature and/or the context of its use justify different treatment, this
should be duly justified;
− All equipment related to the administration of the project (e.g. PCs, portables, etc.)
and all equipment purchased before the start of a project is covered by indirect costs
of the project (see below).
The total cost for equipment and materials may not be more than 10% of the total eligible
direct cost of the project.
4.2.4 Subcontracting costs
Any amount paid to an outside body, organisation or individual6 which carries out specific
and limited work for the project through procurement contracts, shall be charged to this
heading.
The beneficiary shall award the contract to the tenderer offering best value for money, that is
to say, to the tender offering the best price-quality ratio, in compliance with the principles of
transparency and equal treatment for potential contractors, care being taken to avoid any
conflict of interests.
The beneficiary is expected to clearly document the tendering procedure and retain the
documentations for the event of an audit.
6 This refers to individuals who may be self-employed i.e. who are responsible for their own social security or social
contributions, pensions and taxes. National legislation on the definition of these individuals can vary and should always be considered.
16
Moreover, In the event of procurement exceeding EUR 60.000, the beneficiary must abide to
Article I.10.1, II.9 and II.10 of the grant agreement and in addition provide at least three
competitive bids as referred in the grant agreement.
Sub-contracting must satisfy the following conditions:
− the essential activities of the project may not be subcontracted;
− it may only cover the implementation of a limited part of the action;
− it must be justified having regard to the nature of the action and what is necessary for
its implementation;
− it must be clearly stated in the proposal or prior written authorisation from the Agency
should be requested in case it has an impact on project's objectives/activities/outputs.
If the beneficiary calls on the services of an outside expert (i.e. a person not on the payroll of
the beneficiary organisation) as a consultant, the costs will be eligible subject to the
conditions mentioned above and provided that they are strictly necessary for the performance
of the project and are reasonable in amount. All the costs directly connected with sub-
contracting must be declared under the sub-contracting budget heading whatever the nature of
the costs concerned (e.g. staff costs plus travel costs, etc.) and be included and detailed in the
contract signed with the sub-contractor.
A subcontract must at least indicate:
− the reference to the tender and offer;
− the reference to the EU project;
− the start/end date;
− the tasks to be implemented within a certain time schedule;
− the value of the contract;
− the payment modalities (amount or percentage and deliverables to be achieved; law
applicable in case of contestation, etc.)
− date of signature of the agreement
For translations carried out by an outside body, only expenditure directly related to
translations from and into the official languages of the countries formally participating in the
action will be accepted, unless explicit prior authorisation is granted by the Agency.
Translation costs may not be higher than the market prices in the country where the
translation is done.
NB: When the rules of your institution oblige you to work with a unique supplier for each
assignment with the aim of obtaining the fairest economic conditions, this situation can be
accepted provided that you can prove that a procurement procedure was launched in order
to choose this subcontractor “in tempore non suspecto”(i.e existing framework contract).
The total cost for Subcontracting may not be more than 50% of the total eligible direct cost of
the project.
4.2.5 Other Costs
For each cost under this category, a clear description should be entered.
Other direct costs, not covered by those indicated above, may be allowed, provided they are:
− necessary for the performance of the project;
− reasonable in amount;
17
− fully documented and clearly itemised in the application;
− not indicated under another heading or item of expenditure.
Other direct costs are reimbursed on the basis of real costs.
Specific items of expenditure eligible under this heading include:
− costs incurred in producing, translating and publishing documents, when those
activities are performed by the beneficiary organisation;
− Costs to cover the Report of Factual Findings on the Final Financial Report - Type I,
required by the grant agreement (see part 4.3 of this Handbook);
− the organisation of seminars such as rent of rooms, catering services, the production of
proceedings of a seminar (posters, badges, banners, programmes...), interpretation
booths, local transport, the purchase of product-related consumables (reams of paper
for printing of publications, blank DVD), etc; however, if the costs incurred for
conferences and seminars are made under a subcontracting agreement, they should be
included under subcontracting costs;
− travel and subsistence costs reimbursed to third parties (i.e. for the costs of people who
are neither staff of the beneficiary organisation nor sub-contractors); the rules
applicable to the reimbursement of costs for staff of the beneficiary organisation will
be applied;
− bank transfer and exchange costs (but excluding exchange losses) relating to receipts
and payments for eligible expenditure under the project.
Please note:
All costs related to the administration of the action (i.e. consumables, supplies, photocopying
costs, telephone costs, internet access, paper, etc.) are not eligible under this sub-heading.
They are covered by Indirect Costs.
4.2.6 Indirect costs
The eligible indirect costs for the project represent the beneficiary's general administrative
costs, with due regard to the conditions of eligibility described above. Indirect costs are costs,
which are recorded in the project's accounts and incurred in connection with the implementation of the
project but which are not identifiable as specific costs. They cannot include any eligible direct
costs.
The indirect costs of the project eligible for European Union funding is a flat rate amount set
at a maximum of 7% of the total amount of eligible direct costs. This indirect costs rate was
contractually7 agreed and is given in Annex III of the Grant agreement. The corresponding
costs need not be justified by accounting documents.
This percentage may not be modified once the budget is approved and cannot be
transferred to another category.
In addition indirect costs shall not be eligible under a project grant awarded to a beneficiary
who already receives an operating grant8 from the Commission during the period in
question for the same activities.
7 See Special Conditions of the grant agreement: article 1.3.
8. The management fees provided for in the Delegation Agreement of E+ National Agencies is principally
considered compatible with the flat rate for indirect costs foreseen in action grant agreements (EPALE-NSS, etc.) as far as the risk of double funding is concerned. Indirect costs of E+ National Agencies can therefore be considered eligible, provided that the NA does not receive any other operating grant from the Commission during the period in question and for the same activities. In addition, the beneficiary should be able to
18
Examples of indirect costs are:
− all costs for equipment related to the administration of the project (e.g. PCs, portables,
etc.); − communication costs (postage, fax, telephone, internet access, mailing, etc.);
− infrastructure costs (rent, electricity, etc.) of the premises where the project is being
carried out; − office supplies;
− photocopies.
4.3 Calculation of the final grant amount and supporting documents
The final amount of the grant to be awarded to the beneficiary is established after completion
of the action, upon approval of the request for payment containing the following documents:
− a final report providing details of the implementation and results of the action;
− the final financial statement of costs actually incurred.
Supporting documents to be provided with the financial statement are as follows:
Option 1
In case of grants for an action equal or inferior to EUR 60.000, the beneficiary is required to
submit the following sample of supporting documents:
Budget item/heading Sample to be annexed to the Final Financial Report
Staff The three highest consolidated staff costs (i.e. staff member
costs) for the whole eligibility period
Subcontracting The three highest value subcontracts
Travel and subsistence 25% of the highest costs declared under this budget item
Example of underlining documents to be submitted in support of the final payment:
1) Staff costs: employment contract (or equivalent document), payslips (or
remuneration’s receipts), proof of payments (if applicable) and, if foreseen by the call
for proposals, the time sheets or equivalent documents showing the manpower’s work
effort (i.e. number of working days);
2) Subcontracting: quotes (if applicable), contracts, invoices and proofs of payments;
3) Travel and subsistence: copy of tickets and boarding passes, hotel invoices (and proof
of payments).
Option 2
- in case of grants for an action of more than EUR 60.000, but less than EUR 750.000
The beneficiary is required to submit, in support of the final payment, a “Report of Factual
Findings on the Final Financial Report - Type I” produced by an approved auditor or in
case of public bodies, by a competent and independent public officer.
The procedure and the format to be followed by an approved auditor or in case of public
bodies, by a competent and independent public officer, are detailed in the “Guidance Notes”
provided in the Audit procedure available at:
http://eacea.ec.europa.eu/about/eacea_documents_register_en.php. The use of the report
format set by the “Guidance Notes” is compulsory.
demonstrate a clear separation of the respective activities and subsequent budgets.
19
If the eligible costs actually incurred by the beneficiary are lower than anticipated, the Agency
will apply the rate of co-financing stated in the grant agreement to the expenditure actually
incurred.
In the event of non-execution or clearly inadequate execution of an activity planned in the
application attached to the funding agreement, the final grant will be reduced accordingly.
The "Report of Factual Findings on the Final Financial Report" – Type I is an integral part of
the final report.
The submission of a proper Report of Factual Findings on the Final Financial Report, doesn't
prevent the Agency to request additional supporting documents inquiring on the triggering
event generating the costs and proving the direct linked with eligible staff working days.
The following documents are to be kept as supporting evidence for the costs that will be
submitted in the Final Report
Staff costs: ► employment contract
► salary payslip (monthly or annual slip)
► time sheets that will confirm the number of days worked will need to fulfil
the following minimum requirements:
− to have the title and reference number of the EU project;
− it has to be done for each person working on the EU project;
− it has to be filled in minimum on a monthly basis;
− it has to mention the hours and project activities spent on the EU
project versus total working hours on other normal activities with
indication of activity title and tasks;
− it has to be signed and dated by the person and by an authorised
person.
► annual accounts
Equipment costs: ► contracts and invoices, proof of payment
Travel: ► original plane/train ticket, original boarding pass or e-ticket and e-boarding
pass
► invoice from the travel agency
Subsistence costs: ► internal rules pre-existing to the project
► method of calculation
► attendance list of participants or, if not available, minutes of meetings or
invitation to meeting
► hotel/accommodation invoices
Subcontracting costs: ► tendering specifications/terms of reference (if applicable)
► offers received (dated and signed) (if applicable)
► evaluation report, award decision, notification letters (if applicable)
► procurement contract
► invoices
20
Other direct costs: ► invoices of the specified costs (only real incurred costs are considered for
this sub-heading)
Internal and non official documents (e.g. self declarations) are not acceptable as
supporting documents.
All documents mentioned above (invoices, employment contracts, salary payslips,
subcontracting contracts) need to fulfil the respective requirements imposed by the
national legislation.
4.4 Checks and Audits
The audit we are referring to here are the ones launched a posteriori by the Commission,
Agency or Court of Auditors. It does not refer to the audit certificate ("Report of Factual
Findings on the Final Financial Report" – Type I or II requested with the final report).
Please refer to Articles II.20 and II.27 of the Grant agreement for more information on
possible checks and audits.
We draw your attention to the fact that monitoring missions, ex-post controls and external
audits can be carried out at any time during the implementation of the project or up to 5 years
after the final payment. This period shall be longer if there are on-going audits, appeals,
litigation or pursuit of claims concerning the grant, including in the case referred to in Article
II.27.7. In such cases, the beneficiaries shall keep the documents until such audits, appeals,
litigation or pursuits of claims are closed.
The filing system of all documents relating to the project should be organised from the start
of the project and all accounting documents should be duly classified. However, when a
project is informed that it will be audited, the following measures should be taken:
− check that all adequate supporting documents (accounting and operational material)
exist and are duly classified;
− request missing documents from the beneficiary concerned as a matter of urgency;
− check that all the supporting documents are adequate and incurred during the
eligible period;
− check that the allocation of costs is consistent within each budget category: e.g do
not reallocate "staff costs" to the category "other costs" because the budget category
"Staff costs" is overspent.
Please note that costs which are not duly justified by adequate supporting documents
will be rejected by the Agency/auditors. Moreover, the Agency reserves its right not to
accept late reception of documents (late meaning after the contractual deadlines have
passed or, in case of an audit, after the transmission of the final audit report by the auditors
to the Agency).
Be aware that the most frequent reasons for the Agency/auditors to reject the costs
are:
1) The lack of supporting documents relating to expenses claimed: missing invoices,
inconsistent allocation of costs, inadequately supported expenses coming from project
beneficiaries;
21
2) Ineligibility of costs: unforeseen costs for which no prior authorisation has been
requested to the Agency, overhead expenditure exceeding the maximum ceiling,
contribution in kind claimed, costs incurred outside the eligibility period. Costs that
do not meet the criteria set out in the legal basis/guidelines or contradict with sound
financial management;
3) The non-respect of accommodation/subsistence EU rates, the wrong application of
exchange rates, depreciation error, recalculation of overheads due to ineligible costs,
reclassification of costs between headings/categories, dual claiming and declared
expenses exceeding real costs;
4) Inadequate audit trail: missing papers or electronic trail that gives a step by step
documented history of a transaction.
Therefore, it is worth insisting on the following:
− all supporting documents relating to the costs of the project’s implementation must
be gathered;
− all invoices should state the project’s reference and possibly the reference to the
relating Work Programme’s activity;
− the importance of having a separate bank account (or sub account that allows
identification of payments made) for the project funds;
− the need to justify not only the "EU funds" part but also the "own contribution" part,
as the final calculation of eligible amounts to be covered is calculated based on the
total expenditure;
− the need to have a good internal control system leading to transparency. This has to
be reflected in a reliable and easy audit trail, where financial data can be traced from
general ledger to source documents and which constitutes a basis of objectivity;
4.5 Claims/Appeals
Any complaint/appeal against the analysis of the project made by the Agency ("closure
letter") must be in line with the following conditions:
− a formal complaint must be submitted in writing by the beneficiary after checking the
validity of arguments and documents. It further must address the arguments stated by
the Agency in the closure letter.
− the deadline for requesting information on the determination of the final grant is two
months from the date of notification by the Agency of the final amount of the grant
determining the amount of the payment of the balance or the recovery order or, failing
that, of the date on which the payment of the balance was received. After this time
such requests will no longer be considered.
All justifying documents must be annexed to the complaint and organised by beneficiary with
clear reference to the budget line concerned in the Excel table together with a short translation
of the key words if necessary.
22
The Agency will only consider official documents (i.e. no self-declarations) and new evidence
not yet submitted with the final report.
5. Amendments
5.1. Introduction
Any amendment to the grant agreement must be subject to a prior written supplementary
agreement. It is important to understand that the amendment request should not be used
retrospectively e.g. changes that have in reality already been carried out prior to the
submission of the request.
The amendment request has to:
− be made (where required) on the specific template amendment request form provided
by the Agency under the link mentioned below.
− be submitted to the Agency by an official letter or form signed by the legal
representative of the beneficiary, that is, the person who signs the contract or his/her
legal replacement;
− be submitted to the Agency before the change occurs;
− be submitted to the Agency at the latest one month before the closing date of the
action;
− duly justify the reasons for the proposed changes.
The Agency reserves the right to reject an amendment request that is not sufficiently justified.
The changes which require an amendment request form are:
− Change of the beneficiary organisation or change of name of beneficiary organisation
− Changes to the eligibility period
− Changes to the budget breakdown
− Change of bank account
− Changes to the work programme
Guidance on filling in the form can be found on the form itself, available at:
http://eacea.ec.europa.eu/erasmus-plus/beneficiaries-space_en
5.2 Cases where the amendment request form is not required
The following section describes those cases where the use of the amendment request form is
not needed.
5.2.1 Changes via the Participation Portal
Beneficiaries are no longer required to send a request for amendment for the modifications
which they can make themselves in the Participant Portal.
(http://ec.europa.eu/education/participants/portal/desktop/en/organisations/register.html)
Nonetheless it is requested to inform the Agency by e-mail when a modification is made
via the Participation Portal. The Agency will confirm by letter that the change(s) was
introduced in the Participant Portal by the beneficiary.
23
The following modifications must be made via the Participant Portal:
− Change of the legal status of the beneficiary
− Change of legal name of the beneficiary
− Change of address
5.2.2 Change of legal representative of the beneficiary organisation
In this case it is not necessary to use the amendment request form. A letter signed by the new
legal representative together with an official document confirming the name of this new legal
representative is sufficient. Examples of official documents include statutes and/or minutes of
the Board.
5.2.3 Change of project coordinator
A change of project coordinator (i.e. the project manager in the organisation designated as
EPALE National Support Service) does not require the use of the amendment request form.
However, a letter signed by the legal representative of the beneficiary organisation must be
submitted to the Agency outlining the reasons for the envisaged change.
5.2.4 Change to the budget breakdown
An amendment request relating to an adjustment to the budget breakdown is not necessary
provided that that this adjustment does not affect the implementation of the action and the
transfer between budget headings of eligible direct costs (between Heading A: staff costs and
Heading B: operational costs including travel and subsistence; equipment; subcontracting;
conferences, seminars; others ) does not exceed 10% of the amount of the heading for which
the transfer is intended (the heading that increases), irrespective of the adjustment made
between items of operational costs.
Please note that it is not possible to modify the total eligible budget, the amount of the
Community grant or the co-financing percentage.
6. Recognition of Commission funding and use of Erasmus + logo
The obligations linked to publicity and using of the logo are defined in the article I.10.3 of
the Grant agreement.
The Erasmus + logo and the mention can be found at: https://eacea.ec.europa.eu/about-eacea/visual-identity_en
The project visibility activities as well as publications and results that are distributed must
have the Erasmus + logo and the mention "Co-funded by the Erasmus+ programme of the
European Union" or "With the support of the Erasmus+ Programme of the European Union".
For Publications, please follow the instructions for the text and the use of disclaimer available on the
Agency website: https://eacea.ec.europa.eu/about-eacea/visual-identity_en