projektfinanzen –die programmregeln › fileadmin › user... · 26 flc seminar, schwerin | 23...

17.05.2019

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Projektfinanzen

– Die Programmregeln

First Level Control Seminar

Schwerin | 23 Mai 2019

Dana Hennings, Bartłomiej Wierzbicki, Managing Authority/Joint Secretariat

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Content

FLC Seminar, Schwerin | 23 Mai 20193

1. Basics

2. Budget lines

3. State aid

4. Final remarks


Basics

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5 Hierarchy of rules (Article 18(3) of Regulation (EU) No 1299/2013)

Programme

Manual

Hierarchy of rules

All cost must be …

� essential

� paid by a project partner and non-recoverable (e.g. VAT)

� NO sub-partners � NO cost sharing

� paid in the eligible period � Reimbursement principle;

NO advance payment for ERDF

& Norwegian funds

� supported by relevant documents

� real costs (exceptions: unpaid voluntary work, simplified cost options, depreciation)

� in line with the principles: efficiency, economy/effectiveness

6 FLC Seminar, Schwerin | 23 Mai 2019

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Eligibility periods


• Contracting phase (min. 3 months) project costs

• Implementation phase (max. 36 months) fully eligible

• Closure phase (3 months) � limited eligibility

• Post-project phase � no costs eligible

�


Budget lines

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Budget lines

Pro

ject

b

ud

ge

t

BL1 - Staff

BL2 - Office & administration

BL3 - Travel & Accommodation

BL4 - External expertise & services

BL5 - Equipment

(BL6 - Infrastructure & works)

(BL7 – Project specific activities)



Budget lines

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1. Full-time and part-time staff

2. Unpaid voluntary work

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BL1 - Staff: Types


� Employed by partner organisation

� Formally engaged in project activities

100%

of the employee‘s

working time is

spend for project

work

< 100%

of the employee‘s

working time is

spend for project

work

Full time Part-time

BL1 - Staff: Full-time and part-time

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Gross employment costs

� Fixed in employment document or by law

� Non-recoverable

� Examples:

� Salary

� Other costs directly linked to the salary

BL1 - Staff: Eligible costs

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Full time Part-time


Full time Part-time

� Employment document

� Job description

� Documentation of gross employment costs

� Payment proof

� Staff costs tool

+ method specific

documents

BL1 - Staff: Documentation

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Fixed percentage of time worked per month

� Percentage fixed in employment document in advance

☺No timesheet needed

☺Simple calculation

�Over- or undercompensation possible

BL1 - Staff: Calculation options

Part-time


Calculated with a yearly hourly rate

� Annual gross employment costs of previous 12 months

divided by 1,720 hours

☺Only need to calculate it once

�Over- or undercompensation possible

�Timesheet needed


Part-time

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Calculated with a monthly hourly rate

� Monthly gross employment costs of actual month divided

by monthly working time set in employment contract

�Timesheet needed

�Hours for vacation and sick leave are not covered


Part-time


Calculated with a contracted hourly rate

� Hourly rate set in the employment contract multiplied with

actual working hours

�Can only be used by staff that is paid on hourly rate basis

�Timesheet needed

�Hours for vacation and sick leave not covered


Part-time

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Fixed % Annual

hourly rate

Contracted

hourly rate

Monthly

hourly rate

Fixedworking hours

Flexibleworking hours

Part-time

Do not mix the calculation methods!

Avoid double-financing!


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a) Programme templates -> option in staff costs tool

b) Own internal time registration system

Minimum requirements:

• Completed by each employee individually

• Contain the amount of hours worked on daily basis

• Signed by employee and his/her supervisor

• Cover 100% of the working time of the employee

(incl. activities outside project)

Staff cost tool: Brief monthly summary describing the activities

BL1 – Staff: Timesheets


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Documentation

• Signed agreement with voluntary worker

• Signed timesheets

• Staff cost tool

Calculation

• Hourly rate � Max. hourly rate for equivalent work

• Limit per partner � Unpaid voluntary work < Own contribution

• Other essential expenditure (e.g. travel costs, material) can be

reported in other budget lines

BL1 - Staff: Unpaid voluntary work

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15%flat rate

of BL1 staff costs

Automatic calculation

Costs covered under BL2 cannot be reported

under any other budget line!


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• Office rent

• Insurance and taxes of buildings and equipment (e.g. fire, theft

insurances)

• Utilities (e.g. electricity, heating, water)

• Office supplies

• General accounting

• Maintenance, cleaning and repairs; Security; IT systems;

• Communication (e.g. telephone, fax, internet, postal services)

• Bank charges, transnational financial transaction charges


Types

• Travel costs (e.g. tickets, fuel, car mileage, toll, parking fees)

• Accommodation

• Daily allowances

• If not covered by allowances: Meals (other than catering!), Visa

Rules

• Most economic way of transport

• Every travel must be relevant for project activities

• Only for project staff � Speakers, experts, other guests in BL4


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Reporting documents

• Invoices or equivalent accounting documents of travel costs

• Payment proof

• Proof of reimbursement of costs to the employees where

employees made a direct payment for travel




Eligible

• Studies, surveys, legal/technical consultancy, translations

• Financial and/or project management services

• Project events (e.g. catering, premises, event management)

• First level control costs (for decentralised FLC systems)

• Travel and accommodation costs of guests with active role

• …

Not eligible

� Basic courses

� Services from other project partners/own staff

BL4 - External expertise & services

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• Office equipment

• IT hardware & software

• Furniture & fittings

• Laboratory equipment

• Machines & instruments

• Tools or devices

• Vehicles

• Other

BL5 - Equipment

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1. Equipment which is part of an investment

• Clear link to an investment output

• Full costs eligible

2. Other equipment

• Tools/devices to implement other project activities

• Depreciation/rental/leasing costs for period of use

BL5 - Equipment

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BL5 - Equipment

Investment equipment in the application


BL5 - Equipment

Investment equipment in the application

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• Only investment related costs

� Blocked if no investment outputs planned

• Full costs eligible

• Examples: Works for …

site preparation, delivery, handling, installation, renovation

BL6 - Infrastructure & works


• Application

Indicative specification of contracts (sections 6.1, 6.2 and 6.3)

• Documentation

� Procurement

� Contracts and invoices

� Proof of delivery

� Payment proof

BL4, BL5 and BL6

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State aid

State aid


What is State aid?

• Programme funds = public funds

• Company receives benefit over competitors

• In general: State aid is prohibited

• BUT: State aid instruments allow exceptions

� De minimis

� General Block Exemption Regulation (GBER)

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State aid


What kind of State aid is granted?

• Project partners with State aid relevant activities

� Because: advantage over competitors through

first-hand knowledge, new customers, new services or

new products

� Entire partner budget affected

Example: Group of activity marked as State aid relevant38

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39 Example: State aid co-financing rate and instruments – Section 6.6

Example: Entire State aid budget – Section 6.740

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State aid


What kind of State aid is granted?

• Project partners with State aid relevant investments

� Because: advantage over competitors through lower

investment costs

� Budget lines 5 and 6 affected

Example: State aid relevant investments in the work plan42

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Example: State aid relevant investments in BL643

Example: Only part of the budget is State aid relevant44

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State aid


What has to be observed?

• Follow the requirements included in:

� Application (e.g. max. State aid budget available)

� Clarification form (e.g. project-specific requirements)

� De minimis award letter (e.g. retention period)

� GBER declaration (e.g. general and specific conditions)

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Layout of de minimis declaration and award letter46

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Layout of GBER declaration and GBER and SME declaration47

State aid


What has to be observed?

• Accounting: Carefully separate State aid expenditure

� Note! Revenues not deducted

• Reporting:

� Separate State aid expenditure

� Provide details on State aid relevant activities

• State aid budget cannot be exceeded

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State aid


What is the role of the first level controller?

For all State aid partners:

� State aid relevant activities in line with application form

� State aid expenditure correct in accounting system & report

� State aid budget of the project partner not exceeded

+ For GBER:

� Specific conditions complied with (cf. GBER declaration)

� Activities started after application was submitted to MA/JS

State aid


What is the role of the first level controller?

For all partners:

� Other activities are of non-economic nature

• Activities, goods or services for

− which no market exists, or

− that could not be carried out by a private operator

which intends to make profit

• Infrastructure not exploited economically and available

for public use free of charge

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Extract from first level control report and checklists

First level control report and checklist/PP

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First level control report and checklist/LP

(Progress report, section 14.3)


Final remarks …

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Every contract with externals must …

• comply with public procurement rules

• follow principles of

– transparency

– non-discrimination

– equal treatment

• contracts below national thresholds but > EUR 5,000 (net):

bid-at-three rule

Applies to private partners as well!


Activities outside the EU & Programme area


Do I need prior approval by MA/JS?

• Programme area & EU � NO

• Other countries � YES

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Please also consider…


• Special rules for revenues & cash-in flows

• Visibility rules

• Retention period

� ~ 4 years after final payment (exact date from MA/JS )

� Stricter rules for State aid

• Originals or in versions “in conformity with the original on

commonly accepted data carriers”

• Durability & ownership of (investment) outputs

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Projektfinanzen – Die Programmregeln

Dana Hennings & Bartłomiej Wierzbicki

Finance Officer

Managing Authority/Joint Secretariat

Phone +49/381 45 484 5280 & -91

e-mail: [email protected]

www.interreg-baltic.eu

Interreg Baltic Sea Region believes

in an integrated and prosperous Europe for all

projektfinanzen –die programmregeln › fileadmin › user... · 26 flc seminar, schwerin | 23...

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