Financials and Cost Verification for Twinning Manual Updates
Twinning
Manual –
from Brussels to
Malta
Valetta, May 8-9 2017
Claus Lech
Overview
–
clarifications & changes
1.
Financials and cost verification
2.
Reserve
3.
Mandated Bodies and verification of status
4.
Security related suspensions
5.
Proposal – selection – contract
6.
Work-plan
7.
Reporting
8.
Communication and Visibility plan
9.
Other issues
The Financials – since Brussels
Following the legal/contractual clarifications we have
reviewed and updated
•
Manual text
•
Annex A3 Budget
•
Annex A7 Financial
•
Introduced Annex B
•
C annexes
1. Financials and cost verification
Commission Decision defines – types of costs
•
Unit Costs
•
Flat rates
•
6% of direct costs as indirect cost compensation
•
Actually incurred costs
1. Financials and cost verification – Unit costs
RTA – analytical accounting statement
"The institution dispatching the RTA shall receive a reimbursement equalling
the remuneration of the RTA on the basis of an analytical accounting
statement of the last closed accounting year”. "Similarly, the institution
dispatching the RTA shall receive a reimbursement equalling the non-wage
labour costs incurred for the RTA, including compulsory social security
contributions such as those related to health, pension, unemployment), based
on an analytical accounting statement of the last closed accounting year” .
•
We might have to circulate an interpretation of “analytical”.
1. Financials and cost verification – Unit costs
If RTA is retired
•
By analogy - method to calculate the compensation
based
on the analytical accounting statement of the last closed
accounting year when the expert
was still in service
.
Once the unit cost has been established, we pay this amount and do
not care about the income for the time of assignment.
1. Financials and cost verification – Unit costs
Per diem
“Maximum”:
The per diem rate indicated is the maximum rate applicable for
the country concerned. A lower per diem rate can be agreed and authorised.
Proof
Once a unit cost for per diem has been established, the
MS does not have to
prove how much it actually paid
, but evidence that:
•
The activity took place
•
the MS paid per diem to the Expert / study tour participant
1. Financials and cost verification – Unit costs
Travel
Some MS have established systems via agreements with Travel agencies
providing unit price. Up to CA to agree on “reasonable” figures.
Visa
As actually incurred costs.
Proof
Once a unit cost for Travel has been established, the
MS does not have to
prove how much it actually paid
, but evidence that
•
The travel took place
•
T
he MS paid per for travel
1. Financials and cost verification – Unit costs
RTA Assistant(s)
The usually applied rates for this type of expertise known by the
Contracting Authority.
EUD to be consulted by CA and MS before fixing.
•
The “unit cost” is then used in the contract and being the price
fixed when selecting the assistant(s).
The term “Public Procurement Procedure”
1. Financials and cost verification – Flat rates
Flat Daily Allowance compensation
The flat rate as a simplified cost is established in the Commission
Decision.
The rate is not possible to increase. It is based on thorough analysis.
The
MS does not have to prove how much the actual cost was
, but
must provide evidence that the expert undertook activities in the
Beneficiary country triggering the FD
1. Financials and cost verification – Flat rates
Twinning Project Support Costs
–
Flat rate
This flat rate is as a simplified cost established in the Commission
Decision and cover
Costs related to time
:
•
spent by officials or assimilated agents in the MS in order to prepare and follow-up
missions in the BC;
•
s
pent by the Member State(s) project leader(s) in order to coordinate project
implementation from his/her home administration;
•
spent by and costs incurred for the delivery of activities during study visits of partner
country's officials or agents to a Member State;
•
devoted to the logistical arrangements necessary for the organisation of activities in
the partner country
The
MS does not have to prove how much the actual cost was
, but
evidence that experts undertook activities in the Beneficiary country
triggering the TPSC.
1. Financials and cost verification –
Actually incurred costs
All other cost items
•
Communication and Visibility plan implementation costs
•
External suppliers / providers of any kind
•
Excessive Interpretation and excessive printing costs (exception)
•
Travel Unit Costs not possible to fix at contract stage
1. Financials and cost verification –
6% indirect
What is it to cover?
For indirect costs linked to the direct costs of the implementation of
the project. Fixed at 6% - as in other grant contracts – defined in
Commission Decision.
The term ”Eligible”
All direct costs (unit costs or flat rates or actually incurred costs) in a
grant contract must by definition be linked to the implementation to
be eligible. Since 6% is linked to the indirect costs the cost is of
course linked to ”eligible” cost items.
2. Reserve
2.5% and ….
•
Not a direct cost before activated as such
•
Not subject to 25% addendum provision
•
•
Specifically foreseen for sustainability actions
3. Mandated Bodies and verification of status
Only two options exist
1.
The MS National Contact Point
2.
The applicant body it-self
Set up
•
MS to agree internally and define their own institutional setting
•
Included in self-declaration form
•
Re-registration? Criteria and MS questionning ”responsibility”
•
If no....during selection stage
•
No control of status at Expenditure verification stage
3. Mandated Bodies and verification of status
Simplification of classification of Mandated Bodies
•
Criteria in itself restricting the type of bodies -> No status as restricted.
•
Full mandated body or ad hoc mandated body.
•
Further simplification?
General management bodies with no specific sector
specialisation
•
Assigned a role by a decision by a ministry/government ”agreement” to
assist the PA. Fulfilling the requirements, but without Union Acquis
reference/specialisation
•
Special case: Six-pillar assessed
4. Security related suspensions?
•
Considered "Force Majeure"
as defined in Article 11.8 of the General
Conditions. In accordance with Article 11.2 the "coordinator" can suspend the
implementation based on force majeure or other exceptional circumstances.
The Twinning "coordinator" refers to the "Lead MS". Therefore the MS can
suspend based on force majeure.
•
During the suspension period the MS may request the reimbursement of
the minimum costs necessary for a possible resumption of the Action.
The
MS and the Contracting Authority shall agree in writing on such costs,
including the reimbursement of legal commitments entered into for
implementing the Contract before the notification of the suspension was
received, which the MS cannot reasonably suspend, reallocate or terminate on
legal grounds.
5. Proposal – selection – contract
Proposal
•
Availability statements
Selection
•
Full selection sheet to be shared
Contract
•
MS involvement in preparations aspects?
•
Special Conditions - provisions correct?
6. Work plan
Initial
•
Involvement of Project Leader(s)
•
Involvement of Support Staff
•
Limitations of input if complex project?
•
Successive updates & Steering committees
Side letter
•
Reserved to
–
text revised
STE requirements
•
Depends on definition in Fiche
7. Reporting
•
Bi-annual/quarterly?
•
MS PL to decide
•
Certified correct?
•
Removed
•
Template with budget reference to contract budget?
•
Contract budget is ONLY on budget headings
8.
Communication and Visibility
•
Link inactive
•
Always under same budget heading?
•
What type of costs?
9. Other issues
Study visits
•
No compensation for EU MS – for travel & per diems BC staff?
BC obligations
•
Recommend to strenghten narrative (fiche)?
Sustainability
•
Costs for such actions?
•
Reserve
specifically foreseen for sustainability actions
Next steps
•
A large scale awareness programme.
•
Welcoming any invitation to present. Limited by our
ressources. We are 4 staff for all Twinning.
•
A decision is a decision. And it is a good decision.
•
Re-checked all questions/remarks/proposals. Any Q left?
Clarifications – simplified costs (LU)
•
Once simplified cost amounts (as specified in the Action Budget)
have been assessed and approved by the CA
such costs will not be
subject to an ex post verification of actual underlying cost
data.
Hence, Auditors will not be required to check supporting
documents to verify the actual costs incurred
but they will verify
the correct application of the method and formula for the
calculation of the cost
based on related inputs and relevant
quantitative and qualitative information.
•
- Beneficiaries shall keep adequate records and documentation to
prove
that the costs are declared according to the agreed
method and formula
and that the qualitative and quantitative
conditions have been respected.
Thank
you…..and
comments
please
Meeting of MS National Contact Points for
TAIEX and Twinning
Malta 8-9 May 2017
The Financials and Cost Verification section of the Twinning Manual focuses on Commission Decision-defined types of costs, unit costs, flat rates, and the process of verifying actually incurred costs. It delves into unit costs related to RTA, method of calculating compensation, per diem rates, and proof requirements for per diem payments.
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Presentation Transcript
Twinning Manual from Brussels to Malta Valetta, May 8-9 2017 Claus Lech
Overview clarifications & changes 1. Financials and cost verification 2. Reserve 3. Mandated Bodies and verification of status 4. Security related suspensions 5. Proposal selection contract 6. Work-plan 7. Reporting 8. Communication and Visibility plan 9. Other issues
The Financials since Brussels Following the legal/contractual clarifications we have reviewed and updated Manual text Annex A3 Budget Annex A7 Financial Introduced Annex B C annexes
1. Financials and cost verification Commission Decision defines types of costs Unit Costs Flat rates 6% of direct costs as indirect cost compensation Actually incurred costs
1. Financials and cost verification Unit costs RTA analytical accounting statement "The institution dispatching the RTA shall receive a reimbursement equalling the remuneration of the RTA on the basis of an analytical accounting statement of the last closed accounting year . "Similarly, the institution dispatching the RTA shall receive a reimbursement equalling the non-wage labour costs incurred for the RTA, including compulsory social security contributions such as those related to health, pension, unemployment), based on an analytical accounting statement of the last closed accounting year . We might have to circulate an interpretation of analytical .
1. Financials and cost verification Unit costs If RTA is retired By analogy - method to calculate the compensation based on the analytical accounting statement of the last closed accounting year when the expert was still in service. Once the unit cost has been established, we pay this amount and do not care about the income for the time of assignment.
1. Financials and cost verification Unit costs Per diem Maximum : The per diem rate indicated is the maximum rate applicable for the country concerned. A lower per diem rate can be agreed and authorised. Proof Once a unit cost for per diem has been established, the MS does not have to prove how much it actually paid, but evidence that: The activity took place the MS paid per diem to the Expert / study tour participant
1. Financials and cost verification Unit costs Travel Some MS have established systems via agreements with Travel agencies providing unit price. Up to CA to agree on reasonable figures. Visa As actually incurred costs. Proof Once a unit cost for Travel has been established, the MS does not have to prove how much it actually paid, but evidence that The travel took place The MS paid per for travel
1. Financials and cost verification Unit costs RTA Assistant(s) The usually applied rates for this type of expertise known by the Contracting Authority. EUD to be consulted by CA and MS before fixing. The unit cost is then used in the contract and being the price fixed when selecting the assistant(s). The term Public Procurement Procedure
1. Financials and cost verification Flat rates Flat Daily Allowance compensation The flat rate as a simplified cost is established in the Commission Decision. The rate is not possible to increase. It is based on thorough analysis. The MS does not have to prove how much the actual cost was, but must provide evidence that the expert undertook activities in the Beneficiary country triggering the FD
1. Financials and cost verification Flat rates Twinning Project Support Costs Flat rate This flat rate is as a simplified cost established in the Commission Decision and cover Costs related to time: spent by officials or assimilated agents in the MS in order to prepare and follow-up missions in the BC; spent by the Member State(s) project leader(s) in order to coordinate project implementation from his/her home administration; spent by and costs incurred for the delivery of activities during study visits of partner country's officials or agents to a Member State; devoted to the logistical arrangements necessary for the organisation of activities in the partner country The MS does not have to prove how much the actual cost was, but evidence that experts undertook activities in the Beneficiary country triggering the TPSC.
1. Financials and cost verification Actually incurred costs All other cost items Communication and Visibility plan implementation costs External suppliers / providers of any kind Excessive Interpretation and excessive printing costs (exception) Travel Unit Costs not possible to fix at contract stage
1. Financials and cost verification 6% indirect What is it to cover? For indirect costs linked to the direct costs of the implementation of the project. Fixed at 6% - as in other grant contracts defined in Commission Decision. The term Eligible All direct costs (unit costs or flat rates or actually incurred costs) in a grant contract must by definition be linked to the implementation to be eligible. Since 6% is linked to the indirect costs the cost is of course linked to eligible cost items.
2. Reserve 2.5% and . Not a direct cost before activated as such Not subject to 25% addendum provision Specifically foreseen for sustainability actions
3. Mandated Bodies and verification of status Only two options exist 1. The MS National Contact Point 2. The applicant body it-self Set up MS to agree internally and define their own institutional setting Included in self-declaration form Re-registration? Criteria and MS questionning responsibility If no....during selection stage No control of status at Expenditure verification stage
3. Mandated Bodies and verification of status Simplification of classification of Mandated Bodies Criteria in itself restricting the type of bodies -> No status as restricted. Full mandated body or ad hoc mandated body. Further simplification? General management bodies with no specific sector specialisation Assigned a role by a decision by a ministry/government agreement to assist the PA. Fulfilling the requirements, but without Union Acquis reference/specialisation Special case: Six-pillar assessed
4. Security related suspensions? Conditions. In accordance with Article 11.2 the "coordinator" can suspend the implementation based on force majeure or other exceptional circumstances. The Twinning "coordinator" refers to the "Lead MS". Therefore the MS can suspend based on force majeure. Considered "Force Majeure" as defined in Article 11.8 of the General the minimum costs necessary for a possible resumption of the Action. The MS and the Contracting Authority shall agree in writing on such costs, including the reimbursement of legal commitments entered into for implementing the Contract before the notification of the suspension was received, which the MS cannot reasonably suspend, reallocate or terminate on legal grounds. During the suspension period the MS may request the reimbursement of
5. Proposal selection contract Proposal Availability statements Selection Full selection sheet to be shared Contract MS involvement in preparations aspects? Special Conditions - provisions correct?
6. Work plan Initial Involvement of Project Leader(s) Involvement of Support Staff Limitations of input if complex project? Successive updates & Steering committees Side letter Reserved to text revised STE requirements Depends on definition in Fiche
7. Reporting Bi-annual/quarterly? MS PL to decide Certified correct? Removed Template with budget reference to contract budget? Contract budget is ONLY on budget headings
8. Communication and Visibility Link inactive Always under same budget heading? What type of costs?
9. Other issues Study visits No compensation for EU MS for travel & per diems BC staff? BC obligations Recommend to strenghten narrative (fiche)? Sustainability Costs for such actions? Reserve specifically foreseen for sustainability actions
Next steps A large scale awareness programme. Welcoming any invitation to present. Limited by our ressources. We are 4 staff for all Twinning. A decision is a decision. And it is a good decision. Re-checked all questions/remarks/proposals. Any Q left?
Thank you ..and comments please Meeting of MS National Contact Points for TAIEX and Twinning Malta 8-9 May 2017
