Presentation on theme: "Fiche No 11 – Delegated act on general rules on eligibility of expenditure for cooperation programmes 2 nd Expert Group Meeting, 4 July 2013."— Presentation transcript:
Fiche No 11 – Delegated act on general rules on eligibility of expenditure for cooperation programmes 2 nd Expert Group Meeting, 4 July 2013
Second draft of fiche No. 11 General comments: Fiche aims at providing specific rules for ETC which are not foreseen in CPR; There is need of common specific rules at EU level in terms of simplication, harmonization and in a transparent way; The objective is to limit room for interpretation; In depth developments can be done in the framework of harmonized tools; It is up to the MA to put into practice and to monitor the eligibility of expenditure defining what is eligible and what is not eligible. A list of ineligible expenditure would not be exhaustive.
S ECTION I: S TAFF COSTS Issue raised MS which raised the issue Change in the fiche (§1) To clarify "definition of scope" to avoid different interpretations CZ, FR, Interact Definition adjusted "without recourse to outside service-providers" moved in the sentence" and completed "This category of costs covers the reimbursement of eligible costs actually incurred and paid; contributions in-kind and flat-rate" (§2) To clarify the operation that is additional and not part of statutory responsibility – use of experts FR, LV The objective is to avoid financing normal salary. § completed with "staff costs will cover ad hoc tasks pertinent to an operation" (§3) Additional benefits should be foreseen (cafeteria). HU"Beverages" added to examples Employment contract should be also included into the list of supporting documents HUThe fiche does not contain reference to any list of supporting documents
S ECTION I: S TAFF COSTS Issue raised MS which raised the issue Change in the fiche (§4) notice period, severance pay should be eligible; Not in line with current flexibility rules applied at programme level HU FR Agreed and added Security systems are different in MS. It is considered more appropriate to have a common set of rules at EU level. (§6) hourly personnel rate should be paid on a monthly basis or calculation system left to the project. Problems with self-employed contracts for certain beneficiaries (associations, NGO) HU, FR, INTERACT Do not agree. Annual basis should be the common approach for all the programmes. This § has been completed for clarity These as external services (service providers) – not to be included in staff costs (§6) Do hourly rate remuneration include holiday and sickness leave? PLThey are excluded – completed in this §
S ECTION I: S TAFF COSTS Issue raised MS which raised the issue Change in the fiche (§8) What do non-taxable bonus payment and exceptional or extraordinary provisions of pension rights" mean? CZ, INTERACT additional provisions of pensions to those legally foreseen are not eligible. Bonuses should be evaluated against sound financial management principles in particular regarding economy and efficiency Standard scale of unit costs not at programme, same standard costs for all MS not possible MT, PLDefinition of standard scale of unit costs added Clear message that in case of flat costs according to methodology, no verification is carried out by 1st and 2 nd level controllers LVIndeed, this is part of the simplification. Information will be added in fiche. When applying flat rate no verification is carried out by 1st and 2 nd level conrollers. However beneficiaries re still obliged to record costs in their accounting in accordance with applicable legislation, i.e. the costs can be controlled by a tax office, statutory auditor, etc for tax reasons.
S ECTION II: O FFICE AND ADMINISTRATIVE EXPENDITURE ( INDIRECT COSTS ) Issue raisedMS which raised the issueChange in the fiche (§1) to clarify definition, insurance, To add foreign exchange difference costs to establish exhaustive list to move bank charges, financial transactions to be moved from section IV PL, FR, CZClarifications brought. Agreed to move some items from section IV to section II.
S ECTION III: T RAVEL AND ACCOMMODATION COSTS Issue raised MS which raised the issue Change in the fiche Definition of scope travels outside the eligible area, visas costs, taxes for travel and accommodation (e.g. irrecoverable VAT). To add "principles of effective and economic financial management should be applied when choosing transport means and accommodation". FR, LV, PL, INTERACTAgreed. Additional clarification provided. Per diem at programme level but MS allowed to set per diem according to national rules MT It is up to the programme to establish the rates. Per diem for EU officials could be taken as a reference if wished. Difference between daily allowance and per diem? FRNo real difference. It is a sum granted as reimbursement for expenses.
S ECTION IV: E XTERNAL EXPERTISE AND SERVICE COSTS Issue raisedMS which raised the issueChange in the fiche bank charges, financial transactions to be moved to section II FR, INTERACTAgreed, moved to section II Are gifts eligible?FR Yes up to a certain amount, to be better clarified in the fiche Are foreign exchange difference eligiblePLYes, included in section II. Documentation supporting the eligibility of in-kind contribution is not mentioned FRDealt with in the framework of CPR How experts costs have to be handled?FRCovered by point 7 section IV
S ECTION V: E QUIPMENT EXPENDITURE Issue raisedMS which raised the issueChange in the fiche Definition of scope, to add investment, costs of equipment that is not depreciable, taxes for equipment expenditure FR, PL, LV, INTERACTDefinition completed Purchase of landFRCovered by CPR Additional section to be added for Infrastructure and construction works CZ Categories established on the basis of Art. 17 (ETC Reg.). The sections cover the 5 categories reported in ETC reg. Audit trail requirements, supporting documents FRPart of the description of the monitoring and control system