Financial rules in Horizon 2020 - ETNA 2020 training workshop, Athens September 6, 2016
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Financial rules in Horizon 2020 ETNA 2020 training workshop, Athens September 6, 2016 Katarina Rohsmann Austrian Research Promotion Agency (FFG), NCP Academy Partner
Overview Funding instruments and funding rates The project budget in the proposal Eligibility of costs Cost categories Financial reporting and payments Audits Frequent mistakes FFG, September 6, 2016
Financial information in the Grant Agreement derived from the proposal Grant Agreement H2020 Eligibility of costs: mainly in art. 6 (art. 10 to 15 for Third Parties) http://ec.europa.eu/research/participants/data/ref/h2020/mga/gga/h2020-mga-gga-multi_en.pdf FFG, September 6, 2016
Funding instruments and funding rates Instrument Funding rate Research and innovation actions (RIA) 100% Innovation actions (IA) 70% / 100% Coordination and support actions (CSA) 100% SME instrument phase 1 € 50.000 (lump sum) SME instrument phase 2 70 % Fast Track to Innovation 70% / 100% Prizes fixed amount (see ‚rules of the contest‘) • Innovation Actions, Fast track to innovation: 100% for ‚non-profit organisations‘ • The total costs (direct and indirect costs) are multiplied with the funding rate FFG, September 6, 2016
Budget for the proposal Starting point: • What are the organisation’s tasks in the project? and/or • How many people from the organisation will work for the project? part A (tables) part B (narrative part) Make sure that the two parts match! FFG, September 6, 2016
Budget table in part A (full proposal) 25 % flat-rate, except subcontracting and ‚in-kind contributions not used on the premises‘ transport only if projects: explicitly n/a mentioned total requested • Only the white fields must be completed amount • RIA, CSA: Costs of Linked Third Parties are added to the beneficiary’s costs • IA: separate column for costs of Linked Third Parties FFG, September 6, 2016
Budget table in Part A (stage 1 of a two-stage proposals) • Only the total requested amount for the action must be indicated • No major deviations allowed between stage 1 and 2 FFG, September 6, 2016
Budgetary information in part B 3.4 Resources to be committed Please provide the following: • a table showing number of person/months required (table 3.4a) • a table showing ‘other direct costs’ (table 3.4b) for participants where those costs exceed 15% of the personnel costs ------------------ 4.2: Third Parties involved in the action • include information on subcontractors, Linked Third Parties and third parties providing in-kind contributions (must be indicated in Annex 1 of the Grant Agreement in order to be eligible costs) FFG, September 6, 2016
Table 3.4a: staff effort Table 3.4a: Summary of staff effort Please indicate the number of person/months over the whole duration of the planned work, for each work package, for each participant. Identify the work-package leader for each WP by showing the relevant person-month figure in bold. WPn WPn+1 WPn+2 Total Person/ Months per Participant Participant Number/Short Name 1 PM: 1/12 of ParticipantNumber/ the annual Short Name productive Participant Number/ hours Short Name Total Person/Months FFG, September 6, 2016 9
Table 3.4b: other direct costs Table 3.4b: ‘Other direct cost’ items (travel, equipment, other goods and services) Please complete the table below for each participant if the sum of the costs for’ travel’, ‘equipment’, and ‘goods and services’ exceeds 15% of the personnel costs for that participant. Participant Number/Short Cost (€) Justification Name if below 15%: can Travel be completed Equipment voluntarily Other goods and services Total FFG, September 6, 2016 10
Eligibile costs: overview FFG, September 6, 2016
General eligibility criteria for actual costs • Incurred by the beneficiary • incurred during the duration of the action (except travel costs for kick-off meeting and costs for final reporting) • indicated in the estimated budget of the action • identifiable and verifiable • necessary for the action as described in the GA • in compliance with national laws on taxes, labour and social security • in compliance with beneficiary's usual accounting practice (may not contradict the rules of the Grant Agreement) • reasonable, justified, sound financial management N.B.: Non-refundable VAT is eligible FFG, September 6, 2016
Personnel costs: overview UNIT COSTS ACTUAL PERSONNEL COSTS Calculated by the Fixed by beneficiary according Commission for Calculation to its usual accounting SME owners method defined practices and natural in the model (‘average personnel persons without grant agreement costs’) a salary FFG, September 6, 2016
Calculation of personnel costs on a yearly basis personnel costs = hourly rate x hours worked for the project Annual gross salary: Calculation of the hourly rate: basic salary social security contributions taxes and duties annual gross salary other mandatory compo- ------------------------------------------- nents of the basic salary annual productive hours (3 options) ≠ bonuses, extra payments for participating in the project… FFG, September 6, 2016
Annual productive hours Option 1: „1720 fixed hours“: • standard number which may be used by any beneficiary (pro-rata for part-time employees) Option 2: „Individual annual productive hours“: • calculation: ‘annual workable hours’ of the individual employee + overhours – absences (sick leave etc. – not [bank] holidays) Option 3: „Standard annual productive hours“ • calculated according to the usual accounting practises • must correspond to at least 90 % of the ‚standard annual workable hours‘ No more hours than the „annual productive hours“ may be charged on all EU-funded projects per person and year FFG, September 6, 2016
‚Last closed financial year‘ • Only for calculation of personnel costs on a yearly basis: • If the financial year is not closed at the time of reporting, the beneficiary must use the hourly rate of the last closed financial year available • No adjustments! salary rises lead to financial losses FFG, July 6, 2016
Calculation of personnel costs on a monthly basis If parts of the remuneration are generated over a period longer monthly gross salary than a month, the beneficiaries ------------------------------------------- may include only the share which annual productive hours / 12 (option 1 or 3) is generated in the month (irrespective of the amount actually paid for that month) Each beneficiary must use only one option (per full financial year or per month) for each full financial year for all H2020 projects FFG, September 6, 2016
‚Standard‘ and ‚additional‘ remuneration Standard remuneration Additional remuneration Mandatory complements Bonus payments • resulting from law, collective agreement or working contract • only eligible for non-profit organisations Basic • mandatory fixed complements (e.g. • payed for additional work or remuneration holiday pay, complement for hazardous expertise work) • mandatory variable complements (e.g. • strict requirements – see for merit or performance) not triggered Annotated Grant Agreement by the work in specific projects FFG, September 6, 2016
Personnel costs – decision tree See: Annotated Model Grant Agreement, p. 52 FFG, September 6, 2016
Situation 1 Mr A is the founder of the start-up company „A Ltd“. He is self-employed and doesn‘t receive a salary. The company „A Ltd“ has four employees, however its tasks in the project shall mainly be carried out by A himself. A says: „If I participate in this project, I cannot accept anything less than my standard hourly rate of EUR 75.“ Solution: • A cannot charge his “standard hourly rate“ • „A Ltd“ can claim “costs of SME owners who do not receive a salary” for A • These costs are unit costs which must be calculated according to the rules of the Grant Agreement • Further information: Annotated Grant Agreement on art. 6.2.A.4 (p. 71-72 of v.2.1.1 of the AGA): http://ec.europa.eu/research/participants/data/ref/h2020/grants_manual/amga/h2020- amga_en.pdf FFG, September 6, 2016
Situation 2 Ms B has been working for „ABC cars“ (a large company in the automotive industry) since 2005. Due to an internal headcount limit of „ABC cars“, B is employed by the temporary work agency „PeoplePower“, which is responsible for the payroll tasks. B says: „This is just a formality. I consider myself as a full member of my team at ABC cars“. Solution: • B is not employed by the beneficiary, but by a Third Party • Rules regarding secondment of personnel do not apply because the Third Party is a temporary work agency • The beneficiary cannot charge B‘s costs as personnel costs, but only as costs of a service (other direct costs) or subcontracting • Further information: Annotated Grant Agreement on art. 6.2.A.2 (p. 64 of v.2.1.1 of the AGA): http://ec.europa.eu/research/participants/data/ref/h2020/grants_manual/amga/h2020- amga_en.pdf FFG, September 6, 2016
Situation 3 Dr C is a specialised researcher at „ABC electric vehicles“, an affiliate of „ABC cars“. Her expertise is needed for one task of a project in which „ABC cars“ participates. C says: „I will contribute to this task and ABC cars will charge my personnel costs in its financial statement – after all we are from the same company group“. Solution: • Dr C is not employed by the beneficiary, but by a Third Party (affiliate of the beneficiary) • His personnel costs cannot be included in the financial statement of the beneficiary as if he was an employee of the beneficiary • The affiliate could join the project as a Linked Third Party and claim Dr C‘s costs in its own financial statement (there are more possibilities, but this is the most obvious solution) • Further information: Annotated Grant Agreement on art. 14 (p. 135 ff. of v.2.1.1 of the AGA): http://ec.europa.eu/research/participants/data/ref/h2020/grants_manual/amga/h2020-amga_en.pdf FFG, September 6, 2016
Situation 4 Mr D is a freelancer and supports different organisations in the management of international projects. He works from his home office, using his own office equipment. „ABC cars“ is looking for someone to support the management of a H2020 project on a freelance basis. D says: „I always wanted to be my own boss. Working under someone‘s instructions just isn‘t my thing.“ Solution: • In principle, D‘s costs could be claimed as „costs for natural persons working under a direct contract” • However, one of the requirements would be that D works “under the beneficiary’s instructions” • N.B.: In some countries, it is legally impossible to fulfill this requirement • Further information: Annotated Grant Agreement on art. 6.2.A.2 (p. 64f. of v.2.1.1 of the AGA): http://ec.europa.eu/research/participants/data/ref/h2020/grants_manual/amga/h2020- amga_en.pdf FFG, September 6, 2016
Situation 5 Prof E works for the „University of E-City“. Like all professors in his country, he is employed by the government and receives his salary directly from the government. Prof. E is supposed to act as a head scientist in a H2020 project. E says: „The university does not incur any costs for me. Does this mean that I must do all the work for free?“ Solution: • Prof E is considered an „in-kind contribution provided by a Third Party free of charge“ • The Third Party and its contribution has to be identified in Annex 1 of the GA (otherwise, the costs could be approved retroactively, but at the full discretion of the EC/agency) • Rules regarding „receipts“ do not apply in this case, because Prof E was not provided to the beneficiary „specifically for the action“ (all professors are employed by the government) • Further information: Annotated Grant Agreement on art. 12 (p. 126 ff. of v.2.1.1 of the AGA); receipts: AGA p. 31 f.: http://ec.europa.eu/research/participants/data/ref/h2020/grants_manual/amga/h2020- amga_en.pdf FFG, September 6, 2016
Types of personnel costs in H2020 A.1: Costs for employees (or equivalent) A.2: Costs for natural persons working under a direct contract (observe requirements – legally impossible in some countries) A.3: Costs for personnel seconded by a third party against payment A.4: Costs of SME owners A.5: Costs of ‘beneficiaries that are natural persons’ NOT personnel employed by a temporary work agency Details: see Annotated Grant Agreement FFG, September 6, 2016
Natural persons working under a direct contract FFG, September 6, 2016
Time records • Only the hours worked for the project must be recorded • Exception: persons working exclusively on one project (‚declaration‘ • Time records are the proof that the personnel costs have incurred • if the time recording system is not deemed to be ‚reliable‘, all personnel costs may be rejected FFG, September 6, 2016
Time records Minimum requirements: signature • title and number of the action • reference to task or work package • beneficiary’s full name • full name, date and signature of the person working for the action • number of hours worked for the action • supervisor’s full name and FFG, September 6, 2016
Subcontracting • A purchase of goods, works or services that are identified in Annex 1 as action tasks • Tasks to be implemented and estimated costs must be set out in the proposal (table 4.2) • Based on ‘business conditions’: best value for money or lowest price, • Subcontracting to affiliates: only allowed if ‚usual provider‘ or framework contract • No indirect costs on subcontracting FFG, September 6, 2016
Other direct costs (1) Travel costs and related subsistence allowance: • must be necessary for the action and • in line with the beneficiary‘s usual practises on travel Equipment, infrastructures and other assets: • only the depreciation costs are eligible • only the part of the equipment‘s „full capacity“ used for the project can be charged (must be recorded) • rent/lease eligible if not exceeding depreciation costs FFG, September 6, 2016
Other direct costs (2) Costs of other goods and services: • the beneficiary carries out a task itsself and is supported by third party (unlike subcontracting) • best value for money or lowest price • e.g. consumables and supplies, dissemination costs, rent for meeting rooms, IRP-related costs, certificates on the financial statements FFG, September 6, 2016
Costs of Linked Third Parties • May carry out work in the project and report its own costs • rules regarding eligibility of costs, funding rates and third country participation apply • Name and tasks of the Linked Third Party must be indicated in the proposal FFG, September 6, 2016
Exercise on eligibility and budget categories (1) • costs for drafting the CA before the project starts: ineligible (not incurred during the duration of the action) • catering during full-day project meeting: eligible (other direct costs/costs of other goods and services) • 1st. class train ticket - company usually books 2nd. class: ineligible (not in line with the beneficiary‘s usual practises) • test series performed by external company (task 4.2): eligible (subcontracting – purchase of a service identified as an action task) • costs for attending a conference (no ‚active‘ contribution): ineligible (no ‚active contribution‘, therefore not necessary for the project) • costs for Certificate on the Financial Statement (CFS): eligible (other direct costs/ costs of other goods and services) FFG, September 6, 2016
Exercise on eligibility and budget categories (2) • consulting service on IPR issues: eligible (other direct costs/costs of other goods and services) • non-refundable VAT included in hotel bill: eligible (other direct costs/travel costs) • tickets for visiting Acropolis during kick-off meeting: ineligible (social activity, not considered necessary for the project) • article processing charge (APC) for open access publication eligible (other direct costs/costs of other goods and services) • costs for externalising the coordinator‘s tasks to a project management agency: tasks of the coordinator (as defined in art. 41.2 of the GA) may not be subcontracted FFG, September 6, 2016
Reporting and Payments Pre-financing Interim Interim Balance Payment payment payment 30 days after GA enters 90 days 90 days 90 days into force/10 days before the project starts Reporting Reporting Reporting Period 1 Period 2 Period 3 Periodic Periodic Periodic Final report report report + report The coordinator distributes the payments FFG, September 6, 2016 35
Periodic reporting Two parts to be completed: • Periodic technical report • Periodic financial report: → Individual financial statement, explanation on the use of resources → Periodic summary financial statement (= request for interim payment) To be submitted within 60 days after the end of a reporting period FFG, September 6, 2016
Financial reporting in the Participant Portal • Click to complete ‚use of resources‘ • Other direct costs only need to be explained if they exceed 15% of the personnel costs FFG, September 6, 2016
Certificate on the Financial Statements (CFS) • Required at the end of the project if funding per partner (or Linked Third Party) exceeds 325.000 EUR (only actual costs and ‚average personnel costs‘) • may be performed by any qualified auditor • costs are eligible as other direct costs • template/further info: Annex 5 of the Grant Agreement FFG, September 6, 2016
EU audit (2nd. level audit) • May take place within two years after the balance payment • Possible consequences: rejection of costs, reduction of the grant, recovery; extension to other projects in case of ‘systematic errors’ N.B.: records and supporting information must be kept for five years after the balance payment FFG, September 6, 2016
Frequent mistakes • Costs claimed are not substantiated (no proper documentation…) • Costs claimed are not linked to the project • Third parties and subcontracting costs are not properly reported • Depreciation costs are not correctly charged/full price is charged • Personnel costs: • incorrect calculation of productive hours • charging of hours not worked for the project • errors related to time records (inconsistent with information on sick leave/travels/holidays, ‚signed‘ while a person was absent…) FFG, September 6, 2016
Guarantee Funds • Similar to an insurance between all beneficiaries – no „collective financial responsability“ of the consortium • 5 % of the pre-financing payment are transferred directly to the fund (and released at the balance payment) • Cases covered: amounts owed by a beneficiary to the funding body (e.g. due to bancruptcy) • Cased not covered: amounts owed by a beneficiary to another beneficiary (e.g. due under-/owerspending) FFG, September 6, 2016
When in doubt… • Have a look at the H2020 Online Manual: http://ec.europa.eu/research/participants/docs/h2020-funding-guide/index_en.htm • Look for information in the Annotated Grant Agreement: http://ec.europa.eu/research/participants/data/ref/h2020/grants_manual/amga/h2020-amga_en.pdf • Ask your legal and financial NCP: http://ec.europa.eu/research/participants/portal/desktop/en/support/national_contact_points.html • Contact the Research Enquiry Service: http://ec.europa.eu/research/participants/portal/desktop/en/support/research_enquiry_service.html FFG, September 6, 2016
THANK YOU FOR YOUR ATTENTION Katarina Rohsmann Expert for legal and financial issues in the EU framework programme Austrian Research Promotion Agency (FFG) Sensengasse 1, 1090 Vienna, Austria phone: +43/5/7755-4009 email: katarina.rohsmann@ffg.at FFG, September 6, 2016
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