Guidance notes on the
Intevention Logic
and on
Building a priority axis
27 September 2013
Introduction
• Presentation of two guidance notes pertaining to
programming and aimed at desk officers in the
Commission
• The two guidance notes are interlinked, hence
should be read together – there are links also to
other guidance, including the template for the
operational programme
• This is an introduction of this guidance to the
expert group, but feedback is welcome
• The guidance notes have been developed
specifically for the ERDF, ESF and CF (they do not
cover EAFRD and the EMFF)
Intervention logic
Aim of the guidance
• Intervention logic is at the heart of the
programming process, but not clearly defined in
legislation
• The guidance aims to set out the main elements
of the intervention logic, with reference to
applicable legal terms and setting out examples
• The guidance has been prepared taking into
consideration the context of cohesion policy (e.g.
the existence of thematic objectives, investment
priorities), but in general reflects the basics of
setting out an intervention logic for any strategy
Development needs and objectives
• The starting point of programming is the
identification of development needs or
challenges to be addressed, which should help to
identify the funding priorities
• This is followed by:
• the selection of thematic objectives and investment
priorities as set out in the CPR and Fund-specific rules;
• the definition of at least one specific objective per
investment priority to target the latter appropriately in
the specific national or regional context
• definition of result indicators linked to specific
objectives
Actions and output indicators
• Only after the development needs, objectives and
the result sought have been clarified, should one
consider the types of actions to be supported,
choosing (a mix of actions) which best achieves
the objectives defined
• Output indicators should be logically linked to
and reflect the types of actions planned. Outputs
generated by actions should also contribute
logically towards the results that one aims to
achieve.
Testing of the intervention logic
• The programming process should allow for a reflection on
and adjustment of the intervention logic proposed
• This is also one of the purposes of the ex-ante evaluation
• The outcome should be a programme which includes a
consistent and coherent intervention logic
• The authorities should also be open to change the
intervention logic in mid-period, if circumstances change or
if the actions implemented are not sufficiently effective
Comments
Building a priority axis
Aim of the guidance
• Provisions under Article 87 (1) are essential for
the purposes of programming and attaining a
sound intervention logic
• However, they are rather complex, with multiple
possibilities for derogations and multiple
conditions for such derogations
• It is also not always evident from the legal text,
what are the implications in terms of practical
(financial) management
Initial proposal by the Commission
for Article 87 (1) CPR
• Possibility to set up multi-fund and potentially multicategory programmes, BUT…
• Priority axis = 1 Fund, 1 category of region, 1
thematic objective
• Only derogation = ESF, to achieve proportionality in cases
where small amounts of ESF are used to complement ERDF
and CF
• Objective driven programming and management –focus on
achieving a clear intervention logic
• Simple approach – financial management and monitoring at
the level of the priority axis
Agreement between co-legislators on
Article 87 (1) CPR
• COM proposal maintained as a general rule
• As a derogation from the general rule it is possible to set
up priority axes covering more than one Fund, category of
region and/or thematic objective
• Derogations possible only where appropriate and in
order to increase the impact and effectiveness in a
thematically coherent integrated approach
• In addition, a priority axis covering more than one thematic
objective requires a due justification
• Explanation and, where required, a justification for the setup of such priority axes is required in the model of the
operational programme
Priority axes covering more than one
category of region
Can be justified where where identical objectives and actions
are pursued across all regions
NB: the development needs of different categories of regions
can diverge. In this case, the objectives and the intervention
logic will also be different
multiple priority axes
Re-percussions:
• Co-financing rate and financial management by priority
axis and by category of region
• Breakdown of performance framework and output
indicators (and in case of ESF, also result indicators)by
category of region
Priority axes covering more than one
Fund
Only justifiable where Funds pursue clearly complementary
objectives and where actions need to be implemented in parallel
to attain objectives – in most cases objectives can also be
attained through mono-fund priority axes
NB: CF/ERDF and ESF investment priorities, scope and
indicators are different, entailing a different intervention logic
Repercussions:
• Creation of "sub –priority axes" - a description of the priority axis
split completely in two or three (possible exception for
combination of the ERDF and CF contributing through the same
intervention logic)
• Financing rate and financial management by priority axis and by
Fund
• Breakdown of the performance framework and output indicators
by Fund
•
Priority axes covering more than one
thematic objective (1)
• The most complex case – risk of losing thematic
coherence, focus on objectives and of
compromising the intervention logic
• Thematic coherence must always be maintained
• Combination of more than 2-3 thematic
objectives should not be necessary, not even in
the case of axes based on territorial strategies
Possible exception: integrated actions for urban
development
Priority axes covering more than one
thematic objective (2)
• Thematic objectives and investment priorities are
objectives, not lists of activities – any actions
contributing to these objectives can be pursued
• If a priority combines more than 2-3 thematic
objectives it is likely that the intervention logic is
skewed = actions are put before objectives
Priority axes covering more than one
thematic objective (3)
To be considered:
• It should be verified that the intervention logic is
sound – that investment priorities are put
forward as objectives, not chosen on the basis of
actions that the MS seeks to support
• The financial allocation by thematic objective
within a priority axis is subject to COM decision
and cannot be changed without COM decision –
significant rigidities may be introduced
Implications on financial management
Axes
Axes covering
multiple Fund
Financial plan of the OP
• Co-financing rate by Fund
• Separate budget commitments - payment
applications/accounts by Fund
Axes covering
• Co-financing rate by category of region
multiple categories • Separate budget commitments –expenditure
of regions
broken down by category of region in
payment applications/accounts
Axes covering
multiple thematic
objectives
• Allocation broken down by thematic objective
and fixed in the financial plan
• No breakdown in payment applications and
accounts
• Follow-up through the categorisation system
NB: Financial plan of the OP is adopted by the Commission and a
Commission decision is needed to change it
Combination of derogations
• In principle the CPR allows for the flexibility to set up
priority axes which cover multiple Funds, thematic
objectives and categories of regions - all at the same time
• Where derogations are applied cumulatively, all conditions
also apply cumulatively – all combinations need to be
justified against the requirements of Article 87 (1)
• Such arrangements can lead to significant complexity in
financial management, monitoring and reporting
arrangements – to be considered very carefully
Financial instruments
• Article 110 CPR provides an incentive (higher co-financing
rate) to set up priority axes implemented exclusively
though FIs
• Article 87 (1) applies regardless of the form of support
granted - priority axes must remain thematically coherent
and the derogations under Article 87 (1) can be applied
only where appropriate
Examples:
• Pairings of complementary priority axes implemented
through grants and FIs
• Seeking economies of scale though multi-regional or
national priority axes implemented through FIs
ETC
• The combination of Funds and categories of
regions within a priority axis is not relevant for
ETC
• The issues concerning the combination of
thematic objectives within a priority axis ARE
relevant also for ETC – the same conditions apply
Comments?