ERDF User Manual Chapter 6: Financial Management Contents 1. Introduction ..................................................................... 2 2. Financial Tables .............................................................. 2 N+2 spend targets and decommitment ............................................................... 3 Exchange Rates .................................................................................................... 3 Expenditure declarations to the Commission and requests for payment ....... 4 Liability for exchange rate losses ....................................................................... 5 Management of Financial Tables ......................................................................... 5 The 7.5% Advance......................................................................................................... 5 Legal proceedings and administrative appeals ................................................. 6 Exceptions to the N+2 rule ................................................................................... 6 3. Accounting and Budgeting Requirements ................... 7 Overview of the Claims and Payment Process .................................................. 7 Accounting System Requirements ...................................................................... 7 Accounting for ERDF Transactions .................................................................... 8 Advance Payments ........................................................................................................ 8 Claims Expenditure .............................................................................................. 9 Ensuring correctness and regularity of expenditure ........................................................ 9 Processing approved expenditure .................................................................................. 9 Forecasting information ..................................................................................... 10 End of Month Reconciliation.............................................................................. 11 HM Treasury Reporting ...................................................................................... 11 Point of Contact within CLG .............................................................................. 11 Example of Accounting Treatment .................................................................... 12 Annex A: Definitions of Expenditure Categories ............... 13 Page 1 Version 1: August 2009 ERDF User Manual Chapter 6: Financial Management 1. Introduction 1.1. This chapter makes provision about the financial aspects of management and control of the operational programme and contains guidance to aid effective management of financial tables covering spend and decommitment targets, exchange rate issues and RDA accounting and budgeting requirements. 2. Financial Tables 2.1. The annual budget allocations are set out in euros in the financial tables for each approved Operational Programme (OP). RDAs will use the yearly allocations in the financial tables loaded on MCIS as the basis for planning expenditure. 2.2. Changes to the Euro value of financial tables can arise from: i. the Commission exercising automatic decommitment to any part of a budget commitment in an operational programme under the N+2 principle as set out in Articles 93 to 97 of Regulation 1083/2006; ii. The Commission can also apply financial correction in accordance with provisions of Articles 99 to 102 of Regulation 1083/2006 arising from identified serious deficiencies in the management and control systems for operational programmes and/or irregularities; and iii. virement of funds between priority axis and/or years. 2.3. The Certifying Authority will enter a single record on MCIS showing indicative translated Sterling values of the Programme which will form the basis of the indicative Sterling value of the programme for planning purposes. RDAs will monitor the indicative Sterling value of yearly allocations in the financial tables for the basis of planning expenditure. Any changes to Sterling value of the financial tables will be made by CA to the MCIS Project Record following the authorisation of the payment of an RDA claim or as a result of changes to the Euro value of the Programme described above. The CA will apply the monthly EC Euro rate to the reimbursements made to the RDAs and use the Treasury forward planning rate to establish the value of the remaining programme. RDAs should follow the same principle for their own planning purposes. RDAs must monitor ERDF spend and commitments carefully to ensure that any changes in exchange rate between Euro and Sterling does not result in an over spend against the programme allocation. 2.4. Any impact on the budget of an operational programme arising from a financial correction applied by the Commission will be met by CLG from its departmental resources if and to the extent that it would otherwise result in the RDA incurring a deficit (having spent more ERDF overall than it is entitled to receive from the certifying authority). It is recognised that the RDA, as a statutory authority, cannot carry a budget deficit. 2.5. The risk of financial correction is to be minimised by ensuring that CLG, as managing authority and certifying authority, and the RDA, as intermediate body, carry out their regulatory functions effectively and efficiently and in accordance with the Structural Funds Regulations and the implementation system put in place by CLG as the MA. Nevertheless, circumstances may arise under which the Commission decides to make a financial correction. In that event, any resources made available by CLG from its own departmental resources to make up for the Page 2 Version 1: August 2009 ERDF User Manual Chapter 6: Financial Management budgetary impact of the correction will take account of sums recovered by the RDA from grant recipients responsible for irregular spending. The procedure for dealing with irregularities is set out in Chapter 5. The role of the Audit Authority is also relevant here and is set out in Chapter 8. 2.6. The OP budget allocation must be managed in line with Articles 75 to 102 of Regulation EC (No)1083/2006. The remaining paragraphs of this section provide guidance on N+2 spend targets and decommitment, exchange rates and management of financial tables. N+2 spend targets and decommitment 2.7. The N+2 is a European Commission requirement set out in Article 93.1 that states that the annual budget allocations that is approved in an OP’s financial table must be spent within two years of the year for which they were allocated. 2.8. Basically, the ERDF budget allocated in the financial tables for the year 2007 has to be spent and a claim submitted to the Commission by the end of 2009, funds committed for 2008 have to be spent and claimed by 2010 and so on. 2.9. Declarations for payment are made by the Certifying Authority to the Commission. These are based on the aggregate claims made by RDAs at priority axis level for each of the Operational Programmes for the defrayed expenditure made by projects – see Chapter 7. Applications for payments will normally be sent by the CA three or four times a year. The end of year Declaration needs to be submitted by the 31st December to ensure that the maximum spend is lodged with the Commission for that year. 2.10. Any part of the budget for the year in question that remains unspent is automatically decommitted by the EC. Auto-decommitment applies at programme level (not priority axis). It is only if the programme fails to hit its spending target that funds are decommitted. 2.11. The final two payments will have de-commitment deadlines that extend beyond the actual period of the programme 2014 and 2015. Any part of the programme allocation still open on 31 December 2015 will be automatically decommitted if the Commission has not received an acceptable payment application for payment for it by 31 March 20171 Exchange Rates 2.12. Amounts set out in operational programmes, certified statements of expenditure, applications for payment to the Commission and expenditure mentioned in the annual and final implementation reports have to be reported in euros.2 All ERDF transactions within England are conducted in pound sterling (GBP). 2.13. All projects will receive a funding agreement (offer letter) setting out the maximum grant levels in Sterling and the project spend profile will also be in sterling. Projects will claim grant from the RDA for their expenditure and be reimbursed in Sterling. At no time will the euro be involved. In turn, the RDAs will claim and receive reimbursement from CLG in Sterling. The rate of exchange of the euro to the pound will not affect any of these transactions. 1 2 Article 93(3) of 1083/2006 Article 81 of 1083/2006 Page 3 Version 1: August 2009 ERDF User Manual Chapter 6: Financial Management 2.14. However in order to manage the financial tables to avoid decomitment the RDAs will need to convert the euro value to Sterling. As stated in paragraph 4 the Certifying Authority has the responsibility to maintain the Sterling value of the programmes at priority axis level and N+2 targets at programme level. This will allow RDAs to contract, monitor outturn and forecast spend (for N+2) against these sterling values. It will also allow the conversion of the sterling data into euro for reporting in the Annual Implementation Reports. The value of programmes will change each time: Expenditure is recorded within the accounts of the Certifying Authority The forecast planning exchange rate (issued by HMT) is updated. 2.15. Any gains/losses resulting from the difference between the Sterling value that make up CA application to the EC and the amount of translated sterling that CA receive will be met by CLG from its own resources and not passed on to the RDAs. Expenditure declarations to the Commission and requests for payment 2.16. Chapter 7 sets out how the Certifying Authority will make certified declarations on expenditure to the Commission. The Certifying Authority will convert all amounts reimbursed to the RDAs into euros using the monthly EC exchange rate for the month in which it is paid before aggregating the expenditure for submission to the Commission. RDAs will be informed via MCIS any changes made to the claims by CA or MA before the claims are approved for payment. Article 77 provides that the Commission will reimburse expenditure by applying the co-financing rate set for each priority axis to the amount of eligible expenditure mentioned under that priority axis in the certified declaration of expenditure. The Certifying Authority will meet the RDA’s claims for reimbursement on the same basis irrespective of the proportion of total eligible expenditure in the claims for the priority axis met from the ERDF. In calculating the amount to be reimbursed for claims, CA will also take into account the total ERDF paid out to date to ensure that the cumulative total amount paid does not exceed the Euro value for a priority axis as recorded on MCIS at the point of reimbursement. 2.17. Paragraph 8 of chapter 7 provides that CA will start to reimburse legitimate expenditure incurred by the RDA without waiting for the Commission to approve the management and control system (as long as the Audit Authority’s opinion provides a reasonable assurance on the effectiveness of the RDA's own systems and the MCIS system is in operation). Clearly, for a period of some months, the CA will be reimbursing claims without itself receiving funds from the Commission. Given this, and the fact that CLG does not know when the system of management and control will be approved, the Managing Authority may have to exercise some control over the rate of commitment of ERDF funds to avoid an unaffordable call on CLG resources. This is unlikely to occur, but if it did occur, discussion would first take place within the high level European Programme Board. 2.18. The rate of exchange to be used for each RDA claim will be the month in which the approved reimbursement amount is first registered in CLG’s accounts3 on SAP. This will be the date when the aggregated claim from the RDA is authorised for payment by CA. The rate of exchange to be used is the monthly one published by 3 Article 81(2) of 1083/2006 Page 4 Version 1: August 2009 ERDF User Manual Chapter 6: Financial Management the Commission at the following website: http://ec.europa.eu/budget/inforeuro/index.cfm?fuseaction=currency_historique&curr ency=72&Language=en 2.19. The Commission will then reimburse the claim in euros to the Bank of England. This is converted back into Sterling at the daily rate of exchange used by the Bank of England. It is then transferred to CLG’s accounts in Sterling. Any financial impact of a correction applied by the Commission to the certified declarations will be borne by CLG. It will not be passed on to the RDA or reduce the approved value of the programme. Liability for exchange rate losses 2.20. The Commission can take up to two months to reimburse the claims and there will be times, because of exchange rate fluctuations, when the Sterling value of the repayment from the EC is less than the Sterling value of the amount submitted for repayment by the CA. There will also be times when there is a Sterling “profit”. CLG will cover all foreign exchange (FX) rate fluctuations. There will be no liability arising from FX losses for the RDAs. Management of Financial Tables The 7.5% Advance4 2.21. As actual funds (rather than committed funds) can only be drawn down on production of a payment claim, the EC provides a cash advance, or "float", in order to help get the programme underway. This float is advanced when the programme is approved and is made in three instalments: the first in 2007 of 2% of the total grant value of the OP; and the second, 3%, in May 2008, and the final 2.5% in June 09. 2.22. This 7.5% advance, also described as pre-financing, reduces the n+2 target for 2009 by its value. These amounts then roll through for the duration of the programme. The n+2 target is a cumulative one and not an individual annual target each year. If there is a cumulative overspend at any year end against the target the excess spend will count towards the following years cumulative n+2 target. If there is a cumulative underspend, that underspend will be decommitted and the total value of the programme reduced by the same amount 4 Article 82 of 1083/2006 Page 5 Version 1: August 2009 ERDF User Manual Chapter 6: Financial Management 2.23. The table below illustrates how it all is calculated. Per year 7.5% = 35 2007 2008 Total costs 200 200 ERDF budget 100 100 2009 2010 2011 2012 200 200 200 200 100 100 100 100 N+2 Cumulative Cumulative Years for Grant ERDF E.U budget % spend N+2 Target aggregation 50% 0 50% 0 65 (100 less 50% 100 35 advance) 2007 50% 200 165 2007-8 50% 300 265 2007-9 50% 400 365 2007-10 2013 2014 2015 TOTAL 200 100 50% 1400 700 50% 500 600 700 465 565 700 2007-11 2007-12 2007-13 2.24. This effectively means that the first n+2 period only requires 47.5% of the Euro value of the 2007 commitment allocation to be spent by the end of 2009. However, it also means that there is a catch up exercise by 2015 and more has to be spent in the final year. The Sterling value of the advance is translated from Euros at the date the advance was received by the Bank of England. This Sterling value is then deducted from the indicative Sterling value target for 2009 N+2 to determine the projected value of Sterling claims required to achieve N+2. However, it is the target in Euros that has to be achieved and RDAs must monitor exchange rate movements to ensure their Sterling targets are realistic. Legal proceedings and administrative appeals 2.25. If an operation has been suspended by a legal proceedings or an administrative appeal (such as may arise where the RDA exercises a discretionary right to suspend the payment of grant for an operation or the grant recipient challenges a decision by the RDA), the amount potentially concerned by automatic decommitment will be reduced by the amounts that the certifying authority as not been able to declare to the Commission. The member state has to ask the Commission to make the reduction5. Exceptions to the N+2 rule6 2.26. Details of exceptions to the automatic decommitment are set out in Article 96 of EC Regulation No 1083/2006. In essence those parts of the budget commitment will be disregarded in calculating the automatic decommitment: a. where an application for payment has been made by the CA but the Commission has interrupted or suspended reimbursement in accordance with Articles 92 and 93, once the problems are resolved the automatic decommitment rule will apply; 5 6 Article 95 of 1083/2006 Article 96 of 1083/2006 Page 6 Version 1: August 2009 ERDF User Manual Chapter 6: Financial Management b. where an application for payment has been made but the Commission caps reimbursement to CLG due to lack of budget resources; and for which it has not been possible to make an acceptable application for payments to the Commission for reasons of force majeure seriously affecting the implementation of the OP; and c. major projects have their own rules for calculating decommitment. In accordance with Article 94 of EC Regulation 1083/2006 when the Commission takes a decision to authorise a major project the amount potentially concerned by automatic decommitment will be reduced by the annual amount concerned by such major project. The starting date for the calculation of the automatic decommitment deadline set in Article 93 (ie. two years from budget commitment) will be the date of the subsequent decision of the Commission to authorise the major project. 3. Accounting and Budgeting Requirements 3.1. This section sets out: the process for the recording and reporting of ERDF expenditures within RDA’s accounts the financial data sets required by CLG as a department for their own reporting purposes and to meet information requirements of the EC, Her Majesty’s Treasury (HMT) and other interested parties. 3.2. RDAs which have elected to manage their ERDF programme expenditure through the Management Control and Information System (MCIS) will be provided with an electronic interface into their own accounting systems for a number of the required financial entries. Overview of the Claims and Payment Process 3.3. Projects will make a claim to a RDA either on a monthly or a quarterly basis seeking reimbursement of legitimate expenditure incurred. RDAs will scrutinize the claims and if satisfied make a payment to the projects. RDAs will then aggregate all expenditure incurred under a particular priority axis and using MCIS submit a claim to the CA for reimbursement. CA will apply the intervention rate for that priority axis to the eligible expenditure to calculate the ERDF due back to RDAs and make a payment. The total reimbursement to RDAs through interim and final payments will not exceed the agreed Sterling value of the Euro amount at priority axis as calculated by the CA and reported to RDAs through MCIS. CA will use the reimbursements made to RDAs the basis for quarterly declarations to the Commission. Accounting System Requirements 3.4. ERDF resources are EC resources, which are paid through several layers of administration before they are used to meet expenditure by the final beneficiary. The regulations require that there is a separation of ERDF money from domestic public funding. Therefore, the accounting systems of RDAs must be established so that a separate funding stream for the ERDF transactions can be readily identified. This can be achieved through the use of appropriate account codes and/or cost centre codes specific to ERDF. It would be beneficial for RDAs to operate a separate bank account for the ERDF programme as this will allow a clearer and Page 7 Version 1: August 2009 ERDF User Manual Chapter 6: Financial Management easier identification of interest received which is attributable to ERDF funding. Those regions who are undertaking Competitiveness and Convergence programmes should account for these programmes separately. 3.5. All central government departments are required to report to HM Treasury on a monthly basis their actual and forecast expenditure (including those bodies they sponsor such as agencies and NDPBs) within DEL. For CLG this includes the ERDF expenditure of the RDAs. This is done on the Treasury’s Combined Online Information System (COINS) which is used to manage public expenditure. Treasury sets the format for the information to be provided by departments. To meet this requirement RDAs will need to maintain forecasts of expenditure on a monthly basis on an Excel spreadsheet which is allocated across the ten categories set by the Treasury as listed below. These categories are included in the reference data sheet of the data dictionary. Although this reporting requirement is different from Treasury’s cash management scheme under which RDAs’ monthly cash repayment forecast in Sterling will be included in the CLG’s return to the Treasury, a single return can fulfil both the requirements (for further details refer to Certifying Authority Chapter 7): Expenditure reporting for Current and Capital for each of the category: NDPBs, other bodies & organisations within central government Local Authorities Public Corporations Private sector Non Profit Institutions Serving Households (NPISH) Private sector companies Description of current and capital expenditure and the organisations listed above is set out in Annex A to this chapter. 3.6. The above requirements relate only to recommended set up and data capture within RDAs own accounting systems so that accounting based transactions and reports can be compiled. Accounting for ERDF Transactions Advance Payments 3.7. To provide RDAs with a cash reserve to cover claims expenditure before reimbursement from the CA, the EC has provided an advance payment equivalent to 7.5% of the total programme ERDF grant allocation. CA has paid over this amount to the RDAs in three instalments in the order they were received from the EC 3.8. When received, RDAs should account for the advance payment as: Dr Cash Cr Deferred Income 3.9. Note that the advance payment is to be treated as a liability on the balance sheet, as per SSAP 4, Accounting for Government Grants. RDAs should ensure that income is released on to the Income and Expenditure Account in the same period as the expenditure is incurred. In this way, the effect on the overall net balance sheet position is nil (cash asset = deferred income liability), and therefore, no cost of capital charge will be incurred. RDAs can take advantage of the interest earned on the cash deposit to use as match funding of ERDF projects. Page 8 Version 1: August 2009 ERDF User Manual Chapter 6: Financial Management 3.10. The advance payment will be held on the balance sheet until 92.5% of the OP is completed. CLG will reimburse RDA interim claims up to 92.5% of programme value after which, the advance will be used by RDAs to fund the remaining 7.5% until programme completion. Whilst the Commission imposes a 5% retention of funds until the programme is completed, the 5% gap will be borne by CLG, who will then seek reimbursement of the final 5% from the Commission in accordance with programme closure requirements. 3.11. The advance amount or any part of it may be recovered by the C A as a last resort if the Programme is not being implemented effectively. Although this is most unlikely to arise, the Council Regulation does make provision for: the revision of the Programme following implementation difficulties (Article 33.1) (which could involve a change in the Implementation Provisions whereby a RDA ceases to be an intermediate body); and reimbursement of the pre-financing amount if no application for payment under the Programme is sent to the Commission within 24 months from the date on which the pre-financing amount was paid (Article 82.2). 3.12. In the unlikely event of a decision to recover the advance or any part of it a RDA must repay the amount specified in a demand for payment made by the CA within 10 days of receiving the demand. Claims Expenditure Ensuring correctness and regularity of expenditure 3.13. Once claims are received, procedures must be undertaken to ensure the correctness and regularity of expenditure declared under the operation programme. This topic is covered in User Guide, Chapter 7. Processing approved expenditure 3.14. Once the necessary expenditure checks have been conducted and the validity and correctness of the expenditure is assured, the claim can be processed through the RDAs normal accounting system. a. The accounting entry for this will be: Dr ERDF Expense Cr Creditor b. The coding must be sufficiently detailed to enable analysis by expense type as defined in the Data Dictionary and the ten categories detailed in paragraph 32. c. When RDAs record the expense for third party claimants, they subsequently should release income from Deferred Income. Thus at the same time as establishing the third party creditor, RDAs should undertake this release transaction. d. The accounting entry for this will be: Dr Deferred Income Cr ERDF Income Page 9 Version 1: August 2009 ERDF User Manual Chapter 6: Financial Management e. To ensure that the ERDF income is readily identifiable, RDAs will need to establish either a specific income account for this, or alternatively, use an existing income account coupled with a separately identifiable ERDF cost centre code. f. As shown above, ERDF expense and income within the RDAs accounts should always be equal and therefore there will be no impact on the Income & Expenditure Account Surplus / Deficit. g. RDAs will pay third party claimants through their accounts payable system in the normal manner. The extinguishing of the creditor will result in the following journal entry: Dr Creditors Cr Cash RDA requests reimbursement from CLG h. The process for applying for reimbursement is described in Chapter 7 that covers the role of the Certifying Authority. In brief, by the 5th working day of a month, RDAs will send an aggregated claim to the Certifying Authority team within CLG for reimbursement of prior month’s expenditure. The aggregated claim will be raised using the CLG provided MCIS system. The instructions on the use of MCIS are not covered here as there is separate guidance provided for this purpose as part of the MCIS rollout and training. i. At this time, RDAs should record their entitlement to reimbursement from the CA. Accordingly, RDAs will undertake the following journal: Dr Debtor CLG Cr Deferred Income CLG reimburses RDAs j. The certifying authority team within CLG will undertake checks of the RDA claim. When satisfied that the expenditure is valid, the C A team will advise the RDA to expect payment into their bank account within three working days of processing. It is expected that RDAs should receive reimbursement by the 23rd of the month. RDAs receive reimbursement from CLG k. On receipt of the funds from CLG into the RDA bank account, the RDA will extinguish the Debtor CLG in their accounts. The associated accounting entry for this will be: Dr Cash Cr Debtor CLG Forecasting information 3.15. For reporting and monitoring purposes, the CA will require monthly forecasting data for the current financial year. This data is required to be submitted across the ten possible expenditure types as set out in paragraph 32 of this Chapter. In April each year, the Commission also requires a current and subsequent year Page 10 Version 1: August 2009 ERDF User Manual Chapter 6: Financial Management forecast to form part of the member state returns. Instruction regarding submitting monthly forecast data into MCIS will form part of the MCIS User Guide. The forecast data should be supplied by working day 5 of the month. End of Month Reconciliation 3.16. Balance sheet accounts relating to the ERDF programme should be reconciled monthly in line with the RDAs’ own processes and procedures which apply to other balance sheet accounts. HM Treasury Reporting 3.17. The ERDF year end transaction streams and balances between CLG and the RDAs are subject to the Whole of Government Accounts year end agreement and reporting processes. Point of Contact within CLG 3.18. The first point of contact within CLG for ERDF related queries and issues will be the assigned CA team. Page 11 Version 1: August 2009 ERDF User Manual Chapter 6: Financial Management Example of Accounting Treatment Example of Accounting Treatment The table below sets out the accounting treatment of the following scenario: In one month a RDA receives a claim of £20,000 from a beneficiary and decides to reimburse £15,000. CLG reimburses RDA £15,000 and claims it from EC in Euros. The payment received from EC is converted into £s which is worth £16,000, a gain of £1000 due to exchange rate differences. RDA CLG Ledger Accounts Process 1 Action RDA Receive claims Debit from projects Credit Expense Creditors Ledger Accounts Debtor Deferred CLG Income Debit Credit Accrued (RDA) Income Income Foreign Cash Debtor Exch. Brussels -20,000 15,000 Credit aggregated claim to CLG for Creditor 20,000 Debit At month end RDA sends an Expense -20,000 Credit 2 Cash 20,000 Debit RDA pay £15,000 Income -15,000 15,000 15,000 -15,000 15,000 -15,000 -15,000 reimbursement of claims paid. 3 4 CLG pays RDAs Debit the reimbursement Credit CLG submits declaration for Debit reimbursement in Euros Credit 15,000 15,000 -15,000 -15,000 15,000 -15,000 from EC. 5 CLG receives reimbursement Debit in Euros from EC Credit Net balances 16,000 -1,000 20,000 -5,000 0 5,000 -20,000 0 15,000 Page 12 0 0 -15,000 -1,000 -15,000 1,000 0 Version 1: August 2009 Annex A: Definitions of Expenditure Categories Definitions of expenditure categories below that are referred to in paragraph 30 are based on guidance made available by HM Treasury, ONS, BERR and CLG Current Expenditure It is the day to day operating costs. The most significant examples are direct paycosts, accommodation costs, consultancies, the costs associated with capital expenditure (such as depreciation), consumable supplies and materials, and travel and subsistence. Capital Expenditure This is the cost of acquiring, producing or enhancing fixed assets such as buildings, plant and machinery, and office equipment. NDPBs, other bodies & organisations within central government This includes central government departments and their agencies including Trading Funds, Non-departmental public bodies, NHS Health Authorities and Boards. Local Authorities All tiers of local government, police and fire authorities, transport authorities; greater London Authority (GLA), state schools and colleges except City Technology Colleges and City Academies. Public Corporations These are public trading bodies which have a substantial degree of financial independence from the public authority which created them. Examples are Post Office, Transport for London, Royal Mint, Land Registry, British Nuclear Fuels. Private sector NPISH These are non-profit institutions serving households. These include bodies such as charities, universities, churches, trade unions or member’s clubs, National Trust. Private sector companies Private sector companies are taken to be organisations established and operating for profit, where these profits accrue to shareholders, partners, or sole traders. Annex A Page 13 Version 1: August 2009