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European Regional Development Fund (ERDF)
Programme 2007 - 2013
Project Monitoring Guidance
Introduction
This document is intended to provide guidance on requirements, process and types of
evidence needed to kept and presented during a Project Engagement Visit (PEV),
Progress and Verification Visit (PAV/Article 13 Visit), Article 16 Visit and other audits that
a project will have conducted on it.
It should be used in conjunction with the ‘Guide to Applying for Funding and Running an
ERDF Project’, the information in the project Offer Letter, and in the ERDF Prospectus.
The organisation named on the Offer Letter has the responsibility to ensure that every
aspect of the project is run properly and in accordance with ERDF regulations.
The requirements for managing an ERDF project can be onerous, this guidance is not
meant to be exhaustive or prescriptive, and it provides some basic help and information to
deliver a successful project. It should be used as a tool to help all those involved in the
project think about how to:
o Implement good practice
o Set up systems which are easy to use
o Keep a close eye on how the project is delivering
o Ensure the project does not store up any problems further down the line.
There are pitfalls to avoid, and this guidance has tried to set out what some of those
might be based on the experience of previous ERDF Programmes.
ERDF Monitoring Guidance
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Index
Introduction
Index
Page
1
2/3
1. Management Structure
1.1 Document Retention
1.2 Project Files
1.3 European / National Statutory Requirements
1.4 Equal Opportunities
1.5 Fair Employment
1.6 Health & Safety
1.7 Legitimacy of Operation
1.8 Managing Partnerships
Page
4/5
5/6
7
7
7
7
7
7/8
2. Financial Systems and Records
2.1 Expenditure Audit Trail & Financial Processes
2.2 Defrayment
2.3 Match Funding
2.4 VAT Details
Page
8
9
9
10
3. Verification of Expenditure and Income
3.1 Project Costs
3.2 Eligible and ineligible expenditure
3.3 Eligible Capital Costs
3.4 Eligible Revenue Costs
Staff Time Sheets
3.5 Non Eligible Costs (Capital and Revenue)
3.6 Apportionment and Depreciation
3.6.1 The 20 Year Ruling
3.7 Inventory of assets
3.8 Change of use, disposal and charging of assets
Page
10
10
10
11
11/12
12
13
13
13/14
14
4. Physical Progress – Delivery of Outputs and Results
4.1 Evidencing performance indicators
4.2 Data Collection, Calculation and Reporting
4.3 Progress monitoring Reports
Page
14
15
15
5. Compliance
5.1 Publicity
5.1.1 Capital Projects: Billboards
5.1.2 Capital Projects: Permanent Plaques
5.1.3 Revenue Projects: Poster & Plaques
5.1.4 Information & Communication Material
5.1.5 Events
5.2 Tendering and Procurement
5.2.1 Guidance
5.2.2 EU Procurement Thresholds
5.2.3 Responsible Procurement
5.2.4 Supporting Evidence
5.3 State Aid
5.3.1 Definition of an SME
Page
15
15
15
16
16
16
17
17
17/18
18
18
18
18/19
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5.3.2 De-Minimis
5.3.3 Block Exemptions
5.4 Revenue Generating Projects
Page
19
19/20
20
6. Cross Cutting Themes
6.1 Environmental Sustainability
6.1.1 Carbon Calculator
6.1.2 Green Travel Plan
6.1.3 Sustainable Procurement Plan
6.1.4 Sustainable Buildings Policy
6.2 Equality and Diversity
6.3 Data Protection
Page
20
21
21
21
22
22
22/23
7. Monitoring and Audits
7.1 Project Monitoring
7.2 What is a Monitoring System?
7.3 European Programmes Executive Monitoring Requirements
7.4 Project Engagement Visit (PEV)
7.5 Progress and Verification Visit (PAV) Article 13Visit
7.6 Article 16 Visit
7.7 Other Visits
7.8 Essential Criteria to Monitoring Visits
7.9 Irregularities
7.10 Material Changes
7.11 N+2
7.12 Start and End Dates
7.13 Common Mistakes
Page
23
23/24
24
24/25
25
25
25/26
26
26
26/27
27/28
28
28
8. Supplementary
8.1 Who’s who
8.2 References
9. Annexes
Annex 1. Time Sheet - Example of an ERDF Project Timesheet
Annex 2. Depreciation Methodologies
Straight line method of depreciation
Reducing balance method of depreciation
Annex 3. Inventory of Assets - Example of a Project Asset Register
Annex 4. SME Definitions
4.1 Example Letter for SME Block Exemption
4.2 Example Letter for SME De-Minimis
4.3 SME Registration Form
4.4 ERDF SME Checklist
Annex 5. De-Minimis - Example of a De-Minimis Return Form
Annex 6. Carbon Calculator Examples of Evidence
Annex 7. Common Mistakes
Annex 8. A13 PAV Visit Procurement Evidence Checklist
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3
1. Management Structure
It is a requirement that the project has management and delivery personnel structures in
place. That organisation charts and job descriptions clearly show a person’s involvement
with an ERDF project.
The project must have Management Information Systems (MI) in place to assist delivery
of the project and should include, minutes of meetings held relating to the project,
monitoring reports, time sheets for staff working part time on the project, databases,
spread sheets or an off the shelf electronic client management system.
It is essential that all delivery partners are fully aware that they are subject to and must
follow all European Commission (EC) rules and regulation as set out in the offer letter and
will be subject to a full examination of their documentation, systems and processes as
part of the Article 13 checks.
1.1 Document Retention
An essential requirement of European funding is keeping correct and up to date project
records. Failure to demonstrate that there is accurate evidence of the project, its outputs
and activities may result in the project having to repay part or the entire grant. Final
responsibility for this rests with the organisation named on the Offer Letter, who must
ensure that any project partners and sub-contractors also comply with these rules. There
should be a document retention policy clearly stating how and for how long the project will
store ERDF documentation.
The project must keep original copies of all documents/invoices which show a
complete audit trail for every aspect of the project, from application, staff recruitment and
marketing, to outputs, finances and evaluations.
Project Name:
Project No.:
THIS IS A EUROPEAN REGIONAL DEVELOPMENT FUNDED
PROJECT FILE
TO BE RETAINED UNTIL AT LEAST 31ST DECEMBER 2025
PLEASE DO NOT DESTROY WITHOUT FIRST RECEIVING
CONFIRMATION FROM THE NORTH WEST DEVELOPMENT AGENCY
THAT THE 2007-2013PROGRAMME HAS OFFICIALLY CLOSED
These documents should be
comprehensive, reliable and
accessible, and must be
kept until at least three
years after the UK receives
its final payment from the
EC. This means that the
project will have to keep all
documentation relating to
the project until at least 31st
December 2025.
PROJECT PART-FINANCED by the EUROPEAN UNION
It would be advisable to put
a label similar to the one (above) on all project files. At the end of a project, if
records/documents are archived there must be someone who knows where they are
and how to retrieve them.
There is always the possibility of unforeseen impacts on the project, such as staff leaving,
the project should have procedures in place that ensure that new staff can access the
documentation and understand how and what the project is supposed to deliver and its
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progress to date. There should be a chronological record, or history, of project delivery
and how decisions about the project were reached.
Documents which exist solely in electronic form can also be stored. Checks will be made
to ensure that the versions held comply with national legal requirements and can be relied
on for audit purpose. Where documents exist in electronic form only, the computer
systems used must meet accepted security standards of COBIT, (Control Objectives for
Information and Related Technology), which can also be relied on for audit purpose.
Ref: ERDF User Manual – Chapter 2 Eligibility Rules – 1.3 page 3
As a minimum, all expenditure relating to the project, down to the smallest transaction,
must be recorded and all financial transactions must be clearly traceable through the
projects financial accounting system. Output records will vary according to the nature of
the project (see Section 4, below).
Below is a list of records the project must keep – this list is not exhaustive and the project
will be expected to retain any other evidence relating to the project:
o ERDF application forms (i.e. Eol, Concept & D&A Forms) and all correspondence
from contract negotiations
o The signed Offer Letter
o Tenders, contracts and procurement documentation
o Planning consents, where applicable
o Records of any project income
o Reports relating to the project, and minutes of meetings where the project was
discussed
o Documentation relating to any changes made to the project during delivery
o Staff costs
o Receipts and invoices
o Recruitment evidence
o Evidence of auditable, accountable match funding
o Evidence of expenditure, including proof that funds left the project bank account
within the correct period
o Records of beneficiaries and the steps taken to ensure their eligibility
o Compliance with equal opportunities and environmental sustainability requirements
o Proof of performance indicators delivered – how, where, when, who etc.
o Publicity materials, including photos of billboards for future reference – with the
ERDF logo
o Details of partnerships, including SLAs
o Records of businesses supported, for state aid purposes, and records of support
received by business if you are exempting them from state aid under De Minimis
o The project’s state aid notification, where applicable
o Auditors’ statements
o Annual reports and project evaluations
o Details of monitoring procedures
1.2 Project Files
It is advisable to set up separate project files to ensure the all records are easily
retrievable during a monitoring visit/audit, to help manage the project and to comply with
ERDF requirements. Below is a suggested format of how the project could structure its
Project Files:
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Management & Administration
Project Activity:
Application forms
Offer letter and revised offer letters (if
appropriate)
Project work plans
Evidence of recruitment process (if applicable)
Policy documents:
Equal opportunities
Fair employment
Health & Safety
Document retention (detailing how and for how
long project files will be kept)
Minutes of meetings/reports:
Minutes of all meetings relating to the project
Minutes of all partnership meetings (if applicable)
Progress reports
Financial
Finance reporting:
Policies & procedures
Authorisation limits
Management accounts
Financial reports
VAT registration details
Evidence of cost centres / cost codes
Original invoices & receipts
Equipment/Machinery etc:
Asset register
Invoices (originals)
Receipts (originals)
Land Acquisition:
Land valuations
Receipts for land on accounts summary
Site Preparation/building/construction:
Tender reports from project QS
Valuations from contractor QS
Payment records
Contractor tipping notes (if appropriate)
Delivery of Outputs & Results
Beneficiary records:
Beneficiary files
Beneficiary feedback / evaluation forms
Monitoring spreadsheets
MI / Activity reports
Survey reports
Letters from SME’s detailing employment/sales
Before & after photographs for environmental
enhancements, land serviced
Procurement:
Procurement policy
Tenders
Quotes
OJEU notices (if applicable)
Management structure:
Organisation chart (highlighting project personnel)
Job descriptions (all those involved in the project)
HR records
Valid insurance certificates:
Employer’s liability*
Public liability*
Buildings & contents*
*Originals wherever possible or copies signed as copy
of the original (see 1.1)
Staff Costs:
Payroll records
A copy of pay slips (if possible/appropriate)
BACS/Bank statements*
Management accounts
*Originals wherever possible or copies signed as copy
of the original (see 1.1)
Depreciation:
Depreciation policy
Depreciation methodology / calculation
Site investigation:
Specialist reports
Consultant invoices
Environmental impact assessments / studies
Overheads:
Working papers for apportionment methodology /
calculations
Cost codes
Management accounts
Staff time sheets signed and authorised
Publicity:
All press cuttings/articles/brochures/flyers relating to the
project
Pictures of billboards (if applicable)
Stationary with Logos
State Aid:
De minimis – details of any public financial assistance
received in the past 3 years
Details of aid received
Details of Block Exemptions /specially approved
schemes
Letters to Beneficiaries confirming aid type & amount
received from the project
Cross Cutting Themes:
Details of themes covered i.e. Environmental
Sustainability, Green Travel Plan, Sustainable
Procurement Plan, Sustainable Buildings Policy,
Equality & Diversity, Equal Opportunities policy
If there is any doubt as to what to keep or for how long, seek advice.
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Ref: www.erdfnw.co.uk - Guide to Applying for Funding & Running an ERDF Project.
1.3 European & National Statutory Requirements.
It is a requirement to have procedures/policies in place in place relating to Equal
Opportunities, Fair Employment and Health & Safety.
1.4 Equal Opportunities
The aim of the Equal Opportunities policy should be to ensure that the organisation is
committed to valuing diversity by promoting and implementing equality of opportunity in all
activities across the whole spectrum of its business. This commitment should be
underpinned by the relevant legislation which includes:
o Equal Pay Act 1970 (amended by Equal Pay regulations 1983)
o Rehabilitation of Offenders Act 1974
o Sex Discrimination Act 1975 (amended 1986; Gender Reassignment Regulations
1999)
o Race Relations Act 1976 (Race Relations Act Amendment Bill)
o Disability Discrimination Act 1995
o Protection from Harassment Act 1997
o Human Rights Act 1998.
1.5 Fair Employment
The organisation should be committed to the promotion of equality of opportunity in
employment and the elimination of discrimination or harassment on the basis of marital
status, ethnicity, religious and political belief. The project must be able to demonstrate a
fair recruitment process and provide evidence of job adverts, interview notes and job offer
/ acceptance letters.
1.6 Health & Safety
The organisation should be firmly committed to achieving and maintaining high standards
of health and safety. All employees carry a legal obligation to take reasonable care for
their own health and safety and for that of others who may be affected by their acts and
omissions. As well as including their colleagues, this duty also extends to the care of
contractors, visitors and members of the public.
1.7 Legitimacy of Operation
The organisation must be able to demonstrate the legitimacy of its operation by providing
evidence of employer’s and public liability insurance, building & contents insurance
(copies of valid certificates) and whether the organisation is VAT registered (VAT
registration number).
1.8 Managing Partnerships
The Offer Letter recipient is the organisation that is accountable for the ERDF grant, and
is therefore responsible for ensuring that project partners are aware of the ERDF Offer
Letter conditions, monitoring and audit processes and requirements, are able to provide
the necessary information at the correct time for each claim and are keeping detailed
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financial records and information to support progress and outputs detailed on the claim
forms.
Is it essential that, from the very outset:
o All partners are clear on their roles and responsibilities
o All partners have a budget which includes the match funding they have agreed to
bring to the project
o All partners are clear about what they have agreed to deliver in terms of outputs,
results and impacts and the timescales for these
o There is an agreed record keeping system, monitoring and reporting timetable in
place, and structures to ensure things are done correctly and on time
o All partners are aware of what records are to be kept and are trained in both
financial and general record keeping for European Structural Funds, and know
exactly what the expectations are
o Partners’ records are monitored by the accountable organisation on a regular
basis.
o All partner meetings are minuted/recorded
This information should be formalised in a Contract or Service Level Agreement (SLA).
Also arrangements should be consider for:
o How and when information will be reported
o Who will report the information to whom
o How progress, general issues and problems will be communicated between the
partners and the accountable organisation
o How you will co-ordinate the work of the partners
o How partners will be made aware of ERDF requirements
o What tools will be made available for managing the partnership budget
Projects run the risk of getting into difficulties if they cannot ensure partners comply with
these requirements. It will be the responsibility of the grant recipient, not any partners, to
provide information, problems with partners will not be accepted as an as excuses for non
delivery or the late submission of claims. If claw back is initiated, funds will be taken
from the grant recipient, not any partners, even if the problem is their fault!
Ref: www.mcisproject.co.uk/documents.php - Communities & Local Government ERDF User Manual.
Ref: www.erdfnw.co.uk - Guide to Applying for Funding & Running an ERDF Project.
2. Financial Systems and Records
2.1 Expenditure Audit Trail & Financial Processes
The project should maintain accounting records that allow easy identification of the
project and any grant income and expenditure to the project. Whenever possible the
project should have a separate bank account from the parent organisation or as a
minimum, separate cost centres or cost codes should be used for each project. The
project should have an organised system for filing original numbered invoices and
receipts which can be easily retrievable and preferable specific to the project.
There should be a clear segregation of duties relating to the appropriate authorisations for
bank accounts and delegated duties, who checks and signs claims and who monitors and
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controls project expenditure. The project should ensure that there is either a simple cash
book system, a manual double entry system or computerised system for managing the
project finances. The project should also produce regular meaningful financial reports.
2.2 Defrayment
Under ERDF, eligible expenditure within a grant claim has to have been incurred and
payment made by the applicant for it to have been defrayed, i.e. defrayal occurs at the
point when the funds leave the payer’s bank account.
Where one applicant takes the lead and has a number of partners supporting the delivery
of the project, defrayment by the partners is sufficient; it is not necessary for the lead
partner (applicant) to have defrayed the expenditure as well, as long as they are named
within the D&A and the ERDF offer letter. If they are not, the expenditure must be
defrayed by the lead partner (applicant) before it is deemed eligible.
If a partner is not identified at appraisal / contracting stage, a change control would need
to be submitted detailing the reasons why the inclusion/change of Partner was required,
the level of eligible expenditure the partner would be incurring etc. This would be
reviewed by EPE / PRG and a decision made. If approved, a contract variation would be
issued, and only when the contract variation is signed off by both parties can defrayment
by the new partner be eligible.
It is also important to note that Article 20 of Reg 1080/2006 requires the lead beneficiary
to check the expenditure has actually been incurred and spent on the agreed project
activities by partners. It takes the risk and is supposed to ensure that the other partners
will assume responsibility for any financial irregularities. Therefore the lead applicant
(partner) needs to ensure effective systems and processes are in place to verify partner
expenditure has been defrayed and that some form of contract is in place between the
lead partner and other partners to ensure they are responsible for any financial
irregularities they make.
2.3 Match Funding
The projects match funding should have been confirmed prior to receipt of the Offer
Letter. If there are any changes to the nature of the match, in terms of amounts, or where
the match is coming from, the project should notify the NWDA Contract Manager (CM) as
this is considered to be a material change to your project.
The project must spend the match and the ERDF according to the grant rate. So, if the
project has a grant rate of 50%, when the project submits a claim it must be able to show
that half the costs incurred have been covered by ERDF and half by the match. If the
project fails to do this, and to prove how it has kept track of the match, this will be picked
up at audit and the project could be penalised.
Ref: www.erdfnw.co.uk - Guide to Applying for Funding & Running an ERDF Project.
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2.4 VAT Details
If the organisation is VAT registered, it must provided evidence in the form of its VAT
registration number. If VAT is included in the project costs the organisation must have
conformation that VAT cannot be recovered and give the rationale as to why it cannot be
recovered.
Ref: www.mcisproject.co.uk/documents.php - Communities & Local Government ERDF User
Manual, Chapter 2: Eligibility Rules Section 2.1 & Chapter 6: Financial Management.
3. Verification of Expenditure and Income
3.1 Project Costs
The project must be able to demonstrate how project costs have been recorded, how they
have been calculated and included in the claim and that there is a clear audit trail. This
relates to cost for staff, plant/machinery and equipment, depreciation, land acquisition,
site investigation/preparation/building and construction and other costs such as
consumables/fees/rents, revenue and income.
3.2 Eligible and Ineligible Expenditure
Different types of projects have different eligible costs. Make sure the project only
claims for items and activities which are eligible for the Priority Axis under which it is
being delivered.
Below are some examples of eligible and ineligible costs for capital and revenue projects.
Please note that this list is not exhaustive, but is intended to give a guide as to what can
be included. Claiming ineligible items may result in the project being investigated and
having funding withdrawn.
Contributions in-kind are ineligible for ERDF, except in cases where a clear independent
valuation can be made, such as the donation of a building or land.
3.3 Eligible Capital Costs
o Purchasing land. Costs must not be more than 10% of your total project cost
unless it is an environmental project
o Purchasing buildings
o Site investigation
o Site preparation
o Building and construction. This covers all works to land and to the fabric of a
building but does not include decorative items such as artwork
o Plant, machinery and equipment with an asset life of more than one year
o Retention, as long as this is paid within the lifetime of the project
o Security Provision. This must be to ensure the success of the wider project and
cannot include CCTV in town centres or as a stand alone initiative
o Signage, which must acknowledge the project’s ERDF contribution
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3.4 Eligible Revenue Costs
o
o
o
o
o
o
o
Salary costs of staff who are directly involved in the project’s delivery *(see timesheets)
Recruitment and training of delivery staff
Travel and subsistence of delivery staff
External consultancy support, for example specialist business advisors
Marketing and publicity
Overheads in accordance with specific guidance
Equipment with an asset life of less than one year and costing less than £2.5k
For overheads on projects in the Higher Education Sector the 2008 HEI Guidelines apply:
Ref: www.mcisproject.co.uk/documents.php - Communities & Local Government ERDF User
Manual, Chapter 2: Eligibility Rules Section 2.3 Overheads in the Higher Education Sector in
England
Staff Timesheets*
The only instance where a timesheet is not required is when an employee is employed
100% on an ERDF project and only then where a job description evidences that there
work is 100% based on ERDF eligible activity. The timesheet should only be used for staff
who are not 100% employed on ERDF projects.
Timesheets should be completed on a daily basis and should record the persons name
and period covered, along with project number and title, a description of all ERDF and
non-ERDF activity. Holidays and sickness should be recorded as non-ERDF activity as
this is the only way that salaried staff hours can be correctly calculated.
The timesheet must be signed by the person as evidence that it has been filled in
accurately and then passed to the agreed supervisor or line manager for verification.
If the organisation uses Microsoft Outlook, it is acceptable to use ‘Calendar’ to record the
time worked on ERDF project as long as all the above information (information that’s on
the timesheet) is recorded on Calendar and it is signed and counter signed as a true
record.
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Staff Declaration: I declare that the details provided are true and accurate record
Signature: Joe Bloggs Print Name: Joe Bloggs Date: 12/01/09 Position: Project
Manager
Supervisory conformation: The above record is true to the best of my knowledge
Signature: L Manns Print Name: Larry Manns Date: 12/01/09 Position: Line
Manager
Ref: Annex2 - Example of an ERDF Project Timesheet.
Ref: www.erdfnw.co.uk Guidance Guide to Applying for Funding & Running an ERDF Project.
3.5 Non Eligible Costs (Capital and Revenue)
o Loan Charges
o Moveable infrastructure such as cars and office equipment, except when a) related
to projects involving research and development or the delivery of vocational
training, e.g. computer equipment, teaching equipment and machinery for skills
enhancement/delivery, and b) essential fixtures and fittings directly related to the
sole purpose of a project as agreed in the offer letter
o Recoverable VAT
o Any costs spent outside the eligible project period, including site acquisition costs
o Any costs spent before the project start date given in the Offer Letter
o Costs related to research or studies carried out in respect of the project before its
official start date
o Service charges or interest arising on financial leases and hire purchase
arrangements
o Costs resulting in the deferral of payments to creditors
o Legal costs in respect of litigation
o Costs involved in winding up a company
o Payments into private pension schemes or payments for unfunded pensions
o Bad debts
o Gifts and donations
o Repair costs (maintenance costs to the item)
o Compensation for loss of office (e.g. councillor losing his/her public office position)
o Costs of works being carried out as a statutory requirement
o Notional expenditure including overheads allocated or apportioned at rates
materially in excess of those used for any similar work carried out by the applicant
o Payments for activity of a political nature
o Depreciation or impairment of assets purchased with ERDF or any public funds
o Provisions
o Contingencies and contingent liabilities
o Dividends
o Payments for unfair dismissal
o Entertainments
o Statutory fines and penalties
o Criminal fines and damages
o Profit made by the applicant (unexpected income)
o Costs incurred by organisations in relocating personnel displaced by the
refurbishment or conversion of a building for ERDF use
o Discounted sales of equipment
o Discounted provision of services or advice (e.g. solicitors’ accountants’ or SME
staff time)
o Provision of volunteers’ time
If there are any questions on specific costs, please contact your NWDA CM.
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Ref: www.mcisproject.co.uk/documents.php - Communities & Local Government ERDF User
Manual, Chapter 2: Eligibility Rules Section 2.1.
Ref: www.erdfnw.co.uk - Guide to Applying for Funding & Running an ERDF Project
3.6 Apportionment and Depreciation
The apportionment methodology used to calculate the costs of project staff and
overheads will be agreed with your NWDA CM during contract negotiations. This will then
form a condition of the Offer Letter. It must be ensured that consistency is applied to the
approved methodology across the entire duration of the project.
Depreciation is permitted on items which you already own – not those purchased with
ERDF funding. When calculating depreciation it must be in line with the delivery
organisation’s accounting policy; if the delivery organisation does not have one, then
there are several methods for calculating depreciation (see Annex 3). ERDF claims must
be based on the real costs of the equipment.
It is important that ERDF requirements are adhered to if they differ from the organisation’s
policy. For example, buildings are usually depreciated over 20/25 years and equipment
over 5 years. An asset life of less than 1 year is unusual, even IT equipment is usually no
less than 3 years. There may be a need for the organisation to justify anything less than 1
year and then to consider whether it would have been more reasonable / cost effective for
the organisation to have leased the equipment instead. (See also section 5.5)
3.6.1 The 20 Year Ruling for Capital Projects
The project that includes the construction/refurbishment of a building must provide details
of the planned usage for next 20 years, a copy of lease or written commitment from
landlord that they are committed to providing the usage for the next 20 years along with a
20 year cash flow. It should be understood that offer letters are issued on this expectation.
If it is anticipated that the lifespan will be shorter, it would need to be clearly stated in the
grant offer letter and documentation to support the reasons why are held on file.
3.7 Inventory of assets
As per the Standard Terms and Conditions:
“Fixed Asset” means any asset that consists of land and/or buildings, plant, machinery
or other thing that is, or is to be, fixed to any land and which is to be acquired, developed,
enhanced, constructed and/or installed as part of the Project.
"Major Asset" means an Asset which is not a Fixed Asset but has a value as at the date
of the Funding Agreement (or date of acquisition if the acquisition is funded by this Grant)
of at least £5,000.00.
For all fixed assets and any other assets with a value over £2,500 which have been either
bought, built or improved using ERDF grant the project must set up and maintain an
inventory, which includes, for each asset, the following:
o The date of purchase
o Description of the asset
o The price paid net of recoverable VAT
o Amount of ERDF grant paid
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o Location of the asset and the title deeds (if applicable)
o Serial or identification numbers
o The name and address of any person to whom a disposal is made
o Date of disposal
o The deprecation method agreed at the contract stage
o The date and proceeds (net of VAT) of any disposal (consent is required in relation
to any disposal other than a disposal which was planned for and formed part of the
original application)
Ref: Annex 4 - An example of a Project Asset Register.
3.8 Change of use, disposal and charging of assets
The project is not normally permitted to use any asset for any purpose other than its
approved use throughout its useful economic life. If the project does wish to change its
use, or stop using it altogether, it must get prior written consent from your CM which may
be subject to conditions including repayment of grant. When requesting any changes to
the use of an asset it should include an explanation on how this will not prevent the
project achieving the agreed objectives.
If the project wants to dispose of an asset during the project’s lifetime it will be necessary,
after getting consent from your NWDA CM, for the NWDA to execute a Deed of
Covenant. The project should dispose of the asset on the open market, on normal market
terms. If the project does not get approval from the CM it will be required to pay back the
proceeds of the sale.
4. Physical Progress – Delivery of Outputs and Results
4.1 Evidencing Outputs and Results
Each output and result is different in terms of its definition and how it can be delivered.
For example, if you safeguard jobs you must break down the total into equalities groups,
and demonstrate that the job was at risk before your project intervened.
It is extremely important that the project not only understands what each output means,
but also how it will be expected to evidence it. Not collecting the right evidence could
mean that, even if the project has met its targets, these outputs will not be counted and
the project could be seen to be underachieving. In extreme cases this can lead to claw
back of grant.
Everyone involved in delivering the project must understand what the evidence
requirements are, and that the right evidence is collected for the output being claimed at
the time. Claiming 100 SMEs supported, then having to go back over a 3 year project to
get signatures and letters of support from them all would be extremely difficult!
During contract negotiations the project will have received information on the evidence it
will need to provide on performance indicators. This includes guidance on the importance
of the Programme’s two (environmental sustainability and equality and diversity) Cross
Cutting Themes (CCTs), (see section 6).
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4.2 Data Collection, Calculation and Reporting
Are the appropriate output definitions understood and in use?
Is all the necessary output data being collected?
What systems are being used to collect data? Are they robust?
What verification evidence is being collected?
Is it acceptable in relation to types of evidence and authenticity?
How is this information being stored?
Is it easily accessible for checking?
Who completes and checks the Output Monitoring Return? Is it the appropriate
people?
o Are returns submitted on time with the appropriate information?
o
o
o
o
o
o
o
o
4.3 Progress Monitoring Reports
Projects are required to provide a Progress Monitoring Reports with each claim. The
project must also provide a Progress Monitoring Reports even if a £0 claim is made. This
is in order to comply with CLG requirements.
Ref: nwda.co.uk/extranet – 2009 Output Definitions SP & ERDF.doc.
Ref: www.mcisproject.co.uk/documents.php - Communities & Local Government ERDF User
Manual, Chapter 11: Indicators.
Ref: www.erdfnw.co.uk - Guide to Applying for Funding & Running an ERDF Project.
5. Compliance
5.1 Publicity
All projects must publicise the fact that they are funded by ERDF. There are strict
requirements the project must adhere to, depending on the nature of the project, or risk
claw back of grant. These are detailed as follows:
5.1.1 Capital Projects: Billboards
The project should put up a billboard if the project is an infrastructure project whose public
contribution exceeds €500,000 the size of the sign must be appropriate to the scale of the
site, the project should ensure that the ERDF logo covers at least 25% of the billboard
and that the text (This project has been part-funded by the European Union) is at
least the same size as any other logos or text used on the billboard.
Billboards should remain in place for at least six months after the project has finished, and
then be replaced by a permanent plaque. The project should make sure it has
photographs or other evidence for the billboard so that in the event of an audit once
the project is completed, there is evidence to demonstrate that it did erect a billboard.
5.1.2 Capital Projects: Permanent Plaques
If a project has received an ERDF grant of more than €500,000 and consists of the
purchase of a physical object or the financing of infrastructure or construction then a
permanent plaque, that is visible and of significant size, has to be put up no later than 6
months after the completion of the project. Again at least 25% of the plaque must be
ERDF Monitoring Guidance
Updated August 2011
16
dedicated to the Northwest ERDF logo with text (This project has been part-funded by
the European Union).
5.1.3 Revenue Projects: Posters and plaques
In order to inform beneficiaries and the general public of the role played by ERDF in a
project, the project must display a poster or plaque at the project or the project premises.
Again at least 25% of the plaque must be dedicated to the Northwest ERDF logo with text
(This project has been part-funded by the European Union).
5.1.4 Information and Communication Material
All press releases related to ERDF funded projects must be approved by the NWDA’s PR
team and must include:
o The Northwest ERDF logo
o A description paragraph about ERDF in the Northwest
o A quote from an ERDF spokesperson
A project can also publicise through items such as booklets, leaflets, newsletters. These
should include a clear indication of the fact that the project has received an ERDF
grant, (This project has been part-funded by the European Union) and must include
the Northwest ERDF logo. In the case of websites and other electronic means of
communicating about the project, the same rules apply.
The Logo must appear in a prominent position on any materials relating to ERDF funded
projects and activities. The logo must be positioned in its own clear space, standing apart
from other images and text. The minimum reproduction size for the logo is 50mm.
The Northwest ERDF logo should be published in full colour
whenever possible using black, Pantone Reflex Blue and
Pantone Yellow. It can be reproduced in single colour using
black or Pantone Reflex Blue. It can also be produced in
black and white when full colour is not an option.
5.1.5 Events
If events are organised events relating to an ERDF funded project such as conferences,
seminars, fairs and exhibitions, the funding recipient must:
o
o
o
o
o
Notify the NWDA Marketing Department in advance
Include the Northwest ERDF logo and text on all pre and post event materials
Invite a relevant ERDF spokesperson to speak at the event
Verbally acknowledge the support of ERDF funding during the event
Display an ERDF exhibition stand (if appropriate)
The NWDA will distribute ERDF plaques to projects on request. A copy of the Branding &
Publicity Requirements document is available form the NWDA via your CM or from the
NWDA ERDF website.
Ref: www.erdfnw.co.uk - Guide to Applying for Funding & Running an ERDF Project.
ERDF Monitoring Guidance
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5.2 Tendering and Procurement
It is the applicant’s responsibility to ensure Public Procurement rules are followed and to
provide the appropriate evidence at audit. If in doubt, please seek legal advice.
5.2.1 Guidance
Please be aware that the principles of transparency, openness, fairness, equal treatment,
proportionality must be adhered to at all times; this applies also to all procurement below the EU
threshold (Commission interpretative Communication re contract awards not or not fully subject to
the provisions of the Public Procurement Directive (2006/C179/02))
All procurement of works equipment goods and services shall be based on value for
money and in accordance with all relevant law including EU Procurement Directives if
applicable. ERDF grants will be suspended, withdrawn and/or reclaimed from
projects if it is found subsequently that the procurement rules have not been observed.
The Grantee will not split purchases to fall below the thresholds set out in this clause nor
extend or vary existing contracts so that the total value of the contract for its duration
exceeds these thresholds.
5.2.2 EU Procurement Thresholds
The table below sets out EU thresholds above which the grantee is required to advertise
the contract in the Official Journal of the European Union (known as OJEU). Bids for
contracts must be assessed on an objective basis and contract awards should be
published in the OJEU.
The Current EU Procurement thresholds are:
Supplies
Services
Works
£156,442
£156,442
£3,927,260
(€193,000)
(€193,000)
(€4,845,000)
The above thresholds which came into force on 1 January 2010 are subject to change by
the EU (approximately every 2 years). For purchases below these thresholds, EU rules
state that competition and appropriate advertising must still take place.
Any purchase to be made which is above these thresholds (the figure used within NWDA
for goods and services is £156K for ease of use) must be publicly advertised in the
Official Journal of the European Union (OJEU). Advertising in OJEU for this value of
contract is a legal requirement of the European Union and it means that suppliers based
anywhere in Europe are able to tender for goods, services or works within another
European Union country.
Ref: EU Procurement Thresholds:
www.ogc.gov.uk/procurement_policy_and_application_of_eu_rules_eu_procurement_thresholds_.asp
5.2.3 Responsible Procurement
In procuring goods, services or works, the grantee is responsible and accountable for
achieving value for money (VfM). In addition, the grantee is urged to seek continuous
improvements in Value for Money. VfM is best achieved by competition. Competition
ERDF Monitoring Guidance
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promotes economy, efficiency and effectiveness in public expenditure and contributes to
the competitiveness of suppliers.
5.2.4 Supporting Evidence
It is a requirement of the Programme that all of the documents relating to procurement
such as evidence of tenders and any letters offering contract along with documents
showing how decisions were made and by whom are retained and are available for
inspection during management, monitoring and verification visits/audits.
Please see Annex 8 Article 13 Progress and Verification Visit Procurement
Evidence Checklist
Ref: www.erdfnw.co.uk - Guide to Applying for Funding & Running an ERDF Project
5.3 State Aid
The grantee should be aware if the project is operating under State Aid and what the
requirements are. State Aid is aid that is considered to distort the competition between
companies and pose a threat to the operation of the internal market. European
Community rules on State Aid apply limits to the level of help the public sector can give to
industry. Examples of State Aid include direct grants, subsidised loans or where there are
benefits to companies from subsidised business support schemes (e.g. reduced cost
business consultancy, subsidised rents, training). This is a very complex area and
detailed guidance should be obtained.
5.3.1 Definition of a Small to Medium Enterprise (SME)
SMEs are generally defined by the EC as Independent enterprises that are not more than
25% is owned by another company/group that have fewer than 250 employees and an
annual turnover not exceeding €50 (£34 million) or a balance-sheet total not exceeding
€43 (£29 million) these figures will vary due to the interest rate, please check. (For
exchange rates, please see 8.2 references). The 25% threshold in terms of ‘independence’
may be varied in certain circumstances, which tend to be based upon the level of control
exercised over the company. In general the consolidation rules in FRS 2 (Financial Reporting
Standards issued by Accounting Standards Board) are to be followed. The following points should
be noted:
1. You will need to examine two most recently filed annual accounts immediately preceding
the date of the grant. The SME must satisfy the criteria in at least one of those years. This
ensures that the grant itself does not breach the SME limits
2. If the enterprise is a start up, then management accounts will suffice
3. Where aid is provided in instalments, the SME criteria should be checked in accordance
with 1 above every time an instalment is paid, as that could qualify as a severable
contract.
4. In consolidating the results of a group, no account is taken of group members who are not
enterprises, i.e. not involved in the market (e.g. core charitable or some types of core
social enterprise activity)
If there is any doubt in deciding whether a project is an SME or not, contact the North
West Development Agency (NWDA) Legal Team – jane.worthington@nwda.co.uk
ERDF Monitoring Guidance
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It is the responsibility of the Applicant to gather all information on SMEs. If there is any
change to a projects SME status, the project must notify the NWDA immediately using
the SME Declaration Form, failure to do so will result in clawback of grant. Any outputs
achieved prior to the change in status can be claimed but the SME becomes ineligible for
further support once no longer classified as an SME.
Ref: www.erdfnw.co.uk -Guide to Applying for Funding & Running an ERDF Project.
Ref: Annex 5 - SME Definition and Templates.
5.3.2 De-Minimis
A value below which a cost is not to be taken into consideration, for example there is a de
minimis level under which State Aid to companies does not have to be reported to the EC.
For projects where De minimis is applicable, a return will need to be completed on an
annual basis. It is advisable that where a project assists companies over extended
periods (businesses, clubs etc) they ask the company for a declaration every six months.
The total amount of aid that may be granted to any one undertaking under the De Minimis
Regulation is €200,000 in the period 1.1.2009 to 31.12.2010.
De minimis declarations must be recorded in both pounds sterling (£) and Euros (€).
For further guidance on state aid and de minimis issues please refer to:
www.nwda.co.uk/extranet (username “state” password “aid).
Ref: Annex 6 - Example of a De-minimis Return Form.
5.3.3 Block Exemptions
Block Exemptions are Commission Regulations which set out the circumstances where
certain aid can be granted without prior Commission approval. Where an aid measure
complies with the conditions set out in a Block Exemption Regulation only a summary
information sheet must be submitted to the Commission when the aid is granted. The
Block Exemptions also contain additional annual reporting conditions. Covered by the
Block Exemption Regulations are:
o
o
o
o
o
o
o
Small and medium-sized enterprises
Aid for training
Aid for employment
Services of General Economic Interest (SGEI)
Revenue Projects
Capital Projects
Cross Cutting Themes
If is applicable, the project must specify what block exemption it falls under. The project
will also need to complete annual returns to NWDA on what aid, and amounts that have
been given.
5.4 Revenue Generating Projects
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In accordance with Article 55 of EC General Regulation 1083/2006, the definition of a
revenue generating project is any operation involving an investment in infrastructure the
use of which is subject to charges borne directly by users, or any operation involving the
sale or rent of land or buildings or any other provision of services against payment.
The Commission has further reiterated that while projects which generate revenue may
be supported by ERDF, any anticipated revenue should be deducted from the eligible
expenditure at the time of the offer of grant. The ERDF grant should be based on eligible
expenditure alone, excluding anticipated revenue. If it is not possible to calculate the
anticipated revenue, the revenue to be generated within five years of the completion of
the project should be deducted from the eligible expenditure.
Further guidance is being developed relating to this. If the project falls within this category
of activity the European Programme Secretariat will advise what extra information will be
needed in support of an application.
6. Cross Cutting Themes (CCTs)
During contract negotiations the project will have received information on the evidence it
will need to provide on performance indicators. This includes guidance on the importance
of the Programme’s two (environmental sustainability and equality and diversity) CCTs.
The project may have agreed CCT targets during contract negotiations. It must ensure
that it monitors progress against these CCTs and collects data to support their
achievement. The project will be expected to demonstrate that it has actively sought to
meet the CCT targets and must provide all relevant evidence.
6.1 Environmental Sustainability
This theme is central to ensuring that any potential negative environmental impacts of the
Programme are minimised, or mitigated, and that positive impacts are maximised.
Key messages of the theme are to improve:
o energy efficiency and related carbon mitigation measures
o air and water quality
o protection of the local environment (green spaces, biodiversity, quality of life)
o resource efficiency to minimise waste and encourage recycling
o sustainable transport; and
o sustainable construction
6.1.1 Carbon Calculator
There is a requirement for all projects to complete the Carbon Calculator which should
reflect the projects significant carbon impacts and cover issues to do with Energy, Waste,
Water and Transport. The carbon calculator will need to be completed on a quarterly or
six-monthly basis to monitor the actual impact of the project and retained as part of the
audit trail. The actual carbon impact (tonnes of CO2) should be reported within the
progress monitoring report.
The
Carbon
Calculator
is
available
as
an
on-line
tool
at:
http://www.nwdacarboncalculator.com
ERDF Monitoring Guidance
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Your project sponsor\development manger will have set your project up on the system.
When you have been added on to the system you will receive an automated email giving
you a password. Details of how to log on and complete the calculator are available on the
login page or contact NWDA’s Mark Joslyn for further help and support.
Examples of evidence to back up the carbon calculator would be mileage claims, waste
transfer notes, utility bills all of which should be stated on the evidence sheet within the
calculator and retained as part of the audit trail.
Ref: Annex 7 - Carbon Calculator, examples of evidence.
Ref: On-line Carbon Calculator http://www.nwdacarboncalculator.com
6.1.2 Green Travel Plan
All projects are required to provide a green travel plan for the project by the first quarter
claim. There is no stated format for green travel plans but it should provide measurable
actions with timescales that can be reported. For capital projects the plan should cover
how the completed site will have in place green travel plan measures such as cycle paths,
incorporated additional bus routes, improved public transport facilities and centralised
logistics. For revenue projects it should focus on how the project will influence businesses
and initiatives it engages with to incorporate green travel i.e. running events and
workshops at locations with good public transport access.
There will be a requirement as part of the quarter 4 claim and final claim/evaluation to set
out how the green travel actions originally stated have been implemented and what has
been achieved.
6.1.3 Sustainable Procurement Plan
All projects are required to provide a Sustainable Procurement Plan, which as with the
Green Travel Plan should provide a series of concise actions on how the project will
minimise its environmental impacts and influence the organisations and businesses the
project may be working through and with. Sustainable procurement can cover a wide
range of issues, for e.g. switching to less hazardous materials, increasing the recycled
content of materials, more energy efficient plants and methods, and ensuring materials
are purchased from ethical sources. The project should ensure that it provides specific
examples of how it will ensure sustainable procurement is embedded into the project and
that it can be evidenced (e.g. a supplier’s certification).
6.1.4 Sustainable Buildings Policy
All construction projects over £500,000 and major refurbishments are required to meet
the targets set in the Buildings Policy.
Ref: nwda.co.uk/extranet – Sustainable Buildings Guidance Note or ask your NWDA CM
6.2 Equality and Diversity
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The guiding principle of this theme is that all policies, programmes and projects should be
designed, developed and monitored with the diversity of the region in mind, and should
proactively tackle barriers to economic participation and success.
Key messages of the theme are to ensure that all potential projects:
o are designed and delivered in a way that promotes equality and diversity with
specific indicators and measurable targets set
o recognise the business case for promoting equality and diversity, not only in terms
of social and economic impact, but also how it can help to increase the number of
businesses reflect current and likely future changes in legislation
o make equality and diversity integral to the project throughout its life cycle
o take responsibility for having access to expertise and resources designed to further
the Programme's equality objectives
o have robust monitoring and evaluation processes that include assessing the
Programme's key Equality and Diversity objectives
All potential projects will be evaluated via the appraisal process to determine the
perceived benefit to the region against both the Action Area objectives and consistency
with the messages of the cross cutting themes. Projects will be supported that can
demonstrate they have taken all practicable measures to embed the cross cutting
themes.
Ref: www.erdfnw.co.uk - Guide to Applying for Funding & Running an ERDF Project.
6.3 Data Protection
Data Protection Act 1998
The Data Protection Act governs the use of personal information by businesses and other
organisations. There is a need to comply with the act if an organisation uses personal
information as part of its business, for example, because the organisation holds customer
details or details on employees.
Personal information is information about a living individual who is identified or who is
identifiable. It includes information such as a name and address, bank details, and
opinions expressed about an individual.
If an organisation is processing personal information covered by the Act it must comply
with the data protection principles.
These require that personal information is:
o Processed fairly and lawfully
o Processed for one or more specified and lawful purposes, and not further
processed in any way that is incompatible with the original purpose
o Adequate, relevant and not excessive
o Accurate and, where necessary, kept up to date
o Kept for no longer than is necessary for the purpose for which it is being used
o Processed in line with an individual's rights
o Kept secure with appropriate technical and organisational measures taken to
protect the information
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o Not transferred outside the European Economic Area (the European Union
member states plus Norway, Iceland and Liechtenstein) unless there is adequate
protection for the personal information being transferred
Ref: nwda.co.uk/extranet – 2009 Output Definitions SP & ERDF.doc.
Ref: Office of Public Sector Information - www.opsi.gov.uk/acts/acts1998/ukpga_19980029_en_1
7. Monitoring and Audits
7.1 Project Monitoring
Project monitoring will be carried out to ensure the project is progressing as it should be.
It cannot be stressed enough how important it is to set up monitoring systems before the
project stars and ensure that they are suitable for the project.
Effective monitoring will allow:
o Assess performance and gauge progress
o Keep control – in order to keep the project on profile you must make efforts to
control delivery
o Identify strengths and weaknesses
o Compile interim progress reports
o Measure actual results against targets and act in the event of any shortfalls or
problems
o Learn from the project, which will help with planning and management
o Prove you did what you claim to have done
o Keep to the approved application
o Know when you need to inform your NWDA CM of any material changes
o Communicate effectively within your organisation and between partners
It is vital that all delivery staff and partners, fully understand what the project aims to do
and how, and that delivery meets all NWDA requirements. All delivery staff and partners
should be aware of this and know how to use your monitoring system from the outset.
7.2 What is a Monitoring System?
Monitoring is an essential and integral part of the lifespan of the project. Effective
monitoring will help to keep the project on course and ensure that it delivers its planned
outputs/objectives. This is important in assisting the NWDA and the region to achieve
their goals.
The Monitoring and Evaluation plan (M&E plan) is a contractual document and should be
used to detail the requirements for monitoring and evaluation agreed between the NWDA
and the delivery partner to avoid any misunderstanding of what the role is of each party
and their responsibilities. It should detail the agreed objectives of the project, baselines,
outputs and results/outcomes and projected spend as well as the level and type of
information to be provided and to what timescales.
Any agreed changes to the project should be reflected within the M&E plan.
The project should set up a system to record the data that provides information for claims,
interim and final reports and project evaluation. It should include documentation
ERDF Monitoring Guidance
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supporting the appraisal and approval of the project in order to demonstrate the need for
the project, and its aims and objectives. Keep all conference programmes,
participants/beneficiary details, materials and reports. Ensure that accurate time records
are compiled of staff working on the project, detailing their activity and contribution to the
project.
The project will need to maintain spreadsheets and schedules detailing project
expenditure and income. These are the basis of the financial claims made to NWDA. The
costs incurred in the delivery of ERDF, or charged to ERDF indirectly, must be
identifiable, so a separate cost code is recommended. Claims must be linked to the main
financial records in order to provide the audit trail, and be backed up by original source
documentation (invoices, travel expense claims, and remittance notes for income).
The project should design non-financial records in such a way that they collect all relevant
data required to prove activity took place and that it was eligible activity. These records
must have supporting information to show when and how the information was gathered
and should link to other documents such as registration forms. Original source
documentation and working papers must support all final claims or final reports.
The project should also maintain and regularly update a project risk register.
A common-sense approach that tries to keep structures as simple as possible is usually
the most productive. A good idea is to have separate files and cost centres that keep
together all areas of project activity enabling easy access to expenditure details without
mixing up budgets, invoices etc. from different parts of the organisation or from different
projects an organisation may be running. This is particularly important where an
organisation has more than one project which receives European Union (EU) funds, as
these must be kept entirely separate.
Ref: nwda.co.uk/extranet – 2009 Output Definitions SP & ERDF.doc.
7.3 European Programmes Executive Monitoring Requirements
Your NWDA CM will be an organisations point of contact at the NWDA. Your CM will
monitor projects through the processing of quarterly claims and through project visits,
discussing any issues that arise from these with those delivering the project.
7.4 Article 13 - Project Engagement Visit (PEV)
The key purpose of a PEV visit is preventative; it should identify any problems, make
suggestions for improvement in order to prevent reoccurrence and improve delivery. Your
NWDA CM will conduct a Project Engagement Visit (PEV) ideally within the first three
months of a project to ensure familiarity with the procedures for managing an ERDF
grant. This visit is to give your CM the opportunity to get to know those delivering the
project and make an assessment of the project’s possible monitoring needs. This is the
key opportunity to ensure that those who are responsible for delivering the project
understand the terms of the Offer Letter and the results that are expected from them. It is
also the point at which NWDA can ensure that the project appreciates the full extent of
ERDF financial controls and other key aspects of project management in line with NWDA
requirements.
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This is a good time for those delivering the project to ask any questions and raise any
issues as dealing with issues at this point could prevent them becoming bigger problems
later on.
7.5 Article 13 Visits - Progress And Verification Visit (PAV)
A member of the NWDA Quality Assurance Team will conduct one or more in-depth
Article 13 monitoring visit(s) during the lifetime of the project. An Article 13 Visit (of
Commission Regulation (EC) No 1828/2006) will verify the
project’s declared
expenditure, that the project’s products or services have been delivered in accordance
with the Offer Letter, that claims are correct and that the project’s operations and
expenditure comply with European Commission (EC) and national rules. An Article 13
monitoring visit is not an audit or inspection check. During the visit claimed expenditure
and outputs will be verified to source documentation. Inspection will also verify
compliance with other requirements for example publicity and public procurement.
Irregularities found during an Article 13 visits may not result in the funds being deducted
from the ERDF grant but this dependant upon the severity of the irregularity.
Projects may be subject to various other audits including:
7.6 Article 16 Visit
The Department for Communities and Local Government (CLG) is required to audit at
least 5% of Programme-level expenditure each year. Every year a number of projects will
be selected for an in-depth Article 16 inspection. Article 16 (of Commission Regulation
(EC) No 1828/2006) refers to the audit of a sample of projects.
Article 16 audits are undertaken on a sample basis on a risk based assessment and will
be conducted by Internal Audit Service (IAS) from CLG. This audit can last for several
days.
It is likely that there will be some level of duplication between Article 13 and 16 visits but
Article 16 visits will take into consideration any Article 13 visits that have taken place
when determining the scope of the visit and vice versa. It is important to note that
irregularities found during an Article 16 visit will result in funds being recovered directly
from the ERDF grant as no opportunity will be given to rectify the matter.
7.7 Other Visits
There is also the possibility that the project will be audited by the European Commission
or the European Court of Auditors, both of whom pick a sample of projects for scrutiny.
This will cover all aspects of the project. The project will also have internal and or external
auditors of its own.
As part of the Funding Agreement, the majority of projects will be expected to complete
an annual audit and a final audit gaining and audit certificate before the final claim can be
paid
A statement of grant expenditure is required for Local Authority and Health Authority
projects receiving £100,000 or more over the project lifetime. An Independent Consultants
report is required for projects receiving more than £50.000 in the projects lifetime.
ERDF Monitoring Guidance
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7.8 Essential Criteria to Monitoring Visits
It is essential that key members of staff involved in the project are available during
any Article 13 PEV and PAV visits and the 16 Monitoring Visit or any other audits
carried out on the project. These should be the project manager; person(s) responsible
for general record keeping of the project; person(s) responsible for the activity of the
project; person(s) responsible for the financial record-keeping of the project.
If the project has delivery partners, it will be the recipient of the offer letter as the lead
applicant, who is responsible for having documentation relevant to the delivery partners
available, should it be required for monitoring or inspection purposes. It is essential that
management control systems provide a sufficient audit trail.
Ref: www.mcisproject.co.uk/documents.php - Communities & Local Government ERDF User
Manual, Chapter 4: Monitoring Assurance Framework.
Ref: www.erdfnw.co.uk - Guide to Applying for Funding & Running an ERDF Project
7.9 Irregularities
The EC definition of an irregularity as given in EC Regulation 1083/20061 is “any
infringement of a provision of Community Law resulting from an act or omission by an
economic operator, which has, or would have, the effect of prejudicing the general budget
of the Communities by charging an unjustified item of expenditure to the general budget”.
Action will be taken to follow up and correct any irregularity in a timely manner and steps
will be taken to ensure the irregularity is not repeated. If an irregularity is identified funds
will be recovered and deducted from the Total ERDF Grant Allocation.
Ref: www.mcisproject.co.uk/documents.php - Communities & Local Government ERDF User
Manual, Chapter 5: Irregularities.
7.10 Material changes
From time to time the project may need to alter or adapt based on issues arising during
monitoring, or due to changing circumstances. The project may need to vire money from
one expenditure category to another or reprofile its output indicators, or there may be a
change to the projects match funding profile. Some changes may be small. Others,
however, might be classed as ‘material.’
Where any change to a project is required it is essential that those delivering the project
inform your CM and get their approval before implementing the change. This is
because the Offer Letter is a contract between those delivering the project and the
NWDA, and any changes to that contract must be notified and agreed in writing. As long
as the changes are reasonable, the project is still delivering eligible activity and it still
represents value for money, obtaining approval for changes should not usually a problem.
However, if the project goes ahead and make a change without getting prior agreement,
the project risks losing the ERDF grant for the entire project.
If the project implements any changes that have not been agreed by NWDA, it might also
be committing a financial irregularity that has to be notified to the European Commission.
There is no guarantee that a “retrospective” change will be agreed, and this could result in
the project losing some, or even its entire, ERDF grant.
ERDF Monitoring Guidance
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Examples of material changes include:
o
o
o
o
o
o
o
o
o
o
o
o
o
o
Change of project ownership, control or final beneficiaries
Change to the nature or purpose of the project
Change of expenditure category
Virement of more than 10% of category cost between individual categories of
expenditure
Virement of any costs between capital and revenue costs
Change in the agreed expenditure for fees, management, administration or
purchase of land
Any change in the agreed annual expenditure profile for the project
Project as a whole, involving a reduction of more than 10% of the forecast
expenditure in any year
Any change involving a reduction in the amount or proportion of public sector
funding for the project
Any change in the agreed annual profile for the quantifiable targets involving a
reduction of more than 10% in the agreed targets for any year
Virement of more than 10% of project financing between funding sources (not
including ERDF grant as this may not be vired)
Change of more than 20% to quantifiable targets
Any change to the expected physical or financial completion dates
If irregularities or fraud are detected or suspected
Please note that this list is not exhaustive, if unsure always check with the NWDA first.
7.11 N+2
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 Operational Plan’s financial table must
be spent within two years of the year for which they were allocated.
Therefore, 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. The project may not be able to
roll forward spend from year to year within the project lifetime. Delays in project spend
could mean that NWDA misses its annual N+2 spend target set by the European
Commission, leading to funds being taken away from the Programme by the Commission.
For example, if a project is worth £300,000 and has profiled to spend £150,000 in year
one and it only spends £100,000, the project may lose the £50,000 it failed to spend,
rather than being allowed to carry it over into year two.
It is important that the project notifies your NWDA CM of any potential changes to its
funding profile at the earliest opportunity. The project will need to be able to make a
strong case for rolling forward any funds.
Ref: www.erdfnw.co.uk - Guide to Applying for Funding & Running an ERDF Project.
7.12 Start and End Dates
There are a number of different dates to consider.
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Key Milestones and Payment Dates/Intervals
Milestones
ERDF
Format: Date/Month/Year – DD/MM/YYYY
NB: If no precise
date inserted default
of month end will be
used
Start Date
Project Activities Completion Date (the date when the Grant
Single
Programme
If dates same as
ERDF leave blank
DD/MM/YYYY
Recipient finishes input into Project Activities)
Financial Completion Date – Last date for the Grant Recipient
to submit its Final Grant Claim to the Agency (usually 3 months
after completion of Activity End Date)
Final Payment Date – The last date that the Agency will make
a payment to the Grant Recipient (i.e. after the Audit report and
usually 3 months after the Financial End Date above)
Practical Completion of the Targets (Results) This is the final
evaluation of the Project to ascertain GVA etc and when MCIS is
closed.
Key milestones – list here the rigid milestones that are critical to
happen by key dates; other milestones are referred to by reference
to the M&E plan
7.13 Common Mistakes
There are a number of mistakes projects make, which can result in grant being
withdrawn. Please see Annex 8.
8. Supplementary
8.1 Who’s who
The Northwest Development Agency (NWDA) is the Intermediate Body for the 200720013 Programme. The NWDA Quality Assurance department will be responsible for
carrying out the Progress and Verification Visit (PAV – Article 13).
The Contract Manager (CM) is your main contact at the NWDA.
The Department for Communities and Local Government (CLG) are the Certifying
Authority for the 2007-20013 Programme and will be responsible for carrying out the
Article 16 Monitoring Visits.
8.2 References:
Guide to Applying for Funding & Running an ERDF Project - www.erdfnw.co.uk
(Click on News, Events & Resources – ERDF Branding, Publicity and Guidance)
ERDF Branding & Publicity Requirements – NWDA Marketing Department www.nwda.co.uk
Latest NWDA application forms and supporting guidance – www.nwda.co.uk/extranet
ERDF Monitoring Guidance
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(User name: Single, Password: Prog)
For NWDA staff, please refer to the toolkit on the intranet.
For Euro Exchange Rates please go to:
http://ec.europa.eu/budget/inforeuro/index.cfm?fuseaction=currency_historique&c
urrency=72&Language=en
For EU Procurement Thresholds please go to:
www.ogc.gov.uk/procurement_policy_and_application_of_eu_rules_eu_procurement_th
resholds_.asp
ERDF Monitoring Guidance
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9. Annexes
Annex 1 - Example of an ERDF Time Sheet
Period Covered: From
Name:
Date
Project Number
Project Name
To
Describe Activity
Time spent onNon- eligible Total Time
ERDF activity ERDF time
Per Day
(hh:mm)
(hh:mm)
(hh:mm)
Staff Declaration: I declare that the details provided are a true and accurate record
Signed:
Print name:
Date:
Position:
Supervisory Conformation: I declare the above record is true to the best of my knowledge
Signed:
Print name:
Date:
Position:
(See section 3.4)
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Annex 2 – Depreciation Methodologies
Straight line method of depreciation
The straight line method of depreciation is calculated by dividing the cost of the asset
(minus any residual value) by the length of time over which it will depreciate. For straightline depreciation, it is normally expected that the minimum number of years over which an
item can be depreciated is three years. This method of depreciation results in a fixed rate
of depreciation which is the same amount in the first year as it is in the last.
The formula is:
Original cost – residual value
Length of depreciation
x
use
Example
o The ERDF project uses a computer that was bought a year ago for £5,000
o It is being depreciated over three years and at the end of that time it is expected to
have a residual value of £500
o The project uses the computer for two days a week over twenty six weeks. NB:
Three years is 156 weeks
The straight line depreciation calculation is:
£5,000 - £500
156 wks
28.85
x
2/5 (2 days out of 5) x 26 wks use
x
0.4 x 26
= £300 per annum chargeable to the ERDF project.
Reducing balance method of depreciation
The reducing-balance method of depreciation is calculated by applying a fixed percentage
to the written down value of the asset. In the year in which the asset is purchased the
percentage is applied to the original cost. In successive periods the percentage is applied
to the assets written down value. This method of depreciation results in a different rate of
depreciation for each year.
(See section 3.6)
ERDF Monitoring Guidance
Updated August 2011
32
Annex 3 – Example of an ERDF Asset Register
Project Number:
Project Name:
Date
Purchased
Description
of Asset
Serial / ID
Number
Location
of Asset
(Operating
Partner)
Location of
Title Deeds
Amount of
NWDA Grant
Paid
Total
Cost
VAT
Recoverable
(y/n)
Date of
Disposal
Sale
Proceeds
(Net of
VAT)
Depreciation
Comments
Declaration: I declare that the details provided are a true and accurate record
Signed:
Date:
Print name:
Position:
NB. Best set up as a Excel Spreadsheet
(See section3.9)
ERDF Monitoring Guidance
Updated August 2011
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Annex 4.1
Date
SME Name and Address:
Dear
Name of Project:
Value of General Block Exemption Support
This letter is provided to confirm the value of the support recently provided to your company by
the [
] project, under the activity description shown below.
This assistance was provided under Article [___] of the General block exemption Reg 800/2008
OJL 214/3 of 9.8.2008
This is not an invoice for your contribution, but is intended only as confirmation that firstly you
have received the support shown and secondly that your records could evidence that you have
paid your contribution, particularly if payment was made to a third party. If you happen to be
visited by auditors or monitoring officers verifying activity on your project you would be expected
to have this information recorded and available.
Description of
the support
you received
Date of
support
Provider
Total Value
Your contribution
(e.g. at least 50% of
the total value if
using Art 26 and 27
reg 800/2008)
I confirm that the above information is correct and have taken a copy of this form for our records.
Name:
Signature:
Position:
Date:
Yours sincerely
Project Manager
(See section 3.12)
ERDF Monitoring Guidance
Updated August 2011
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Annex 4.2
Date
SME Name and Address:
Dear
Name of Project:
Value of SME De- minimis Support under Regulation 1998/2006 OJL 379 of 28.12.2006
This letter is provided to confirm the value of the support recently provided to your company by
the [
] project, under the activity description shown below.
This project is funded under the de-minimis aid scheme. Therefore the value of support that you
have received from this project (shown below) will count towards your de-minimis ceiling (EU
200k per undertaking (individual companies, businesses or groups) in any 3 consecutive tax years
including the one in currency) and you will need to keep a records of this information. You will also
be required to declare this support if you receive any further de-minimis support within the next 3
tax year period.
Our records show the following, please confirm that you could evidence that you have received
the support shown. If you happen to be visited by auditors or monitoring officers verifying activity
on our project you would be expected to have this information recorded and available.
Description of the
support you received
(you only need to
declare aid provided
specifically as de
minimis in the past)
Date of
support
Provider
Total Value (£)
I confirm that the above information is correct and have taken a copy of this form for our records.
Name:
Signature:
Position:
Date:
Yours sincerely
Project Manager
(See section3.12)
ERDF Monitoring Guidance
Updated August 2011
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Annex 4.3 - SME Registration Form
As part of the management and monitoring of your project, information should be collected from
the SMEs benefiting from the project activity. The information provided is intended for use by
Northwest Regional Development Agency and will be shared with auditors as required.
This form is for the assisted SME to complete and return to the project manager. As a public
body, Northwest Regional Development Agency is subject to the provision of Freedom of
Information Act 2000 and any information that you provide to the Agency is potentially subject to a
Freedom of Information request.
Name of SME:
Main Contact:
Are you:
Address:
Male
Position:
□
Female
□
Postcode:
Telephone Number:
Email:
Date trading started:
How would you best describe the activities of the company?
How many people does the company employ?
Micro
- less than 10 employees
Small
- less than 50 employees
□
□
□
Medium - less than 250 employees
It is a requirement that you meet either the annual turnover or balance sheet requirements
for one of the most recent two years preceding the date of the grant award.
What is the Annual Turnover for the SME?
Micro
- less than or equal to EUR 2 million ()
Small
- less than or equal to EUR 10 million ()
Medium
- less than or equal to EUR 50 million ()
□
□
□
What is the Annual balance sheet total?
Micro
- less than or equal to EUR 2 million ()
Small
- less than or equal to EUR 10 million ()
Medium
- less than or equal to EUR 43 million ()
ERDF Monitoring Guidance
Updated August 2011
□
□
□
36
Annex 4.3 - SME Registration Form Continued
Does any other organisation own more than one quarter of your company?
□
No
If yes please provide details:
□
Yes
It is a requirement that the SME declares any de-minimis support received in any three tax year
rolling period. Have you received any de minimis support in the last three years?
□
No
If yes please provide details:
Name of Provider
Yes
Date of
payment
□
Brief reason for payment
Amount
(£)
I understand that my business (or any group it is a member of) may only receive de-minimis
subsidised support to the value of 200,000 euros under the de-minimis block exemption, from any
public agency within a three year rolling period.
The three year cumulation works like this. For a grant award to the beneficiary dated 31.12.2008
you would need to cumulate only aid granted expressly as de minimis from 06.04.2006, as that is
the tax year, including the one in which the grant is given, which is 3 years past.
Please supply evidence of your company’s:
□
□
Equal opportunity and diversity policy
Environmental sustainability policy
Does the project take account the need to imbed spatial cohesion
□
Declaration:
I understand that this project is supported by ERDF and declare that the details given on this form
are true to the best of my knowledge:
Signed:
Position within company:
Date:
(See section 3.12)
ERDF Monitoring Guidance
Updated August 2011
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Annex 4.4
ERDF SME Process Checklist
As part of the record keeping for your project you should keep a project file for each beneficiary, it
is expected that this would show initial contact through eligibility to support provided and
evaluation.
This form should be included in the file and used to check the evidence you have to support your
activity.
Name of SME:
Main Contact:
Description
Telephone:
Type of evidence
Person
Responsible
Date
Completed
Do you have evidence of
beneficiary eligibility
Have you given advice on
cross-cutting themes
How have you established
the most suitable type of
assistance
Have you established the
baseline position for jobs
& turnover
Have you recorded results
achieved at:
6 months
12 months
18 months
Has the SME signed
State Aid declaration
Have you sent the
notification of support
received (nature and
value) to SME
Have evaluation forms
been completed
(See section 3.12)
ERDF Monitoring Guidance
Updated August 2011
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Annex 5 – Example of an ERDF De-Minimis Return
DE MINIMIS STATE AID DECLARATION
We declare that we have looked at all our funding agreements and related documents for
the past three years and confirm that:
No state resources were provided to us expressly as de minimis/under Reg 1998/2006
(de minimis) in the past three years
OR
The following amounts were received by us expressly as de minimis in the past three
years:
Payer
Amount
Date
Limit is E 500,000 until 31.12.10 (Translates at £450,000)
Name: ..........................................................................................................
Signed ………………………………………….
Date …………………………….
Position …………………………………………………
If you require any assistance in completing this declaration, please contact Jane
Worthington, NWDA on 01925 402240 or see the De Minimis Guide in
www.nwda.co.uk/extranet username “state” password “aid”.
(See section 5.3.1)
ERDF Monitoring Guidance
Updated August 2011
39
Annex 6 - Carbon Calculator Examples of Evidence
Section/ measure
Evidence
1. Energy
Coal, Diesel, Fuel Oil, Liquid Petroleum
Gas( LPG)
Electricity, Gas, CHP
On site Renewable
Delivery notes & Invoices
Utility Bills
Type of renewable and annual production in
KWH/ rating, evidence of ROC’s (Renewable
Obligation Certificate), visually see the device
2. Waste
All waste
Materials Recovery Facility (MRF),
Composting, Energy from Waste (EfW)
Plant, Anaerobic Digestion, Recycling,
Transfer Station
Waste Transfer Notes ( legally needed for all
waste to be transferred has to be kept)
Infrastructure & Construction – Site Waste
management – legal requirement since April 1
2008 for all projects over £300k. Provides detail
of what waste will be produced and where it will
go.
Copy of contract with the company e.g. recycling
company or Energy from Waste plant.
3. Water
Water Used
Water disposed of
Utility Bill, meter reading, Extraction licence,
Bore Hole meter reading
Water in is often the same as water out,
Discharge Licence
4. Travel
By Fuel USE – Diesel, Gas, LPG
Personnel transport - cars
Public transport
Freight
5.Building projects
SBEM
6.ENWORKS Resource Toolkit
Enworks Toolkit
7 Specific GHG reduction project
Fuel delivery notes to site, fuel invoices, hours
worked by machines against manufactures fuel
consumption rate per hour
Expense claims
Expenses claims, financial transactions, minutes
from meetings of attendance
Tacho Graphs, Invoices from haulage company,
Site Waste Management Plans – distance where
waste will be transferred to for recycling or
disposal, therefore distance travelled can be
demonstrated.
SBEM calculation – required as part of building
regs.
Copy of Toolkit and evidence of support from
ENWORKS e.g. letter
Seek advice from the Environment & Energy
team if none of the above are applicable
(See section 6.1.1)
ERDF Monitoring Guidance
Updated August 2011
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Annex 7. Common Mistakes
Outlined below are some of the common mistakes projects make, and which can result in
grant being withdrawn. Here is what the project should avoid:
o Claiming grant for expenditure which hasn’t actually left your bank account. It must
have been spent, and cleared your account, before you claim it back
o Not realising that you can only claim in arrears, not in advance, and having
problems with cash flow as a result
o Claiming expenditure that happened before your project start date
o Double funding – mixing up two (or more) sources of EU funds
o Failing to keep adequate timesheets. You must be able to demonstrate how staff
have been engaged in delivering your project, particularly if they are part time or
are providing time as match funding
o Accidentally claiming for the same thing twice, or more than 100% of a person’s
time. This can be avoided by keeping accurate timesheets and beneficiary records,
and monitoring your project effectively
o Failing to keep originals of documents and not keeping documents for long
enough. Get these organised in your audit file and keep it for a minimum of three
years after the UK has received its final payment for the programme from the EC,
not when your project has finished
o Losing invoices and receipts
o Not informing NWDA of material changes to the project and having them agreed
before you claim. This could result in grant being withheld or withdrawn
o Not noticing that there have been any material changes to the project, a prime
example of bad project management!
o Claiming for ineligible items or for items that were not in the approved bid
o Claiming for ineligible beneficiaries
o Not undertaking proper monitoring of your project or collecting information often
enough. Make sure that the person monitoring the project has a copy of the Offer
Letter
o Trying to “reconstitute” records and timesheets because systems weren’t in place
soon enough, or because people didn’t follow procedures
o Partners and sub-contractors failing to supply the accountable body with
information. Get the contracts between everyone involved on the project drawn up
before you start and agree how and when it will be collected
ERDF Monitoring Guidance
Updated August 2011
41
Annex 7. Continued
o Not making sure that everyone involved is aware of EU funding requirements and
that they keep adequate records
o Using incorrect methods of apportionment. These should be agreed with your CM
during contract negotiations then applied consistently throughout the life of your
project
o Using notional costs in the place of actual costs
o Providing inadequate publicity and failing to put ERDF logos on materials – you
must follow the Branding Guidelines
o Trying to cut corners and ending up with more work as a result
o Misunderstanding the difference between in kind and cash match funding. Make
sure you do the preparatory work, and get match agreed (and understood) with all
parties prior to the project starting
o Failing to keep records tidy and keeping associated orders, invoices, claims, etc.
together
o Not ensuring that the person responsible for delivering the project is fully briefed
and understands exactly what the project is supposed to deliver. Make sure that
your finance director, communications manager and all staff who may be working
on the project know about the project before you start asking them to get involved
or deliver for you
o Not ensuring there is a clear separation of roles. Those who authorise claims for a
project must be different from those who drew up the claim, (claims should be
checked by one officer and authorised by another)
o Not having senior management buy-in from the start
o Not communicating about your project across your organisation, and involving
everyone who will be part of the project in its design and planning
o Failing to understand output definitions and how they should be evidenced
o Not undertaking adequate research into your beneficiaries and not understanding
your target group and how to access them as a result
ERDF Monitoring Guidance
Updated August 2011
42
Annex 8. Article 13 Progress and Verification Visit Procurement Evidence Checklist
It is a requirement of the Programme that all of the documents relating to procurement
such as evidence of tenders and any letters offering contract along with documents
showing how decisions were made and by whom are retained and are available for
inspection at PAV visit.
Please be aware that the principles of transparency, openness, fairness, equal treatment,
proportionality must be adhered to at all times; this applies also to all procurement below
the EU threshold (Commission interpretative Communication re contract awards not or not
fully subject to the provisions of the Public Procurement Directive (2006/C179/02))
While this is not an exhaustive list, please use the checklist below to ensure you
have all appropriate documentation ready at the time of the PAV visit (tick
appropriate box(s) indicating your evidence). It is advised you have separate
tender / procurement files for each of the procurements made:
For purchases up to £2,500 (verbal quote acceptable)
A record of who quoted
Dates of the quotes
Value for money consideration
For purchases between £2,500 and £10,000
A record of who was invited to quote
A copy of the quotes
Letter to applicant who was successful
Letters to applicants who was unsuccessful
Followed principles of proportionality and
transparency
For purchases between £10,000 and £156,442
Route of procurement to decide following the
EU principles for procurement
Tender brief
List of tender applicants/quotes
Advertising already from £10,000 onwards
required; low values advertisement on website
sufficient
Tender proposals
Proof of all tenders arrived within deadline
Scoring matrix’s (signed & dated by scoring panel)
Details of any presentations
Proof of standstill period
Letter to applicant who was successful
Letters to applicants who was unsuccessful
ERDF Monitoring Guidance
Updated August 2011
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Annex 8. Continued
For any procurement above the Current EU Procurement thresholds, currently:
Supplies - £156,442 (€193,000)
Services - £156,442 (€193,000)
Works - £3,927,260 (€4,845,000)
Tender brief
OJEU Notice Pre Qualification Questionnaires (PQQ)
Selection process 1 – invitation to tender
Tender proposals
Selection process 2 - Scoring matrix’s (signed &
dated by scoring panel)
Details of any presentations
Letter to applicant who was successful
Letters to applicants who was unsuccessful
Standstill period
It is the applicant’s responsibility to ensure Public Procurement rules are followed
and to provide the appropriate evidence at audit. If in doubt, please seek legal
advice.
For further procurement guidance please see:
European & UK Procurement Regulations http://www.ojec.com/Directives.aspx
Office of Government Commerce
http://www.ogc.gov.uk/contactus.asp
Please do not use single ‘Tender Actions’. There are only very limited occasions
where they are permitted.
ERDF Monitoring Guidance
Updated August 2011
44
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