Thursday, 29 March 2018

#H2020: Simplification is complicated!

So says a briefing paper written by the European Court of Auditors (ECA). And since they audit the European Commission (EC), they must be right.

The briefing paper was requested by the European Parliament and the Council of Ministers as an input to discussions on FP9, the successor to H2020. As usual, the ECA advocates wider use of “lump sums”: a fixed amount of money given if the proposed work is carried out satisfactorily, as well as unit costs (fixed numbers with limited relationship to actual costs, as used in the Marie Sklodowska-Curie programme) and flat rates, such as the current 25% of direct costs provided as a substitute for overheads. Not surprisingly, all of these produce lower error rates in audits than using actual costs, though they often generate funding for beneficiaries which is lower than actual costs.

But one of the ECA’s observations points in the opposite direction: reducing the rigid interpretations auditors place on the existing legal rules. They point out that auditors sometimes use examples given in the 750 page advisory document “Annotated Model Grant Agreement” as the only acceptable interpretations of the legal rules in the grant agreement and legislation. The ECA says that such examples should not limit the room for different interpretations. Now all they have to do is convince the EC’s auditors!

Kind regards Singleimage Limited

Wednesday, 28 February 2018

#H2020 Travel time: eligible or not eligible?

A common question especially from those new to H2020 funding is whether the time spent beyond normal working hours travelling to meetings is an eligible cost. The answer is surprisingly complicated, as shown in the flow chart below.

The simplest case is if the researcher is not filling time records but instead uses the exclusive declaration. No time recording of the extra hours is required, but if extra payments are made for the additional hours, these are eligible costs.  

Next simplest are those working for an organisation with a flexible working policy. The extra hours spent travelling will later be balanced by an equal number of hours of additional holiday. The cost of travel time is eligible for H2020 funding.

If travel time cannot be balanced by additional holiday, then another possibility is that the organisation pays overtime. If it does not pay overtime, then the organisation is not incurring any cost for the extra hours, so there are no costs to claim.

If the organisation does pay overtime, then the costs are eligible, though calculating them depends on their method for calculating productive hours. Those using option 1 (1720 hours per year) or 3 (standard) will increase the cost of the person but not their productive hours, according to the EC. So the hourly cost will increase as well as the hours worked, with the result that eligible costs are greater than real costs. The eligible costs will only be capped if the overtime exceeds the time spent working on non-H2020 activities.

Option 2 – individual productive hours –is less complicated: the hourly rate adjusts for both overtime hours and overtime payments, so the real overtime cost will be eligible.

None of the paid overtime scenarios described above takes account of reimbursement based on last completed financial year. But that’s another story!

Kind regards

Wednesday, 24 January 2018

Brexit December agreement

The agreement reached between the EU and the UK in December includes provisions to support UK participation in H2020 until the end of the programme and completion of all projects.

To achieve this, the UK will contribute to the EU annual budgets for the years 2019 and 2020 as if it had remained in the EU. It will also contribute its share of the financing of the budgetary commitments outstanding at 31 December 2020. The UK also agreed that the UK and UK beneficiaries will respect all relevant EU legal provisions relating to participation in H2020.

So eligibility to apply to participate in EU programmes and EU funding for UK participants and projects will be unaffected by the UK’s withdrawal from the Union for the entire lifetime of such projects.

Singleimage - H2020 Training Workshops and Advice 

Friday, 1 December 2017

#H2020: How exclusive is exclusive?

The exclusive declaration was introduced in H2020 as an alternative for the often unpopular timesheet. One declaration would cover a 12 or 24 month reporting period, with no detail of hours actually worked on an H2020 project, so simplifying the researcher’s life.

But auditors are now checking whether researchers are really exclusively devoted to their H2020 project, which gave rise to a number of questions at a recent event held by the EC’s audit and legal staff. The results are:

·         auditors will check the internet including the beneficiary’s web site plus the researcher’s CV for evidence of non-exclusivity. They may also find evidence by interviewing the researcher to discuss their contribution to the project compared with the periodic report and – accidentally – while checking other expense items such as travel.
·         If the researcher spent a few hours assisting a colleague with, say, a new research proposal, that would be ignored, as would a few working hours spent carousing at a Christmas party.
·         But assisting a colleague with a new research proposal for two weeks or more would break the exclusivity, condemning the researcher to filling timesheets for the remainder of the reporting period. This would apply even if the time spent was actually outside the normal working hours of the researcher.
·         And attending training courses (unless this was explicitly anticipated in the project proposal) would be ineligible for funding, so attending one would break the period of exclusivity. But not providing such training possibly breaches article 32 of the grant agreement on career development of researchers.

Simplification comes at a cost!


Monday, 30 October 2017

Personnel costs eligible despite unreliable timesheets

The EC has agreed to a recommendation from the European Ombudsman to accept personnel costs despite the absence of reliable time records for an FP7 project. External auditors pronounced that the Belgian organisation’s time recording system was entirely unreliable. Despite this, in the case of one deliverable, the alternative evidence of the drafting and multiple redrafts and occasional emails was judged by the auditors sufficient to justify the personnel time claimed. For a second deliverable, the description of dissemination activities carried out by the organisation was considered sufficient by the auditors to justify the hours claimed. The costs of a further six deliverables were considered inadequately justified.

The EC decided to disallow all personnel costs. The Ombudsman considered this disproportionate, suggesting that the EC should reimburse the costs related to the two deliverables where the alternative evidence for the number of hours had been accepted by the auditors. On 6th October, the Ombudsman reported that the EC has accepted this recommendation.

Singleimage - H2020 Training Workshops and Advice

Monday, 2 October 2017

H2020: the Brexit story so far

From the time of the UK referendum until now, the UK government has made five announcements which are important to all involved in Horizon 2020.

12 August 2016
In August 2016, the UK government announced that UK participation in H2020 will continue to be funded after the UK leaves the EU, for proposals selected for funding up to that time. The UK Finance Ministry – the Treasury – said that it would underwrite the payment of such grants. This includes funding for projects scheduled to continue after the UK’s departure from the EU. So this means that UK participants will be funded for all proposals submitted before 29th March 2019 which are selected for funding. Some of the projects funded on this basis are likely to begin as late as the start of 2020 and continue to 2024.

Whether the payments to UK organisations will be made by the EU or UK government remains to be negotiated. But – contrary to the views of some commentators – this will have no effect on UK organisations who are coordinating projects. The model grant agreement has for some years included terms to address the case of coordinators (and beneficiaries) who are not receiving EU funding. These terms were used by Swiss coordinators who were excluded from H2020 funding from 2014 to 2016 except in the “Excellent Science” part of the programme.
17 January 2017
In January 2017, the UK Prime Minister presented her objectives concerning the EU. As usual, the main topics were immigration and access to the single market. But her speech also addressed science and innovation, as one of her twelve objectives. The key paragraph says “We will also welcome agreement to continue to collaborate with our European partners on major science, research and technology initiatives”. An earlier paragraph suggested that the UK would be willing to contribute to the EU budget of some specific European programmes. Together these statements suggest a willingness for the UK to continue to participate in H2020 and its successors after the country’s departure from the EU.

18 July 2017
In July 2017, the UK government’s minister for Universities and Science added detail to the funding guarantee given in August 2016. First, he confirmed that the guarantee of funding covered the years after Brexit for projects funded as a result of proposals submitted before that event. Then he added that the underwriting will also apply, not only to schemes directly administered by the Commission, but also to others that award Horizon 2020 funding. This would include, for example, awards made by Joint Technology Initiatives, Public-public Partnerships, COFUND projects and FET Flagships. It would also include schemes where the application has two stages as long as the first stage application is submitted before the UK leaves the EU.

6 September 2017
In September 2017, the UK government published a document on “Collaboration on science and innovation”, one of 14 papers it has produced to support the Brexit negotiation between the EU and the UK. The paper includes examples of successful research collaboration between the UK and other EU Member States, and of the common problems we all share which would benefit from further research collaboration.
Like the other papers in the series, the one on science lacks concrete detail. But it does state clearly that the UK would like to negotiate continuing participation in the EU’s Research and Innovation Framework Programme, of which H2020 is the current version, after its departure from the EU. The same applies to EU programmes for space, nuclear and defence R&D.
22 September 2017
Also in September, the UK Prime Minister suggested in a speech that, after the UK formally leaves the EU on 29th March 2019, there should be a two year transition period, during which existing EU rules would apply in the UK. This means that existing trade and immigration rules would remain largely unchanged in this period. The Prime Minister also said the UK would honour the financial commitments it made during the period of its membership of the EU. No number was placed on this commitment, but popular rumour is that it would amount to €20 billion over two years. This is similar to two times the UK’s average annual contribution to the EU budget in recent years, minus the amounts UK government receives from the EU for agriculture and regional development.
The Prime Minister also suggested that the UK would like to continue “to take part in those specific policies and programmes which are greatly to the UK and the EU’s joint advantage, such as those that promote science, education and culture – and those that promote our mutual security”, and contribute to the cost of these EU programmes.
UK organisations are guaranteed funding for successful proposals submitted to H2020 before the UK leaves the EU. If a transition period is agreed, the guarantee will run to the end of H2020. And if the UK government and the EU can overcome their differences, UK participation in the successor to H2020 is possible.
Kind regards


Tuesday, 5 September 2017

H2020: 91 amendment types

The EC’s “Amendment Guide for FP7 Grant Agreements” listed 16 possible cases. The equivalent document for H2020 lists 91. What happened to simplification?

The answer is automation. In FP7, amending grant agreements was a manual process in which paper documents were submitted to the EC, possibly after a discussion with the EC’s Project Officer (PO). The PO went off to check the rules, asked the consortium for more information and so the weeks went by. Now, for a specific project, the Participant Portal provides a menu of about 30 possible amendments, including a number which don’t need an amendment, just an updating of data in the Beneficiary Register. When you choose the amendment needed, the Portal explains what supporting documents are required. It also supports the drafting of the letter requesting the amendment.

But, as in FP7, there remains confusion in the case of a change in the work described in Annex 1 to the grant agreement. When is an amendment needed? Only if the change is significant. What is significant? Even the IT gurus could not pin down the answer to this question. You still have to ask your PO.
Kind regards, Singleimage Limited