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Implementation

1. The epidemic threat – assistance for Project Beneficiaries

2. Shall we sign addendum if we change assumptions for methodologies of staff costs (e.g. type of contract) or travel costs (e.g. their quantity)?

No. At the stage of contracting each Beneficiary was obliged to present appropriate methodologies for the lump sums. Such calculated values became maximum limits and fixed values for costs of staff and travels. These amounts will be considered as eligible and paid to the Beneficiary if the final report is submitted in a timely manner (not later than 3 months after project completion). There is no need to update information about e.g. type of contract, its duration, length of travels of their numbers.

3. Can I use exchange rate applicable for the specific procurement while preparing financial report?

No. Any conversion into euro of the real costs borne in national currencies shall be done at
the rate published on the InforEuro for the month during which the payment was done (§ 16 of the Grant Contract).

4. Is there any template for quarterly report concerning promotional and communicational issues?

No. Each beneficiary is obliged to submit to the JTS pictures and written information about the progress of the Project (§ 20 of the Grant Contract) in the form suitable for the Beneficiary. Information shall be sent quarterly starting from the project’s implementation date to info-promo team at the email agnieszka.cwikla@pbu2020.eu and monika.kozlowska@pbu2020.eu . Nice pictures are always most welcome.
However, if Beneficiary has any interesting information about the project, event, meeting, shall feel free to inform JTS beforehand.

5. Given the current situation in relation to COVID-19, will the micro-projects be automatically extended beyond the implementation period specified in the grant contract?

No, extension of the project implementation period will not take place automatically, but only at the Beneficiary's written request and in the form of an addendum (chapter 10.1.3 of the Program Manual for the 2nd Call for Proposals). At the same time, we suggest that the Beneficiaries review their project activities. Hints and/or suggestions can be found  in the supplement to the Programme Manual. In some cases the best solution would be to delay the start of the project rather than extend it. This would also require signing the addendum. Furthermore, we remind you that all project activities financed under the Programme should be completed by 31st December, 2022 at the latest.

6. Does the auditor have to initial himself on a short narrative report, i.e. a brief report?

No, the auditor verifies the Final Report of the project. He does not accept, nor initial the brief report.

7. As a Lead Beneficiary of the project, do I have to inform the JTS about the advance payment transferred to Partners in the project?

Yes, please remember that according to the provisions of chapter 9.1 of the Programme Manual, the Lead Beneficiary is obliged to inform the JTS about each payment sent to Beneficiaries within 7 days of this payment.

8. We would like to postpone implementation of our micro-project. Although we haven’t started any activity, we have already received a pre-financing payment. Shall we pay it back to the Managing Authority?

No, it is not necessary. Grant Contract enters into force on the date when the last of the two Parties signs. Implementation of the Project begins according to the date indicated in point 2 of § 4.

9. If we postpone implementation of our micro-project and indicate new starting date in point 2 of § 4 of the Grant Contract, can we show in the financial report - as eligible - the costs of bank fees incurred up to the new day of project implementation?  We have in the project budget costs connected with bank account fees.

According to the Programme Manual for the 2nd Call for Proposals, part 6.2.1., costs eligible must be i.a. incurred during the implementation period of the project. So, if you change starting date of project implementation, costs of bank fees incurred before the new date set in point 2 of § 4 of GC will not be treated as eligible.

10. Is costs’ division of  90% of EU-financing/10% of co-financing obligatory in case of paying of each invoice?

No, there is no such an obligation, although majority of beneficiaries prefers to divide costs in such a way for accounting purposes. Nevertheless, some invoices can be paid only from the EU funds, some - only using co-financing, some - with two sources. The final amounts will be settled in the financial report – then this division (set in Grant Contract) will be respected. In point 8.2.2 of Programme Manual for the 2nd Call for Proposals you can find obligatory elements of invoice description – among nine requirements, there is an information about “Amount of total eligible expenditure in national currency” without necessity of describing sources’ division.

11. Does the Programme foresee any additional simplifications in terms of public procurement and situation with COVID-19?

Yes, appropriate information in this respect are published on the Programme website regularly in NEWS section.

12. According to the § 4 point 2 of the Grant Contract, implementation of our micro-project shall begin on "the first day of the month following the date on which the first instalment of pre-financing is paid by the MA". Due to the current epidemic situation we are not able to implement soft activities like festival and workshops. We would like to postpone starting date of our project till March 2021. Do we have to sign addendum?

No, your Grant Contract is valid and implementation of your project starts after pre-finanincg payment as it is directly indicated. As long as you do not sent your request for payment and receive money on your bank account, you do not start your project. It is Beneficiaries' responsibility when to start micro-project’s implementation. However, please be remembered that all project activities financed by the Programme shall end on 31 December 2022 at the latest.

13. We are preparing our brief report. Where can I find any guidelines how to fill in the document?

Instruction on how to fill in the reports you can find on our Programme website in materials from trainings dedicated to their implementation https://www.pbu2020.eu/en/pages/399.

14. Our Polish organisation does not have specific internal regulations for low-amount orders and procurements. Do we have to prepare such a document?

EU financing is public money and therefore each Beneficiary shall spend it in a most transparent way. It is a good practice to have internal regulation which in a clear way (also for audit purposes) explains basic procurement rules and steps of awarding the contract even of low value. However, when internal rules do not exist, beneficiary is obliged to abide general  rules on awarding procurement described in the Programme Manual, chapter 6.5.1 Basic rules. Preparing and  awarding a contract within the project should be carried out in a manner that guarantees compliance with the principle of transparency, fair competition and equal treatment of (potential)/contractorsor as well as lack of conflict of interest. In addition it is required that the principle of sound financial management is complied with. 
Please remember, that the beneficiary must each time be in position to prove that the procurement was carried out and contract awarded in line with the above mentioned rules. The auditor will examine each award against these rules and ask for explanations/confirmations from the beneficiary. Should not satisfactory explanations exist, the expenditure may be regarded ineligible. 
Therefore, the Programme bodies strongly recommend to maintain for audit purposes proofs that the award was granted and procurement carried out in line with general rules, e.g. e-mails asking for offers, internal notes, notes on selection of contractor, etc. 
It is also important to underline that -  for contracts around the value of 50 000 PLN - the beneficiary shall be able to prove that he/she carrried out assessment of the value of the procurement. 

15. We had to change our workshops into on-line events. Can we count participants of such on-line actions like participants of usual workshops?

Yes, as far as output indicators are concerned, you can count participants of workshops, trainings, conferences, or webinars as participants of traditional events. Nevertheless, if you have any doubts, please contact your Project Manager.

16. In case of signing the Addendum to the Grant Contract by the LB, are the Beneficiaries obliged to sign a new Partnership Agreement?

Formally speaking, it would be reasonable to sign an addendum to the PA as well. In any case, the LB shall make sure that they possess a document (correspondence, note) that confirm the other Beneficiaries have approved the changes in the contract and are aware of them.

17. I have just signed Addendum to the Grant Contract and extended implementation period of my micro-project by 10 months. Do I have to send another brief report to the JTS?
 
Although only one brief report describing half of the project implementation was previously assumed, the reality forced us not only to extend the implementation of many micro-projects but also to update the data. For monitoring purposes, additional information and a brief report will be required as follows:

  • those who have already sent us brief report and extended micro-project implementation period by more than 6 months, are requested to send to the JTS new brief report for new half of project duration,
  • those who have already sent us brief report and extended micro-project by less than 6 months, are requested to send us short information what has changed since the submission of the brief report,
  • those who have not sent us brief report yet and extended project duration, are requested to send to the JTS brief report for new half of project implementation period.

18. Due to the COVID-19 pandemic and necessity of changes in activities, some savings appear in our project. However, costs of renovation and supplies remain unchanged. Do we have to cut the value of expenditure for supplies and infrastructure (investment and infrastructure component) taking into account new value of EU-financing set in the final report?

Not any longer. Recently, the Joint Monitoring Committee allowed beneficiaries of micro-projects to treat as eligible the amount of investment and infrastructure previously foreseen in the Grant Contract. It means that the limitation – 20% of the EU grant – will be counted on the basis of originally awarded EU-financing. However, in order to accept such expenditure as eligible, all other eligibility rules set in Programme Manual and Grant Contract must be fulfilled and expenditures themselves certified by auditors. https://www.pbu2020.eu/en/news/1824

19. Do we need timesheets as supporting documents proving engagement of external expert budgeted under line 4.1 “Salary of technician staff”?

Everything depends on the contract concluded between your institution and the expert. As a rule, when we talk about the contract with external expert, Beneficiaries shall possess:
evidence of the procurement process (announcement, selection, award of the expert) in line with Annexes 5a or 5b, internal regulations, contract laying down the service to be provided, with a clear reference to the project and the Programme, specifying the scope of duties, invoice, service acceptance note, proof of payment.
If such an obligation derives from the contract, timesheets shall be also a part of supporting documentation.
 
However, timesheets are documents proving usually engagement of the project staff employed on the basis of the labour contract and are rather dedicated to the team budgeted under line 1 “Staff costs”. In case of micro-project, this line is settled as a lump sum.
 
Nevertheless, if the expert has labour contract with your institution and is contracted under budget line 4.1 it is expected, that among supporting documents can be found:
document setting out the percentage of time to be worked on the project per month (if not specified in the contract), job description providing information on responsibilities related to the project, payslips, payrolls or other documents of equivalent probative value, written order to work in overtime, proof of payment of salaries and the employer’s contribution,
timesheets providing information on the number of hours spent per month on the project if the workload accounts for less than 100% of the actual working time of the individual.

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