FAQ BSB JOP 2014-2020 - Beneficiaries 2nd Call for Proposals
This page contains answers to questions submitted by interested ENI CBC Black Sea Basin Program applicants, beneficiaries and controllers. The questions and answers are organized by topic of interest and are updated on a regular basis, as we collect new questions. To preview the questions, click on the topic of interest.
On the programme website there is a section dedicated to Projects news&events where we published the news shared by the beneficiaries: https://blacksea-cbc.net/projects-newsevents/.
Further, these news are disseminated on social media.
For more information and support, we are inviting you to contact the JTS communication officer, Jesica Papusa, email: email@example.com.
In case you decide to change a meeting from live to virtual you have to provide explanations of this change in the progress report. Addendum or notification is required only in case any of the modifications are of the type for which an Addendum or Notification is required, according to MA Instruction to Beneficiaries no.16.
First you have to analyse what is the best option for your project: to postpone the trainings or to change into online version. Both options are acceptable. Please see also answer to question 1.
The amounts that were not spent can be used in order to increase other budget categories if this can bring an added value to the project. The transfer of amounts within the same budget heading can be done through a Notification. If you want to transfer amounts between 2 different budget headings, you have to submit a request for Addendum.
Minor transfers are referring to amounts transferred between categories under the same budget heading and do not have major impacts on the project results. Please read carefully the provisions of the Instruction no. 16 on Notifications and Addenda.
No limit is established at Programme level for the number of Notifications or Addenda that might be submitted. We still recommend that the necessity of changing the project must be the result of an analysis and consultations between all partners.
Make sure you do not operate any change prior to obtaining the approval of JTS or MA on the Notification or Addendum, as applicable.
The LP should analyse and prioritise the necessities at project level and should take into account the needs of each partner. As we didn’t establish a limit number of notifications throughout the total duration of the project, or during one month, more notifications can be submitted depending on the emergency of implementing the necessary changes.
The PPs can implement modifications prior to the approval of the MA of the addendum on its own risk. All partners must be aware that implementing changes that might not been accepted by the MA can lead to the ineligibility of costs.
For changing the hourly rate and number of hours, a Notification must be sent to the JTS. Please note, that the acceptance of such a proposal is conditioned by respecting the rules of eligibility for staff costs, among which, the new proposed hourly rate must correspond to those normally borne at institution level for similar positions. Also, please analyse if by changing the number of allocated number of hours, this will not affect the quality of the project result.
In this case, reorganising of one project activity has leaded to the necessity of changing the procurement plan. You have to submit a Notification that encloses all changes that are interconnected. The decision of notifying a delay or just to justify it at progress report must be taken by analysing the consequences of a delay. If a delay in achieving one project deliverable is not leading to delays in achieving other deliverables or is not affecting a phase in the project implementation, then you can choose to just report as delayed and to provide justifications in the progress report.
Changing of the name of one staff member can be done without notification/addendum. However, be aware that according to Instruction no.16, modification of the Human resources heading positions in the way of deleting or adding new positions in the project team can be done only through an addendum.
The programme structures are permanently analysing the impact of the COVID-19 pandemic on the projects. Consultations with the NAs and European Commission are taken place as often as required. The MA has already taken measures in supporting the beneficiaries to overcome the COVID 19 challenges (Note – Information for beneficiaries regarding project implementation in the context of coronavirus disease COVID-19 (March 2020); Note for Beneficiaries regarding indicative measures possibly to be taken in order to deal with health-related risks caused by COVID-19 (June 2020).
The decisions at each project level must be taken after consultations between all partners, case by case, and communication with the JTS project officer must be intensified in order to provide the best solution suited for the reality of each project.
The savings can be used only if they will bring an added value to the project and only after approval of the JTS/MA. Please be aware that the already declared ineligible costs cannot be considered savings.
Do not correlate the timing of submitting a Notification or an Addendum with the submission of the progress reports or interim reports. To decide when is the optimal moment in order to submit a Notification or Addendum, you must calculate when the changes must be implemented. Also, even if a modification request can be submitted after submission of the interim report, the system will link the report to the version of the application form approved in the day of the submission of the report. The eligibility of costs enclosed in the interim report will be analysed in relation to the budget of the version valid at the moment of the submission of the report. All modifications requests submitted during analyses of a report (progress or interim) will not be taken into consideration as references for the report.
Extension of the project duration due to COVID 19 will be closely analysed by the MA, on case by case. The beneficiaries have to duly justify and to provide clear information with the reasons for delays and the reasons which impeded the timely rescheduling of activities.
According to article 8.5 of the grant contract, exchange rate losses are Non-eligible costs, so you cannot adjust them.
However, considering that the Beneficiaries have to upload the expenditure in the original currency and the conversion into euro is made automatically by the eMS using the monthly accounting exchange rate of the European Commission of the month during which the expenditures was submitted for verification, the management structures introduced the option for those beneficiaries who anticipate big losses because of the exchange rate to submit several financial reports to the controllers. Instructions on how to use this option is included in the revised version of the Project Implementation Manual – see Annex 5 – Guide on reporting in eMS, section 4.3.2. ‘List of Expenditures (LoE) – Currencies other than euro.
In the Project Implementation Manual, Annex 5 Guide on reporting in the eMS, section 2.7 Procurements it is mentioned that the Contract Amount (in Euro) – “is only indicative and the exchange rate will be the exchange rate of the European Commission, from the month in which the contract is signed“.
Please see instructions provided in the Project Implementation Manual and in Annex 5 – Guide on reporting in eMS.
If you are not allowed to keep in EURO the ENI funds received, you have the option to elaborate more reports before interim/final report as described in the revised Annex 5- Guide on reporting in eMS. This approach will allow the system to use for each report that is submitted, the exchange rate of the month during which the expenditures was submitted for verification.
There is no such reference amount. It is up the beneficiary to decide whether they want to consider the option of submitting several financial reports. (see reply to question 1)
The external experts do not have to complete timesheets. The supporting documents for the services contracts are: documents concerning procurement, contract, invoice, acceptance of the provided services, payment document.
Only staff members, which are working part-time, have to complete timesheets.
Under “Office and administration” budget line.
Travel and accommodation costs of the employed staff are not included in the employment/work contract. Travel and subsistence costs of experts shall be included in the service contracts for these experts and budgeted under the External expertise and services budget line.
You must follow the regular procedures of project’s modification (Addendum or Notification, as applicable) which are described in Project Implementation Manual (see section 8 – Modifying Grant contract).
Contribution in kind as defined in Article 14(1) of the Regulation no. 897/2014 are not eligible costs and may not be considered part of the minimum 8% co-financing by the Lead Beneficiary or the beneficiaries.
Please be aware that the exact contribution and ENI funds are established at the final authorizing process and not by the beneficiaries.
If external educators for training are mentioned (foreseen) in the external expertise budget line, you must conclude service contracts with them following carrying out a public procurement procedure. Otherwise, if they are mentioned on the staff line, you can hire university lecturers to perform this activity through a part-time employment contract.
Please pay attention to the correct framing of the related costs in the project budget (either budget line 1 – Staff costs, or budget line 4 – External expertise and services) and also to the programme rules in terms of notifications and addenda to the grant contract, if the case.
However, please be aware that the Beneficiary is not allowed to conclude a service contract with any of its employee irrespective of the purpose. Contracting services with Beneficiaries’ own staff is considered conflict of interests.
The partners will not attach/upload invoices or any other supporting documents related to indirect costs, in any case (project with or without infrastructure).
Supporting documents for indirect costs will be kept by the partners, in their own accounting system and archives.
According to Annex 2 of the Instruction 15 laying down specific provisions for the expenditure and revenue verification of a grant contract funded under the ENI CBC Black Sea Basin Joint Operational Programme 2014-2020, a contradictory procedure should be possible, if the Beneficiary does not agree with the findings of the controller. In this case, the Controller should designate a different member of its staff, having similar competences, for re-performing the verifications for the expenditure in question and replying to the Beneficiary. If no agreement is reached, art. 13 of the same Annex is applicable.
Yes, these amounts can be reallocated to other budget lines, through notification or addenda, as applicable.
If you intend to use these savings for activities that were not initially foreseen in the project budget, their necessity and contribution to project objectives has to be duly justified and approved by the MA.
You should follow the regular procedures of project’s modification (Addendum or Notification, as applicable) which are described in Project Implementation Manual (see section 8 – Modifying Grant contract).
The original financial documents do not need to be translated in English. They have to be uploaded in eMS in scan version of the original documents and named in English. In case during the verification process of the interim/final report the Managing Authority, will need clarification regarding certain documents, a translation in English of the respective documents or parts of them may be asked.
The invoices are going to be uploaded in eMS. All the supporting documents are uploaded in a scanned version in eMS. The originals are not sent by post, they are kept at the partner premises for the verifications of the programmes’ structures.
According to the Grant Contract, art.11.8, the Lead Beneficiary and the Beneficiaries shall keep all records, accounting and supporting documents related to the Contract for five years following the payment of the balance of the Programme, and in any case until any on-going audit, verification, appeal, litigation or pursuit of claim has been disposed of.
The documents shall be easily accessible and filed so as to facilitate their examination and the Lead Beneficiary and the Beneficiaries shall inform the MA of their precise location upon request.
Please also note that, according to instruction 15, the controller will carry out an on-the-spot check at least once during the life of the projects.
The paid leave is eligible, proportionally with the number of hours worked in the project, therefore it must be mentioned in the timesheet.
These situations have to be analyzed on a case-by-case basis, taking into account the information in the Application Form and the justification provided by the beneficiary.
Regarding the modification of the Application Form please check Instruction no. 16 of 20 February 2019 to Beneficiaries regarding Addendum and Notification.
These situations have to be analyzed on a case-by-case basis, taking into account the information from the Application Form and the justification provided by the beneficiary.
Regarding the modification of the Application Form please check Instruction no 16 from 20 February 2019 to Beneficiaries regarding Addendum and Notification.
PCR tests for staff members or guests, target groups and/or final beneficiaries for whom travel and accommodation costs are covered from “Travel and accommodation” costs budget line, shall be covered from this budget line.
For guests, target groups and/or final beneficiaries for whom travel and accommodation costs are foreseen and covered from budget line ‘’External Expertise and services’’ shall be covered from this budget line.
For the reimbursement process the beneficiaries shall present supporting documents (invoices/receipts, etc) and upload them in the eMS when the expenditure will be declared (at interim or final report).
If savings are not registered under these budget lines, the tests may be reimbursed from ‘’Office and administration’’ costs.
In order to help the beneficiaries and to reduce the risk of losses due to the exchange rate differences, the Managing Authority has introduced the option to submit more frequent financial reports, using the approach described in the Project Implementation Manual (revision 3)/ Annex 5, section 4.3.2.
Our recommendation is to elaborate such financial report every 4 months, in order to correlate them with the usual 4-month reporting process.
If you decide to use this option of multiple financial reports before the interim report:
1. A precondition is that the partner needs to have assigned the controller in the eMS. For this procedure, please take into consideration Instruction no 15/Feb 2021 (the second revision of Instruction 15 is available here and the Annexes here) and also the eMS Manual for CCPs and controllers (available here ), which contains step by step instructions on how to assign a controller in eMS.
2. The LB should send an official request to the JTS indicating the partners who would like to submit such reports and the timeframes for which they would like to report costs in eMS before the Interim / Final reports. We strongly advise to carefully analyze the frequency of these reports, taking into account the time required to complete them. Please note that these reports need to have continuity and overlaps in the reporting periods should be prevented, that is why a consultation at the partnership level should be consider in order to avoid delaying the overall interim reporting process.
3. The partner will have to open the first report in the eMS (period 1), the following reports being generated by the JTS officer at the Beneficiary request. For step by step instructions, please refer to the Project Implementation Manual (revision 3)/ Annex 5-“Guide on reporting in eMS”.
These situations have to be analyzed on a case-by-case basis, taking into account the information in the Application Form and the justification provided by the beneficiary.
Please note, that the acceptance of such a proposal is subject to the rules of eligibility for staff costs, among which, the new proposed hourly rate must correspond to those normally borne at institution level for similar positions.
The savings from the first part of the implementation period, up to the interim report, may be used also, after the interim report, following the regular procedures of project’s modification which are described in Project Implementation Manual (revision 3) and Instruction no 16 from 20 February 2019 to Beneficiaries regarding Addendum and Notification.
In this respect, please check section 5.4 from Project Implementation Manual
In principle, when the beneficiaries request the increase of the number of equipment (same type of equipment), which require only the rephrasing of the comment box in the budget, a notification is enough.
But if the modification requires the change of the unit rate and/or of the values in the budget, then an addendum is necessary.
According to Project Implementation Manual provisions ‘’ The Lead Beneficiary and Beneficiaries have to have dedicated bank accounts in Euro for the implementation of the Project, in order to identify the funds paid by the MA.
Also, the Lead Beneficiary and Beneficiaries may have a different bank account opened in their national currency (not applicable for Greek beneficiaries) for transfers representing co-financing and for other operations related exclusively to project implementation, if necessary.’’
The Lead Beneficiary and Beneficiaries must ensure that expenditure for the project is easily identified and traced to and within their accounting and bookkeeping systems.
Please note that clear reference to the Programme and project (e.g Programe and project eMS Code) has to be seen in relevant documents (e.g invoices, contract, reports, agendas, lists of participants, materials published, documents elaborated for events, etc).
There is no restriction in Black Sea Basin Program. Please check in this respect Instruction 15 from 20 November 2018 to the Beneficiaries laying down specific provisions for the expenditure and revenue verification of a grant contract funded under the ENI CBC Black Sea Basin Joint Operational Programme 2014-2020, second revision, Project Implementation Manual and if the case, your national legislation.
Also, when conducting the procurement, please ensure that the controller is listed on the most recent lists of controllers selected for carrying out the expenditure verification performed within the projects funded by Joint Operational Programme Black Sea Basin 2014-2020.
No, there is a conflict of interest and the respective costs will be declared ineligible by the program’s structures. Please check very carefully the situations of conflict of interest described in the section 5.2.4 of the Project Implementation Manual in order to avoid the cost being declared ineligible.
No, you may not offset. According to the provisions of Instruction 16 and Project Implementation Manual, art.3.8 ‘’ minor changes of amounts between items within the same main budget heading not having a major impact on the latest approved eMS version of the Budget’’ are subject of a Notification.
Please note that the template proposed in Annex 3 to PIM, should be followed. The hours worked each day on tasks not related to the BSB Project should be indicated in the timesheet, in order to allow the verification bodies to check that the number of hours in a working day do not exceed the limit specified in relevant national legislation.
In order to help the beneficiaries regarding the losses due to the exchange rate differences, Managing Authority has introduced an option as described in the Project Implementation Manual (revision 3) and also in Annex 5 Guide on reporting in the eMS: ‘’as an exception from the normal practice used for reporting expenditure, those beneficiaries who anticipate big losses because of the exchange rate, may consider using the approach described in Annex 5 Guide on Reporting in eMS, section 4.3.2 ‘List of Expenditures (LoE)’ tab – Currencies other than Euro.‘’
This method of reporting at the Inforeuro exchange rate of the month during which the expenditure was submitted for examination is provided by the Grant Contract, by the Programmes’ provisions and also by the EC Regulation no. 897/ 2014.
Also, the Decision of using the euro exchange rate of the month during which the expenditure was submitted for examination (option b) of article 67 of the aforementioned Regulation) was jointly taken by all participating countries in BSB JOP.
The draft of the Grant Contract was annexed to the Guidelines for Applicants, therefore, all potential beneficiaries have been informed accordingly and the approved requirements of the programme were made available to the large public and the launching of calls, evaluation and selection of application, as well as contracting and implementation processes have been organized in line with these provisions.
These situations have to be analyzed on a case-by-case basis, taking into account the information in the Application Form and the justification provided by the beneficiary.
Please note, that the acceptance of such a proposal is subject to the rules of eligibility for staff costs and the fact that the number of hours have to be correlated with the activities from the project.
Considering the provisions of the Guidelines for Applicants call 2, in the budget line Equipment may be included equipment and ‘’Consumables necessary for the functioning of the equipment’’.
How you structure your budget lines for equipment and consumables depends on how you envisage that the procurement procedure will be organized, are there suppliers that can offer both the equipment and the consumables, does the equipment require to use consumables manufactured by the same equipment manufacturer, etc.
As long as the advance payment is foreseen in the procurement documents and in the contract and also accepted by the national legislation provisions the advance payment may be declared and introduced in the interim report.
In cases where flexibility is needed and organising one single procurement procedure for all similar services / supplies / works needed over a long period of time would be difficult in a changing context, please consider that the respective services / supplies / works may be purchased following several procurement procedures.
However, please pay due attention to avoiding the artificial split of the estimated value of the contract.
For example, in case it is decided to organise a procurement procedure for services for an online event of 1.000 euro and then 2 procurement procedures for physical events, each of 10.000 euro, then the total estimated value of 21.000 euro must be taken into account when checking the thresholds for the procurement procedures stipulated in the applicable law. For example, in case of PRAG 2020, the above situation would imply the use of simplified procedure (formerly known as competitive negotiated procedure) for each of the three procurement procedures, and not the use of single tender procedure and neither the use of payment by invoice, for neither of them.
Also, you should take into account whether there is a need for a modification of the Contract through an addendum or notification.
The procurement rules you have to apply should comply with the provisions described by Regulation 897/2014 and Grant Contract and more information you can find in the Projects Implementation Manual – Chapter 4 – Procuring services, supplies and works.
Please pay attention that the procedure to be applied depends on the estimated contract value.
This depends on the country of the beneficiary. The procurement rules you have to apply should comply with the provisions described by Regulation 897/2014 and Grant Contract and more information you can find in the Projects Implementation Manual – Chapter 4 – Procuring services, supplies and works.
For guidance, you can also check the summary available on the programme website:
In any case, please consider all the legal provisions mentioned above.
In relation to the value of the contracts, please make sure to avoid the artificial split of the estimated value of the contract. For example, two studies of similar nature, each estimated at 12000 euro, amount to a total estimated value of 24000 euro, which, in case of PRAG 2020, for instance, implies the use of simplified procedure (formerly known as competitive negotiated procedure), and not of single tender procedure.
In relation to the situation where the same tenderer is successful in more than one procurement procedure, please check the specific procurement provisions applicable in your case (national law / PRAG in force at the moment of the launch of the procurement procedure).
In case a procurement notice has to be published (depending on the applicable procurement rules), the appropriate media is as follows:
– In case of beneficiaries mentioned in art. 9.2 of the grant contract (contracting authorities/entities in Member States), the publication requirements are those stipulated in the national procurement law.
– In case of other beneficiaries than the ones above, the following rules apply:
• the rules stipulated in art. 53-55 of Regulation (EU) 897/2014, supplemented by:
• the provisions of PRAG in force at the moment of the launch of the procurement procedure or, in case of Ukrainian public beneficiaries, the provisions of national law, and
• the rules stipulated in the last paragraph of art. 9.3 of the grant contract (submission of procurement notice to the Joint Technical Secretariat and any other appropriate media).
Please see the answers to questions 1 and 4 above.
In case of PRAG 2020, for instance, it would be acceptable to make payment against invoice without prior acceptance of a tender if the total estimated amount for all the four events would be up to 2500 euro.
Please see the answer to question 5 above.
In case of PRAG 2020, if the value of the 2 laptops is 2000 euro in total, you can purchase them directly by invoice without prior acceptance of a tender.
In case of beneficiaries applying the national procurement law according with the grant contract, please check the respective national provisions.
As regards national legislation, beneficiaries may ask the National Authority for guidance.
Example of artificial split: two similar renovation works estimated at 15.000 euro each are contracted on the basis of single tender procedures, while simplified procedure should have been carried out, as their cumulative estimated value is of 30.000 euro (in case of PRAG 2020). For other examples, please see the questions and answers no. 1 and 4 above.
For provisions related to avoiding artificial split / slicing of contracts, please check the specific procurement provisions applicable in your case (national law / PRAG in force at the moment of the launch of the relevant procurement procedure).
The procurement rules you have to apply should comply with the provisions of described by Regulation 897/2014 and Grant Contract and more information you can find in the Projects Implementation Manual – Chapter 4 – Procuring services, supplies and works.
The details from the question (electronic tender, simplified electronic tender, 67000 euro) are not mentioned as such in the Regulation (EU) 897/2014 or in PRAG.
For hiring the staff, you do not have to follow procurement procedures. In case you need to acquire services (e.g. expert consultancy), than you have to follow the procurement rules.
Please see also the answer to question 11 in the section above Q&A on Financial management of this document.
This phrase is part of the information concerning payment sent by the Projects Authorizing Unit (MA). This means that according to Romanian legislation, you have 30 days from the receipt of the information to submit an appeal to the Managing Authority.
By the corroboration of the legal provisions applicable in the case of this programme, it results that there is no restriction on the origin of supplies or nationality of tenderers.
The procurement rules you have to apply should comply with the provisions described by Regulation (EU) 897/2014 and Grant Contract and more information you can find in the Projects Implementation Manual – Chapter 4 – Procuring services, supplies and works. For guidance, you can also check the summary available on the programme website:
In any case, please consider all the legal provisions mentioned above.
For support, you may contact the Joint Technical Secretariat and, in case of specific national legislation, the National Authority in your country.
All services, supplies or works that must be purchased in the project must follow the procurements rules.
In case PRAG 2020 is used, the specific information about the single tender procedure can be found in sections 2.6.8, 3.3.3, 4.2.4, 4.6 and 5.2.4.
Please check very carefully the situations of conflict of interest described in the section 5.2.4. of the Project Implementation Manual in order to avoid the cost being declared ineligible.
Also, please consider in this respect the provisions of Project Implementation Manual section 5.2.4. ‘’ The external experts and service providers are sub-contracted to carry out certain tasks or activities which are strictly linked to the project and are essential for its effective implementation (e.g., studies and surveys, translation, promotion and communication, services related to meetings and events, etc). Do not forget that in order to conclude service contracts you have to follow the requested relevant procurement rules!’’ So, for every cost budgeted under ‘’External expertise and services’’ a service contract signed is needed, following the applicable procurement procedure.
In relation to the procurement as separate procedures, please make sure that artificial split of the estimated value of the contract is avoided, as it is one of the most common breaches related to procurements.
Also, you should take into account whether there is a need for a modification of the Contract through an addendum or notification. For other information about carrying out several procurement procedures instead of a single one, please check the FAQ on the programme website, section for the beneficiaries of the second call for proposals, subsection public procurement, first question.
Yes, it is allowed for the PRAG templates to be translated and used in the national language.
Controllers are independent auditors, or public officers, contracted or appointed, as the case, to examine the costs and revenues declared by the beneficiary.
The controller is the generic term used within the JOP BSB 2014-2020 and may be either an auditor, or a competent public officer, according to the systems used in each participating country.
The controllers are independent and should not give an ex-ante opinion on the eligibility of costs.
As regards changes to the grant contract, if you need clarifications, please consult JTS.
For more details regarding the system in your country, please consult the content of MA Instruction 15/2018, or get in contact with the nominated Control Contact Point. The contact details are available on the programme website – https://blacksea-cbc.net
Each partner will select/ get appointed a controller in its own country. Each partner need to have the expenditure verified by its own Controller.
In case you need to make revisions to the project budget, please follow the regular procedures of project’s modification (Addendum or Notification, as applicable) which are described in Project Implementation Manual (see section 8 – Modifying Grant contract).
The Republic of Moldova applies a de-centralized system, according to which the controllers are selected by the beneficiaries from a list established at national level by the Control Contact Point (Ministry of Finance). Contact details are available on the programme website – https://blacksea-cbc.net/black-sea-basin-2014-2020/management-structures/control-contact-points/.
Contracting of controllers must comply with Programme’s procurement rules as described by Regulation 897/2014 and Grant Contract. Depending on the estimated budget of the service, the applicable procedure should be carried out. For limited values of up to 2500 Euro, only invoice or contract is required.
Please check the provisions of Instruction no. 15 of 20 November 2018. The second revision of Instruction 15 is available here and the Annexes can be downloaded from here.The partner, depending on the country that s/he belongs to, will choose the relevant path to follow. Pay attention that if the controller is selected from a long list of auditors, the partner should follow the applicable procurement procedure for selection.
No, in the consolidated interim report the partners cannot upload financial documents which weren’t on eMS when the FLC control was carried out.
The financial part is compiled automatically by the system based on available FLC certificates included in the project report by the lead partner. Other documents may be attached only at the request of the program structures that perform the expenditure verification (FLC, JTS, Managing Authority).
Regarding the criteria for the eligibility of declared cost please take into account the provisions of article 8 from the Grant Contract and section 5.1 and 5.2 from Project Implementation Manual. Also, in the reporting process, in order to ensure that the controllers/Managing Authority have all the necessary information in order to perform the expenditure verification, we kindly remind you of the obligation to provide/ upload in the eMS all the supporting documents and annexes requested in the Project Implementation Manual.
According to article 8.3 of the Grant contract, this flat-rate for office and administration costs does not need to be supported by accounting documents. This means that no justifying documents proving the expenditures incurred under this category have to be provided during the interim report and final report.
If during the reporting process you encounter technical problems that may delay or stop your reporting process, contact JTS officers in order to ask for support.
No, there is no preferred template for internal appointment of the staff to work on the project. In this respect, please check the supporting documents requested for expenditure verification for costs declared under budget line ‘’Staff’’ (section 6.5.3 PIM)
The interim reporting process is done through the eMS / the interim partner and project reports being filled in and submitted in eMS.
There is not a template for the financial report in eMS. The financial report si filled in, in the eMS, by filling in the List of Expenditures. Please check, in this respect the Project Implementation Manual, revision 3 and Annex 5 Guide on reporting in the eMS.
According to article 5.5 of the Grant Contract ‘’if half of the implementation period has elapsed and the part of the expenditure actually incurred and paid which is financed by the MA is less than 70 % of the previous payment, the Lead Beneficiary shall present an interim report within 90 days following this period; the interim payment shall be reduced by the amount corresponding to the difference between the 70 % of the previous payment and the part of the expenditure actually incurred and paid which is financed by the MA.’’
After the end date of the interim reporting period, the partners have 90 days to prepare the report and submit it to the JTS. To meet this 90-days deadline, partners are advised to prepare in advance a schedule of the reporting process. Please be aware that the expenditure verification process by the controllers takes up to 30 days, excluding the periods dedicated to providing the answers to clarifications, if the case.
The co-financing will be established by the MA when authorizing the report by applying the percentages from the Grant Contract art. 3.2.
In eMS for partner interim report, you will fill in ‘’Contribution section’’ In this section you have to specify the source(s) of partner contribution matching the ENI of the current report. The eMS give the partner target amount (i.e., the total contribution calculated by deducting the fund co-financing from total eligible expenditure introduced in the List of Expenditures). The system proposes the same sources of contribution as specified in the application form.
The total value of contribution from all sources needs to correspond to the total amount of match-funding. Please check provisions of Annex 5 section 4.3.3.
Regarding the documents that you need to upload in the Procurement section please check section 2.5 from Annex 5 – Guide on reporting in the eMS.
Photos of the notebooks procured may be attached in the Attachment section of the interim partner report.
The contracts with the audit company for partners from the Republic of Moldova do NOT have to be registered on the platform of the Ministry of Finance amp.gov.md.
There is no reference to the number of months /weeks before submitting the Interim Report when the partner should contract the FLC. The partner should take into account the time necessary for the procurement process. The recommendation is to be sure that, at the moment of the partner interim report submission, the partner has signed the contract with the controller and the controller is already assigned in the eMS by the respective CCP.
Please check in this respect the provisions of Annex 5 where is specified that ‘’ Always include in the partner report generated for interim reporting period expenditure paid within the respective period.’’. The respective costs will be introduced in the final report.
Regarding the documents that you need to upload in the Procurement section please check section 2.5 from Annex 5 – Guide on reporting in the eMS.
Photos of the equipment procured may be attached in the Attachment section of the interim partner report.
For the interim reporting, each partner will create in eMS, a partner report consisting of a narrative part, and also a financial part. The financial part is in fact the “List of expenditure” (LoE) section of the eMS partner report.
After clicking on ‘Add real cost’ a LoE appears, where the system asks you to give basic information on the cost item.
For step-by-step instruction on how to generate and fill in a partner report, please refer to the Project Implementation Manual (revision 3), Annex 5 – Guide on reporting in the eMS.
When generating a partner report, please check in the application form in eMS, the reporting period for the interim report. Please also note that since reports are automatically generated to cover the defined reporting periods set out in the version of the application form to which the report is linked, any future changes to the estimated reporting periods will require deleting the old report and generate a new one that corresponds to the revised reporting periods.
According to art.8.1 from the Grant Contract ‘’ Costs incurred should be paid before the submission of the final reports’’ to the controller.
In this respect please be aware that for final report, beneficiaries may include, expenditure(s) incurred between the first day after the interim reporting period and end of implementation period, and paid before the submission of the final report to the controller.
Expenditure is considered incurred when the activity that has generated the expenditure (for example the works executed in accordance with the conditions of the contract) has been completed or the services foreseen in a contract have been provided.
Supporting documents to the expenditure(s) declared (e.g invoice, contract, take over certificates or confirmation of service delivery – documents indicating the completion of the operation, or any other accounting documents of equivalent probative value, etc) must be issued during the implementation period and demonstrate that the costs have been incurred during the reporting period
Supporting documents (as they are detailed in section 6.5.3 Supporting documents for expenditure verification, from Project Implementation Manual), will be provided and uploaded in the eMS for all the costs paid irrespective of the source of financing, EU funds or co-financing.
The Indicative list of supporting documents required for expenditure verification included in Annex 3 of PIM is the same with section 6.5.3 Supporting documents for expenditure verification from Project Implementation Manual. In sections 4.3.2., 2.5 and 4.3.4 from Annex 5 Guide on reporting in the eMS are described and mentioned the sections where the respective documents should be uploaded. We recommend to check all the sections mentioned above.
The “Internal ref. number” from the List of expenditures is the number that the respective document has received in the partner organization (internal number) and is used to make easier the identification of the document.
Reporting, Monitoring & Evaluation
The progress report submitted at every 4 months of implementation must be submitted only outside eMS application form. The documents that must be attached at the progress report are: an updated procurement plan; promotional materials; photos of equipment/supplies.
The progress report must be signed by the legal representative. The project manager can sign the report only if she/he has been empowered by the legal representative and in this case, the empowerment decision must be attached to the progress report.
With this modification, the management structures intended to simplify the process and to avoid the delays in reporting (reverting due to repeating mistakes done in reports, as it happened with reports submitted by projects contracted under the 1st call for proposals). This approach, decided for the 2nd call beneficiaries, comes following the feedback received from beneficiaries in regard to reporting.
There is no specific obligation regarding the approach used for collecting the contribution to project reports by the Lead Beneficiary from the partners. It is up to the partners to decide on the appropriate mechanism.
The beneficiaries of the second call will not submit the progress report through eMS. They will only send the already elaborated reports to the Lead Beneficiary/JTS via eMS Mailbox.
There is no general approach on how the projects to respond to the COVID 19 challenges. The cases will be analysed one by one and the solutions will have the purpose of decreasing as much as possible the delays or other negative effects on the project results. However, please consider the Information for Beneficiaries of the ENI CBC Black Sea Basin Programme regarding project implementation in the context of coronavirus disease COVID-19 issued by the Managing Authority and published on the programme website in March 2020.
Please remember that the progress described in each 4 months progress reports is related strictly to the reporting period. Therefore, you will report the same organisations that have been involved in the previous periods, but, when you will prepare the interim report (where you have the obligation to report the progress from the beginning of the project) you will count the organisations only once.
When deciding to reorganise an activity, please make sure you will achieve the same expected results as in the original version of the application.
A JTS officer is assigned for each project. All beneficiaries can contact the JTS project officer any time by using their email address or telephone, as communicated by JTS or according to the information published on the programme website.
The original financial documents do not need to be translated in English. They have to be uploaded in eMS in scan version of the original documents and named in English.
In case during the verification process of the interim/final report the Managing Authority, will need clarification regarding certain documents, it may ask for a translation in English of the respective documents or parts of them.
The appointment decisions for staff (project management team) does not have to be translated into English, considering the fact that is going to be verified by the controllers of each partner.
Information related to the Project Management team are going to be introduced in the Supplementary Information section.
The documents do not have to be translated in English. They have to be uploaded in eMS in scan version and named in English. If, during reporting or verification of reports translation into English of a document is required, the beneficiary shall submit an unofficial translation in English signed by the legal representative of the respective partner.
Also, for projects with an investment component that have the obligation to submit technical documentation connected with the investment, they will send the documents in national language, accompanied by an English short description of their content.
In eMS, in the section “Project Budget Overview” you can find different formats/tables of the project budget.
Under each format/table you have the option “Export”.
This will allow you exporting the table in Excel format.
In principle, all staff costs, irrespective of the project activity they are linked to (management or implementation), shall be reported under the Group of Activities management (Work package Management in eMS) if not in contradiction with the provisions of the national legislation or internal requirements of the organization.
If budgeted under other Group of Activities (not Management), as to comply with the provisions of the national legislation or with the organisation’ internal rules, they shall be reported under the respective Group of Activities.
The method of payment of staff costs must be fully in compliance with the applicable national legislation and with the provisions of the employment contract. The supporting documents for the payments made must reflect the above mentioned approach.
If the procurement plan was revised due to the modification of the budget there are two situations:
– a modification of the budget through a notification. The notification should be submitted with at least 10 days before the date on which the changes should be implemented. The procurement should start after the notification is accepted.
– a modification of the budget through an addendum. The addendum should be submitted 45 days before the date on which the amendment should enter into force. So, the modification requested through the addendum will enter into force after the signature of the both parties (MA and LB) and the procurement should start after the addendum has entered into force.
If the modification to the procurement plan is not related to the budget values, you can submit an updated procurement plan with every progress report.
The procurement could start according to the needs and the schedule.
In order to be assigned as a “User” in eMS you have to be registered in the eMS. The assignment of the users is done by the Lead Partner. Please check section “2.4 User Assignment” from Annex 5 – Guide on reporting in the eMS
In order to calculate the spent amount in euro you will have to have a situation of the expenditure paid in the reporting period, in original currency, then you will convert this amount using the monthly euro exchange rate of the European Commission, from the month when the progress report is submitted to JTS. There is no need to insert the amounts in national currency in the progress report.
You have to report the staff costs in the same manner as the other costs. The co-financing will be established by the MA when authorizing the report.
Yes, you can consider financing a part of the staff’s salary with your own contribution/ national contribution, within the limits of the total amount of national contribution.
If the eligible costs of the project at the end of the project are less than the estimated eligible costs, the grant co-financing shall be limited to the amount obtained by applying the percentage of 8% to the eligible costs of the project approved by the MA, at the final financial report.
The supporting documents you need to submit for verification are the same as for all declared expenditures. An indicative list is available in the Project Implementation Manual, section 6.5.3 “Supporting documents required for expenditure verification”.
According to the provisions of Annex 5 – Guide on reporting in the eMS – for “Staff costs” each item in the List of Expenditure needs to be separated per person per month (as staff employed are paid on a monthly basis – full or part time).
In accordance with the Joint Ministerial Decision of the MCS of ETC Programmes no. 300488/ΥΔ1244/06.04.2016:
The staff cost of the Greek beneficiaries of the Joint Operational Programme Black Sea Basin 2014-2020 (BSB) corresponds to the gross cost of the persons employed by the beneficiary in any of the following ways:
a) Full time employment
b) Reduced time employment under a fixed monthly rate (percentage of time) – According to ENI CBC Black Sea Basin, this option is not applicable for projects funded under the BSB Programme
c) Reduced time employment with flexible number of hours per month
d) On an hourly basis
The gross staff cost includes the salary or fee paid to the staff and all the related payments, i.e. taxes and social security contribution.
In accordance with the Law of State Accounting no. 4270 of 2014, the documents supporting the staff cost expenditure may have any of the following 4 forms:
1. Payroll (In Greek: “μισθοδοτική κατάσταση”)
2. Service Invoice – including the Social Contribution – issued to 1 or 2 employers (In Greek: “Τιμολόγιο Παροχής Υπηρεσιών”)
3. Service Invoice – not including the Social Contribution – issued to more than 2 employers (In Greek: “Τιμολόγιο Παροχής Υπηρεσιών”)
Receipt of Professional Expenses (In Greek: “Τίτλος Κτήσης”. Previously known as “Απόδειξη Επαγγελματικής Δαπάνης”)
The role of each team member must be defined within the partnership and must correspond with the roles and responsibilities of each partner, in order to ensure the coverage of the expertise necessary for the implementation of project activities.
Until now the Programme structures did not take into consideration this option.
If a duly justified project’s extension is approved by the Managing Authority, then the deadline for submission of the interim report will be updated in accordance with the new project duration.
The Lead Beneficiary will ensure the coordination between partners in order to make sure that the deadline for submission of the consolidated report is met; LB is responsible for consolidating information at project level and uploading all FLC Certificates; LB will receive the potential clarifications from JTS and must share the information with partners; in order to respond to clarifications, the LB might need to revert the reports to partners (action made in eMS); LB has to communicate to JTS any issues that might delay the submission of the report
The JTS verifies if the evidences provided are sufficient to prove the deliverables obtained, if the content of deliverables correspond with the application form; e.g. for events organised
– it is verified if the agenda of the events contain all topics described in the application form, if the target group corresponds and is relevant for the event, if number of participants corresponds with the number indicated in AF, if the submitted photos demonstrate that the event was organised
The level of details must be sufficient in order to clearly demonstrate the progress for each deliverable and the results achieved.
The description of the progress of Project Output Indicators must correspond with the information in the application form and with their contribution to the already preselected Programme Output Indicator. In order to better understand how to quantify and report the target value reached, please see the following example: if a project plans to deliver 5 products to promote tourism (i.e. project output = Products promoting tourism / target value = 5) and 2 such products are completed by the time a certain Progress Report is submitted, then the beneficiary will indicate “2” under “Achieved in this report”. If, by the time the next Progress Report is submitted, the remaining 3 products are also completed then the beneficiary will indicate “2” under “Achieved so far” and “3” under “Achieved in this report”. Under the “level of achievement” the appropriate status shall be indicated (e.g., proceeding according to workplan – if under preparation; behind schedule – if delayed as compared to the due date, etc.)
In case the evidence exceeds the limit of 20 Mb, the partners should create .rar or .zip packages of no more than 20 Mb of each and upload them in more parts.
The partners will describe their contribution in each GA and will upload the documents for which they were responsible; the LB will consolidate the information, describing the progress at project level, but with references to the partners involved
The interim report is prepared in electronic version and is submitted via eMS; therefore, the report cannot be technically signed; all other supporting documents to be uploaded should be signed by the legal representative of the LB/beneficiaries.
Yes, you can start writing reports, but please be aware that no request for notification/addendum are submitted during this process; the report will be linked to the version of the application form valid at the moment of creation of the report.
The Lead Beneficiary will submit its interim partner report and the consolidated project report.
For the financial part of the interim report there are no major differences. Please be informed that the Instruction 15 laying down specific provisions for the expenditure and revenue verification of a Grant Contract funded under the JOP BSB 2014-2020 and its Annexes were revised, as to:
– simplify the control work and remove the identified overlaps. In this respect, the former Annex 6 – Template of report on expenditure and revenue verification and Annex 7 – list of factual findings to the instruction have been removed;
-respond to the Beneficiaries’ needs and bring a solution to mitigate the potential losses due to exchange rate variations. Consequently, the Instruction includes (see section 2.7) the option for Beneficiaries to submit financial reports in the eMS, prior to the submission of the Interim/Final Reports.
– clarify, or detail some of its provisions.
Also, in Project Implementation Manual revision 3 some aspects related to the reporting process were clarified of described in a more detailed way and Annex 9 and 10 (Checklist for narrative and financial interim/final report) were introduced in order to support the beneficiaries.
Please take into consideration the provisions of the Project Implementation Manual which specifies that ‘’throughout the process of expenditure verification of the Interim Report until the approval by the controllers/MA of the report, Beneficiaries shall not make or request budgetary modifications to the sub-budget lines included in the report for which verification is ongoing’’.
Please check, in this respect, sections 2.5, 4.3.2 and 4.3.4 from Annex 5 – Guide on reporting in the eMS.
For those projects for which the reporting period coincides you will submit only interim report within 3 months after end date of reporting period. The 3rd progress report will be related to the period that will include also the preparation period for the interim report (the 3 months to which we make reference). For example: if the end date of the reporting period for interim report is March, 30, you will submit interim report until June, 29 and the 3rd progress report (for period March, 30 – July, 29st) will be submitted until August, 30th.
Depends on the changes requested through Notification or addendum. If they include changes related to the reporting period of the interim report, you will have to delete the reports created prior to these changes. If not, then is not necessary to delete the reports. Still, please remember that all changes requested through addendum don’t have to be retroactively applied. We also do not recommend submission of addendum during preparation of interim report. Please coordinate all activities (analysis of the necessity to change activities/budget and reporting tasks) in order to ensure an efficient and smooth project implementation. Being involved in making changes in the application form and in drafting the interim report will be challenging. Also, deleting the reports already created will take time for saving first the information already filled in and then recreating the reports. Please be aware of your obligation to follow programme deadlines. Any delay will lead to delays in receiving the second installment and this might affect the financial resources of some partners.