Based on Q&As raised in the framework of the meeting on closure for ENPI CBC programmes held in Brussels on 10 May 2017 and updated after the meeting on recoveries for ENPI CBC and ENI CBC programmes held in Brussels on 27 June 2017
Q. EC instructions are unclear with respect to final date for “projects closure”. If tight deadlines have been already fixed, it is important to be informed as soon as possible, to speed up project closure.
A. Projects should be closed in time for drawing up the final accounts and performing the final audit work, so that submission of the report takes place within the set date (30th June of N+2). Each programme will need to plan carefully how to reach this goal, including the necessary measures to speed up project closure.
Q. Par. 6.1 p. 28. Are exceptions to the cut-off date due to final report costs and external audit costs acceptable?
A. Expenditure may be incurred until the date of submission of the report, even if it is paid afterwards. Therefore, the costs referred in the question (the preparation of final report and external audit) are eligible, even though they have to be included in the audited accounts.
Q. The reference “…since the last audit” in paragraph 7.5 p39 means that the final external audit report includes only the results on the expenditures and payments for the final reporting period (from 01/01/2017) not subject to an external audit verification yet?
A. Yes. The audit reports, including the external audit report, should not cover the “entire programming period”, but only the amounts not included in previous reports. In relation to the entire programming period, the information in the reports should be presented in a summarised way.
Q. The information related to the financial part of the report (letter B p. 35) shall be included in the report by detailing each expenditure, recovery, revenues etc… for each year starting from the beginning of the programme or they should refer only to the final reporting period (from 01/01/2017)?
A. The information in the report shall refer to the whole duration of the programme. Table 5A “Technical assistance” was updated. The costs in this table can be reported on categories as reflected in the table 3 of the Annual Financial Report: staff, subsistence costs, travel costs, equipment and supplies, indirect costs etc.
A. The tables that include the financial information requested are provided together with the updated Guide and this set of questions and answers.
Q. In point 4.6 you mention that the interest generated on pre-financing can be used for covering expenses which are not included in the reported costs, such as the cost of staff of the bodies hosting the JMA. Can you please specify what type of staff costs can be reimbursed?
A. Not all staff costs of the bodies hosting the programme bodies have been reported and financed by the technical assistance budget. Even though the ENPI CBC IR did not allow for co-financing of technical assistance, additional staff has been assigned to the programme and has devoted part of their time to programme management. Programmes may make now an estimation of the cost of this non-previously reported staff. Interest generated on prefinancing and other revenues may cover these costs, which so far have been paid from the ordinary budget of the institution.
Q. We have the implementation period of TA agreed until 31.12.2017 and the execution period of programme until same day. We are not prepared to cut-off the use of ENPI TA before the latter part of year 2017 (for example 30.10.2017). We have not requested any funding of ENI CBC yet. Also we were not aware that the Final report should be ready even before execution time, at 30.06.2017. How should we act in order to get extension to the submission time of the final report?
A. It is not possible for the EC to grant an extension of the submission time for the final report without also extending the execution period. Please contact directly the EC in this situation.
Q. TA should not exceed 10% of the financial provision. Is this calculated on the actual spent amount or on the overall EC available budget? In the first case, we may exceed the 10%. What we have to do in this case?
A. Article 18 of ENPI CBC IR stipulates that “No more than 10 % of the Community’s total contribution to a joint operational programme may be allocated to technical assistance.” In principle, this percentage has to be respected also at the moment of closure. Should the percentage be higher in the end, the deviation needs to be duly justified. Where sound justifications exist, percentages above 10% may be approved.
Q. As indicated in the Instruction Note issued by the EC, the costs may be incurred until submission of the final report. Nevertheless, the programmes will need to decide their own cut- off date, taking into account the time to be used for drawing the final report and get it audited.
Final report by the (JMA): a) Executive summary b) Technical part c) Financial part d) Audit reports
Q. According to the ENPI regulations the beneficiaries have to keep all programme documents seven years after closure. How shall we deal with cases when beneficiaries were dissolved without prior informing the JMA and/or handing over the documents to any partner?
A. Specific instructions should be issued for the project beneficiaries and partners on how to deal with the cases of liquidation of institutions with no successor. The transfer of all documents to the beneficiary should be recommended. In case of liquidation of the beneficiary, the documents should be transferred to one of the partners (theoretically the lead partner) and JMA be informed. If such instructions are clearly set for the closing projects, there is no additional responsibility for JMA.
Q. Should the tables presented in the “Guide on closure” on pages from 33 to 38 be used as the matrix of the final report? Can you please provide us with the electronic version of the above tables and the matrix of the final report?
A. The electronic version is provided together with the updated Guide.
Q. In the case that the JMA makes an in-kind contribution to the technical assistance, where should it be indicated in the final report?
A. In accordance with article 19.3 and 35 of the ENPI CBC IR, the JMA may provide contribution in kind, subject to the prior approval of EC (e.g., if indicated in the JOP). This co-financing (both as expenditure and as income), should be clearly separated in ad hoc additional lines in the table 2 of the Guide on closure (pg. 34) and will not be taken into account in the calculation of the actual co-financing rate.
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