Frequently asked questions
Frequently asked questions from applicants and project partners are answered on this page.
Project implementation and COVID-19 (coronavirus) epidemic
Has the FLC to perform on-the-spot checks during the COVID-19 pandemic?
According to the programme rules, FLC are obliged to perform an on-the-spot check for Call 3 and Call 4 projects at least once during a project lifetime. In case the implementation of the on-the-spot check may not be possible due to the COVID-19 situation, the following alternative action(s) may exceptionally be taken by the FLC: The on-the-spot check may take place virtually in terms of an online meeting (e.g. via zoom or webex) or - if that is not possible - via a video phone call. In the course of these virtual meetings the beneficiary shall present the project accounting and the archiving of files to its FLC-body and shall proof compliance with publicity requirements and the existence of equipment purchased (if relevant). It is up to the FLC to require further means of proof like photo documentation, however such further action should not replace the online meeting or video call.
In principle, documentation requirements do not change. In the case of a virtual on-the-spot check, the relevant section on on-the-spot checks in the FLC report shall be completed and provide - beside detailed information on the focus of the on-the-spot check - a description of the alternative actions taken.
It is stressed again that virtual on-the-spot checks should only replace normal on-the-spot checks in case the latter ones are actually not possible due to COVID-19 pandemic.
How can negative effects be reduced on project activities?
Project meetings/events may have to be cancelled, postponed or partners/stakeholders may not be able to attend due to an official/institutional travel ban or travel warning for a particular region. The situation evolves quickly and remains unpredictable, it is not clear when travelling and events organisation could be resumed normally. Therefore projects are recommended to look into their work plan and check how activities could be rearranged in order to achieve the set objectives differently. For instance, project meetings could be organised online, desk activities given the priority as opposed to events, stakeholders engagement designed differently through online tools. The programme is aware that this could be challenging and the project officers at the JS are available to support in this process, and to assess each specific case.
Are costs eligible for meetings/events which had to be cancelled or could not be attended?
The current epidemic is a clear case of force majeure and cancellation costs can be considered eligible if they are not recoverable by any means and the justification is documented.
Cancellation costs may include for instance venue rental, catering, travel tickets and accommodation. Project partners should first of all minimise costs and seek reimbursement timely. This should be done according to contractual terms or based on the specific rules which may be set by public authorities to face the current health situation. Project partners are advised to get in touch with their FLC to check the eligibility of costs. They should also provide evidence to their FLC that costs are irrecoverable. This may include for instance a refused refund request or the print out of contractual terms with reference to the applicable rule.
Cancellation costs in line with the above mentioned requirements are eligible starting from 24 February 2020.
Which guidelines should be applied by FLC for the certification of cancellation costs due to the COVID-19 epidemic?
As for any other expenditure, the FLC should check that the expenditure incurred was necessary for the project implementation. Additionally, cancellation costs should meet the following criteria:
- The meeting / event linked to the cancellation costs was cancelled, postponed or could not be attended due to the COVID-19 outbreak. Cancellation occurred starting from 24 February 2020.
- Sufficient evidence is provided by the project partner to confirm that costs were irrecoverable by any means. This may include for instance a refused refund request or the print out of contractual terms with reference to the applicable rule.
How to report staff costs if specific working conditions (i.e. short-time work) due to the COVID-19 pandemic apply?
Due to the COVID-19 pandemic, some member states have introduced short-time work* schemes. Should your PP institution in general and any ASP project-assigned employee specifically be affected by short-time work, the following general rules shall be considered in case of staff costs co-financing on the basis of real costs:
- Staff costs that are not finally borne by the PP institution itself are not eligible. Consequently, only the part of the staff costs finally covered by the employer/PP institution shall be taken into consideration when calculating the staff costs.
- In case of part-time assignment, this definitely-borne part of the staff costs shall be allocated to the project pro-rata only and in accordance with the % as fixed in the project assignment.
- Any necessary change of an assignment (especially the project-related tasks and/or extent of assignment) due to the particular circumstances related with the COVID-19 pandemic, shall be well-documented by issuing an amendment of the assignment and additionally well-justified in a note for file.
- The issuing of new assignments in periods of short-time work would have to be well-justified.
- The calculation of staff costs on an hourly basis is still not foreseen by the programme.
*The same conditions apply for the “stand by situations” when an employee is not working due to COVID-19 pandemic but still receives part of its salary.
What is an ideal number of partners in a project?
The programme has rules on the minimum and maximum size of a partnership, which are at least 4 project partners from 4 countries and max. 15 project partners (including the lead partner and non-EU partners). Priority 4 projects are encouraged to limit the number of partners in the partnership to 10. Overall, experience shows that a number between eight and twelve partners seems adequate for a successful implementation. The ideal size is determined by the objectives of the projects and the competences needed to implement it; a good balance should also be sought in terms of territory and type of partners (e.g. administrations, business support, NGOs, private sectors, etc.). When defining the partnership, the following questions might be helpful: Which partners does the project need to be able to achieve the project objectives and results? Which partners are able to influence policies or procedures to enable that the envisaged changes in the chosen field?
What is the role of observers and what is a good quality network of observers?
Observers may have different roles in a project. They enrich the partnership with expertise in the chosen field and/or promote the project results among target groups. They may test project outputs or implement them at the end of the project. Ideally, they support the uptake of results at policy level. Therefore, not the number of observers, but their relevance within the chosen topic to achieve the envisaged results is important.
Where can I get information on projects that have already been funded?
There are several possibilities to find co-financed Interreg projects, which were implemented already in former periods or which are still running that you can check on similarities or synergies:
On EU-wide level the Interact database keep.eu includes projects from the running funding period 2014-2020 as well as from previous funding periods (2000 – 2006, 2007 -2013).
If you would like to check especially Alpine Space projects from 2007 - 2013 the programme offers an overview on previous projects including their outputs and results which can be found on the following website: www.alpine-space.org/2007-2013
All websites of Alpine Space projects 2014 – 2020 can be accessed via an overview on the programme website. Here you can search by priorities, topics and location of partners.
What is the difference between an output and a deliverable?
Outputs are products delivered by the partnership as a result of the activities conducted during the project implementation. They must answer the needs of the target groups and, at the same time, demonstrate durability and transferability beyond the project partnership. Equally important is the fact that project outputs should be measurable and contribute to the programme output indicators. In the Alpine Space programme there are three types of project outputs: transnational cooperation structures, transnational strategic elements and transnational implementation elements, all of which are fully described in the cooperation programme.
Instead, a project deliverable is a side product that contributes to the development of an activity whose purpose is to support the completion of an output, either on its own or in combination with other activities.
Does the LP have the responsibility to collect and upload national requirements in the eMS?
No, national requirements are not uploaded in the eMS. They are sent by the project partners to the relevant Alpine Space contact point.
Does the programme co-finance infrastructure?
No, but under the budget line “equipment” small scale investments are possible, such as laser scans, sensors or drilling rigs.
Which rules do apply if a private project participant intends to contract an affiliated organisation?
Factsheet 1.4. on the eligibility of costs says that "expenses of organisations contracted via in-house-procurement (formerly known as affiliated institutions) can be considered as eligible as long as based on verified actual and eligible costs without any additional fees charged. The respective expenses shall be reported in the budget lines they would normally belong to if directly implemented by the project partner ...i.e. staff costs calculation for an employee of such an organisation is the same as the one for an employee of the project partner".
The logic behind this rule is that public procurement law is not applicable if contracting authority and contractor are tightly connected (so called "in-house procurement", see factsheet 4.2). With the aim to ensure that ERDF-money is spent according to the principles of efficiency, economy and effectiveness also in these cases, the programme partners have defined the rule set out above.
Private partners are not subject to procurement law per se. However, as Alpine Space projects are co-financed with public funds, the partner states wanted to ensure that the principles of efficiency, economy and effectiveness are also applied when private partners purchase something in the course of a project. Therefore simplified rules for purchases of private partners have been defined in factsheet 4.2.
The principle of equality as it is laid down in community and national laws says that similar cases shall be treated in the same way. For the relevant question this means the following: Purchases of private partners shall not be regulated stricter than those of public partners. If EU-procurement directives regulate that procurement law is not applicable if contracting authority and contractor are tightly connected (for criteria to be fulfilled see directive 2014/24/EU, article 12 and respective national procurement law) then also private partners shall not be bound to any purchase rules in case they intent to contract an affiliated organisation. This means that the rules as set out for purchases of private partners in factsheet 4.2. do not apply. However, since the private partner and the contractor are affiliated the above-mentioned rule of factsheet 1.4. still applies.
Should the staff costs be documented with timesheets as it was for ASP 2007-2013?
Timesheets are not requested by the Interreg Alpine Space programme 2014-2020. The type of supporting documents to be provided depends on the option selected in the application form for the calculation on staff costs.
In case of real costs: the staff costs have to be documented by a project assignment issued for each single staff member involved in the project (including an indication on the percentage of assignment that will be the further basis for the calculation of the staff costs) and by six-monthly task reports provided for each single assignment per staff member.
In case of the flat rate: no staff-specific documentation is required (20% of the direct costs reported in the budget lines “travel and accommodation costs”, “external expertise and services costs” and “equipment expenditure” will be calculated automatically in the eMS ). It has only to be proven that the beneficiary has at least one employee (e.g. by providing a registration at the social insurance agency). For more details please check factsheet 1.4, chapter A.
Can one person have more than one assignment per project?
Yes, employees can have more than one assignment per project. In order to capitalise on the simplification measures it is strongly recommended that the assignment has a duration of at least 6 months corresponding to the reporting period.
What to do if the calculated extent of assignment was considerable overestimated for one period?
If the assignment is valid for the whole project period (and therefore the extent of assignment was calculated as an average of 36 months), the actual involvement will in many cases not reflect the extent of assignment for single reporting periods (in some it might be less in others higher). This shall not be of any relevance as long as it reflects the actual involvement of the person seen in relation to the whole project duration.
How to make a plausibility check on the extent of assignment?
The FLC can request more details as regards the calculation of the extent of assignment (e.g. detailed estimation of working hours on single WP activities). On the basis of that a plausibility check should be feasible.
How to deal with project assignments in case of staff changes?
The assignments are always linked to a person/employee. If there is a staff change, a new assignment has to be set up and signed.
When should project assignments be issued and signed?
Assignments should be issued and signed in advance (before the starting date of assignment). Only in justified cases (such as the project start phase) minor delays may be accepted.
Are sick or parental leave allowances eligible?
Sick or parental leave allowances are eligible as long as they are definitely paid and borne by the PP institution and only within the extent of assignment.
What is the difference between activities planned in the project assignment and activities described in the six-monthly task report?
In the project assignment the employee plans in advance activities in the assignment period. In the six-monthly task report the employee describes the tasks that were actually done. Deviations between the percentage of involvement per work package of the assignment and the six-monthly task report are acceptable as long as the total extent of the assignment of the person is not concerned. The percentage of involvement per work package indicated in the six-monthly task report is the base for calculation of staff costs reported in the eMS.
How to report values for staff costs in the eMS?
If the project partner selected the flat rate calculation method, the expenditure will be automatically calculated by the eMS. In case of applying the real costs option, the project partner shall enter separate expenditure items for every single employee per work package. This expenditure does not need to be split for each month but can be accumulated per reporting period. The latter should be beforehand communicated and agreed with the relevant FLC.
A simple excel tool that can help calculating the exact amounts that need to be reported in the eMS can be downloaded here. Please mind that this is not an official programme tool and shall not be considered as the base for (in)eligibility of the staff costs.
Is evidence of adequate publicity required in case of recruitment of a new staff for a project activities?
The corresponding stipulation of the eligibility rules must only be obeyed if applicable law (e.g. national or regional law) or internal rules/policy of the beneficiaries organisation require the publication of job advertisements.
Costs for trips
Can observers ask for a reimbursement of their travel and accommodation expenditures?
Yes, project partners can reimburse the travel and accommodation costs of observers (including daily allowances) if agreed in advance (written agreement, information on the expected input of the body, the estimated amount and procedure of reimbursement). These costs can then be reported to the programme (under the budget line “external expertise and services costs”).
Travel and accommodation costs for observers travelling outside the programme area are only eligible if they are previously approved by the JS.
Are travel and accommodation costs of bodies considered as target groups related to the participation in project related activities (workshop/event) eligible?
The travel costs of bodies considered as target groups are eligible if the workshop/event demonstrates a transnational added value and if the participation of this body is necessary for the implementation of the workshop/event. Either the costs are directly paid by the project partner or pre-financed by the body considered as target group. In case of the latter, the reimbursement shall be agreed in advance (written agreement on the expected input of the body, the estimated amount and procedure of reimbursement). These costs can be reported to the programme (under the budget line “external expertise and services costs”).
Should the lump sum for preparation costs be included in the list of expenditure?
No, from call 3 onwards the respective share of the preparation costs as indicated in the AF will be automatically included by the LP and submitted to JS/MA for the payment. There is no need for partners to include the lump sum for preparation costs in the list of expenditures.
Under which period should expenditure incurred in June but paid in July be reported?
PP should agree with the FLC on the approach to be applied and shall follow this agreement for the entire project implementation period. Generally, expenditure incurred and invoiced in June could also be reported for the period January-June as long as the payment was effected within a minor delay after the reporting period concerned and well in advance of the first level control. As concerns the staff costs, it is recommended that staff costs for the month of June are considered for the period January to June even if the payment of the salary took place in July.
Can a project partner report expenditure that incurred before but paid after project closure date?
Yes, the eligibility rules clearly state: “expenses based on payments initialised with a minor delay after the project implementation period can be accepted as long as the activities have been implemented and the invoices/payslips have been issued before the project closure date (time period to be agreed with the FLC body responsible)”.
How can the PP correct the partner report if the FLC spots wrong or insufficient information?
This is only possible if the FLC rejects a partner report and reverts it to the PP for corrections. By using this function the PP needs to resubmit the partner report and the FLC starts with the verification procedure from the beginning again. The FLC also has a possibility to enter corrections and/or additional information in some parts of the eMS such as the list of expenditures and the FLC report. No specific instructions are set for the communication between FLC and PP. For more details please check the eMS technical guidance for controlling.
Is it necessary to provide more detailed information in the field “description” when filling in the list of expenditure in the eMS?
Yes, the provision of additional information is very useful for all responsible persons in the subsequent workflow (FLC, JS, MA, auditors, etc.). Therefore please provide at least the following minimum information under “description”:
Staff costs: name of staff member to whom the staff costs are connected and months concerned.
Travel and accommodation costs: staff member, date, destination and purpose of the travel
External expertise and service costs: short description of the external service
Equipment expenditure: identification of the equipment.
Are costs connected with meals organised during the project meetings/events eligible?
Catering costs for either internal or external meetings/events are eligible if planned in the application form or clearly linked to the project activities.
When externalised (e.g. catering, restaurant), these are eligible under the budget line external expertise and services. If organizational costs are borne by the beneficiary itself (e.g. ticket from the supermarket for internal meetings) they fall under the office and administration costs and do not need to be reported.
How to proceed if a project partner (PP) exceeds its total partner budget? Shall the FLC certify the exceeding expenditure?
As stated in Article 5 (4) lit e) of the partnership agreement it is the PP's obligation to "only implement changes in its approved budget if they comply with the flexibility rules stated in the Alpine Space project implementation handbook and if prior approval from the lead partner (LP) or the programme bodies has been provided, as appropriate". If a PP exceeds its total ERDF budget, it has to provide evidence to the FLC that this excess spending is in line with the programme flexibility rule: i.e. that compared to the last application form approved, the total project ERDF budget is not exceeded, and the total ERDF budget per partner does not exceed 20% or ERDF 10,000 EUR - whichever is greater. Because the excess spending of a partner must be compensated by another, compliance with the programme flexibility rule must be checked at project level. For this reason, the approval from the LP (or ERDF LP) is required (e.g. new budget allocation approved by the LP/ERDF LP, or email where the LP/ERDF LP confirms the possibility to report additional expenditure in line with the programme flexibility rule). If this approval is not provided, or if the excess spending goes beyond the flexibility rule, the related expenditure shall not be certified by the FLC.
Should the exceeding take place within a regular (but not yet final) report, it is recommended to consider the expenditure items exceeding the budget limitations as sitting duck in the eMS. Consequently, in the case of a later approval of a PP budget increase by the LP resp. the programme bodies, as appropriate, the FLC body could certify the expenditure in question within a following report.
How to proceed if a project partner (PP) spends more than planned in a budget line or work package? Shall the FLC certify the exceeding expenditure?
Generally the FLC body should certify expenditure exceeding single budget lines and work packages only if these changes have been approved by the lead partner (see Article 5 (4) lit e) of the partnership agreement. If approved by the LP, the expenditure shall be certified even if the expenditure of the PP in a budget line or work package goes beyond 20% or ERDF 10,000 EUR. This is because the 20%/ERDF 10,000 EUR must be respected at project level (and not at the level of a single partner allocation in a given budget line/work package). The only exception is the budget line equipment: here any new/modified expenditure must be approved by the JS in advance.
The LP shall generally carefully monitor the financial implementation of the project and shall inform under "problems encountered and solutions found / deviations" in the PR about any considerable budget deviations on project level. Should any budget line or WP exceed the programme’s flexibility rule (20% or 10.000 € - whichever is greater) on project level, the LP shall furthermore indicate on the level of which project partner a necessary ERDF deduction shall take place. The Managing Authority will consider the exceeding amount as financial correction in the eMS and correspondingly will forward a reduced payment order to the Certifying Authority.
FLC related questions
Is it accepted that the FLC certifies a higher amount as eligible expenditure than actually declared by the project partner?
No. Should there be a deficiency in the list of expenditure submitted by the partner and actually an amount higher than declared would be eligible, the FLC should revert the report. The partner could then revise the figures and insert the higher amounts before submitting it again to the FLC for verification.
Shall the FLC certificate be printed from the eMS, signed by the authorised person and sent to the partners by hardcopy? Or is the e- submission in the eMS sufficient?
An e-verification in the eMS is sufficient. If in a member state e.g. signatures of superiors are necessary, the person in charge could anyhow print the certificate and request a signature of the hardcopy before providing with an e-verification in the eMS.
How shall project partners provide to the FLC the relevant documentation of expenditure (e.g. original invoices; proofs of payment public procurement documentation)? Can these documents be uploaded in the eMS?
The documents shall either be forwarded to the FLC by regular mail (or e-copies by e-mail) or checked by the FLC on the spot. They should not be uploaded in the eMS.
What is the retention period for the FLC documentation?
The subsidy contract foresees that the project participants shall “retain for audit purposes all files, documents and data about the project until the MA informs that keeping of documents is no longer required for the project. Other possibly longer statutory retention periods as might be stated by national law remain unaffected by this regulation”. Usually the files are retained on the level of the beneficiary (and not the FLC) and all relevant FLC work results are documented in the eMS, thus the FLC should not be concerned by the regulation on retention periods.
What is the purpose of the “FLC correction type”?
The “FLC correction type” has to be specified by the FLC whenever a deduction is done. This data is required by the European Commission and will be evaluated on a regular basis aiming at the identification and improved tackling of frequent error sources. In case the “FLC correction type” is missing FLC might be asked to supplement this information.
How to proceed if there is a shift between budget lines “external” and “staff” and more staff costs could be reported than actually calculated according to the application?
The budget is to be considered as the plan and framework but has no consequences on the eligibility of expenditure. There might be more or less staff costs certified than actually planned (and more or less staff assigned than actually planned). Please consult also factsheet 4.6 on project changes.
What consequences do changes in the national contribution of project partner have (e.g. national subsidy not foreseen in the AF granted)?
There are no consequences as long as double financing can be excluded (see factsheet 1.4. p. 3: if national public subsidies are in total higher than 15%, the ERDF contribution is reduced correspondingly). There is no need to change the AF as the information on the actual national funding should anyhow be updated regularly within the framework of the partner report and finally confirmed by the FLC within the final report.
Can I involve additional observers than originally planned in the application form?
Yes, this is possible whenever this brings added value to the project. Adding an observer is considered a minor change and does not require a request for change. Timely information on the name and role of additional observers is to be provided to the JS.
Are changes of budget between periods possible?
The budget per period stated in the application form cannot be changed (unless there is a reduction in the approved ERDF). However, in a given period partners may spend more or less than initially planned. If so, these deviations need to be explained in the project report. Projects should also be aware that spending less than 80% of planned ERDF per period expose them to the risk of losing funds (in case of programme decommitment of funds).
How to deal with new project equipment or a change in the equipment planned in the AF?
The LP should contact the JS and establish whether this new/modified equipment is a project output or an equipment item necessary for the project implementation.
In the first case (output equipment), a request for change procedure has to be initiated and it requires the prior approval of the programme committee.
In the second case (equipment necessary for project implementation), the new/modified equipment requires prior, written approval by the JS. The JS email should be kept as part of audit trail and provided to the relevant FLC. This deviation is to be managed within the financial flexibility rule, it is also to be reported and justified in the relevant project report.