INTERREG IVC Seminar Approbation Bodies - Amsterdam
On 6 October 2011 the INTERREG IVC Approbation Bodies in charge of designating the first level controllers in countries with a decentralized control system met in Amsterdam. Out of 16 countries having opted for a decentralized first level control system under INTERREG IVC, the meeting gathered 26 participants from Belgium, Bulgaria, Cyprus, Denmark, France, Germany, Italy, Poland, the UK, the European Commission, the INTERREG IVC Audit Authority and Managing Authority/JTS.
Erwin Siweris (JTS) welcomed the participants and opened the day by introducing together with Marie Lèbre (JTS) the state of play of the INTERREG IVC programme.
Xavier Delvart and Eugenia Triantafyllopoulou from the European Commission (DG Regio, Audit Directorate), then gave a presentation about the designation of FLC according to Article 16 of Regulation (EC) No. 1080/2006. The EC gave an overview of the background considerations for introducing such an article to the Regulations in 2006, the main features of the DG Regio audit strategy as well as the first results of audits carried out in 2010 and 2011. On the latter, even if most first level control systems in the MS already audited seemed to work well, needs for improvement were identified with regard to project documentation (missing justifications for staff/overhead calculations); public procurement procedures and the quality of first level controllers work and its documentation.
In an interview with Petra Geitner (JTS), Tuula Manalius (Finland), Christophe Uliasz and Marjolaine Hubert (France), then shared with the participants their experience with the designation of FLC. They introduced the institutional framework they operate in and described the approval process. Whereas in Finland the designation of FLC is carried out by a Ministry at national level, the approbation in France is done for all partners by a regional body. The importance to pro-actively contact the project partners to initiate the approval process was highlighted as well as the possibility to publish standard documents on the INTERREG IVC website. Both bodies also provide further guidance to project partners and FLC either through training as it is the case for Finland or also through documents such as standard terms of references for the procurement of an external controller in France. The interview was followed by a presentation given by Anelia Stoikova (Bulgaria). The Bulgarian FLC system is characterized by a pool of control experts. The pool is constituted through competition; the selection process also includes an exam. For each reporting period, the project partners are attributed a FLC from this pool on a random rotation principle. The system is secured through quality checks and training carried out at national level.
The approbation bodies' activity does not stop with the designation of FLC. The approbation bodies are also intervening as a FLC helpdesk answering to FLC question. In her presentation Stefania Amorosi (JTS) replied to questions frequently raised in this context and submitted before the seminar by the participants. She highlighted that project partners should be reminded of the importance to carefully plan the control process to minimize delays. Especially with regard to the decommitment risk the programme is facing for 2012, approbation bodies were invited to follow closely the appointment of FLCs and to approve them timely before 30 June 2012 so that all projects are in a position to submit their report on 1 October 2012. The FLC's obligation to carry out on-the-spot checks completing the administrative checks was also mentioned. Concerning the possibility to use sampling for the on-the-spot checks and during administrative checks, Stefania insisted that the methodology for the selection of the sample has to be sufficiently documented and that sampling is only possible provided that the sampling basis is sufficiently representative/constituted of documents of the same nature.
With the help of a practical case study, Johanna Baehn and Katja Ecke (JTS) drew the approbation bodies' attention to the importance of appropriate control documentation. In work groups the approbation bodies reviewed an example of a control report and expenditure list. They identified as main weaknesses inconsistencies between filling the different documents and sections, a lack of comments clarifying the control steps undertaken and the corrective measures applied in case of a finding. Reviewing a control report and list of expenditure was suggested as one possibility to monitor the quality of FLC work and its documentation.
Another option of quality assurance is also the organisation of training events. Philippe Rousseau (Belgium) shared with the participants his experience from organising a joint training event for controllers and partners from the IVB NWE and IVC programmes. A half day format had been chosen combining presentations given by Enterprise Flanders, the second level audit representative and the IVC JTS with an interactive workshop session encouraging participants to network and exchange on common first level control and eligibility questions.
The presentation of second level audit results given by Mahesh Bhardwaj (JTS) focused on findings identified in the field of staff, administration, travel, public procurement and the quality of FLC performance more generally. Suzy Gappa representing the CICC as INTERREG IVC Audit Authority (France) in this context underlined that particular attention should be paid to these issues at the stage of FLC approval and during approbation bodies' quality controls. The JTS also informed the approbation bodies that the communication of second level audit results, CA quality checks (as well as of any other checks) will not only be done to the MC members but also systematically addressed to the approbation bodies to ensure a good flow of information. In case of severe problems with FLC encountered during the monitoring of progress reports the JTS already now sends emails directly to the MC members and approbation body of the country concerned.
The last workshop dealt with the evaluation of the current system in order to identify recommendations for the future. Participants discussed in 3 groups around a set of questions introduced by Elisa Milos (JTS). In the conclusion of the session, participants seemed to agree that centralised and decentralised control systems should continue to co-exist in the future giving each Member State the possibility to set up a control system reflecting its administrative culture, the number of partners participating in the programme, its past experience with the control of EU-funds and budgetary considerations. There was discussion across the groups as to whether or not the role of the approbation body should be precisely defined.
There was a general call for the harmonisation of rules and control documents across INTERREG programmes (ex. rules and timesheet model for the calculation of staff costs). The path of simplification already followed by INTERREG IVC should be further continued and explored. In a control system particular emphasis should be placed on training much more than on control (and control of the control) considering that errors rarely arise from intentional fraud, but from a lack of knowledge and complex rules requiring further explanation and guidance.
Overall the meeting gave a good overview of the different practices and characteristics of a decentralized first level control system and how it is put into practice across the different countries. The meeting was also a good opportunity to network and to exchange on the different roles that the approbation body in the decentralized first level control system is actually assuming. The approbation body is not as such foreseen in the regulations but was set up to comply with the stipulation of Article 16 of Regulation 1080/2006 in a decentralized context. The meeting has shown that the approbation bodies functions in practice goes well beyond the designation of first level controllers and involves further tasks such as FLC support, training, quality checks to help to secure the system - and this in the Member States' own interest considering that final financial responsibilities lies with the Member State. The EC invited the participants to systematically report on the various activities undertaken by the approbation bodies in the context of the annual implementation report - a suggestion that the JTS together with the Approbation Body and Monitoring Committee representatives will certainly follow-up on.
Presentations and other supporting documents can be downloaded here.