FAQ Questions and answers relating to the 2014 call for proposals for NGO operating grants for funding in 2015 (Latest update September 2014) CORRIGENDUM: In the first version of the Application Guide, pages 27 and 40, where it said "For the requirements relating to the audit report, please see 3.5.", it should read instead "For the requirements relating to the audit report, please see 6.4.2". Contents General... 2 Eligibility... 3 Administrative issues (A form)... 4 Technical issues (T form)... 5 Financial issues (F form)... 6 General... 6 Form F1 Income and revenues... 7 Form F2 Personnel... 8 Form F3 Travel and subsistence... 9 Form F5 External assistance/subcontracting... 10 Form F6 Other direct costs... 12 Grant agreement... 13 1
General 1) Question: Can proposals be submitted in other languages than English? Answer: It is recommended that applicants fill in the technical part of the proposal in clear English, although proposals may be submitted in any of the official EU languages, except Irish or Maltese. Note that the grant agreement, project management, formal reporting and all communication with the EASME will have to be in English. 2) Question: Should the documents submitted with the proposal be stapled or not? Answer: Preferably, the application forms should be submitted un-stapled, whereas the annexes can be stapled. 3) Question: Should audit reports be submitted in original or are copies accepted? Answer: Audit reports from the two previous years can be submitted as copies. 4) Question: Can the reports from the auditors that must be attached to the proposal be presented in other languages than English? Answer: Yes, all EU languages are accepted, but if English versions are available, attach them to the application as well. A translation does not have to be by a certified translator). 5) Question: What is the legal basis of Operating grants? And what is the budget for 2014-2020? Answer: The legal basis is the new LIFE Regulation (No 1293/2013) and the LIFE multiannual work programme for 2014-2017 (MAWP) 1 which allocates EUR 38.6m to operating grants for the period 2014-2017. 6) Question: How will the EUR 9 million be split? Answer: While 7 million come from the Sub-programme for Environment and 2 million from the Sub-programme for Climate Action, there is no split related to proposals. The decisions on the proposals to be funded will be made based on their quality and they will be ranked in one single list. 7) Question: What is preferable, staying in one objective (environment/nature or climate) or to cover both? Answer: There is no preference in this regard; what is important is the quality of the proposal, be it focused on one area or covering both. 1 http://eur-lex.europa.eu/legal-content/en/txt/pdf/?uri=celex:32014d0203&from=en 2
8) Question: About the provision on not being able to apply for a bigger amount as requested the last time: Will this be the same the next year? Answer: The rules for the next call are not yet defined so it is too early to say anything about this. Eligibility 9) Question: Is it a problem for eligibility if the majority of the applicant s member organisations are outside of Europe? Answer: International organisations are only eligible if they fulfil all eligibility criteria: be a non-profit-making legal person, independent from government and public authorities, from political parties and commercial organisations; be primarily active in the field of environment and/or climate action and involved in the development, implementation and enforcement of EU environmental and/or climate policy and legislation; operate at EU level with a structure and activities covering at least three EU member states; be legally registered in one of the EU28 Member States or in a third country in accordance with Article 5 of the LIFE Regulation (see Application Guide, pp. 9-10 for full details). 10) Question: Which third countries are eligible for funding? Answer: Section 3.4 of the Application Guide refers to third countries in accordance with Article 5 of the LIFE Regulation, which are eligible only if they have a bilateral agreement with the EU. At the moment (September 2014) there is no such agreement with any country outside the EU, and none is under elaboration. 11) Question: In the case of a new network, what documents are necessary to present? Answer: For the possible exception from the 2-years requirement for new networks, audit reports from the two previous years from three founding members in three EU Member States should be provided, together with the financial viability forms (F8) for all of them, as well as latest activity reports (for assessment of technical and financial selection criteria). 12) Question: Is the fact of having three offices in three different EU member States sufficient to fulfil the eligibility criterion? Answer: Yes, this is considered satisfactory according to the current rules. You usually prove this by your statutes or membership list. 3
13) Question: In the context of the eligibility criteria, what is meant by independent? Answer: It means independent, both financially and politically, in particular of government and other public authorities and of political parties or commercial interests. This is normally proved by the organisation's statutes. 14) Question: As for the obligatory Activity Report that needs to be submitted together with the application (for assessment of technical soundness) can this be an Activity Report used for other donors? Answer: If the Activity Report used for other donors contains a good picture of the activities, it can be used. It should be a yearly report that describes the organisation s activities of the previous year. It can take various forms, and different formats are accepted as long as it gives a good picture of the activities in order to assess technical soundness. It should be the most recent available report, and it should preferably be in English. 15) Question: The last activity report is a mandatory annex to the grant application. For organisations that were benefitting from an NGO operating grant in 2013: Is it acceptable to send the report produced for the purposes of the final payment the preceding year? Answer: Yes, it is acceptable, but it is preferable to attach the usual yearly activity report of the organisation. Administrative issues (A form) 16) Question: In form A4 it is asked to indicate whether a member organisation is active in the implementation of the work programme (yes/no). What does this mean? Answer: Yes should be indicated only for member organisations that have a prominent and active role in the implementation of the work programme. Please note also the answer further below on eligibility of costs for members. 17) Question: In form A6, should we mention only the grants for which we were main beneficiary, or also grants in which we are partners? What is the level of details expected? Answer: You have to include all EU contribution that go through your accounts. You have to inform us of the form of financing, the year of attribution, the reference of the financing and the amount. 18) Question: Are forms signed by co-financers needed? Answer: No, the old A6-form where co-financers needed to sign their commitment to provide matching funds is no longer needed. 4
19) Question: What are the requirements for the narrative reporting? Answer: A format for the final activity report will be made available on the web page and sent out to beneficiaries at the project start. The reporting should be based on the information that has been presented in the application and included in the signed contract. The activities carried out should be described, and in case some were not fully carried out, an explanation should be given. Furthermore, impacts should be reported. Technical issues (T form) 20) Question: How is the budget of the proposals assessed? Answer: The assessment of the budget in relation to the proposed activities will be made by evaluating how appropriate the budget is in terms of value for money, overall amount and distribution between cost categories (Award criterion 7 technical and financial coherence of the work programme). 21) Question: Is there a limit to the length of the description of the work programme using the T form? How detailed should the description be? Answer: The whole T section should not exceed a maximum of 50 pages. Furthermore, the work programme should be described only using this form without attaching other documents as annexes. The description should be succinct and to the point but sufficiently detailed to allow a proper assessment. The description of activities and results should be as concrete as possible. Clear links to EU policy initiatives should be given. 22) Question: Since the pre-financing is only released after the signature of the grant agreement, can we plan the majority of the activities after that date? Answer: The earliest possible date for eligibility of costs is 1 st January 2015, or if later the first day of the organisation's financial year 2015. Before signing the contract, also retroactively, you work on your own risk. However, whenever it is difficult to advance money from your own resources, major activities can be planned for the later part of the year. It would be important to describe these considerations in the application. 23) Question: How detailed should the information on activities outside the work programme be (T2.3)? Answer: Titles are enough if they are self-explanatory; otherwise a summary of a couple of lines should be given. The purpose is to provide an understanding of the full set of activities of the organisation. If the establishment or increase of a reserve is planned, this should be mentioned here. 5
Financial issues (F form) General 24) Question: What is the annual budget for operating grants? Answer: For this year's call the budget available is EUR 9m. For the following years the budget still needs to be determined. For the period 2018-2020 the budget allocation will be decided at a later stage. 25) Question: What is the average amount of grants, and what are the highest and lowest levels? Answer: As a point of reference, the average amount of the NGO grants is around EUR 325.000. The maximum amount that may be awarded by the EASME is EUR 900.000. For organisations that have been awarded an operating grant under the previous LIFE programme in 2014, the maximum amount is limited to the originally requested amount for 2014. In all cases, the maximum EU contribution is 70% of total eligible expenditure. Only costs necessary for the implementation of the work programme must be listed in the estimated budget. Moreover, they must be reasonable, justified and comply with the requirements of sound financial management in particular regarding economy and efficiency. Matching funds must be available and the organisation must have the capacity to carry out the work programme. 26) Question: Would a lower requested co-funding rate be an advantage in the evaluation? Answer: There is no such award criterion. Applications are evaluated at the same basis independently of requested co-funding rate. 27) Question: What costs for member organisations are eligible? Answer: No costs incurred by member organisations are eligible. Reimbursement for travel for representatives of member organisations invited to meetings organised by the beneficiary could be eligible, but not staff costs, as for example the commissioning of a study: This would be sub-contracting and would then have to follow sub-contracting rules. 28) Question: Is it possible that selected applicants will be offered a small percentage of the requested amount? 6
Answer: A lower contribution might be proposed as was the case in the past. However, in principle, the amount requested would be offered unless during the revision phase it would appear that the budget submitted with the proposal was excessive. 29) Question: Can other EU grants be used to make up the 30% cofinancing (or more) from other sources? Answer: No, other EU grants cannot be used as matching funds. 30) Question: Is it possible to build up a reserve with the grant from the EU? Answer: It is not possible to finance a reserve with the grant from the EU. The establishment and/or the increase of a reserve, is not eligible expenses. However, it is possible to finance it from other sources, which need to be clearly outside the work programme covered by the operating grants. For example, the new Financial Regulation allows the use of donations as reserves. 31) Question: Are costs for reimbursement of volunteers eligible? Answer: If volunteers are paid, these costs could be eligible under the staff cost category. Furthermore, travel costs and related costs like other specific costs are eligible. 32) Question: Can in-kind work be reimbursed? Answer: No. In kind contributions are part of the ineligible costs. Contributions in kind shall be presented separately in the estimated budget to reflect the total resources allocated to the action. Form F1 Income and revenues 33) Question: When must co-financing (level and evidence) be confirmed? Answer: Estimated co-funding should be indicated in the application Form F1. Co-funding commitments are no longer required. 34) Question: If additional income is secured during the year how should this be dealt with? Answer: Additional income and corresponding activities can be added during the year without problem. The maximum amount of the EU grant will not change, unless a profit would be gained due to maintaining the EU funding. It should be clearly described in the final reporting that this additional income was secured, and how it was used for the implementation of the work programme. 7
All income generated by the work programme as well as all financial contributions assigned by the donors to the financing of the eligible costs shall be declared in the final financial reporting in Part B. 35) Question: Can membership fees be part of the minimum 30% matching funds? Answer: Yes, this is a common source of matching funds. 36) Question: How should membership fees be presented? Answer: The amount should be indicated in form F1. If the list of members is long, it is sufficient to indicate the global amount. 37) Question: How do we deal with other income from the EU budget, such as a project grant? Answer: Any activities financed by other EU sources must be excluded from the work programme and the budget. It should be mentioned in form A7 and T2.3 as well as in Part C "Costs covered by other EC financing" and Part D "Other EU financing" of the estimated budget. In addition, you may not charge overhead costs for these project grants, as they would be included in the operating grants. Form F2 Personnel 38) Question: Is it possible to employ staff residing outside of the EU? Answer: Yes, staff having an employment contract and being on the payroll of the organisation, may have their place of residence outside the EU. In all cases, requirement of national legislation for employees must be respected. Otherwise, it would be considered subcontracting. 39) Question: Does the budget breakdown have to be by person or are more general categories possible? Answer: It should be by person/position. If the name is not yet known, the position is sufficient. If the estimated amount of a salary is unusually high, a request for proof in the form of last year's salary slip will be requested during the phase of the revision. 40) Question: Can extra-legal costs (pension plan, extra sickness insurance, lunch checks etc.) be included in personnel costs? Answer: Any costs can be included that are covered by the employment contract and which are in line with your usual policy on remuneration. 41) Question: What is meant by "premises of the organisation"? Could offices in other countries be considered? 8
Answer: Yes, premises of the organisation do not necessarily have to be the head-quarters but could be sub-offices or branches, even located in other countries. 42) Question: Are working hours for board members spent at board meetings eligible costs? Answer: Board members shall be "a managing body" of the beneficiary (main applicant) if the meeting is related to the work programme, working hours spent can then be eligible. However, if the board member does not receive a salary (i.e. if not on the payroll) then no staff costs can be declared. 43) Question: If staff works both under the operating grant and under specific action grants, what is the best way of recording this? Answer: Time sheets are highly recommended. Other types of systems to record working time are also accepted. Documentation setting out the time/proportions to be allocated by each staff member to the different activities should be available. Such documentation is not requested at the time of application nor final reporting for the operating grant, but will be requested in potential monitoring visits or audits. If the allocation of the time to the work programme cannot be demonstrated, related costs might not be considered eligible! 44) Question: Are there any salary grids or ceilings for various staff categories? Answer: No, they should be in line with the beneficiary's usual policy on remuneration. Form F3 Travel and subsistence 45) Question: What should be the level of detail for travel and meetings? Answer: It is understood that, at the time of the application, it may not be possible to foresee exactly what travel and meetings will take place during the funding year, so details cannot always be given. However, best possible estimates should be indicated in the application. All individual trips do not have to be indicated, but could be summarised or grouped by purpose or destination. 46) Question: Is it possible to hold meetings or workshops in third (noneligible) countries? Answer: This would be possible if the cost is incurred by the beneficiary and if it is justified (why must the meeting/workshop take place there?) and cost-efficient. Of course, the costs have to be related to the work programme of the organisation and be incurred, reasonable, necessary, following the principles of sound financial management (cfr. article II.19.1 of the GA, that establishes the criteria for eligible costs). 9
Form F4 Other direct costs Question: What costs should be reported under this category? Answer: The costs arising directly from requirements imposed by the grant agreement (dissemination of information, specific evaluation of the action, translations, reproduction, etc), including the costs of any financial services (especially the costs of financial guarantees), and all other costs that cannot be included in the other categories (like e.g. costs of consumables and supplies, communication costs, heating, paper, copies, etc provided that they are identifiable and assigned to the work programme. Furthermore, overhead costs should be included here. Form F5 External assistance/subcontracting 47) Question: Is free-lancing considered as sub-contracting? Answer: Yes. See more on the distinction between staff and sub-contracting in the application guidelines under personnel. 48) Question: Can temporary staff be considered as personnel? Answer: Temporary staff employed under the work programme can be considered as "personnel"; however it mostly depends on the nature of such a contract. See more on the distinction between staff and sub-contracting in the application guidelines under personnel. 49) Question: Is sub-contracting outside of the EU accepted? Answer: In principle yes, but there needs to be justification on the reasons. Of course it must fulfil all other requirements for sub-contracting. Furthermore, it would need to be demonstrated that the expertise is necessary and relevant and a description should be added how the implementation will benefit the EU. 50) Question: Can member organisations be sub-contracted? Answer: Yes, they can, if a member organisation is to undertake and carry out part of the work programme. In that case, however, care must be taken to make sure that all principles for sub-contracting are respected, in particular conflict of interest, best value for money, and equal treatment of candidates. No advantage should be given to the members because of their specific status. 51) Question: Is it possible to envisage support for third parties? How do you interpret the Grant Agreement text which seems contradictory in the general and specific conditions. 10
Answer: The specific conditions prevail over the general conditions in the grant agreement, so support for third parties is not possible. 52) Question: Is there a minimum threshold for sub-contracting under which a tender procedure is not necessary? Answer: Where the implementation of the work programme requires the award of procurement contracts, the beneficiary must award the contract to the bid offering best value for money or the lowest price (as appropriate), avoiding conflicts of interest. Moreover the beneficiary is expected to clearly document the tendering procedure and retain the documentation for the event of an audit. For procurement contracts with a value of more than EUR 60 000, the beneficiary will request three offers from three different companies. For procurement contract with a value of more than EUR 125 000, the beneficiary will publish a call for tender in a legal publication website or in the Official Journal of the European Union. (See Art. I.7 of the grant agreement) 53) Question: What are the rules for subcontracting less than EUR 60.000? Answer: The general rule is best value for money. For subcontracting of less than 60.000, the rules of the organisation for subcontracting should apply. If there are no such rules, they should be put in place. 54) Question: Is the threshold set per year, per supplier or per contract? What about framework contracts? Answer: The threshold of EUR 60.000 and EUR 125.000 is per estimated value of contract. If the intention is to use a framework contract, the beneficiary is expected to clearly document the procurement procedure used to establish the framework contract and retain the documentation for the event of an audit. 55) Question: Are costs for print service considered as sub-contracting? Answer: It depends on the case and the nature of the work. For example, if an external print shop is contracted it would be considered as sub-contracting, whereas if internal printers are being used it would be considered as other costs (covering the costs for paper etc the hours are then declared under the staff costs). 56) Question: What is the difference between subcontracting and external assistance? Answer: The two wordings have the same meaning. 57) Question: How can a distinction be made between "sub-contracting" and for example overheads within the "other direct costs" category? Answer: Sub-contracting is a single purchase of services not of goods. 11
But if the services are necessary for the normal functioning of the organisation, e.g. hiring a bookkeeper, cleaning offices or auditor, then this can be included with the "other direct costs". A project to develop a new web page could be "sub-contracting" while maintenance of an existing web site could be "other direct costs". 58) Question: The application guidelines specify that any service undertaken by an external party is considered to be subcontracting. What is meant by service? Answer: All single, specific services e.g. physical or intellectual activity and supplies contracts are covered by this definition. Any other "regular" services or staff, or indirect costs like heating, cleaning, insurance, etc., even if covered by service contracts, should be reported under other direct costs. 59) Question: How can the operating grant be combined with another grant which entails a restriction (pre-defined service providers) as to the sub-contractors that can be used? Answer: If the sums involved for the sub-contracting are small it may be ok to award them without a formal prospecting of the market. If however the sums are bigger amounts it would be difficult to prove that the sub-contractors imposed by the other grantees give the best value for money. In exceptional cases monopoly situations may be used to justify the use of negotiated procedures without market prospecting. 60) Question: What does the column activity ref. refer to? Answer: This indication should make it possible to link the sub-contracted action with the work programme (T-form). The reference could be in the form of a page reference, paragraph numbering, activity number etc. Form F6 Other direct costs 61) Question: What costs should be reported under this category? Answer: The costs arising directly from requirements imposed by the grant agreement (dissemination of information, specific evaluation of the action, translations, reproduction, etc), including the costs of any financial services (especially the costs of financial guarantees), and all other costs that cannot be included in the other categories (e.g. costs of consumables and supplies, communication costs, heating, paper, copies, etc ) provided that they are identifiable and assigned to the work programme. 62) Question: If I have an operating grant, is a computer eligible? Answer: It can be considered as direct cost (equipment). Please assign a percentage of allocation that is defendable (e.g. if the person working on it is working full time on the work programme then 100% of the depreciated cost can 12
be charged otherwise a percentage of allocation in line with the use for the work programme is needed). 63) Question: What are the rules for overhead costs in case of an action grant in combination with the operating grant? Answer: If the beneficiary of an EU operating grant receives at the same time an EU grant for an action, overheads cannot be charged to the latter. In general terms if an additional specific action is carried out with financial support outside the normal activities which give rise to the operating grant, it is essential, so that these two assisted operations (the work programme on the one hand and the specific action on the other) can be monitored and controlled separately, that the body has the management and accounting tools it needs to manage such a situation in an accurate and verifiable way. 64) Question: Does EASME have recommendations for a method for allocating overheads? Answer: Please note that under the operating grant all costs are direct costs. Costs which are not only related to the NGO grant work programme should be charged by applying an allocation percentage in line with the usage for the work programme. The allocation percentage should be defined in a way that it is reasonable and defendable. A beneficiary will need to be able to demonstrate this upon request. Grant agreement 65) Question: Contracts will be signed in March 2015; will grants cover the period from 01/01/2015? Answer: Yes, the grant will cover retroactively the period from 01/01/2015 with the earliest start date however being the start of the financial year of the NGO. Of course, until signature of the Grant Agreement, the NGO works on its own risk (due to the risk of not getting the grant. 66) Question: Once the grant agreement has been signed, is there any flexibility in case the distribution of actual expenditure between budgetary categories is different from the foreseen budget? Answer: There are two forms of flexibility. Firstly, there can be budget transfers between budget categories limited to 20% of the total eligible costs of the action without prior notification as long as the implementation of the work programme is not significantly affected. Secondly, for changes of more than 20% or with changes affecting the implementation of the work programme significantly, an 13
amendment can be made if approved in advance by the EASME. A request for an amendment must be sent to the EASME in due time before the end of the grant year, but always before the relevant costs were incurred. A general update of the budget, to avoid cuts of amounts above the allowed 20 %, would not automatically be considered to be a reason for a formal amendment. It should also be kept in mind that the process for a formal amendment of the grant agreement is relatively heavy, so it is recommended to introduce requests for amendments well in advance. 67) Question: If a change in the work programme does not exceed the 20%, but implies the deletion of a complete activity is an amendment of the grant agreement necessary? Answer: It is suggested to contact the EASME if there is a risk that the change could qualify as being "significant". Amendments must be requested in advance. 68) Question: If a change relates to involving a new sub-contractor, does this have to be approved by the EASME in advance? Answer: Approval of the subcontractor itself is not necessary as long as its selection followed the rules set-out for subcontracting. However, the subcontracting task must have been foreseen. If the transfer between budget categories exceeds 20%, a request for amendment is needed. 69) Question: Will audits of the funded organisations be carried out? Answer: The EASME (or its designated representative, including the Commission/European Court of Auditors) can make ex-post audits of some selected organisations up to 5 years after the end of the grant period. 14