1. Can expenditures on translation of the Programme documentation be included in the budget heading 5 “Preparation costs”?
The costs for the preparation of strong partnerships are limited to travel and the subsistence costs of staff employed by the beneficiaries incurred by all project beneficiaries in the relation to the preparation of the Grant Application Form (section 4.2.5. of the Guidelines for Applicants and Beneficiaries).
2. What is meant by the “joint financing” cooperation criterion?
The joint financing criterion implies to the financial contribution to the total project budget from the resources of beneficiaries. The amounts of such co-financing are to be decided between the Lead Beneficiary and beneficiaries and their distribution is to be indicated in the Grant Application Form and Partnership Statement(s). It is highly recommended that each Lead Beneficiary and each beneficiary provides its own co-financing to the project budget (see section 1.6. of the Guidelines for Applicants and Beneficiaries).
3. Is it allowed to include costs of interpreting services for activities delivered in national languages in both participating countries?
If it is necessary for the project implementation, it is possible to include the translation services, but the contracts should be awarded with respect to the applicable procurement rules and procedures (see section 7.4. Guidelines for Applicants and Beneficiaries). These expenditures should be included in the budget heading 3 “Supplies, external services and other costs”.
4. Can the amount of co-financing be less than 10% of total eligible costs?
No, the amount of co-financing shall be equal to 10% of the total amount of eligible costs as for any project the Programme funding (grant) shall be equal to 90% of the total amount of eligible costs (see section 1.6. of the Guidelines for Applicants and Beneficiaries).
5. Which monthly accounting exchange rate should be used when preparing the Part II Project Budget of the Grant Application Form (if currency is other than EUR)?
When preparing the Project Budget, it is recommended to use the monthly accounting exchange rate for the last month for which the currency exchange rate is defined at the time of submitting the Grant Application Form at the InforEuro: https://ec.europa.eu/budget/contracts_grants/info_contracts/inforeuro/index_en.cfm.
Expenditure incurred in a currency other than Euro shall be converted into Euro using the monthly accounting exchange rate of the EC when preparing progress and final reports (see section 7.3.4. of the Guidelines for Applicants and Beneficiaries).
6. Can a beneficiary located in the adjoining region procure the equipment during the implementation of the project?
When procurement of goods or external services are planned during the implementation of the project, the expenditure must be planned in Budget Heading 3. If the equipment planned to procure is registered in the accounting system of the organisation as a short-term asset according to the accounting policy, then the acquisition of such equipment should be planned in budget Heading 3. Equipment and other investments (including software) that is considered and registered to be the long-term assets should be planned under Budget Heading 4. If the organisation is located in the adjoining region, the long-term investment is not supported and no expenditure should be foreseen in Budget Heading 4.
Please note that all project costs must meet the eligibility criteria listed in the section 4.1 of the Guidelines for Applicants and Beneficiaries and, in particular, all planned costs must be necessary for the implementation of the project activities and the achievement of the results.
7. Can we plan to increase the salary of regular staff then planning the expenditure as the intensity of their work during the project implementation period will increase?
According to the Programme rules there are 4 options to calculate staff costs when planning the project budget. If the employees of the organization will execute the project activities as well as their regular tasks, one of the proposed options should be chosen:
1) Part-time assignment of the existing position in the beneficiary’s organization to the project on a fixed percentage of time/ flexible number of hours. Thus, the employee shall dedicate a fixed percentage of time/ flexible number of hours to work on the project within his working day and the implementation of the project shall not result in any increase of salary and/ or additional income/ payments for a person working in this position.
2) A person is employed full-time or part-time by the beneficiary’s organization to work exclusively for the project. This position has not existed before the project, it will exist only during the project. If it is planned to engage the employee to work on this position, it should be borne in mind, that internal combining of two positions in accordance with the legislation of the Russian Federation (article 284 of the Labor Code of the Russian Federation) implies that "duration of labor hours when combining jobs should not exceed 4 hours per day" and "within one month duration of labor hours when combining jobs should not exceed half of monthly rate of standard working time." Therefore, if it is planned to increase the workload of employees who are already employed by the organization, duration of additional labor hours under this kind on contract must not be more than 4 hours a day and the costs shall be considered eligible if they do not exceed those normally borne by the organization.
Please take note that each chosen option shall be enforced and proved by the set of supporting documents listed in the Annex 1 “Detailed rules on eligibility of expenditure” to the Guidelines for Applicants and Beneficiaries.
If it is assumed that 4 hours are not enough time to perform the project tasks, there might be a need to employ a new staff member to execute project activities within the newly created position according to the option 4 indicated in the Annex 1 to the Guidelines for Applicants and Beneficiaries.
Please note that contracting agreements regulated by civil law (гражданско-правовые договоры/договоры подряда) are not considered as staff costs and cannot be included under the Budget Heading 1. Such type of contracts can be planned under the Budget Heading 3; however, costs of the subcontracting project beneficiaries or employees of the project beneficiary are considered as ineligible.
As well please note that the participation in the implementation of the project alone is not the ground for additional bonuses, premiums, or for increase of the usual rates of the salaries, bonuses, premiums. When choosing options 2 and 3 the employee should get the same salary as before the project as the staff costs should be reported proportionally to the worked amount of time within the working day and these costs can be paid from the project budget or from own co-financing of the beneficiary.
For more detailed information on options to calculate staff costs as well as other provisions concerning the costs planned in the Budget Heading 1 please refer to the Annex 1 “Detailed rules on eligibility of expenditure” to the Guideline for Applicants and Beneficiaries.
8. Point 7.8.2 in the Guidelines for Applicants and Beneficiaries (hereinafter – Guidelines) indicates that: „...evaluation of the project and expenditure verification shall be performed immediately after the end of the project implementation period. It is important to include to the final report all the costs related to closure of the project (such as the costs related to final reports, expenditure verification and evaluation of the project).“ Could you please indicate the deadlines when the costs for expenditure verification should be paid so that they are eligible?
Eligibility of costs is described in the section 4 of the Guidelines and general principles for eligibility of costs – in the section 4.1 of the Guidelines.
Eligible costs are costs actually incurred and paid by the Lead Beneficiary and beneficiaries which meet all of the following criteria: 1) they are incurred and paid during the implementation period of the project. In particular: (...)
Thus, audit costs related to expenditure verification should be incurred (and paid) within 2 months after the implementation period of the project and must be included in the financial tables of the final project progress report.