IMPLEMENTATION ISSUES

1. Can 1 auditor conduct expenditure verification for all beneficiaries?

Each beneficiary from Lithuania and Kaliningrad region shall select an auditor using the applicable public procurement procedure. Each beneficiary is separately responsible for having its expenditure validated by the auditor. Lead Beneficiary is responsible for the preparation of overall project report. No consolidated audit report is required to be prepared by the auditor of the Lead Beneficiary. The Lead Beneficiary shall collect the information on selected auditors from each Lithuanian and Russian beneficiary and send the information to the JTS for the verification of selected Lithuanian auditors. The MA has the right of rejecting the selected auditor(s) (see section 7.5.3. of the Guidelines for Applicants and Beneficiaries).

2. Should the consolidated progress/final report be prepared and submitted together with other documents?

The Lead Beneficiary is responsible for preparation of the consolidated progress/final report (after the Lead Beneficiary collects the reports from each beneficiary, which have already been verified by the auditor) prior to preparation of the request for the further pre-financing/payment of the balance. No consolidated report is required to be verified by the auditor and the consolidated audit report is not required to be prepared.

3. Is it allowed to make amendments in the project throughout the implementation period?

Introduction of amendments in the project activities is allowed, however, all amendments must be clearly and sufficiently justified, needed for more efficient implementation of the project and conform to the eligibility rules of the Programme. These amendments cannot affect the overall objective of the project. The procedure of introduction of amendments according to the respective type of amendments shall be followed (see section 7.6. of the Guidelines for Applicants and Beneficiaries).

4. Are the holiday pays and sickness leave eligible to be reported as project costs?

Holiday payments as well as sickness leave are recognised as eligible costs only in case 1) of full-time assignment of the existing position in the beneficiary’s organisation to the project and 2) if a person is employed full-time or part-time by the beneficiary’s organisation to work exclusively for the project. More detailed information on eligibility of expenditure is provided in the Annex I “Detailed rules on eligibility of expenditure” to the Guidelines for Applicants and Beneficiaries.