Projects are required to submit two claims a year to the JTS. Apart from the first claim (that also includes the preparation period), all claims cover a six-month period, from the 1st of January to the 30th of June and from the 1st of July to the 31st of December. Projects have a period of two months after each claim period to submit their claim. The partnership therefore submits their claim by the 1st of September (covering the first semester January-June) and by the 1st of March (covering the second semester July-December).
Payments will be made by the Programme on a 'first come first served' basis and therefore projects are encouraged to send in their claims to the JTS as soon as they are able following the claim period. Depending on the quality of the progress report submitted by the project and the time the partnership needs to answer the potential queries sent by the JTS, the grant payment can be made between one month and three months after the JTS has received the claim.
Every project partner needs to have 100% of its own claimed expenditure checked by an independent controller: this is the so-called First Level Control.
There are two different first level control national systems in place within the Programme: a centralized system in Belgium-Flanders and a decentralized system in the Netherlands, United Kingdom and France.
The First Level Control must be performed by an independent and competent controller designated by the Approbation authority at national level (except for Belgium where the first level controller is the central authority itself).
The expenditure declared by each beneficiary can be fully accepted, partially accepted or fully rejected by the first level controller. A detailed report on the control done (First Level Control Checklists) and a certificate attesting the eligibility of the approved expenditure (First Level Control Certificate) must be signed by the first level controller following the control done.
First Level Control shall be done through the following three steps:
Ongoing administrative control on documents;
At least one administrative control at the premises of the beneficiary (complementary to step n°1);
At least one "physical" on-site check in the place of the investment (if existing).
According to this approach, three different templates of check-list are available on the Programme web-site, one for each type of action to be undertaken. Each specific check-list has very tailored questions focused on the elements to be verified during each type of control.
First Level Controllers are required to fill in accurately the check-lists, particularly the sections asking for the methodology applied, the detected findings and the recommendations. They shall also trace in detail the results of the control done using the "Comments" boxes for each tailored question. Each check-list shall be considered as a tool at the disposal of the controller to ensure a complete control and to report any observation and useful explanation.
For the Dutch, English and French First Level Controllers, regular seminars are organized by the Member states and JTS to provide uniform information to the First Level Controllers about the Programme rules and offer an opportunity to share frequently found issues. The participation to these seminars is strongly recommended by the Programme!
First Level Control is generally implemented on administrative documentation with a periodicity of 2 controls per year (by the 1st of March and 01st of September each year). In addition, for each project partner, the appointed First Level Controller shall implement at least one on-the-spot check at the premises of the partner’s organisation to complete the administrative control. In case the partner organisation is in charge of some investment costs in the framework of the project, an additional on-the-spot check in the place of the investment is required (in the last six-month period of the project).
The procedures are different depending on the Member State where each project partner is located:
- In Belgium-Flanders, where a centralised system is in place, the First Level Control is implemented by the Province of West-Flanders.
- For England, France or the Netherlands, where a decentralised system is in place, each Project Partner has to propose a first level controller to the competent National Authority of its own Member State. The National Authority is responsible for the validation of the First Level Controller in compliance with Art.16 of Regulation of the European Parliament and Council (EC) No 1080/2006 (ERDF Regulation). The National Authority can also refuse the proposed First Level Controller if the latter does not match the Programme and/or national requirements.
Yes, each partner needs to appoint a First Level Controller in order to claim ERDF. Only expenditure validated by the First Level Controllers can be deemed eligible.
The Lead Partner's First Level Controller must perform a control on the eligibility of the Lead Partner's expenditure.
In addition, the Lead Partner's First Level Controller has to ensure that the Lead Partner implements well its role of project leader. For this reason, the Lead Partner's First Level Controller must also check that all documents related to the first level controls performed at the project partners' level have been correctly produced and submitted in compliance with the Programme requirements.
The Lead Partner's First Level Controller must ensure the consistency between the Project Financial Reports with the Project Activity Reports and the Application Form. A specific section in the check-list to be used during the 6-months administrative First Level Control is dedicated only to the Lead Partner's First Level Controller.
The price of the First Level Control can vary depending on the partner’s function in the project (Lead Partner or Project Partner), the status of the controller (public or private), the country where the project partner is located, the amount of expenditure per claim, etc. An indicative budget between 3.000 € and 10.000 € per Partner can be deemed reasonable. Anyway, it is important that all project partners foresee from the beginning to include a realistic budget in the application form to cover this requirement. As for all provisions of services, compliance with national and EU public procurement requirements must be fulfilled.