Some say the EC never sleeps… This is indeed true; especially when you look at the changes made in the reference documents of Horizon 2020 during the summer “holidays”. Not only the Annotated Model Grant Agreement (AMGA) has changed significantly – especially, but not exclusively concerning the cost eligibility issues – but a brand-new section for H2020 Audits also showed up! As usual, these were made without any particular notice to the beneficiaries…
My first impression on the new (5.0) AMGA is that, besides many positive changes and confirmation of niche issues (some of them were anyway obvious to those dealing with running H2020 projects), it has become even more complicated and overexplained, mainly when it comes to personnel costs. I think it’s less and less realistic that a beginner, or even a semi-experienced manager gets the full picture on how things should be done correctly in costs reporting. The rules are still clear, I assume, but the annotations list more and more exceptions, exceptions of the exceptions, and finally some further exemptions on the latter ones.
The most important highlights of the updated H2020 AMGA are the following:
- Additional ceilings and protocols for calculating the eligible salary costs, including new ineligible salary components, and clarifications on the fiscal- and monthly-based calculation and their possible adjustment after reporting.
- Adjusted template for the Declaration for persons working full-time, exclusively on the action. Now one must also indicate the work-packages involved and a written explanation on the activities performed by the concerned employee(s).
- Travel costs annotations now explicitly state that the travel costs for invited experts, external advisors and other concerned personnel not employed by the beneficiary are fully eligible. Of course, only when foreseen in the Description of Action. In my view, this has always been meant like this, but now it’s even written down.
- Internally invoiced goods and services: as many mistakes were found during the EC audits performed so far on H2020 projects, it is further clarified how exactly these unit costs can and should be calculated, especially when it comes to shared equipment with third parties. To me, this is the most significant change!
- Slight changes in the third-party articles, primarily to emphasise the responsibility of the beneficiaries over their third parties used.
- Finally, the officers now have even more tools and licences for the potential reduction of grants and recovery of grants paid in case of non-satisfactory performance by the beneficiary, or the consortium.
Of course, these bullet points are just scratching the surface. It’s quite hard to fully understand the necessity and the logic of these changes, particularly when you want to integrate them into the frame of the rules already known. I had several discussions with managers and financial staff members at our project partners, and I must say we all had several different visions on how exactly these changes will affect our projects.
What are your impressions? I would be happy to discuss them in person at one of our training courses: join us in Madrid, Barcelona, Budapest or Vienna.
Next week, I’ll come back on the other main “novelty” of the summer, the EC Audit menu you may all have already noticed in your Participant Portal, and the Audit reference documents section that also recently appeared among the useful docs.