The new approach to management verifications for post-2020 programmes is a typical example of the “continuity with a twist” that illustrates the transition from ENI CBC to Interreg NEXT. While the ultimate goal of the control systems remains unchanged, the new approach brings in a series of twist elements.
As in ENI CBC, there are administrative verifications of reports by beneficiaries and on-the-spot verifications of projects. New is a lower administrative burden for programmes and beneficiaries, and a different allocation of responsibilities between the bodies involved.
This Podia covers the management verification process and highlights the main aspects for the key stakeholders. It is targeted at representatives of the Monitoring Committees (MC), Managing Authorities (MA), Joint Secretariats (JS), the authorities at the national level, and controllers.
The continuity and twist of the new approach are further described in the TESIM documents dedicated to the management verifications in the Interreg NEXT programmes” You can find those in our TESIM Library.
Let's start with the continuity! What remains the same? Well, the main goal of the management and control systems (MCS) will still be to ensure that the expenditure included in the programme accounts is legal and regular. However, the way this works in practice will change.
The control system of the ENI CBC programmes had two verification layers:
An auditor or competent public officer examined the expenditure --> this is the so-called expenditure verification under article 32 of the ENI CBC Implementing Rules (IR)
Then, the MA verified the submitted report before accepting the expenditure and including it in the payment requests to the EC (article 26.5 of the ENI CBC IR).
In the NEXT programmes these two layers will be combined into one! That's twist number one!
OK, what else?
The standard should no longer be the verification of 100% of the expenditure
So how do you think this will work out in terms of workload and reliability? Take the quiz!
Whether the MA and JS will experience continuity or twist depends on the control system they adopt: will verification be done by controllers under the responsibility of the National Controller or will the MA be directly responsible for it? Let's look into both options in the following two blocks.
If you are a public officer working as controller in a country that applied a centralised system in ENI CBC, a lot will stay as it is. The same is true for auditors carrying out expenditure verifications when the country they work in selects private bodies as controllers to carry out the verifications. However, no matter which option is selected, there is a significant methodological twist: verifications will have to follow a risk-based approach. This will allow the controllers to work on the basis of samples and focus their work on the risky areas of the expenditure.
From a methodological point of view, the risk-based approach is the crucial methodological difference compared to ENI CBC. During the 2014-2020 period:
in a vast majority of programmes, the expenditure verifications covered 100% of expenditure
all programmes checked 100% of the reports, following the requirements of article 32 of the ENI CBC IR.
However, a risk-based approach is not entirely new: in ENI CBC, on-the-spot verifications where also carried out on the basis of a risk assessment. So you can draw some inspiration from that experience!
Of course, on-the-spot verifications were not mandatory for all projects in ENI CBC. Their frequency and coverage were proportionate to the size of the projects, the level of risks identified by the MA, and the risks identified by the Audit Authority (AA). Something to think about before setting up your new systems!
It is important to guarantee an on-going implementation of projects. Therefore, the administrative verifications of reports should be done within three months after submission by the beneficiary. Check this out reading article 46 of the Interreg Regulation.
In our next video, we'll go into some of the current experience with administrative verifications and expenditure verifications.
A risk assessment of all approved projects, including the risk criteria and weighting, is prepared in writing before any reports are submitted to the MA (and therefore also before the start of administrative verifications).
On-the-spot verifications and controls have been a significant part of the ENI CBC monitoring and control systems. The experience collected can be used to develop on-the-spot approach for verifications in Interreg NEXT. But first let's see what is the focus of so-called on-the-spots!
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