Replies EC financial officer /Webinar Blue-Action legal and financial 16 February 2017
Q1/ Line GarnesSteffensen: I was wondering if the P.I. has to deliver time sheets as well? Their salary is not paid from the project
If the salary is not paid from the project, no personnel costs are claimed and consequently no need for time-sheets.
Q2/ SolmundurJonsson: Regarding exchange rate - usually in EU projects we use exchange rate on the last day of each period. Is that OK or do we need to use exchange rate for the month the cost is booked?
Conversion of costs into EUR must be made according to your usual accounting practices. In that case, if you're using the exchange rate on the last day of each period, it's OK.
Q3/ World Ocean Council 2: What is the definition of inhouse consultants? They seem to be consdered as salareid employees, filling in time sheets..
In-house consultants are persons who work for the action. They have to fulfil the general conditions to be eligible (i.e. incurred/used during the action duration, necessary, linked to the action, etc.; see Article 6.1(a) and (b)).
- There must be a direct contract between the natural person (individual) and the beneficiary.
- The contract cannot be with a third party legal entity (e.g. a temporary work agency).
- The person must work under the beneficiary’s instructions and, unless otherwise agreed with the beneficiary through a teleworking agreement, on the beneficiary’s premises
- It must be the beneficiary who decides on, designs and supervises all work. The consultant must report to the beneficiary.
- The result of the work carried out must belong to the beneficiary
- The beneficiary must keep records of the hours which the person worked for the action (e.g. time-sheets etc.; see Article 18.1.2).
Also note that: Staff provided by a temporary work agency — A contract with a temporary work agency for the provision of staff qualifies typically as a purchase of services (unless the temporary work agency carries out directly some task of the action — in which case it can be considered as subcontracting). Thus, although NOT eligible as personnel costs, the costs can be charged under other budget categories (i.e. D.3 other goods and services or B. subcontracting), if they comply with the eligibility conditions (especially best value for money and no conflict of interest; see Articles 10 and 13).
Q4/ Catherine Coleman: There has been a recent update to the MGA regarding internally invoiced costs - can you give some guidance on what internal costs can now be claimed. For example facility rates.
Internally invoiced costs — Internally invoiced costs (i.e. where the use of certain resources is shared between different units of the same organisation and the costs of their use are declared through internal invoices) may be eligible if their use and the usage (number of hours) for the action is specifically recorded and it is mentioned in the invoice.
The internal invoice must refer to the use/dedication for the action of specific resources (e.g. per researcher, piece of equipment, etc.).
Example (acceptable internal invoice): Internal invoice with 16 hours of the technician doing the analysis and 10 hours depreciation of the testing equipment used.
Example (not acceptable internal invoice): Internal invoice with a global price for the use of a research infrastructure (e.g. laboratory) or for a service (e.g. an analysis).
The costs must be declared under the budget category that corresponds to the invoiced resource (e.g. personnel, equipment, other direct costs, etc.) and must fulfil the eligibility conditions set out in Article 6.1 and 6.2. Internal invoices may NOT include indirect costs elements or profit margin or mark-up.
Internal invoices for the work of personnel must be supported by time records (see Article 18.1). The hourly rate must be calculated as described in Article 6.2.A. Internal invoices for the use of equipment must be limited to the depreciation for the relevant reporting period (only the part of the depreciation cost corresponding to the time the equipment was used for the action during that reporting period can be declared.) The use of the equipment must be properly recorded in order to allow direct measurement of the use for the action and to ensure auditability (see Article 6.2.D.2).
It is NOT possible to calculate an all-in average cost of internally invoiced equipment including, for instance, allocated indirect costs (e.g. maintenance).
Self-produced consumables — the eligible cost of a consumable is generally determined by its purchase price. The purchase price is the actual direct cost of the consumable for the beneficiary. However, consumables that are manufactured (produced) by the beneficiary itself do not have a purchase price. The consumable is normally recorded in the accounts of the beneficiary (as part of the inventory) for its cost of production. In consequence, the eligible costs of self-produced consumables must be determined on the basis of its accounting value under the following conditions:
- only the direct costs within the accounting value of the consumable (cost of production) may be charged. If it is not possible to accurately determine the part of the accounting value corresponding to the direct costs then the beneficiary may charge the accounting value divided by 1,25 (in order to remove the H2020 flat-rate for indirect costs)
AND
- the amount resulting from the indent above may not be significantly higher than the market price of the consumable.
Example:
In an action in the field of agro-forestry research the beneficiary needs 100 plants to carry out tests. The beneficiary has a greenhouse where it keeps a stock of those plants. The market price of those plants (e.g. checked with offers or prices published in internet) is around EUR 10 per plant. The beneficiary has 150 plants in stock with a global accounting value of EUR 1 200 (= EUR 8 per plant). It is not possible to identify what part of that accounting value corresponds to direct costs of production of those plants.
The beneficiary may use the self-produced plants for the action and charge EUR 6,4 per plant (8/1,25).