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BBO ESF Claim Submission
Risk Assurance BBO ESF Claim Submission Presented by Barbara Ioannou Welcome to the BBO ESF webinar on claim submission. This webinar is intended to provide some practical information and hints and tips on submitting your BBO ESF quarterly claims to the Big Lottery. Areas to be covered include; timeframes, how to submit, what to send, what will happen once the claim has been sent and common errors to look out for. Finally some information on the Article 125 On the Spot compliance check has been included in this webinar. There will also be an opportunity to raise questions via the chat facility, these questions will be collated and responses will be shared in partnership with the Big Lottery. The slides of the webinar will be available on the BBO ESF Support Website. Annex Q of the Guide to delivering European Funding and the hints and tips sent out to all grant holders recently have further details on monitoring covered in this webinar.
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Welcome Introduction to RSM
RSM through the RSM Support Officers is engaged to provide support, information and guidance to potential applicants, applicants and grant holders of the BBO programme to enable them to comply with ESF monitoring, reporting and audit requirements on actual cost agreements. Areas RSM provide support on include: Eligibility Audit Data reporting Publicity Cross-cutting themes, and Management
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RSM/BIG LOTTERY ROLES AND RESPONSIBILITIES
Delivery of Support Services to grant applicants RSM Project Support Officer Big Lottery Funding Officer Joint Working Application, Assessment & Grant Management Functions Claims, site visits, query log, FAQs, compliance issues log
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Timeframe of claim submission
Claim due dates Claims are due to be submitted 14 calendar days after the end of the reporting period by 12pm. (14th Jan, 14th April, 14th July, etc.) Please ensure you liaise with your Funding Officer re any queries you have with this deadline. Some deadlines are on non working days –missing these deadlines is still considered late. Ensure you have liaised with your Funding Officer. If you miss the deadline your claim information will not be processed and the Big Lottery will withhold your payments. It is discretionary whether you will be granted approval to submit the information in the following quarter. Annex Q includes the claims timetable up to 2020
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Kiteworks - How to submit
Funding Officer will set up a shared folder using the BLF secure file transfer service, an account will then be created for you allowing you to put information directly in the folder. You will receive an from Kiteworks to finalise setting up your account. All information must be transferred this way to meet the data protection and security requirements associated with the ESF programme. must never be used for sending project information or evidence to your Funding Officer or across your partnership. Regarding Kiteworks Funding Officers are tasked with setting up their projects Kiteworks so not all projects will have their Kiteworks set up yet. Their FO will be contacting them about this in readiness for the January claim. ‘ Your Funding Officer will set up a shared folder using our secure file transfer service, an account will then be created for you allowing you to put information directly in the folder. You will receive an from Kiteworks to finalise setting up your account. All information must be transferred this way to meet the data protection and security requirements associated with the ESF programme. must never be used for sending project information or evidence to your funding officer.’ Effective communication between grant holders and Funding Officers can help avoid incorrect claim submissions. Any foreseen issues should be expressed as soon as possible. Problems discussed before a deadline are more likely to be resolved than those highlighted during claims testing. Any expenditure removed from a claim may lead to you having to submit in the next claim period.
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What to send? For the period Oct 2016 – December 2016 you will need to provide the following documents by 14 January 2017: Updated Annex A – Payment schedule Annex B – Progress project report Annex D (if required) – Changes to your project form – changes must be discussed with your Funding Officer prior to submission of this form. Updated Annex E (or Annex F for COR 2/1) – Target and project outcome schedule Annex L – Participant monitoring spreadsheet Annex O – Financial monitoring spreadsheet An up to date list of staff working on the project. An up to date list of delivery partners. London Projects – Annually will need to submit an Employment Performance Report. This will be submitted in April. Grant holders are required to submit only the above listed annexes on Kiteworks by 12pm 14th – all supporting evidence (financial and non-financial) needs to be saved electronically by the lead as this will be requested during the compliance testing period. For projects submitting 2 claims in January (covering two claim periods) – these are to be kept separate and sent as two claims, you need to submit a separate Annex for each period e.g. July- September in one Annex and October- December in a separate Annex. GOOD PRACTICE: ensure you have appropriate systems in place for compiling and validating information submitted by partners.
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Once the claim has been sent
Grant holders are required to be on standby once evidence is submitted (14 Jan – 6 Feb) During this period a named contact should be on standby so that any information requests from the Big Lottery can be uploaded within 24 hrs of being requested. This person should have access to the kiteworks folder as set up by the FO. The liaison period ends on 6th February. Any queries not resolved during this period will result in that cost line been extracted from the claim by the Funding Officer. An initial check is carried out to confirm all the required information has been sent. A sense check of transactions to check all costs are eligible. – please check the list on page 3 of Section 8 of the Guide to delivering European Funding which clearly lists what cannot be claimed. Your Funding Officer will then liaise with you regarding the sample to be checked and resolve any queries during the liaison period, for both financial evidence and participant evidence. Checks will be carried out to ensure compliance with ESF programme rules.
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Common Errors Following the claims submitted in October 2016 checks carried out by RSM of the documents and evidence provided to support claims has highlighted key areas. This feedback is important and should be taken into account when preparing claims. It is important that Internal Checks are carried out by the lead prior to submitting annexes to the Big Lottery. If you don’t have the evidence for a cost – should it be in the claim? ESF guidance clearly states that ‘All expenditure must be evidenced, auditable, and defrayed prior to the inclusion in any claim and follow all other ESF compliance rules’. Descriptions - ensure the transaction descriptions used in Annex O are not generic and clearly explain what the expenditure is for and how it relates to the project. Referencing – follow the guidance related to referencing in section 8. Internal checks are carried out – a checking form is created based on Section 8 of the guide to European funding. You should operate a safety first approach throughout, with all partners submitting actual costs information to the lead partner only when it has been incurred and paid and when the evidence to support this is available. GOOD PRACTICE EXAMPLE - Consider preparing a procedure and/or checklist for checking information submitted by partners. This could include a sign off sheet signed by both the staff member completing the checking, and a manager verifying the work has been reviewed. Documenting the checking of partner claims is useful for recording when the checking was performed, any recurring error or issues, and for using to follow up on any actions required to improve or correct claim data. The BBO ESF Webinar on Actual Costs is a good reference for more information on actual costs. Descriptions – ensure the transaction descriptions used in Annex O are not generic and clearly explain what the expenditure is for and how it relates to the project. The description should be detailed that the reader can consider the validity of the expenditure at first glance without needing to view the actual evidence you have retained. Lines we find with poor descriptions will be rejected from your claim. Referencing - Please follow the guidance related to making the ‘Reference Number’ field in Annex O unique and traceable back to the evidence that sits behind your expenditure. You will find the guidance in section 8 of the Guide to Delivering European Funding, lines that do not follow this guidance will be rejected from your claim.
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Common Errors (Cont.) Indirect costs - Indirect costs have been set as 15% of your direct staff costs at each claim. File naming for transactions For example, prefix FM3R12 would be a piece of evidence for the transaction on the row 12 of the month 3 sheet of Annex O. File naming for participants For example, prefix PR20 would be a piece of evidence for the participant on row 20 of Annex L. Self-declaration – only used as a last resort! Indirect costs – Indirect costs have been set as 15% of your direct staff costs at each claim. They are to cover costs of things that are required to deliver the project but which cannot easily be attributed to your project such HR staff, insurance, heat and light etc. Note that this is not 15% of your total direct costs only of direct staff costs. You do not need evidence of your indirect costs. However if you calculate your direct staff costs incorrectly, your indirect sum will need to be corrected too. File naming for transactions - Electronic files submitted for evidence should follow the convention outlined here. Transaction evidence should be prefixed with F(finance evidence), Mx (the month sheet the transaction appears on, 1,2 or 3) then Rxxx (the row the transaction appears on). For example, prefix FM3R12 would be a piece of evidence for the transaction on the row 12 of the month 3 sheet of Annex O. File naming for participants - Electronic files submitted for evidence should follow the convention outlined here. Participant evidence should be prefixed with P (participant evidence) then Rx (the row the participant appears on. For example, prefix PR20 would be a piece of evidence for the participant on row 20 of Annex L. Self-declaration - Where a participant is self-declaring they are economically inactive the Big Lottery expects to see evidence in their entry form that they have exhausted all pathways to try and obtain evidence that this is the case. Self-declaration should only be used as a last resort not a default position, in cases where evidence to prove all avenues have been exhausted is not found the participant and associated outputs and results will not be counted. Could we explain what would be considered as exhausted all pathways? GOOD PRACTICE A Self Declaration form is developed and signed by participant and project worker.
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Common Errors (Cont.) Hourly rate calculations – show the calculations that evidence the hourly rate based on the 1720 method. Annex A/Annex O – changes to Annexes A and O must be agreed with your Funding Officer. Timesheets – follow section 8.2 – ensure start and finish times. Start dates – you may claim costs from the date upon which your funding agreement was signed. 1720 The Big Lottery requires you to use and retain spreadsheets with formulas using the prescribed 1720 rule clearly showing key staff information such as salary and number of hours worked. This way key information can be found and confirmed quickly; assuring and evidencing that the correct calculations have been used. Supporting evidence of salary costs, and employer NI and employer pension will be required to ensure how you have arrived at the hourly rate is correct. There is a handout title Calculating Hourly Rates for Staff Working produced by the Big Lottery in September It is GOOD PRACTICE - Some partners may find the recording of staff costs complex and therefore this area of financial management becomes high risk. It is advised that thorough and uncomplicated guidance is provided to partners and that a comprehensive procedure for checking direct staff costs is prepared. Annex A/Annex O - Changes to your budget must be agreed with your Funding Officers Failure to do so could lead to your claim requiring additional checking and a claim or portion of the claim being rejected. Please follow the guidance related to the process for making changes and amendments in budgets. When recording staff costs on Annex O, it is advised that a consistent approach is taken. Examples of recording staff costs each month may include, completing one line per BBO staff member, recording a total value per partner, or recording one overall staff cost per month. It is advised that pre-submission checks on Annex O totals and Annex A (agreed with Funding Officer during grant set-up) totals are carried out. This allows any discrepancies to be amended before submission; reducing the risk of claims being rejected due to unapproved items. Timesheets must clearly show the start and finish time against every line of activity being claimed for, job role, person’s name and adequate description of activity undertaken. This information is vital in the claims testing process. Full details of timesheet requirements are found in section 8.2, Providing partners with a BBO timesheet template reduces the risk of error and supports coherent checking by the lead. Start dates - Your project start date is the date upon which the funding agreement from Big Lottery Fund was signed. You may claim costs from this date.
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Common Errors (Cont.) Ineligible participants - If a submission for a participant shows lack of evidence to confirm their eligibility, that participant will be excluded from the claim. VAT - Any VAT recovered is ineligible. Self-employed Bank statements - All partners and the lead will need to show evidence from their bank account that the payment has been made, as well as the original invoice. It is the date of payment from the bank account that decides when you make the claim. Procurement - when procuring services over 2,500 evidence of procurement process followed is required and should be saved electronically Ineligible participants - If a submission for a participant shows lack of evidence to confirm their eligibility, that participant will be excluded from the claim. GOOD PRACTICE – Introduce a procedure for transferring data onto Annex L (Participant monitoring spreadsheet) to reduce the risk of error during inputting. VAT - You are required to maintain evidence of your own VAT status and that of your delivery partners. Any VAT recovered is ineligible. It is important for the lead to ensure the VAT status of partners is checked and confirmed. Self-employed (not on payroll)- When using self-employed individuals to deliver services, an SLA/contract should be in place and viewed for evidencing defrayal and procurement. –NI, UTRN and indemnity insurance. Bank statements - Should be retained and stored electronically to demonstrate defrayed expenditure. - Some bank payments will be for blocks of money to one supplier- you’ll have to show calculations/further evidence for which proportion is BBO Procurement – when procuring services over 2,500 evidence of procurement process followed is required and should be saved electronically. The details of procuring services can be found in Procurement Law - ESIF Compliance Guidance Note.
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Article 125 – On the Spot Verification
To verify that your BBO ESF project has been delivered and that expenditure declared has been incurred and paid and complies with EU regulations. The visit will also involve verifying that your project has complied with ESF requirements in the following areas: Publicity and Communications Cross Cutting Themes Sub – Contracting and Partners State Aid Documentation Retention and Data Protection The on the Spot visit will check actual costs and identify any areas requiring remedial action including irregular expenditure. EU regulations – includes ESF National Eligibility Rules - the Operational Programme for England – and the EU requirements in the following areas: • partnership and multi-level governance; • promotion of equality between men and women; • non-discrimination; • accessibility for persons with disabilities; • sustainable development; • public procurement; • state aid; • environmental rules.
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Close Barbara.ioannou@rsmuk.com Final comment:
Ensure up to date versions of the BLF BBO Annexes are always used by downloading the most recent version from the BBO website:
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THANK YOU FOR YOUR TIME AND ATTENTION
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