The MA/JS can only reimburse project costs verified by a controller or by the MA/JS.
Management verifications include checks of accounting records (not for simplified cost options), correctness of calculations and documentation of expenditure. In this process the controllers or the MA/JS verify:
that the co-financed products and services have been delivered,
their purchase complies with applicable law (EU, Programme, national),
the conditions for support of the project have been met.
The MA/JS also check that the activities declared for funding have been implemented in compliance with the aims of the project as approved by the Monitoring Committee.
The verification will mainly ensure that expenditure reported by project partners to the Programme is correct and in accordance with:
provisions of the subsidy contract,
the latest version of the approved project data in BAMOS+,
the EU regulations,
Interreg Baltic Sea Region Programme rules and
national rules.
Therefore, the task of controllers and the MA/JS is to detect, correct and prevent that incorrect expenditure is co-financed from the Programme funds.
The controllers or the MA/JS:
check 100% of the project partners’ expenditure (as standard approach due to the limited number of items in CAT 4-6 with real costs)
or
apply the sampling method (in well justified cases). In cases of sampling, the verification will be risk-based and proportionate to the risks identified ex-ante and in writing.
Independent from the method above (100% check or risk-based sampling) the controller or MA/JS confirms verification of 100% of the expenditure declared by the project partner.
Management verifications include
1. administrative verifications of payment claims made by the project partners and
2. on-the-spot verifications of the projects
REGULATION (EU) 2021/1060, Article 74(2)
Administrative verifications can provide assurance on the correctness of expenditure to a large extent. However, depending on the nature of the project, its activities and purchased equipment or installed investment, such checks cannot always cover all aspects. Administrative verifications must be carried out in respect of all claims for reimbursement by project partners. It is based on examination of the partner report and relevant supporting documents.
On-the-spot checks focus on two main aspects:
Good functioning of internal processes and systems relating to the approval, ordering, accounting and payment of reported costs.
Existence and delivery of goods and services.
An on-the-spot check gives a better understanding of the supporting documents, of the project and of the partner organisation. The controllers can interview the staff and carry out walk-through checks. Particular processes can be traced from the beginning through to the end of the process inside the partner organisation. For example, with those responsible for public procurement processes from the initial launch of the tender through to the selection, contracting and final delivery of the contract. The payment process can be verified from the ordering of the service to its delivery, invoicing, registration in the accounting system and final payment. Moreover, original documents (invoices, timesheets) can be accessed.
The clarification of unclear issues and previously missing documents might also be easier when they are solved on-the-spot.
The MA/JS expects that the controllers carry out at least one on-the-spot check of each project partner during the project duration. The controllers responsible for more project partners can apply the sample method or other methods based on risk criteria and professional judgement to select the project partners to be checked on-the-spot. The controllers must have a method of selection of project partners to be checked on-the-spot as well as documentation of the on-the-spot-check carried out.
The MA/JS and the controllers ensure that the expenditure of a project partner can be verified within a period of three months of the submission of:
Partner report to the controllers in the case of real costs,
Progress report to the MA/JS in the case of simplified cost options
REGULATION (EU) No 2021/1059, Art 46 (6)
