Subcontracting Guidelines & Indirect Costs Management in Financial Communication Campaign

1. Communication campaign Mostcommonissuesidentified: - Subcontracting - IndirectCosts Thanos BATSILAS FCH JU Financial Officer

2. Third parties & other sensitive relations

3. Who ? Works under business conditions with profit purpose Not subordinated to norunder supervision of beneficiary Not anotherbeneficiary Not an affiliate In What Conditions ? Limited and non core part of the project Not R&D Not the coordinator’stasks Tasks and amountindicated and justified in technicalannex Beneficiaryremainsresponsible If IP, it must belong to beneficiary Best value for money, transparency and equaltreatment Severalbids (or public procurement) Except for pre-existingframework agreement Subcontracts (1)

4. Common errors: Subcontracting costs (core tasks) are claimed without being indicated in the DoW (technical annex-I). If not in the DoW, request approval/amendment. Subcontracting costs (minor tasks e.g. website, catering etc) are claimed as other direct costs. To be claimed under subcontracting cost category Subcontracting between beneficiaries is not allowed. If beneficiary A (the “seller”) sells to beneficiary B (the “buyer”), then it is the beneficiary A (and not the beneficiary B) to claim the costs (NB without any mark-up and profit, only the costs)

5. Subcontracts(2) Consultants: sub-contractor or personnel? Personnel costs if the following cumulative criteria : • beneficiary has a contract with a person to work tasks under the FCH JU project, • person must work under the instructions of the beneficiary + in the premises of the beneficiary • the result of the work belongs to the beneficiary • costs of employing the consultant not significantly different from the employees • The remuneration is based on working hours rather than on the delivering of specific outputs/products and should be recorded in the accounts of the beneficiary, • Travel and subsistence costs related to such consultants' have to be paid directly by the beneficiary in order to be eligible. • Not a criteria: whether the consultants are self-employed or employed by a third party,   Common error: claimed as subcontracting costs Subcontract if hiring consultants to perform part of the work & the conditions of Art. II.7 of FCH JU GA are fulfilled: • Sub-contracting agreement based on business conditions w/ profit included • Sub-contractors do not have any IPR or ownership rights on the deliverables • does not usually work on the premises of the beneficiary and is not under the direct instruction /hierarchical supervision by Beneficiary • remuneration based on the delivering of specific outputs/products rather than on working hours ; • Sub-contrcating between beneficiaries of the GA cannot be tolerated. Common error: claimed as personnel costs

6. Indirect Costs Indirectcostsare all those eligiblecosts which cannot be identified by the beneficiary as being directly attributed to the project, but which can be identified and justified by its accounting system as being incurred in direct relationshipwith the eligible direct costs attributed to the project

7. IndirectCosts Actual indirect costs Beneficiarieswithananalyticalaccountingsystemthat can identifytheirindirectcosts and assignthemtothedifferentprojects and activities Simplified method Beneficiariesthatcannotagregatetheirindirectcosts at a detailedlevel (centre, department), butonly at thelevel of the legal entity Methods of calculation Flat rate 20% Industrywhoseaccountingsystems do notmake a distinctionbetweendirect and indirectcosts Non-profitpublicbodies, secondary and High Educationestablisments and researchorganisations (optional)

8. Indirect Costs reimbursement * For this calculation costs of subcontracting and resources made available by third parties outside of beneficiary’s premises must be deducted from direct costs

9. Actual indirectcosts Indirectcostsare all those eligible costs which cannot be identified by the beneficiary as being directly attributed to the project, but which can be identified and justified by its accounting system as being incurred in direct relationship with the eligible direct costs attributed to the project • Linked to the project itself? • Linked to EU-research projects in general? • Linked to research in general? • Including other activities such as teaching, production or sales? • Including all indirect costs at the level of the organization?

10. Actual indirectcosts

11. Actual indirectcosts

12. Actual indirectcosts

13. Actual indirectcosts • Telecommunication, postal and other G&A expenses - Once the accounting system considers these costs as indirect, ensure they are not claimed as direct costs. If claimed as direct costs, they should be removed from the IC pool • Travel and subsistence expenses - Once the accounting system considers these costs as indirect, ensure they are not claimed as direct costs. If claimed as direct costs, they should be removed from the IC pool - Expenses by non-productive employees should be removed - Expenses by productive employees but not linked to the project should be removed • Lawyer fees - Eligible if incurred in direct relationship with the eligible DC attributed to the project • Entertaining expenses (e.g. team building, receptions etc) • Non eligible, to be removed

14. 20% flat rate Subject to the accounting principles of the beneficiaries, the following items may be considered as indirect eligible costs: • costs related to general administration and management; • costs of office or laboratory space, including rent or depreciation of buildings and equipment, and related expenditure such as water, heating, electricity, maintenance, insurance and safety costs; • communication expenses, network connection charges, postal charges and office supplies; • common office equipment such as PC's, laptops, office software; • miscellaneous recurring consumables; etc. provided they can be identified and justified by the accounting system of the participant as being incurred in direct relationship with the eligible direct costs attributed to the project. Such costs are normally deemed to be covered by the flat rate (20%) and cannot be charged as direct costs unless it is established that the accounting principles of beneficiaries consider them as direct costs.

15. Indirectcosts Common errors: • ICM Actual/Simplified • IC pool includes ineligible items, • not incurred in direct relationship with the eligible DC • or already claimed as DC although the accounting system considers them as IC (depending on the characteristics of the operation in question, it is possible that some costs can be considered either direct costs or indirect costs, but no cost can be taken into account twice as a direct cost and an indirect cost. • Budgeted IC or based on 20% flat rate (NB! In case of ICM Actual, this 20% flat rate is rate for reimbursement and not rate to define and claim IC • ICM 20% flat rate • Indirect costs claimed as direct costs without being considered as DC by the accounting principles of the beneficiary • General • Mistake in choice of ICM during the first participation in FP7

16. For further info: Guide to Financial Issues for beneficiaries of FCH JU ProgrammeQuestions?