FAQ BSB JOP 2014-2020 - Beneficiaries 1st Call for Proposals
This page contains answers to questions submitted by interested ENI CBC Black Sea Basin Program applicants, beneficiaries and controllers. The questions and answers are organized by topic of interest and are updated on a regular basis, as we collect new questions. To preview the questions, click on the topic of interest.
According to the EU Regulations in force (REGULATION (EU) No 897/2014), the Lead Beneficiary (Lead Partner in eMS) must assume responsibility for ensuring implementation of the entire project. Details can be found in the Grant contract and the Partnership Agreement.
All the relevant documents and news about project management and implementation are available on our website under the new section Projects Implementation.
If you intend to perform a modification of the Grant contract, please read the content of the Instruction no 16 from 20 February 2019 to beneficiaries regarding Addendum and Notification.
The modifications accepted through a Notification have an administrative and technical character without a significant impact on the project implementation, its intervention logic (objectives, outputs, results). Examples: changes of the contact person / the legal representative / EUR or national currency bank account / address / name of the controller, or minor changes in the Work plan section of the eMS (without an impact on the main objectives of the project and/or on the total project duration), corrections of inconsistencies between or within different eMS sections of the project, minor transfers of amounts between items within the same budget heading, not having a major impact on the latest approved eMS version of the budget, which may otherwise be subject to an addendum.
Before initiating an Addendum, we recommend the Lead Beneficiary (Lead Partner in eMS) to contact the responsible JTS project officer to discuss on the proposed changes.
If you intend to perform a modification of the Grant contract, please read the content of the Instruction no 16 from 20 February 2019 to beneficiaries regarding Addendum and Notification.
The project modification process is initiated through a written request addressed to the JTS with maximum 45 days before the date on which the amendment should enter into force, unless there are special circumstances duly substantiated and accepted by the Managing Authority (MA). Once the approval in principle from JTS is received, a Modification Request session will be opened in the eMS. The modified project data must be entered by the Lead Beneficiary (Lead Partner in eMS) into eMS. The changes will be approved in the eMS only after the approval by the MA of the Addendum. If the modifications are not approved by the MA, these changes will be rejected in the eMS and the Application will return to the previous version.
In the Notification regarding the payment from ENI funds sent by the Managing Authority to the Lead Beneficiary it is specified the email address of the person where the proof of transfer of the amounts to the project Beneficiaries should be sent. The Lead Beneficiary has to make sure that the proof of payment is sent to the respective email address within 7 days from the date of transfer, according to Article 4.6 of the grant contract.
No. Any expenditure should be made in accordance with the approved budget. Any change to the approved budget shall be made only in accordance with the provisions of Instruction no 16 of the Managing Authority to Beneficiaries, which clearly explains the situations when a notification or addendum can be submitted. The Instruction is Mandatory for all Beneficiaries and can be downloaded from the Programme website. Pay careful attention to the dates and deadlines when modifications enter into force so to avoid any situation where costs are declared ineligible for non-observance of the Programme rules.
No. External expertise or services contracts cannot be concluded with Beneficiaries’ own employees. Other project beneficiaries or their staff cannot be contracted as external experts or subcontractors. Non observance of this rule (also specified in the Guidelines for Applicants – page 40), shall lead to non-eligibility of the expenditure.
The Programme is using the euro exchange rate of the month during which the expenditure was submitted for examination (option b) of article 67 of the ENI CBC Implementing Regulation (EU) No.897/2014) and the eMS is configured so to reflect this approach. This rule is stipulated in the grant contract – article 4.15 and cannot be changed. Also, please note that according to Article 8.5 of the grant contract, letter e), exchange rate losses shall not be considered eligible. An aspect which may be of use to consider in reducing the financial burden on your budget is that the eMS recalculates the reported amounts several times – first time when the expenditure item is created and each time it is modified before submission (Please see Annex 5 to PIM, section 4.3.2 List of Expenditure (LoE) tab – Currencies other than Euro).
According to Grant Contract provisions – article 4.15, “Reports shall be submitted in euro. For the purpose of reporting, conversion into euro shall be made using the monthly accounting exchange rate of the European Commission of the month during which the expenditure was submitted for verification in accordance with Article 4.11.”
Amounts introduced into the eMS in currencies different than EUR will automatically be re-calculated into EURO using the monthly accounting exchange rate of the European Commission (http://ec.europa.eu/budget/contracts_grants/info_contracts/inforeuro/index_en.cfm) of the month during which that expenditure was submitted for verification by the concerned partner to its controller. The system recalculates the amounts several times – first time when the expenditure item is created and each time it is modified before submission. The final value is calculated and locked at the moment of the report submission to the FLC (this is the final exchange rate). This conversion rate cannot be modified ever again. Even if the report is reverted to the partner and re-submitted to the FLC the exchange rate from the first submission to the FLC is remaining the valid one.
No, it is not allowed by the program rules to exceed the budget lines up to any percentage from the original value, without prior written approval, even if the total eligible budget is not exceeded.
Any budgetary changes are made with the prior approval of the program structures. In the Instruction no 16 from 20 February 2019, issued by the Managing Authority, to Beneficiaries regarding Addendum and Notification, are mentioned the cases in which the beneficiaries may use a Notification or an Addendum for budgetary changes.
In such case, expenses shall be declared separately according to the budget lines and group of activities foreseen in the approved budget.
Bulgarian private Lead Beneficiaries / Beneficiaries (Lead Partner / Partners in eMS) fall under the category of “contracting entities” and comply with the rules for procurement procedures stipulated in the national legislation, particularly they have to comply with Decree no. 160 of 1 July 2016 on the determination of the rules for the examination and evaluation of tenders and conclusion of contracts in the procedure for selecting with a public invitation to beneficiaries of granted financial assistance from the European Structural and Investment Funds. The Decree defines the rules for the examination and evaluation of tenders and the conclusion of the contracts in the process of selecting a contractor with a public invitation under the Management Act of the European Structural and Investment Funds by the beneficiaries of grant European Structural and Investment Funds. The PRAG rules are not applicable for the Bulgarian Beneficiaries in Joint Operational Programme Black Sea Basin 2014-2020.
The art. 9.3 from the Grant contract lays down the categories of the beneficiaries who must comply with the requirement regarding the procurement notice for publication, namely: beneficiaries from the CBC partner countries and the beneficiaries from the member states which are not contracting authorities or contracting entities. These categories of beneficiaries must submit the procurement notice for publication to the Joint Technical Secretariat in electronic form at least 15 days before the intended date of publication and must arrange simultaneous publication of identical procurement notices in any other appropriate media directly.
Procurement notice for publication will not be sent if competitive negotiated tender procedure without publication will be carried out.
The competitive negotiated tender procedure without publication applies to:
– Service contracts and work contracts between 60 000 and 300,000 Euros;
– Supply contracts for a value between 60 000 E and 100,000 Euros.
For the definition of Service contracts, Supply Contracts and Work contracts, please consult Chapter 5 of the Annex 3 of the Project Implementation Manual, Guide on Procurement by private project beneficiaries.
The thresholds that require submission of the procurement notice by Lead Beneficiaries / Beneficiaries are laid down in REGULATION (EU) No 897/2014 Chapter 4 (section 1) and repeated in the Annex 3 of the Project Implementation Manual, Guide on Procurement by private project beneficiaries.
– over 300 000 Euros follow international restricted tender procedure, with publication beyond the programme area. Considering the size of the grants under BSB programme, this procedure would be exceptional.
– with a value from 100 000 up to 300,000 Euros the projects follow open tender procedure, with publication in the programme area
– valued 300 000 Euros or more shall apply international open tender procedure, with publication beyond the programme area
– with a value of 300 000 Euros but lower than 5 000 000 Euros – open tender procedure, with publication in the programme area is applied.
For a transparent and accurate information regarding the public procurement, the Procurement Notice should be filled in and submitted to JTS by e-mail at email@example.com. The document must be sent in both word and scan format with all the requested information filled in.
In addition, please also note, that Lead Beneficiaries / Beneficiaries have a responsibility to arrange publication of procurement notices in any other appropriate media on the programme territory.
Please indicate in the subject of email your project number and procurement procedure.
Please use the following text in the body of email: Please be informed that project BSB (eMS number and title) will require … (nature of services/supplies/works) for (estimated amount) using (name of the procedure). The contract notice will be published (date), at/on (site, Facebook, any other media). The contact person is (Name, title, telephone no, email). You may add any other relevant information.
The Beneficiaries should follow the provisions stipulated in the Grant Contract Article 9. Provisions for each type of beneficiaries, specific for each participating country are detailed in Annex 3 Fact sheets on Procurement to Project Implementation Manual. These provisions should be strictly observed and followed by all beneficiaries, according to their legal status (e.g public entity, private entity – NGO, association, etc). Non observance of applicable rules, or using different public procurement procedures, different from the Programme rules, may lead to non-eligible expenditures. Please read the article published on Public procurement in section News, available here.
It is the choice of each beneficiary to decide if they want to assign the same controller for both reports or different controller for each report, providing the public procurement rules (in case of beneficiaries from countries in which decentralised system is applied) are fully observed.
The selection of controllers from Ukraine will be finalised in March 2019 and made public on the Programme website.
Reporting, Monitoring & Evaluation
There are 3 types of reports:
Progress reports (several)
– every 4 months;
– includes only narrative description on progress made in the implementation;
– shall be elaborated by each beneficiary and submitted to the Lead Beneficiary (chose in eMS option “submit to the Lead Partner”) who prepares the Project progress report;
– project partners shall not include expenditure in partner progress reports and shall not submit them to the controllers.
Interim report (one)
– half way through the project implementation period or when 70% of the advance payment has been spent;
– includes both narrative and financial parts;
– shall be elaborated by each beneficiary and submitted to the controllers and then to the Lead Beneficiary (Lead Partner in eMS) who consolidates and prepares the project report.
Final report (one)
– 6 months after the end of the implementation period;
– includes both narrative and financial parts
– shall be elaborated by each beneficiary and submitted to the controllers
and then to the Lead Beneficiary (Lead Partner in eMS) who consolidates and
prepares the project report.
The report may not be modified after submission, unless the MA/JTS reverts it for completion.
No. All costs approved under a Group of Activity shall be reported under the respective Group of Activity and not under a different one. The only exception is referring to staff costs, where costs shall be reported only under Group of Activity Management (Work package Management in eMS), notwithstanding the Work Package under which they have been approved, if not in contradiction with the provisions of the national legislation or internal requirements of the organization.
If in the approved Application it has been introduced information about linkages, synergies and complementarities with other projects or initiatives, all beneficiaries have to provide clear details on how these complementarities are being considered during implementation. In the Partner and Project report, details shall be provided in the Description Activity Contribution Section for each activity where complementarities and synergies exist.
Interim Report shall be submitted by the Lead Beneficiary to the JTS, within 90 days following the end of the reporting period: once the project has used at least 70% of the first pre-financing, if half of the implementation period has elapsed, even if the part of the expenditure actually incurred and paid which is financed by the MA is less than 70 % of the previous payment. It is preferable that the verification of expenditures is performed by controllers for all project partners approximately in the same period of time. The Lead Beneficiary has a key role in this process and has to ensure coordination among partners as regards preparation, readiness and availability of documents (reports, FLC certificates, etc) from all partners, in time for submission of Interim Reports to JTS. Thus, time differences among partners as regards submission to the Lead Beneficiary shall be avoided (some partners submit their report to the Lead Beneficiary 20 days after the end date of interim reporting period and other partners submit their contribution to the Interim report 70 days after the end date of interim reporting period).
In line with the provisions of the Contract, Article 5 – Obligation to provide information and reports, point 5.3, interim/final reports shall:
a) cover the project as a whole, regardless of which part of it is financed by the MA;
b) consist of a narrative and a financial report;
c) provide a full account of all aspects of the project’s implementation for the period covered;
d) include the outputs achieved by the project as measured by their corresponding indicators;
e) propose any relevant measures necessary for performing the activities of the project, producing the intended results, achieving the purpose/s of the intervention;
f) be drafted in the currency and language of this Contract;
g) include any update on the communication plan according to Article 10;
h) include a status of the procurement procedures and implementation of the contracts awarded under Article 9.
The Lead Beneficiary and the Beneficiaries should have the same reporting period in eMS in case of progress/interim and final reports.
The level of detail provided by Beneficiaries within the progress, interim/final reports should match to activities as depicted by the Contract, annex 1 – Description of the project and annex 2 – Budget of the project.
In line with article 15 – Obligations to provide information and reports point 5.6, the Lead Beneficiary and the Beneficiaries shall ensure that any information provided to MA/JTS are reliable and true and they are substantiated by adequate supporting documents that can be checked (technical and financial sources of verification).
We recommend you read Chapter 6 – Reporting and project financing (payment claims) of the Project Implementation Manual (PIM) and Annex 5 – Guide on reporting in eMS to the PIM.
Yes. In line with the provisions of the Contract, Article 5 – Obligation to provide information and reports, point 5.2, MA may terminate the Contract according to article 17.2 a) and pursue for the ENI funds recovery.
In line with the provisions of the Contract, Article 15 – Amendments of the Contract, Article 16 – Extension and Suspension and Instruction No 16/2019, the Lead Beneficiary has two options to modify the Contract:
Details about the type of document (Notification or Addendum) that have to be submitted to JTS/MA are provided in the Instruction to Beneficiaries no 16 of the Managing Authority, published on the Programme website.
All amendments should be dully justified and, if the case, substantiated by the Beneficiaries with adequate documents as explained/detailed within the Project Implementation Manual (PIM) https://blacksea-cbc.net/black-sea-basin-2014-2020/reference-documents/.
Prior consultation with the JTS staff is recommended in order to ensure that the amendments are duly justified and acceptable, before JTS opens the Modification request option in the eMS which allows the Lead Beneficiary to upload the required amendments.
Based on the Contract provisions, article 5.1 “in case of a project including an infrastructure component, the Lead Beneficiary shall provide the MA/JTS with all required information related to ensuring the sustainability of the project, in accordance with Article 13.3 of this Contract.”
The Lead Beneficiary shall submit to MA/JTS the sustainability reports for the five years following the project closure, within 30 days after the anniversary date of payment of the final balance for the project, starting with the year following the year of payment (article 5.2).
It requires the Lead Beneficiaries to maintain, beyond the Contract’s execution period, a permanent communication with the Beneficiaries who had implemented works/Small scale investment components.
An Indicative Model for Sustainable report shall be made available by the Managing Authority in due time.
When a report is generated in eMS, this report will be correlated/referring to the last version of the application/contract available in eMS. If you generated the report by mistake, before a modification request was approved (addendum or notification), and the modifications proposed are relevant for this report, you should save all the information introduced in the draft report and generate a new report for the respective implementation period. Don’t forget to save all the information before deleting the initial version of the report. After you delete the initial version of the report, when you will generate the new report, this will be correlated with the last (revised through an addendum or notification) version of the project.
The Beneficiary shall report the amount representing Interest from Pre-financing, if the case, under budget line revenues, specifying Interest from Pre-financing. Also, please pay attention to section 3.1.4 Co-financing, interest and revenues of the Project Implementation Manual, namely: Revenues generated by the project are monitored throughout the whole project life cycle. Beneficiaries will have to fill in and submit with the Interim and Final Report a General Declaration by the Lead Beneficiary/Beneficiary (see Annex 1) on their own responsibility which includes provisions also regarding revenues/no revenues generated by the Project, as applicable. Each Beneficiary is responsible for keeping account and documenting all revenues generated during and after (within the sustainability period) the project implementation period for control purposes.
NO. Target group involved and participating in project activities has to be exclusively from the programme eligible area.
Project partners shall provide relevant information, if available, in the Interim Partner Report – section Reporting per Work Package. The information provided shall highlight the added value of the current project activities and results, to the previously complementary projects implemented by the respective partner, if the case.
Expenditure under this budget line, does not have to be detailed. You should just report the total amount spent at the end date of the reporting period.
Thus, in eMS, in the list of expenditure, you should report only one amount, under Office and administration budget line, this amount representing the total of all costs made under this budget line. Certainly, the respective costs do not have to be reported under another budget line. Also, we remind you that according to article 8.3 of the Grant contract, this flat-rate funding does not need to be supported by accounting documents. This means that no justifying documents proving the expenditures incurred under this category have to be provided during the interim report and final report. It is important to remind you that the verification that the final total amount spent under this budget line at project level falls within the percentage and does not exceed the amount approved for this budget line at project level, shall be made on the Final report, by JTS and MA.
When reporting the target value reached for the target group please be sure that you count only the values registered during the reported period, not from the beginning of the project implementation. Also, please be sure you count the number of entities and not number of persons representing same entity.
It is very important to ensure an active involvement of the target groups. By simply informing the target groups about the projects, it will not create an added value for them at the end of project. When reporting the values reached, be sure that you have the evidences to demonstrate their participation in project activities. For example, you have to be able to prove that 10.000 general public have been actively reached by project activities.
The evidence could be uploaded either under Output or Deliverable level. In this case, you should clearly indicate in the text box (description) where the evidence is uploaded (i.e under Output /Deliverable evidence) and provide the name of the file.
For more details on how to upload documents, please read section 4.3.4 ‘Attachments’ and “Personal data attachments” tabs, of Annex 5 Guiding on Reporting of the Project Implementation Manual.
There is no mandatory number to be uploaded. Please limit the quantity of photos to the minimum and make sure that the one you upload are of good quality and are the most relevant for anyone to understand the nature of the event. Photos with banners, presentations, brochures, folders, etc having the project title and other project visibility elements on them, should be visible.
Depending on the nature of deliverable, the possible solutions might be: splitting the file into smaller portions or providing a link to it (in case of TV/ radio presentation, as an example). Please note, if the link is provided, the LB/B has to ensure its availability after the end of the project, as stipulated by the Grant contract provisions. In this respect, in case the project has a webpage, it is highly recommended that the major project deliverables/outcomes as well as all public and dissemination materials to be uploaded and stored there. It is also recommended that free of charge promotional tools are used such as project Facebook/Twitter accounts etc.
First of all, it is recommended that Procurements section should be filled in on the course of the implementation of the project, after each procedure is completed. To ensure the correct save of each procedure each beneficiary have to consider:
Using Latin characters when typing information in the fields of this section;
Make sure that, before opening a new entry, there is no other entry which was opened and not saved/submitted by any of the partners.
For more details on how to fill in and save documents, please read section 2.7 Project Procurements, of Annex 5 Guiding on Reporting of the Project Implementation Manual.
According to the Project Implementation Manual – Chapter 6 – Reporting and Project Financing, and to Instruction no.19/16.10.2019 to Beneficiaries of the ENI CBC Black Sea Basin Programme regarding preparation and filling in interim reports in eMS, the Interim report must contain consolidated information from the beginning of the reporting period until the end of it. Therefore, all the information should be included in the Interim/final report, as was included in the progress reports covering the same period.
In this case, the LB should mention the section where such documents were provided in the partner reports, without being necessary to upload them again.
For more details on how to upload documents and avoid duplication, please read section 4.3.4 ‘Attachments’ and “Personal data attachments” tabs, of Annex 5 Guiding on Reporting of the Project Implementation Manual.
The draft of the project report contains the list of FLC certificates which have to be ticked in order to appear after its’ submission.
The grant contract – Article 5 – Obligation to provide information and reports, Interim and final reports (alin. 5.3) and the Project Implementation Manual (PIM) – Chapter 6 Reporting and Project Financing, foresees the obligation for all partners to provide their reports (narrative and financial). In cases, (e.g long duration of the process of expenditure verification or financial reporting of a partner), which lead to major delays in submitting the interim report, the Interim Report can be submitted without the contribution of one of the partners as regards the financial part. The amounts which were not reported by the respective partner for the interim will be reported under the final report. Partners should have in mind that narrative reporting should always be provided by all the partners.
When reporting, please provide the most relevant information and explanations for each sub-activity/deliverable mentioned in the Workplan.
Communication & Visibility
All promotional materials (leaflets, brochures, roll-ups, videos etc.) and documents (deliverables, outputs, reports, agendas etc.) produced during the implementation of a BSB project must contain the following elements:
a. The logo of the European Union must appear on all the communication and promotional materials with the following text „Project funded by EUROPEAN UNION”.
b. The Programme’s logo must appear on all communication and promotional materials.
c. The project’s logo should appear on all communication and promotional materials.
d. The Programme’s slogan “Common borders. Common solutions.” will be used on all communication materials in a very visible place.
Also, please note that on the back-cover page of any publication a technical box will be placed which will contain: the title of the Programme; the editor of the material; date of publishing; the Programme text and disclaimer. Please check the compulsory information chapter from the Communication and Visibility Manual (CVM).
Other institution logos, like beneficiaries’ logos, are allowed in BSB project materials and documents, but they will not interfere with the Programme visual identity elements (EU and Programme logo) which will be the biggest and most visible ones.
Moreover, any visual element in an additional logo may be wider OR higher (but not both) than the Programme visual identity elements.
According to the Communication and Visibility Manual (CVM), “The beneficiaries/lead beneficiaries of the ENI CBC Black Sea Basin Programme 2014-2020 are responsible, according to Article 79(2) of the Commission Implementing Regulation (EU) 897/2014, for adequate visibility of the Union contribution to the programme and projects in order to strengthen public awareness of the Union action and create a consistent image of the Union support in all participating countries”.
The recommendation “Press conferences organized in the context of the communication and visibility plan should always be organized in cooperation with the European Commission” should be understood in this context.
Therefore, we recommend you to invite at the press conference the representatives of the EU delegation in your country in order to increase the visibility of both project and EU support.
Regarding the amount of European Union funding in the local currency that should be mentioned in the press release, the recommendation is to use the InforEuro exchange rate from the month corresponding to the date signature of the Grant Contract.
For the definition of the European Union, please refer to the Chapter 5.3 from the Communication and Visibility in EU-financed external actions where is indicated a general statement about the EU: „The Member States of the European Union have decided to link together their know-how, resources and destinies. Together, they have built a zone of stability, democracy and sustainable development whilst maintaining cultural diversity, tolerance and individual freedoms. The European Union is committed to sharing its achievements and its values with countries and peoples beyond its borders”. The Communication and Visibility in EU-financed external actions is posted on the programme website, section Communication, sub-section Communication material.
All websites of the European Union funded projects must be clearly referred to European Union support and linked to the Programme’s website: https://blacksea-cbc.net/, as well as the Directorate-General for Neighbourhood and Enlargement Negotiations: https://ec.europa.eu/neighbourhood-enlargement/about/directorate-general_en.