This blog post asks whether there is a win-win in ERDF projects using “fresh eyes” to save money by avoiding penalties. Previously these QA checks were done mostly in-house, but in the current jobs climate they may need to be re-invented.
Declaration: I am currently contracted to DCLG, and all comments here are strictly my personal thoughts only.
It is in the public domain that all types of EU budgets, including ERDF (European Regional Development Fund), have a target rate for financial irregularities set for them that is ideally below 2% and certainly expected to be below 5%. Also publicised is that there are three types of mistake, each with increasing consequences, and these are: errors, corrections, and irregularities.
An error can be remedied without penalty, but needs to be done by the project and early on in the process of claiming funds.
A correction is where time has run out to remedy a mistake as an error, or it is systemic, so there is a financial cost to the project.
An irregularity is the most severe form of mistake, usually found at audit rather than by the project, and this incurs the largest penalties, up to 100%.
People familiar with ERDF, and especially those people who keep up with the details, will know that the processes for claiming funds have recently become more involved. There is now a new 10% check of all the supporting documents. These new checks are mostly in the hope of changing the culture (where necessary) within projects so that mistakes are picked up at an early stage (as errors) before they can become irregularities.
However, some project cultures do not perceive this new 10% check as an opportunity to QA (quality assure) the other 90% of their claims, but rather as an additional item of bureaucracy. To some extent, again in my personal opinion, this is reinforced by public sector organisations generally having a depleted back-office capacity.
But in fairness it also has to be said that some organisational cultures have considered themselves, speaking bluntly, as somehow above and immune from the grubby details, even when they had more staff than now.
Now, while we are being fair, ERDF is not the easiest fund to access that the world has ever devised, and no-one in ERDF is in a position to claim perfection, whether we are in Brussels, London or Lower Pudlington on the Marsh. But if perfection isn’t possible, nevertheless substantial improvements certainly are possible and necessary.
I have recently started writing some fiction, just out of interest as both my parents were writers, and my first book is around 80,000 words. And no, this isn’t a joke about bidding… One lesson I have come across for new writers from experienced people such as senior publishers, and it is given time and again, is to always have a Copy Editor review your work. Even the best authors have them, and need them. Much lower down the food chain, I found a glass of orange juice of mine had turned into a cup of coffee on the next page. There are bound to be more mistakes like this which I just cannot see. Missing commas. Repeated phases repeatedly.
Copy editing is also an art form in diplomacy, how to nicely let someone know their mistakes, which is mostly saying that, actually, everyone makes them.
So, at the level of each project we have a choice. We can either (a) moan and complain about EU funding and its lower level of tolerance for mistakes than we find in UK funds, or (b) we can take up arms and rebuild into the processes of many projects a respectful, professional, knowledgable QA role.
Clearly I favour the latter, and the scope should start with current and recent claims, then moving on to prepare all the project files in readiness for any full audit. Perhaps if I was more selfish I might instead favour the former – sit back and complain – creating more work for auditors!