European Structural and Investment Funds: claims and verifications

1. Systems check

Q1. When will the visits take place?

A. Visits will be scheduled once individual Strategic Interventions have been approved on EUMIS - this requires the Offer of Grant to have been accepted, appropriate milestones to have been agreed and a claim schedule to have been put in place. Systems checks will not be undertaken until signed acceptances of grant have been received for approved operations.

Pilot system checks are planned for mid-August - a full programme of visits will be undertaken once these checks are complete and priority will be given to Lead Partners who are ready to claim. Where a Lead Partner have already returned a signed acceptance of grant, the Portfolio & Compliance Manager will be in contact to arrange a visit date. The Managing Authority (MA) will provide at least two weeks' notice of a visit.

Q2. Will the MA visit delivery agents?

A. For the majority of Strategic Interventions, visits will take place at Lead Partner level. However, there may be some instances where it will be appropriate for the MA to visit a Lead Partner's delivery agent.

Q3. What does the MA expect in terms of staff training?

A. The MA will expect to see evidence that all staff involved in the delivery of operations are aware of the relevant regulations / guidance documents / audit requirements and have been provided with adequate training to fully understand these requirements e.g. audit and compliance, document retention, data collection, procurement and publicity.

In addition, evidence that the Lead Partner has a process of informing new members of staff (and any organisations they are working with) of these requirements will be requested.

Q4. What will happen if our Management Information System (MIS) is not yet in place?

A. Where a Lead Partner does not have an MIS in place, the MA may decide to defer the visit until the system is available. Alternatively, the MA may choose to conduct the visit and ask the Lead Partner to provide clarification about the data that the system will be expected to collect - once the MIS is in place, a follow-up visit will be scheduled to complete the checks.

Q5. We submitted a procurement manual at the time of submitting our operations why was this not checked then?

A. Procurement manuals were not required as part of the operation application process and have not been assessed. A check of procurement processes will therefore form part of the system check.

2. Milestones

Q1. Is there any guidance on Milestones?

A. The following guidance is available on the ESIF website: http://www.gov.scot/Resource/0049/00499685.pdf

Q2. What are Milestones?

A. The MA will use milestones to monitor progress. Milestones are based on the cost model being used within each individual operation (i.e. procured / flat rate / actual / unit costs). Milestones must have a unique name and will be based on annual or bi-annual activity.

The full cost of a milestone does not have to be met before the milestone can be claimed against. Employability Pipeline operations can have non-cost milestones (separate guidance has been issued to those Lead Partners that intend to deliver Pipelines)

Lead Partners that have accepted the Offer of Grant but have not yet agreed appropriate milestones, please contact the relevant Portfolio & Compliance Manager.

3. Designated signatories

Q1. Is there any guidance on designated signatories?

A. Once operations have been uploaded to EUMIS, the MA will check that all information has been correctly recorded. Once correctly completed, the MA will issue confirmation that the operations have been accepted via a EUMIS Offer of Grant. In addition, the MA will issue a Designated Signatory Form that must be signed by the Lead Partner's Chief Executive, or equivalent in order to confirm the nominated individuals authorised to sign off claims on behalf of the organisation (up to 4 designated signatories can be nominated).

4. Claims

Q1. How are claims entered on EUMIS?

A. Claims are submitted at Strategic Intervention level and not by individual operations - EUMIS details all costs /milestones and records the individual operation they link to. It is therefore easy to distinguish costs relating to each operation within a claim.

Recipients supported within the claim period will be entered on EUMIS - as part of the administrative verification checks, a sample of this data will be checked (in addition to a sample of costs). Costs must be entered individually on EUMIS. Both costs and recipient information can be uploaded via the web interface.

Q2. How should apportioned costs be added?

A. Direct staff costs for management should be as per the budget allocation split between the shared operations.

If other costs are being split between operations, an apportionment methodology should be discussed and agreed with the MA in advance. Once agreed, a copy of the methodology should be retained for future audit purposes.

Costs must be entered on EUMIS in line with the agreed apportionment methodology. If there is any change to the agreed split, the MA must be informed and have agreed a revised methodology prior to any costs being entered on EUMIS.

Q3. How should irrecoverable VAT be entered?

A. For irrecoverable VAT to be claimed, Lead Partners must:

• have provided the MA with a letter from HMRC (or equivalent e.g. accountants) confirming that VAT is irrecoverable (see section 1.15 of the National Rules on Eligibility of Expenditure)
• have selected 'VAT Applies' on EUMIS. If this option has not been selected, a formal Change Request will be required before the claim is submitted.

Entering irrecoverable VAT at claim stage:

• it is the MA's preferred option that Lead Partner's enter the full amount (i.e. cost item + VAT) when inputting a cost on EUMIS.
• where irrecoverable VAT is a separate cost / line within a Lead Partner's own financial system and costs are being uploaded to EUMIS via the web interface, the VAT element can be uploaded as a separate cost /line. Where this occurs, an appropriate description should be added to link the VAT cost to the related net cost being claimed. The 'cost heading' selected for both the VAT and the associated cost should be identical.

Q4. What detail needs to be entered into EUMIS for costs?

A. Please refer to the individual cost model being used:

Staff costs / flat rate costs

• Total Direct Costs (i.e. basic pay + employer's NI + employer's pension) – the percentage of indirect costs will be automatically calculated by EUMIS
• Pay Period (Start and End dates)
• 'Description' - the Employee's name or a unique identifier for each member of staff
• Defrayal Date Procured Costs / Actuals
• Total Amount claimed
• 'Description' – Contractor Name and Contract Reference (if a framework has been used)
• Total Invoice amount
• defrayal date

Grants

• Total Amount claimed
• 'Description' - Grantee's Name
• Total Invoice amount
• Defrayal Date

Wage subsidies

• total amount claimed
• 'description' – the linked participant
• defrayal date

Procured costs when linked to match

• total eligible costs (the MA recommendation is that invoices should record the Total Eligible Costs linked to the grant amount to allow ESF / ERDF to be paid.)
• lead partners should be able to provide evidence of the full cost according to the contract agreement (see p. 27 of The National Rules on Eligibility of Expenditure for further clarification)

Q5. Costs for workshops?

A. Workshops should be claimed as a procured cost or via a flat rate model (based on staff costs). Costs can only be claimed once they have been defrayed.

Q6. How should costs be split between H&I and LUPS operations?

A. In the majority of cases, Lead Partners must have agreed a percentage split and rationale / apportionment methodology with the MA. This will determine how costs are split between milestones when entering applications on EUMIS. Costs will then be split as per the agreed percentage.

Q7. Claim Turnaround time

A. EC Regulations require that all valid claims must be paid within 90 days. The MA will process all claims as quickly as possible and ask that full supporting information is provided by the Lead Partner when requested by the MA. Where there are a large number of items or procured contracts, it is likely that it will take longer to process the claim. It is likely that the first claim for each Operation will take longer to process – as there may be a large number of costs etc.

Q8. Is there a claim form/can a claim be printed?

A. There is no manual claim form – however, each section of the claim can be exported into Excel or Word format in order that a printed copy of all data may be retained.

Q9. Why do costs need to be entered individually into EUMIS?

A. Costs must be entered as individual items on EUMIS. Costs must not be grouped together and entered as one item - the reasons for this are as follows:

• the costs recorded on EUMIS form the basis of the Transaction List created by the MA to check eligibility - therefore the MA must be able to identify individual costs
• the MA is required to check individual defrayal dates
• if grouped together the verification sample would require the MA to check (and for the Lead Partner to evidence) numerous costs for one line
• where ineligible costs are identified, the MA must reject the full cost item (e.g. even if only one of the costs is ineligible)

Q10. Does an employee's pay, the employer's NI and pension contributions need to go as separate lines

A. No. The full amount being claimed for each staff member (per month) should be entered as one cost item (i.e. basic pay, employer's NI and employer's pension contribution).

Q11. FINAL CLAIM – if the MA reject costs which need to be revised and re-submitted as part of any new claim, how does the Lead Partner submit a final claim?

A. Lead Partner's must notify the MA when submitting a claim which includes the final costs of an operation.

• if the MA rejects any costs as part of the verification check, the costs can be revised and resubmitted as part of a new claim and the MA will close the operation.
• if no costs are required to be rejected, the MA will mark the claim as the final one for that operation.

Q12. How does the Strategic Intervention Manager (SIM) check the data within the claim?

A. The SIM can access the 'Claims' tab and select the 'Claimable Items' button - This allows the SIM to see all costs and recipients linked to any milestones that are recorded on EUMIS (and have not been included in any claims).

The SIM can then ensure that all appropriate cost and recipient information is correctly recorded on EUMIS.

The costs table within 'Claimable Items' will allow the SIM to check that the necessary data has been entered. A description must be added against each cost before a claim is created.

Once recipients have been linked to a milestone, they will appear in the next appropriate claim. However the SIM will not be able to see any mandatory data / outputs / results linked to recipients without checking each individual record. A list of all recipients due to appear in the next claim can be provided by the MA on request - this report shows all recipient data, milestones and outputs and results. This will allow Lead Partners to check that all data is correct prior to the submission of a claim.

Q13. Indirect Costs – what does the MA check to verify the indirect costs?

A. The verification process will only check direct costs.

Q14. Payments – how do payments for ESF appear on bank statements?

A. When making a payment, the MA issues a remittance advice note detailing the ESIF payment. In addition, the BACS narrative recorded on the Lead Partner bank statement will generally refer to "Scottish Government".

It is worth noting that even though Scottish Government issues separate payments, some banks may consolidate several payments from the same organisation into a single amount on the bank statement (i.e. where they are paid into a general funding account on the same day).

Q15. Can Lead Partners access the test site?

A. Lead Partners can now access the live EUMIS site.

If any Lead Partner is unclear about the type of data required, or the processes to follow, please contact eumis@gov.scot.

Q16. Is claims guidance available?

A. Claims guidance is available on the ESIF website.

5. Verifications

Q1. What form will verifications take?

A. Verifications will be Desk based and a sample will be selected based on the risk rating of individual operations. A sample of costs, eligible recipients and procurement will be checked

ESF recipient checks
Please refer to the following guidance on the ESIF website:

• EC Guidance for Monitoring and Evaluation – ESF
• EC Guidance for Monitoring and Evaluation – Annex D
• ESF Participant Guidance
• ESF Participant Records Guidance is currently being reviewed and will be published shortly.

Wage Subsidy Checks
Guidance is currently being reviewed and will be published shortly.

ERDF Recipients Checks
Please refer to the following guidance on the ESIF website:

• EC Guidance for Monitoring and Evaluation – ERDF
• Final Recipient Organisation Records

Grant Recipient Checks
Please refer to the following guidance on the ESIF website:

• Grant Scheme Manager Guidance

Q2. Will the MA inform Lead Partners if ineligible costs have been identified before paying the claim?

A. Yes – however it will not be possible to correct the cost before payment. Once the claim has been paid, Lead Partners will be able to revise the costs and resubmit them within the next claim.

Q3. Can any costs identified as irregular at post payment checks be replaced by other costs?

A. No - once claimed, it will not be possible to replace the amount deemed ineligible with other costs.

Q4. How much time does the LP have to provide verification evidence?

A. Lead Partners are encouraged to submit the required evidence as quickly as possible – the claim will not be processed and paid until the verification check is complete.

Q5. Volume of Evidence. Will e-mail cope with size of documents being sent in?

A. The MA is currently reviewing various options for sharing evidence - it is currently anticipated that evidence will be provided by Lead Partners via email.

It should be noted that the Scottish Government is unable to accept emails larger than 25Mb.

Q6. Data security?

A. The Scottish Government's e-mail system is secure.

Please contact the relevant Portfolio & Compliance Manager if you require confirmation of the systems that underpin this security.

Q7. Will the MA require a full BACs list?

A. A full BACs list will not be required provided that a clear link between the amount on the BACs report and the amount on the bank statement can be established (generally, the page that the item appears on and the page that records the BACs total is sufficient). Where necessary, information not linked to the claim can be redacted.

Q8. Is it acceptable to password-protect documents?

A. Yes.

Q9. Certifying Documents

A. One single document should be provided - certifying that all documents provided for the verification are true and original.

Please refer to the 'Document Retention Guidance' on our website for further clarification. http://www.gov.scot/Resource/0048/00489832.pdf

Q10. Any special requirements for scanning?

A. Please see the 'Document Retention Guidance' (see link at Q9) on our website for clarification on scanning requirements.

Q11. Clarity on electronic signatures and keeping information electronically

A. Electronic Signatures (as defined in Directive 93/1999/EC 13 December 1999) and electronic data exchange systems (as defined in Chapter II of Commission Implementing Regulation (EU) No 1011/2014 OF 22 September 2014) are eligible in the 2014-2020 ESFID Programmes. Lead Partners must ensure any systems used conform to the appropriate directives.

6. ESF participants

Q1. Can recipient data be changed?

A. Once a recipient has been entered and linked to a milestone or output, the system locks the mandatory data.

Further guidance will be issued outlining the process for changing 'locked' data.

Q2. Is there any guidance on Exit dates and Returning participants?

A. Please refer to the EC Guidance for Monitoring and Evaluation - Annex D on the ESIF website which contains practical guidance on Data Collection and Validation.

Q3. What happens if a Lead Partner loses contact with a participant?

A. Please refer to the EC Guidance for Monitoring and Evaluation - Annex D on the ESIF website which contains practical guidance on Data Collection and Validation.

Q4. What is the 'supported' field?

A. The 'Supported' field indicates whether a participants can be counted towards target outputs and results.

If a participant is deemed to be ineligible (e.g. via a verification check, because it is not possible to evidence specific eligibility criteria or because the Lead Partner is unable to gather all the mandatory data), the 'Supported' field will be 'unticked' and they will no longer count towards the outputs and results for an operation.

Q5. What if the individual does not have a National Insurance number?

A. If an individual does not have an NI number or only has a temporary NI number, an alternative unique identifier must be recorded on EUMIS instead e.g.

• Scottish Candidate Number (where applicable)
• A unique identifier provided by the Lead partner - this must not be in a similar format to the NI number (so that these individuals can be easily identified by the MA).

Lead Partners should update the MA once affected participants receive an NI number (so that EUMIS can be updated accordingly).

7. ERDF recipients / businesses

Q1. What types of organisation should be listed as 'Third Sector'?

A. Third sector option should include communities, charities and social enterprises.

Q2. Where organisations are not a limited company, what should be entered for 'Company Registration Number'?

A. Lead Partners should record either the Business Gateway reference or a Lead Partner unique reference.

Q3. Can a company be reported before it has been confirmed that they are an SME?

A. The Lead partner/delivery agent must confirm that a recipient is eligible before reporting them on EUMIS. The term 'SME' is as defined by the European Commission: http://ec.europa.eu/growth/smes/business-friendly-environment/sme-definition/

Q4. How should a company be reported if the headquarters is outside Scotland?

A. If a recipient is eligible, but the headquarters are outside Scotland, the main headquarters should be reported as 'head office postcode' and the main office in Scotland should be reported as 'operational base postcode'.

Q5. If a company is a SME based on the balance sheet total rather than turnover, should this be reported?

A. There is a 'Notes' field which should be used to establish that a recipient is an SME if the turnover is in excess of the limits defined by the European Commission.

Q6: Where a company/project is has received support through a series of interventions, when should they be reported on EUMIS?

A: A recipient should be reported once they have achieved the minimum requirement for the relevant milestone (e.g. Once one full day's support (7 hours) or equivalent is complete or a grant/loan has been awarded and first payment has been made).

8. Procurement

Q1. What is required to recorded on the system?

A. The following information will be recorded on EUMIS:

• contract name
• contract reference
• contract type
• OJEU
• contract award amount
• date awarded
• contractor
• total paid to date
• brief description of contract
• comments

A Procurement tab will be available on EUMIS in due course. If Lead Partner's wish to submit a claim before this tab is available, the information listed above should be submitted to the MA in Excel format. Lead Partners will upload this information to EUMIS once the Procurement tab becomes available. In addition, the following should be noted:

• all frameworks and procured contracts must be listed
• when costs are entered against a milestone linked to the contract, the contractor's name should be recorded in the 'description' field
• when costs are entered linked to a framework, the framework reference should be recorded in the 'description' field
• at the time of submitting a claim, the contracts tab should be updated for each operation showing the total paid (to date) for each contract

Q2. What will the MA check?

A. At claim stage the Managing Authority will take a sample of contracts to check based on the risk rating of the operation (in addition, all contracts advertised through the OJEU will be checked) – the full procurement process will be checked.

Q3. How will frameworks be checked?

A. When a framework appears for the first time in a claim, the MA will check the framework itself, as well as how the contractor was 'called off' the framework. In subsequent claims, the MA will sample to make sure contractors have been selected appropriately.

9. Match funding

Q1. How is Match Funding recorded on EUMIS?

A. Match Funding should be declared as received, if Lead Partner or delivery agents have any questions, contact the relevant Portfolio & Compliance Manager

10. Wweb interface

Q1. Can you provide an overview of the Web Interface?

A. A web interface is a piece of software located on a web server that outside applications can connect with. Instead of a human reading and updating data on a web page, an external system can read and update data via a web service. However, just like a human will have to log on to secure web systems, a system calling a secure web service will also have to provide valid logon credentials. When one of your external partners wants to send data to EUMIS, the web service will authorise and identify them by their log on details.

Q2. What can be uploaded?

• costs
• recipient information
• achievements (milestones)
• outputs and results

Q3. Is there anything that can't be uploaded?

A. The following information must be updated manually prior to claim submission

• match funding
• contract information
• income

Q4. Is the Web Interface Specification available?

A. The Final Specification is now available on the ESIF website: http://www.gov.scot/Topics/Business-Industry/support/17404/EuropeanStructuralFunds/NewITSystem/EumisWebAPISpecification/eumiswebapispec This document has recently been updated - please check the website to make sure the most recent version is being used.

An Excel spreadsheet recording all outputs and results as they appear in EUMIS is also available on the website – please note that many of the titles/descriptions have been shortened / altered. In order to upload outputs and results successfully onto EUMIS, Lead Partners will need to ensure that these altered titles / descriptions are used. http://www.gov.scot/Topics/Business-Industry/support/17404/EuropeanStructuralFunds/NewITSystem/EumisWebAPISpecification/EUMISoutputsresults

If you have any further questions please contact eumis@gov.scot

Q5. When will it be available and can Lead Partners test their software?

A. EUMIS is now available for testing. The MA is currently working with a number of Lead Partners to test the system. The test site will remain open for Lead Partners to test their software prior to loading to the live site.

Any Lead Partners intending to use the interface will need to give the specification to their IT developers to make sure that the data can be transferred from individual Management Information Systems and uploaded directly to EUMIS.

Q6. How is it accessed?

A. A separate log in and password is required - this can be integrated into each individual MIS's software, thereby allowing Lead Partner's to upload directly to EUMIS.

Q7. How does it work? Can it upload from Excel?

A. The EUMIS web service takes information from the calling system in XML form (XML is a text mark-up language. It is designed to allow data to be shared between different system types. The XML format is defined by the various XSD definitions. These are needed by the developers writing code to call the web service so that they can correctly assemble the data packages the web service expects.

If Lead Partners are planning to upload data from an Excel spreadsheet and not from an MIS, your IT developers will need to write a piece of software capable of taking the data from Excel and converting it into the xml format required by the interface.

Q8. Is it able to upload participants, achievements and outputs at once

A. Yes. If the recipient is being entered at the same time as the achievements and outputs, the recipient DTO must appear on the upload first. This will ensure the recipient's record exists so EUMIS is able to identify and update it.

Q9. Mandatory fields

A. If all of the mandatory data is not provided, the record will not be inserted into EUMIS when the data is incomplete. There is a set format that should be recorded in the field so that the MA can easily identify these records. In addition, the 'Supported' field should not be selected for this recipient.

Q10. When updating does it override previous data entered?

A. No – the existing record is updated. When sending an update, Lead Partners will provide the operation reference and unique identifier, thereby allowing the additional data to be added to the record.

Q11. How can incorrect data be revised?

A. This depends on the type of data which is incorrect:

• output or result – amended via a Change Request
• mandatory data - lead partner to advise MA (via email and MA will update)
• cost data or achievement data - provided a claim has not yet been submitted, the Lead Partner will be able to manually amend this data

Q12. What records can be inserted/updated?

A. The EUMIS web service has two main methods - "Put" and "Post".

• post methods - insert a new record
• put methods - update an existing record

The web interface documents clarifies whether it is possible to update a particular field e.g.

• data can be added to the recipient records (exit dates, milestones, outputs and results).
• achievements, Outputs, Results, and Costs can be inserted but not updated via the web interface.

Q13. How are records inserted or updated?

A. Single record method calls:
The web service will allow single records to be inserted or updated - thus allowing the external systems to update EUMIS in real time (if Lead Partners choose to do this). In this instance a single record XML fragment will be sent to the web service.

Multiple record method call:
The web service will also allow a bulk submission allowing many different record types to be inserted or updated in one call. In this instance, an unlimited number of records can be sent to the web service for insert or update. It is possible to add a new ESF recipient and any number of achievements, results and outputs for the new recipient at the same time. However, the ESF recipient record must be added first so that it can be linked to the related "child" record (this applies to ERDF recipients and NRA records).

Q14. How are records linked to their correct "parent"?

A. ESF Recipient, ERDF Recipient and NRA records - the "calling system" must provide details of the operation these are linked to.

Cost record inserts – the "calling system" must provide the operation reference and the milestone title / due date.

Achievements, Results and Outputs – must provide the parent record identifier (company registration number or ESF recipient identifier etc) and the Result / Output / Milestone Title.

11. Users on EUMIS

Q1. How do I get access?

A. The MA will create a Strategic intervention Manager profile and will issue the Lead Partner with these details and a link to the system. The Lead Partner can then add additional staff as required. The Lead Partner is also responsible for adding delivery agents and their users on the system.

Q2. Can there be more than one Strategic Intervention Manager on EUMIS?

A. Yes - the Lead Partner can add additional SIMs.

All SIMs can view the relevant Strategic Intervention and all related data. However each SI will have one 'named' SIM under the Contact Details section on the Main SI tab and any work relating to the SI will show on this individual's homepage.

It is possible to change the named SIM by adding the required individual as an SIM and then amending the Named Contact under the Main Details tab. For further information please refer to the Lead Partner User Guide on the ESFID website.

Q3. Can the MA provide details of the various roles in EUMIS?

A. MA Roles:
System Administrator (SA) - The SA monitors overall usage of the IT System and should be contacted in the case of any system errors or issues. The SA's contact details can be found under 'contact us' in EUMIS.
LP Roles:
Strategic Intervention Manager (SIM) – This will be a role for the Lead Partner of a Strategic Intervention and will be responsible for the submission of new operations for approval, grant claims as per the agreed claims schedule, and any change requests.
LP Administrator (LPA) - This will be a role for the Lead Partner. The LPA will be responsible for maintaining user access to the EUMIS IT system within the Lead Partner and its Delivery Agents. The LPA will add users, reset passwords, unlock accounts, and mark users as inactive.
DA Roles:
Operation Manager (OM) – This will be a role for the Delivery Agent (DA) responsible for a specific operation within a SI and will be the key contact for delivery of that operation. They will update all defrayed costs and add details of recipients supported and activity undertaken. They will provide all necessary information to the SI lead partner.
DA Administrator - This will be a role for the DA responsible for maintaining EUMIS IT system users within the DA – they can add users, mark as inactive and reset passwords. This role is optional as this work can be undertaken by the LPA.

Q4. Who can access EUMIS?

Lead Partners and delivery agents enter data on EUMIS:

• if activity is being delivered by procured contractors, the Lead Partner is considered to be the delivery agent.
• if activity is being delivered via a Challenge Fund, the Lead Partner is considered to be the delivery agent - the contractors or organisations will deliver the activity and will provide the Lead Partner with all relevant data to upload to EUMIS (either manually or via the web interface).

12. Other

Q1. Communication – how will Lead Partner be made aware of any updates or new guidance?

A. Updates relating to the 2014 - 2020 Programme are available via:

• the ESIF Division website
• the ESIF Twitter feed - @scotgovESIF
• email – to be added to the mailing list please contact futurefunds2020@gov.scot

Q2. Post payment checks

A. These checks will be similar to the Article 60b and Article 62 checks under the 2007-13 Programmes and will check that Lead Partners have delivered as per the approved operation application.

• further detail regarding these checks will be issued in due course

Q3. Do existing staff need a new contract for ERDF/ESF?

A. Existing staff do not need a new contract - an updated job description will be required (confirming that the post is related to staff who work 100% on the delivery of ESF/ERDF activity).

Q4. What is an Operation Verification Plan?

A. The Operation Verification Plan (OVP) confirms the overall risk rating for each operation and provides a list of potential risks identified by the MA.

Q5. Which version of the National Rules and Guidance should Lead Partners retain?

A. Lead Partners must ensure that the most recent version of any guidance is used and retained. It may be prudent to retain older copies of the National Rules / Guidance that support previous decisions made.

European Structural and Investment Funds 2014-2020 - claims and verifications.pdf

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