European Structural Funds: 2014-2020 analysis of consultation responses

PART 4 - GOVERNANCE AND DELIVERY

Governance

1. It was proposed that for coherence across the Scottish Themed Funds there will be a single Partnership Agreement Monitoring Committee ( PAMC). Operations which are eligible for ESI funding will be owned by Lead Partners and will be monitored by Strategic Delivery Partnerships ( SDPs).

Question 5 - How do you think the governance and delivery arrangements will impact on your sector?

2. 77 respondents addressed this topic as follows:

Partnership Agreement Monitoring Committee

3. Generally respondents think that the PAMC will aid simplification and that it will have a critical role in taking an overview across all three themed funds.

4. Some respondents think that it is important for the PAMC to reflect the geographical and sectoral make-up in Scotland and would welcome clarification on the membership of the PAMC. Others think that the PAMC could address these challenges by either having sub groups of the PAMC (either rural or urban) or have a separate PAMC for the Highlands and Islands.

Delivery

Strategic Delivery Partnerships

5. There has been a significant number of requests for further information on the legal, financial and audit roles of the SDPs. In addition, there have been requests for information on how organisations can become involved in the SDPs.

6. It is generally thought that the remit and membership of the SDPs should be determined through a defined process. This will ensure that membership is not dominated by government bodies and that there is adequate representation for the private sector.

7. It is also thought by respondents that the SDPs will only work if members recognise the importance of partnership working and that potential conflicts of interests should not be underestimated.

Engagement

Local Authorities/ CPPs

8. Respondents from this sector advised that there needs to be fair representation on the SDPs and at the PAMC. The mixed performance of CPPs in engaging with other sectors has been highlighted by some respondents and it has been suggested that this could be addressed by adopting a Code of Conduct for SDP partners.

9. There are some concerns that the proposals are not practical for this sector as resources are held centrally and each council is a distinct legal entity meaning that it would be difficult for them to fulfil the proposed responsibilities of SDP partners.

Further Education

10. A number of respondents have advised that the proposals align well with the college regionalisation.

Third Sector

11. Some respondents raised concerns regarding third sector representation at the SDPs and that the proposals will exacerbate the disengagement experienced by smaller organisations.

12. It was recognised by respondents that further needs to be done to ensure third sector engagement in the Scottish Themed Funds and that the sector must identify and agree on one national organisation to represent them.

Operational Programme

13. Out of 84 respondents 10 have requested a separate programme for the Highlands and Islands area in order to clearly set out the specific delivery and governance arrangements for transition regions.

Question 6 - How do you think the governance and delivery arrangements will impact on your organisation?

14. 70 respondents answered this question as follows.

Simplification

15. Overall, respondents think that the proposals will aid simplification and should reduce the resources required to address the current administrative processes and procedures. It has also been noted by respondents that the proposals should provide new opportunities and that the new programmes will have less onerous audit requirements. There is also general acceptance for focussing on outputs with payments on outputs and agreed milestones.

16. However, some smaller organisations do have concerns over future resourcing demands and the capacity that will be required to deliver and manage large scale operations. In addition, respondents have highlighted that there must be consistency in audit arrangements across all EU funding programmes. This would be particularly welcomed by organisations that access a variety of these funds.

Partnership Working

17. Respondents have recognised that the proposals present the potential for existing partnerships to be merged ensuring cross sector engagement and that new partnerships should only be commissioned where required.

18. However, some think that the proposals will exacerbate the sense of disengagement felt by some organisations and there are concerns that the proposed structure will rely on SDP partners to relay intelligence and knowledge through local connectivity rather than a direct mechanism. To overcome this it has been recommended that the relationship between the SDP partners must be structured.

Local Authorities/ CPPs and relationships with other

19. Generally Local Authorities think that there will be a significant challenge to demonstrate local impact on delivery of national objectives and that partnership working between Local Authorities will become vital. Previously there have been some difficulties in other sectors or organisations engaging with CPPs and respondents have indicated that they would welcome a simple process for engagement. It has been highlighted by some respondents that if this is left unresolved then some organisations will inevitably find funding opportunities are scarce. In addition, some Local Authorities think that the proposals will exacerbate disengagement and that they may not have the opportunity to influence the new programmes.

20. Respondents also think that there is a strengthened role for CPPs and health services that could be better linked to the process.

21. In addition respondents highlighted that having single Local Authorities or CPPs as lead partners, and taking the financial and audit responsibility for large groupings, may be difficult to implement.

Question 7 - Are there any unidentified governance or delivery arrangements that could aid simplification of the future programmes and ensure that the Structural Funds complement each other?

22. In total 71 respondents addressed this question.

23. In general the proposals have been welcomed, however, respondents have either highlighted or requested further information on:

• how the level of financial and legal certainty, required to minimise audit risk, will be achieved;
• how information regarding the new programmes will be communicated to all stakeholders equally;
• how decisions will be made with as much transparency as possible; and
• if the start of the new programmes is delayed how will the funding gap be filled.

Delivery

24. Overall, respondents have advised that the governance and delivery arrangements need to be kept as streamlined and transparent as possible in order to ensure full engagement and participation from all stakeholders. The importance of carrying forward lessons learned from the current programming period was also highlighted and respondents have suggested that rather than creating new structures, arrangements which have been shown to work, should be built upon.

25. Furthermore, there needs to be a fully developed and tested operational framework in place prior to the programme

launch (including Operational Programmes, IT system, National Rules, guidance and cost methodologies). Respondents also requested clear monitoring plans and guidance is needed on how the PAMC and SDPs will work.

26. Some respondents have advised that Integrated Territorial Investments ( ITI), Joint Action Plans and Community Led Local Development should be explored as an option for addressing geographical issues. One respondent advised that if local action groups were able to draw funds from each of the Scottish Themed Funds then they could ensure complementarity between Structural Funds and other EU Funds. .

27. Other respondents also requested a global grants programme and wider availability of Technical Assistance to ensure the involvement of a wider cohort of locally based organisations.

28. In addition, respondents think that further work needs to be done to align the proposals to social policy agendas, such as Equally Well, the Early Years Framework and Achieving Our Potential.

Youth employment initiative

29. The Youth Employment Initiative will support any young person in the EU who has been unemployed for more than four months by offering them a job, training or apprenticeship. The initiative will mean that all regions in the ' NUTS 2' category that had youth employment rates above 20% in 2012 would be eligible for Youth Employment Initiative help. This may mean that the South West of Scotland could be eligible to benefit from this funding.

Question 8 - What other delivery options do you think would be feasible for delivering youth employment initiatives?

30. A total of 60 respondents addressed this question as follows.

31. Respondents highlighted that under the proposals only certain areas of Scotland will be eligible for these funds, however, this is a pan Scotland issue and support is required across the region.

32. In addition, there is an agreement that many sectors, including third, public, private and further and higher education need to be involved in delivering the Youth Employment Initiative.

33. While it is recognised that there is a need for a tailored pipeline for people that require extensive support to get into employment, a separate delivery arrangement for the Youth Employment Initiative could undermine efforts to integrate investment. Some respondents think that the development of a local strategic skills pipeline would ensure that delivery builds on existing models of good practice and would improve outcomes.

34. Furthermore, some respondents highlighted that these funding opportunities should be limited to those under 24 years old as a high proportion of over 24's are accessing other provision.

Audit and control

35. Each ESI fund will have its own implementing regulation and as a result mixing the funds in a single strategic operation may be difficult to manage from an audit and reporting perspective. In order to retain clear reporting and audit lines each operation will need to either:

• draw from one ESI fund; or
• be designed to have clear and distinct elements which only draw from one ESI fund.

Question 9 - What other measures could be taken to reduce the audit and control pressures?

36. 63 Respondents answered this question.

37. Many advised that there needs to be clear, established and tested guidance and National Rules from the outset of the programmes and they need to take into consideration lessons learned from the current programmes. Respondents also request that training on the operational system for the new programmes be provided prior to their launch. There were also requests for guidance on State Aid and National Rules.

38. Respondents advised that processes should be designed with the user in mind and audit requirements should be proportionate to the scale of the funds involved. Some respondents indicated that simplification could be ensured with fewer checks and more on-line reporting, and that this could be achieved by having an annual check that is subject to audit checks and not the current system of continuous audit checks.

39. Some respondents welcomed the introduction of simplified cost options and requested further information on how these would be implemented. In addition, respondents welcomed the move to outcomes based monitoring. However, it was highlighted that outcomes can take a while to be achieved so a milestone approach may need to be developed. Respondents also advised that care will need to be taken when designing the operational system so that it accurately records all the necessary information.

40. There was also an agreement that it is important not to deter projects from seeking multiple sources of funding by ensuring there is flexibility around audit and reporting requirements. Furthermore, funding applications have historically been challenging to complete in tight timescales and respondents recommended two funding rounds to overcome any problems with deadlines.

41. One respondent also highlighted that many of the forms for the current programmes are not accessible and present difficulties to those with certain disabilities. In the new programmes forms should be made available in accessible formats.