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First Class Support for Excellence in Research
Marie Curie Monitoring Action and Information Days
Barcelona, June 9th-11th 2010 Rita, BULTYNCK-LEPOUDRE
Unit A.2 - Finance
Presentation of the REA ex-post Audit processes
First Class Support for Excellence in Research
Today’s agenda
1. Presentation REA Audit processes and procedures Preparation
Execution
Follow up
2. Presentation about Marie Curie Actions financial rules General financial rules for Marie Curie Actions
Details on actions
3. Questions & Answers
First Class Support for Excellence in Research3
• The REA may, at any time, during the contract, and up to five years after the end of the project, arrange for audits to be carried out.– Technical review– Technical scientific audit– Financial audit
• Audits may be carried out either by REA staff or by private audit firms mandated by the REA.
• An Annual Audit Plan has been established in line with the FP7 general audit strategy.
• Technical Audits can be performed at the same time as financial audits
Ex-post Audit of grants beneficiaries
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Aims
• The aim of the ex-post financial audits is 1. verifying contractor’s compliance with the financial
contractual provisions, 2. assessing the legality and regularity of the
transaction, underlying the implementation of the Community budget.
3. reviewing of some relevant systems of internal controls of the Contractor in order to assess whether it is adequate and sufficient to ensure that costs incurred by the Contractor on EC-research funded projects are correctly allocated to those specific projects and recorded as such in the accounting records.
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Ex post Audits by REA auditors
• Approx. 20% of audits • Mostly used for risk based
audits, for which a specific audit programme tailored to the identified risks is required
• Specific audits (follow-up, requests, …)
• Consistency with Research family audits
Audits: In-house / Outsourced
Ex post Audits by
Contracted audit firms
• Approx. 80% of audits • i.e. representative selection
and audits of top beneficiaries
• Supervision of the audit process by REA services
• Consistency with Research family audits
AUDIT ON REQUEST: Performed by auditors on Operational units requests Could be triggered by irregularities during project implementation
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Audit Cycle
Audit Strategy & Selection
Planning & Preparation
Examination on site
Reporting &Audit Closure
Implementationof Audit Results+EXTRAPOLATION
First Class Support for Excellence in Research 77
Preparation: audit of selected beneficiaryPreparation: audit of selected beneficiary
• Selection of Grant agreementsSelection of Grant agreements
Based on various criteriaBased on various criteria
• Creation of audit fileCreation of audit file
Gathering of info from:Gathering of info from:
-- REA operational servicesREA operational services
-- external sources; e.g. internet external sources; e.g. internet
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Preparation: Audit on-the-spot
• Initial contact by the responsible auditor approx. 1-2 month before examination on site to agree on dates and logistics
• Formal letter to announce the audit including detailed annex on information and documentation to be provided
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• Detailed annex to announcement letter includes precise list of information to be provided either– Prior to the audit examination on site (by mail)– At the time of the audit examination
• Most relevant information in the early preparation are the detailed project accounts matching the total as claimed in the financial statements (Form C)
• Exact information requests to be provided in advance also depending on the individual project (s) and audit scope
Planning & Preparation: Information requested
First Class Support for Excellence in Research
Examination on site
Openingmeeting
Analysis of Systems in place
Test of systemsand substantive
evidence
Closuremeeting
Assessmentafter on site
visit
Usually within 4-5 working days (one week) (…)
General info on:
• organisation
• projects
• financial administration
• internal control system
Clarification on audit agenda for further days
Analysis of documents and explanation received and collection of audit evidence
Discussion ofpreliminary findings andobservations
Indication of further audit procedure
Interviews
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Reporting and Closure of the Audit
• Transmission of Draft audit report (after internal consultations and quality control) for comments by the audited organisation– Usually based on the preliminary conclusions– Delay (30 days) to provide comments to the draft
• Consideration of comments and finalisation of the audit report
• Closure of the audit by formal letter indicating – where appropriate - the further procedures on the implementation of audit results
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Implementation of Results: Cases
No findings
Financial Adjustment
(Only) qualified recommendation
Non-systematicfinding identified
Systematicfinding identified
Implementation finalised
Correction of future payments or recovery by the responsible financial services
Extrapolationof audit results
Follow-up Audit
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Follow-up: liquidated damages
• Financial penalty due for overstatement of expenses, unjustified financial contribution received from the Commission/REA
• Only due for the reporting period under question
• When due, has to be paid together with the unjustified financial contribution
• Will be claimed by the mean of Recovery orders issued by REA
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The extrapolationThe extrapolation
Initiation ImplementationDecision Follow-up MonitoringManagement Launch
Final Audit reportThe auditor submits theextrapolation request
ESC meetingExtrapolation decision
Audit closing phaseContract selection
Audit closureLetter of conclusions sentExtrapolation start
Reception of revised coststatements &supporting documents
45 days / 3 months
+ additional deadline
AdjustmentsRecoveries
Eventual follow-up audit
A long process (up to 2 years)
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1 VAT included in the cost charged VAT
2 Other taxes included on a systematic basis Taxes
3 Incorrect calculation of overheads Overhead
4 Other Ineligible items included (like sales/marketing costs/bonuses) Ineligible
5 Average vs. actual costs Average vs Actuals
6 Budgeted, standard, estimated or fixed rates used instead of actual costs Budgeted/standard/estimated
7 Adjustment in productive hours calculation Prod. Hours
8 Unreliable/missing timesheets/ alternative evidence used Timesheets
10 Wrong depreciation method used/no depreciation applied Depr. Method
11 Wrong calculation method used Calc. Method
12 Unjustified change in direct costs model Change Ind. Costs
13 Other reasons (i.e. double charging, no supporting docs, not for project, outside project period)
Other
14 Wrong exchange rate Exch. Rate
15 Owner manager costs estimated/not substantiated Owner Mgr.
16 Marie Curie flat rates vs. actual cost issue MC flat rates
17 Lack of reconciliation of costs claimed/weaknesses internal control No reconciliation
18 Non declaration of interest on pre-financing Interest Pre. Financ.
Main findings leading to extrapolation (FP6)Main findings leading to extrapolation (FP6)
First Class Support for Excellence in Research
Muchas Gracias !
Rita Lepoudre - Bultynck
Head of Unit Finance Research Executive Agency
COV2 15/132, 1049 Brussels ( +32-2-29613407)