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    COMENIUS REGIO PARTNERSHIPS

    GUIDANCE FOR UK APPLICANTS

    2012

    This guidance document consists of:

    1. Introduction2. Eligibility criteria3. Choosing your partner4. Types of activities5. Submission guidance6. Funding

    Annex 1: How to complete sections D and E of the application form

    Comenius Regio grant applications should be submitted by 21 February 2012 to:

    Comenius Regio ApplicationsBritish Council

    10 Spring GardensLondon

    SW1A 2BN

    NB. The Comenius Regio application form is not an online application form andone signed original and two photocopies must be sent in hard copy to theabove address and by 21 February 2012.

    All application documents, including these guidance notes for UK applicants, areavailable on our website at: http://www.britishcouncil.org/comenius-applications-forms-and-guidance.htm

    http://www.britishcouncil.org/comenius-applications-forms-and-guidance.htmhttp://www.britishcouncil.org/comenius-applications-forms-and-guidance.htmhttp://www.britishcouncil.org/comenius-applications-forms-and-guidance.htmhttp://www.britishcouncil.org/comenius-applications-forms-and-guidance.htmhttp://www.britishcouncil.org/comenius-applications-forms-and-guidance.htm
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    GUIDANCE TO UK APPLICANTS ON HOW TO APPLY FOR

    COMENIUS REGIO GRANTS

    1. Introduction

    You are advised to read the Lifelong Learning Programme (LLP) Guide 2012carefully before starting to develop your application. The guide is available atwww.britishcouncil.org/comenius-background-reading.htm

    However as this is a long and complex document, we suggest you read at least the

    following sections:

    Part 1 General Provisions

    Section 1 General Overview of the Lifelong Learning Programme

    Section 2 What is the Life-Cycle of a partnership?

    Section 3A Procedure for Submitting Grant Applications

    Section 3B Procedure for the Assessment and Selection of Applications

    Section 4A General Financial Considerations Applicable to All Actions

    Section 4B Types of Financing

    Section 4E Partnerships

    Section 4F Multilateral Partnerships, Projects, Network Accompanying Measures,

    Observation and Analysis (with reference to Comenius Regio)

    Part 2a Sub-programmes and Actions

    Comenius Section

    Part 2b Summary Fiche for Comenius Regio Partnerships

    The information in these notes will summarise and build on the information containedin the LLP Guide 2012.

    http://www.britishcouncil.org/comenius-background-reading.htmhttp://www.britishcouncil.org/comenius-background-reading.htmhttp://www.britishcouncil.org/comenius-background-reading.htm
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    2 Confirming your institutions eligibility

    Comenius Regio Partnerships are bilateral partnerships between two local or regionalauthorities, each with a role in school education, in different countries.

    Only these authorities may apply for funding. A list of all eligible institutions, in all theeligible countries, of the Lifelong Learning Programme can be found at:

    http://ec.europa.eu/education/comenius/doc/listregio_en.pdf

    Each of the two local or regional authorities must involve at least one school and oneother organisation from its region or municipality in the project. The school should beone of those eligible for the Comenius School Partnerships programme; the otherorganisation can be any organisation or institution in the region which contributes tothe project. For example, it could be a museum, youth club, NGO, association,

    training institute, library or local company.

    3 Choosing your partners

    You can base a Regio Partnership on: existing co-operation with another region ormunicipality in Europe; an existing school partnership; or on contacts through otherEuropean networks and initiatives. There is no partner search facility for interestedRegio applicants yet, but the Comenius National Agencies will help disseminaterequests via their networks. Please contact the British Council if you need support infinding a partner.

    4 Types of activity

    Regio Partnerships focus their work on clearly defined themes. These could includen,for example, the organisation of school education, co-operation between schools andother local partners (e.g. providers of formal or non-formal learning), or commonproblems faced in school education (e.g. new approaches in the organisation ofschooling, disadvantaged pupils and early school leaving, teacher qualifications andcompetence).

    The partnerships should help local and/or regional authorities to improve their

    educational offer to young people. The main purpose of Regio is not to involve pupilsor students directly but to promote the development of structured cooperationbetween the partner regions in the area of school education.

    Examples of the range of activities that can be carried out in Regio Partnershipsinclude:

    Project meetings between all institutions involved in the partnership

    Exchanges of staff involved in school education (e.g. teacher exchanges, studyvisits of staff working in the local/regional school administration)

    http://ec.europa.eu/education/comenius/doc/listregio_en.pdfhttp://ec.europa.eu/education/comenius/doc/listregio_en.pdfhttp://ec.europa.eu/education/comenius/doc/listregio_en.pdf
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    Action research or small studies

    Job shadowing

    Exchanges of experience and good practice with partner regions / municipalitiesabroad

    Peer learning activities and common training sessions

    Conferences, seminars and workshops

    Awareness raising campaigns

    Co-operation with other partnerships in related subject areas, including mobility tonetwork events if relevant, sharing experience with other institutions in the region

    Joint self-evaluation activities

    Dissemination of project experiences and outcomes Drafting, publishing and disseminating documentation related to the co-operation

    activities

    Regio Partnerships can be combined with already existing activities, e.g. in TownTwinning or other European educational programmes, but should clearly createadditional cooperation activities as well as a deepening of any existing cooperation inthe field of school education.

    5 Submission guidance

    Before completing your application, please ensure that it fulfils all the requirementslisted in the Checklist in the application form.

    The application form should be completed by the relevant authority in thecoordinating region (Partner region 1) of the proposed Regio Partnership, in closecooperation with the partner region (Partner region 2). It should give full details of thePartnership including the details of all partners (regional / local authorities, schoolsand other organisations), all planned mobilities and the grant requests for bothpartner regions.

    The coordinating region (Partner region 1) should send a copy of the completed formto their counterpart local authority in the partner region (Partner region 2). Theauthorities in each partner region should complete and sign the declaration (betweensections B and C of the form) on their own copy.

    Each partner should then submit their own copy to their National Agency by 21February 2012, attaching letters of intent from each of the organisations participatingfrom within their region (letters of intent are not needed from any of the organisationsinvolved in the overseasregion). Partner region 2 must not change any of the

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    information contained in the form completed by the coordinating region (Partnerregion 1): both copies of the form submitted to the respective National Agency mustbe identical (except for the Declaration).

    Please note that the form should be completed well in advance before the deadlineso that both participating regions are able to post its copy of the application on time.

    Please ensure you send one original signed copy and two additional photocopies.

    The application must be signed by the local or regional authority only; the otherpartners must instead sign a letter of intent stating their intention toparticipate in thepartnership. These letters must be attached to the application form. A model letter ofintent is included in this guidance as Annex 1.

    The application form should provide the organisational details of all organisations orinstitutions participating in the project. At least 6 organisations (3 in eachregion/country) are necessary to form a Comenius Regio Partnership. The numbermight be higher (e.g. if several schools are involved).

    Please also ensure that you have completed all relevant sections of the ApplicationForm fully, as it will be assessed as received. The British Council will NOT contactyou for replacement/further information if parts of your form are missing or left blank(but MAY contact you over minor eligibility issues if these can be corrected quickly).

    We recommend that you send your application by recorded delivery and keep proofof postage in case your application is delayed or gets lost in the post. Without proofof postage, we cannot accept re-submission of lost application forms.

    All applications will be acknowledged within two weeks of the deadline.

    6 Funding guidance

    Please also refer to Annex 2: How to complete sections D and E of theapplication form.

    All funding requests must be made in Euros.Comenius Regio provides funding for mobility on the basis of lump sums (related tothe minimum number of mobilities conducted by each partner), and other non-mobility costs on the basis of a contribution (maximum 75%) towards non-mobilitycosts. Comenius is based on the principle of co-funding and beneficiaries areexpected to contribute with at least 25% of co-financing to the non-mobilitypartnership costs.

    A "mobility" is a trip abroad as part of a Comenius Regio Partnership either to thepartner institution or to an event which relates to the objectives of the Comenius

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    Regio project. One mobility refers to one trip by one person to another countryparticipating in the Lifelong Learning Programme.

    Granting lump sums for mobilities eases the burden on applicants, who do not haveto calculate the cost of each trip in detail. For other costs, the approach is flexibleenough to allow financing of a wide range of activities.

    Eligible costs

    To be considered as eligible, costs must satisfy the following general criteria:

    They must relate to activities involving countries that are eligible to participate in theprogramme

    They must be incurred by the project partners

    They must be connected with the partnership (i.e. relevant and be directly linked tothe execution of the partnership in accordance with the work plan)

    They must be necessary for performance of the partnership

    They must be reasonable and justified and they must accord with the principles ofsound financial management, in particular in terms of value for money and costeffectiveness

    They must be generated during the lifetime of the project

    They must be actually incurred by the beneficiary and be recorded in their accountsin accordance with applicable accounting principles, and be declared in accordancewith the requirements of the applicable tax and social legislation

    They must be identifiable and verifiable

    The LLP Guide also lists expenses which are definitely not eligible (see Chapter 4F).

    Please note that indirect costs are not funded under Comenius Regio Partnerships;costs relating to mobility are covered by the lump sum. Comenius Regio funding isdivided between mobility costs and non-mobility costs as follows:

    Mobilities

    The table below sets out the maximum lump sum amounts available to UK applicantsfor mobilities within Comenius Regio Partnerships. As in other partnerships, onemobility corresponds to one trip abroad, carried out by one person working for one ofthe organisations included in the application. The National Agency of each countrywill determine the actual amount applicable for Regio applicants in that country.There are two sets of rates for mobilities: one for partners located up to 300 km fromeach other, and one for partners located more than 300 km from each other.

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    Partnership categories Number ofmobilities

    long distances(over 300 km)

    short distances(up to 300 km)

    Small number of mobilities 4 4000 2000

    Limited number of mobilities 8 8000 4000

    Average number of mobilities 12 10000 5000

    High number of mobilities 24 20000 10000

    See section 4.E. Partnerships in the LLP Guide General Provisions

    Additional (non-mobility) costs

    Comenius Regio funding for other project expenditure is divided into four maincategories:

    1. Staff costs: costs relating to statutory or temporary staff, based on real daily staffcost rates which cannot exceed the maximum eligible costs indicated in the LLPGuide, part 4.F. (Table 5a: Maximum eligible daily rates (in EUR) for Staff costs).

    Costs relating to the following categories of staff can be included:

    Statutory staff, having either a permanent or a temporary individual contract with apartner of the consortium. To be considered in this category, staff must report to therelevant partner organisation as an employee.

    Temporary staff recruited through a specialised external agency by any of theconsortium partners.

    Applicants should base the project budget on real daily staff cost rates, which cannotexceed the maximum rate indicated in Table 5a in the LLP Guide, part 4F. Anysurplus will be considered as ineligible. The veracity of thesecosts may be thesubject of an audit.

    Costs related to staff working through subcontracting shall be included under thecategory "Subcontracting costs" (see below). Staff members of project partners arenot allowed to operate in a subcontracting capacity for the project.

    2. Subcontracting: The total costs for subcontracting may not be more than 30% ofthe total project costs, including work such as translation, interpretation, and printing.

    Costs entailed by procurement contracts for the purposes of carrying out specific andlimited work for the project, can be considered eligible whenawarded by a partner toan external body, organisation or individual (only if not employed by any of the

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    Partner organisations of the consortium). This includes work such as translation,interpretation and printing, etc.

    In order to maintain the concept of the project partnership, the management and thegeneral administration of the project may not be subcontracted by the applying local /regional authority.

    Costs are based on a verifiable estimate or, if the subcontractor is identified, on thebasis of an offer. The estimate / offer will cover all costs (i.e. subcontractors staffcosts plus travel costs, etc). All costs incurred through subcontracting must bementioned under the "subcontracting" category. The category "Other costs" can onlycontain costs incurred by the partners themselves.

    The applicant will award any contract to the tender offering best value for money, thatis to say, to the tender offering the best cost-benefit ratio, in compliance with theprinciples of transparency and equal treatment for potential contractors, care beingtaken to avoid any conflict of interests.

    The following specific European Union rules with regard to procurement apply tosubcontracting under Regio Partnerships:

    Contracts with a value below 12,500 can be paid on a presentation of an invoice

    Contracts with a value between 12,500 and 25,000 are subject to a procedureinvolving at least three tenderers (quotations)

    Contracts between 25,000 and 60,000 are subject to a procedure involving at

    least five tenderers (quotations) For contracts of a value over 60,000, national rules with regard to procurementapply.

    3. Equipment: purchase, rent or lease of equipment if justified and necessary for theproject, depreciated in accordance with tax and accounting rules. The total cost forequipment may not exceed 10% of the total project costs. Please also note thefollowing:

    The purchase, rent or lease of equipment (new or second-hand), including theinstallation, maintenance and insurance costs, is considered eligible.

    Equipment is only eligible when specific and necessary for achieving thegoals of the project/action. Proposed equipment costs must always be clearlyexplained and specifically justified. The rules for procurement apply to the purchaseof equipment as well as subcontracting (see above).

    Equipment must be depreciated according to the relevant tax and accounting rulesof the applicant. In the application these costs can be estimated; detailed calculations

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    will have to be provided at the final report stage. Only the portion of the equipment'sdepreciation corresponding to the duration of the project and the rate of actual usefor the purposes of the action may be included within the budget. The applicant must

    explain the depreciation rules applied. If the nature and/or the context of its usejustify different treatment, this should be duly justified.

    We recommend equipment is purchased at the start of the partnership to ensure youare able to claim the maximum cost of the item(s) as the final amount approved isassessed against date of purchase, percentage of use and depreciation rules.

    4. Other project costs on the basis of real costs: costs not covered by other costcategories such as dissemination of information (e.g. one-off press releases orpublicity shots), the purchase of copyrights and other Intellectual Property Rights, thepurchase of information materials (books, studies and electronic data), rental costs,the purchase of consumables (paper for printing publications, blank DVDs etc), travelcosts for experts or speakers at conferences.

    Only activities which are specific and necessary for achieving the goals of the projectcan be considered eligible. Such proposed costs must always be duly justified.

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    Annex 1 Model letter of intent

    Please use this text for the letter of intent to confirm your organisations commitmentto participate in your Comenius Regio Partnership.

    LETTER OF INTENT

    To cooperate in a Comenius Regio Partnership

    I, the undersigned, [name of person legally authorised to represent the participatingorganisation] representing [name of participating organisation], agree to participateas a partner in the Comenius Regio Partnership project:

    [Name of Project]

    The application form for this project is being submitted to the British Council by[name of lead UK organisation].

    I hereby confirm that my organisation will fully participate in the above-mentionedproject, if it is approved for funding by the British Council, and will carry out the rolesdefined for my organisation in the application.

    Signature:

    Name:

    Position:

    Date:

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    Annex 2 How to complete sections D and E of the application form

    This example should only demonstrate the logic behind the forms. It is not taken from a realapplication or complete. Figures are rounded in order to ease calculation.

    D. Proposed activity data

    Work programme: planned activities of each participating organisation

    Please summarise in the table below the planned Partnership activities for both partner regions inthe Partnership. Please present the activities for both academic years 2012/13 and 2013/14, in achronological order. The eligibility period of activities starts on 1 August 2012 and ends on 31 July2014.

    D.1 Planned project activities (other than mobility)

    Partner region 1 Approx. starting dateMM/YY

    Activity description(organisation of an event,publication, study, website,etc.)

    Authority 01/13 Teacher training seminar on"Cultural awareness andcreativity"

    Authority 04/13 Publication of seminarresults and developedteaching materials

    School 1 01/13 Exhibition of art works madeby pupils; teaching material

    Other organisation 05/13 Integration of art exhibitionsin school work

    [Name of Organisation] . .

    Partner region 2 Approx. starting dateMM/YY

    Activity description(organisation of an event,publication, study, website,etc.)

    Authority 02/13 Teacher training seminar on"Technical inventions,creativity and research"

    Other organisation 02/13 Using the expertise of localcompanies in schools

    Authority 05/13 Publication of seminarresults and developedteaching materials

    . . ..

    [Name of Organisation]

    Add rows if necessary

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    D.2 Planned mobilities

    What is counted as "a mobility" is one trip abroad by one person. Only transnational mobility (i.e.travel abroad) counts for the calculation of the minimum mobility numbers.

    Please note that mobility activities can take place only between organisations included in thisapplication or to events organised by the partnership project.

    Mobility may only be undertaken by staff of the organisations included in this application. Pleasenote that any participation of pupils in mobilities has to be justified with regard to the aims of thepartnership. In case you plan to involve pupils in mobilities, please indicate this in the column"Planned mobility description". A justification has to be annexed to the application.

    Partner region 1

    Approx.starting datemm/yy

    Planned mobilitydescription

    Sending Org 2 Duration Destination(place andorganisation)

    No.travelling

    09/11 Project meeting Authority 3 Region 2 2

    09/11 Project meeting School 1 3 Region 2 1

    09/11 Project meeting Other organisation 3 Region 2 1

    02/12 Teacher Training

    Seminar

    School 1 5 Region 2 5

    Partner region 2

    Approx.starting datemm/yy

    Planned mobilitydescription

    Sending Org 2 Duration Destination(place andorganisation)

    No.travelling

    09/11 Preparationmeeting

    Authority 3 Region 1 2

    09/11 Preparationmeeting

    School 1 3 Region 1 1

    01/12 Teacher trainingseminar

    School 1 5 Region 1 5

    01/12 Teacher trainingseminar

    School 2 5 Region 1 5

    1 "In-country" mobility to or from Overseas Countries and Territories and ultra-peripheral regions of the EUwill also be considered as transnational mobility, e.g. mobility by a beneficiary from mainland France to apartner in Martinique.

    2 Please indicate if the mobility is done by the local or regional authority, a school or other organisation.

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    E. Requested EU funding

    E.1 Mobility

    Funding requested and estimated number of persons participating in mobility (perparticipating organisation.For each of the participating organisations, please select the "Partnership type" thatbest corresponds to your Partnership work plan for the whole 2 year duration. ThePartnership type indicates the minimum number of mobilities to be conducted and thelump sum amount related to it.Each lump sum type is linked to a minimum number of mobilities to be carried outduring the grant agreement period these minimum numbers have to be respected

    when entering the numbers of persons taking part in mobility activities into the table.

    The lump sum amounts for each Partnership type are defined at national level andthey can vary from one country to another. Please make sure that, for each of theparticipating institutions, you have selected the grant amounts applicable in thecountry and for the programme in question.

    Please indicate the exact distance between the two applicant institutions (in km).

    DISTANCE: 1000

    Partnership type[Table E mobility action types]

    Nr of planned mobilities Grant amount requested ()[Table G National lumpsum amounts]

    Partner Region 1 COM-12M 12 10 000

    Partner Region 2 COM-8M 8 6.400

    E.2 Other (non-mobility) costs

    In order to fill the following table please refer to part 4.E and 4.F of the LLP Guide.

    Please note that Indirect costs are not eligible for funding support in ComeniusRegio Partnerships, Other (non-mobility) costs in Comenius Regio Partnershipscan only be funded up to a maximum of 25.000 EUR per partner region, Travel andsubsistence costs have to be covered by the mobility lump sum; this also includeslocal transport during the mobility.

    When filling in the table, please make sure that you use the right cost category foryour expenses and that you base your calculation on eligible costs only.

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    Staff costs: costs relating to statutory or temporary staff, based on real dailystaff cost rates which cannot exceed the maximum eligible daily ratesindicated in the LLP Guide, part 4.F.

    Subcontracting: cost entailed by procurement contracts, including work suchas translation, interpretation, printing.

    Equipment: purchase, rent or lease of equipment if justified and necessary forthe project, depreciated in according with tax and accounting rules.

    Other project costs on the basis of real costs: costs not covered by othercost categories like rental costs, purchase of consumables, travel costs forexperts or speakers at conferences.

    More detailed information on cost categories as well as the eligibility of costs can befound in the LLP Guide 2012, chapter 4.F.

    Staff costs

    Partner regionincurring the costs

    Staff category N of workingdays

    Cost per working day(in EUR)

    Costs (in EUR)

    Partner Region 1 Administrator 20 153 3060

    Partner Region 1 Trainer 5 334 1670

    Partner Region 1

    total

    4730

    Subcontracting

    Partner region incurring the costs Service or task subcontracted Costs (in EUR)

    Partner Region 1 Translation of seminar results andtraining materials

    3500

    Partner Region 1 Print of seminar results 4000

    total 7500

    Equipment

    Partner region incurring the costs Equipment Costs (in EUR)

    Partner Region 1 Beamer for exhibition and seminars 1500

    Partner Region 1

    total 1500

    Please indicate the depreciation rules applicable in your institution:

    Electronic devices and IT equipment are depreciated over 3 years.

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    Partner region 2

    Partner region 2

    Partner region 2

    Partner region 2total

    Please indicate the depreciation rules applicable in your institution:

    Other costs on the basis of real costs

    Partner region incurring the costs Type of costs Costs (in EUR)

    Partner Region 1 Material for art exhibition (canvas,frames, )

    2500

    Partner Region 1 Rent conference venue for teachertraining seminar

    2000

    Partner Region 1 Invitation experts 2500

    Partner Region 1

    total 7000

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    E.3 Total requested grant amount

    Please indicate below the total project costs and the total amount of your grantrequest per partner region.

    Please note that the grant will coverthe lump sum amount for mobilityplus maximum 75% of the total non-mobility costs of the project. Indirectcosts are not funded in ComeniusRegio Partnerships.

    Partner region 1 Partner region 2

    A. Lump sum amount 10 000 6 400

    Staff costs 4 730 6 300

    Subcontracting 7 500 6 500

    Equipment 1 500 0

    Other costs 7 000 5 300

    B. Total non-mobility projectcosts

    20 730 18 100

    Total project costs (A+B) 30 730 24 500

    Total grant amount (A + max75% of B)

    25 547 19 975

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    Annex IV Budget examplesThis annex provides concrete examples for Comenius Regio budgets. It aims to explain the

    different rules by giving concrete examples

    General rules:

    Partner region (example) Comments

    A. Lump sum amount 10 000 as defined in therelevant table

    Staff costs 4730

    Subcontracting 7 500

    Not more than 30% of

    total project costs

    Equipment 1 500Not more than 10% oftotal project costs

    Other costs 7 000

    B. Total non-mobility project

    costs 20 730

    Maximum amount to begranted is 25000, but

    the total non mobilityproject costs can behigher

    Total project costs (A+B) 30 730

    Total grant amount (A + max75% of B)

    25 547

    The total grant amountconsist of the lump sumamount (A) andmaximum 75% of thetotal non-mobilityprojects. Please notethat the grant amount

    for non-mobility costscan NEVER exceed25000.

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    Example A

    Partner region(example)

    Comments

    A. Lump sum amount 16.000 as defined in therelevant table

    Staff costs 15 000

    Subcontracting 9 000Below 30 % of the totalproject cost

    Equipment 5 000Below 10 % of the totalproject cost

    Other costs 11 000

    B. Total non-mobility projectcosts

    40 000

    Total project costs (A+B) 56 000

    Total grant amount (A + max75% of B)

    41 000 16 000 lump sum plus25 000

    Comment: 75% of 40000 is 30 000. Thisamount exceeds themaximum amount of25 000. Therefore thetotal grant amountincludes only themaximum amounteligible for thepartnership in total.

    Example B

    Partner region(example)

    Comments

    A. Lump sum amount 10 000

    Staff costs6 500

    7 500

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    Subcontracting

    Equipment

    4 000 This amount exceeds the

    10% threshold. It has tobe reduced to 3444

    Other costs7 000

    B. Total non-mobility projectcosts

    25 000 24 444

    Total project costs (A+B) 35 000 34 444

    Total grant amount (A + max75% of B)

    28 750 28 333The final grant amount

    has to be reducedaccordingly to thereduction of equipmentcosts.

    Please note that the calculation of the final grant amount at final report stage follows the same basicprinciples. At final report stage it is based on eligible costs reported by the beneficiary. It still has torespect the thresholds for equipment and sub-contracting and also the final grant amount for non-mobility costs is a maximum of 4775% of the non-mobility costs incurred.

    Example C

    Approved budget at applicationstage

    Budget atfinal reportstage

    Comments

    A. Lump sum amount 10 000 10 000 If the minimum numberof mobilities has beenconducted, the lumpsum can be paid in full

    Staff costs 6 500 6 800

    A higher amount can be

    accepted if it can becovered by a max shiftof 10% of the budgetfrom another costcategory. In this case itwould be possible toshift budget from sub-contracting to staffcosts. In both cases itdoes not exceed the10%.

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    Subcontracting 7 500 7 000

    Ok

    Equipment 3 000 2 800Ok

    Other costs 7 000 6 800Ok

    B. Total non-mobility projectcosts

    24 000 23 400

    Total project costs (A+B) 34 000 33 400

    Total grant amount (A + max

    75% of B)

    28 000 27 550 10 000 lump sum +

    17550 ( 75% of theeligible non mobilitycosts)At final report stagethe final grant amountfor non-mobility costsis a maximum of 75%of the total non-mobility costs.