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FORCE MAJEURE
Are Salaries eligible if the researcher is not working?
How do I deal with furlough income in personnel costs?
TimeSheets
Equipment
Travel Costs
Periodic Reporting Delays
What happens to costs in Horizon 2020 grants when there are difficulties in implementing the action due to the COVID-19 situation?
Lump Sum Pilot Grants
COVID and Marie Curie Actions
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FORCE MAJEURE:
*Question: Can the clause on “force majeure” in the Horizon 2020 grant agreement be invoked in relation to the COVID-19 outbreak?
Answer: Article 51 of the H2020 MGA sets out the conditions in which the force majeure clause can be used. ‘Force majeure’ relates to an extraordinary and unforeseeable event or situation that is beyond the beneficiaries control and that prevents them from fulfilling their obligations under the action.
If such a situation occurs, beneficiaries must immediately inform the Commission/Agency/Funding Body, which will examine on a case-by-case basis the possible application of the rules on force majeure. Moreover, beneficiaries must immediately take all the necessary steps to limit any damage due to force majeure (e.g. try to cancel the flight ticket, claim the reimbursement from the cancellation insurance (if applicable)).
Costs will be eligible, if they fulfil the general eligibility conditions set out in Article 6 H2020 MGA like any other costs incurred under the action. For example, if a meeting/event cannot take place due to force majeure, travel and accommodation costs may still be charged to the H2020 action if they fulfil the cost eligibility conditions, even if the beneficiary did not travel and did not take part in the meeting/event. If force majeure entails extra costs for the implementation of the action, these costs may be eligible if necessary for the implementation for the action (e.g. a cancelled conference is reorganised at a later stage). However, the maximum grant amount cannot be increased.
*Question: What supporting documentation must beneficiaries of Horizon 2020 grants keep to prove the impact of ‘force majeure’ or delays in the submission of deliverables, reports or implementation of the action due to COVID-19 outbreak?
Answer: Beneficiaries must keep appropriate and sufficient evidence to prove the eligibility of all cost declared, proper implementation of the action and compliance with all the other obligations under the grant in accordance with Article 18 of the H2020 general model grant agreement. Given these exceptional circumstances, beneficiaries might have to depart from their usual records or supporting documents.
Examples:
- In case of force majeure beneficiaries must keep all documents necessary to prove the eligibility of the costs incurred (like any other costs incurred under the action) as well as all documents proving that they have taken all necessary steps to limit any damage due to force majeure. For instance, emails aiming at cancelling the train/flight ticket, claiming the reimbursement from the cancellation insurance (if applicable), changing the flight/train ticket (if possible), etc.
- For personnel costs, in case of difficulties to get the timesheets counter-signed monthly by the supervisor due to the Covid-19 outbreak, an electronic version of the timesheet (scan or photo) can be sent by e-mail to the supervisor who approves it by replying by e-mail to the person. In such cases, the beneficiaries must keep the original timesheet with the signature of the person plus the acceptance e-mail of the supervisor.
- As regards the action implementation, beneficiaries must keep all documents necessary to support the explanations included in their scientific report. For instance, emails exchanged during teleworking period; other paper or electronic documents used instead of the laboratory notebook usually in place at the beneficiary’s premises, etc.
Are Salaries eligible if the researcher is not working?
*Question: Will the EU contribute to the salaries of researchers working in a Horizon 2020 action for the time they could not work due to the COVID-19 confinement measures (for actual costs grants)?
Answer: Horizon 2020 grants can only provide EU funding for the hours actually worked in the action; either in the premises of the participant or on teleworking.
However, if the employee cannot telework during the mandatory confinement period set out by national or regional authorities, that period would qualify as a special absence.
Beneficiaries applying option 2 – individual annual productive hours – to calculate the hourly rates are entitled to remove from the calculation of the annual productive hours all absences of the employee, including the unworked period of confinement. As a result, the number of annual productive hours of the person would decrease in this year and the hourly rate charged by the participant to the Horizon 2020 action would increase. By these means, the Horizon 2020 grant may contribute to the costs of unworked confinement time in proportion to the time worked by the employee in the Horizon 2020 action.
Participants usually applying option 1 – 1720 hours – or option 3 – standard annual productive hours – may opt to apply option 2 in this year to benefit from this possibility. If not all the employees of the participant were subject to unworked confinement periods, the participant may apply option 2 only for the types of personnel subject to those periods. It may keep its usual option (1 or 3) for the rest of its staff; for example, employees who could telework.
Option 2 is not available for beneficiaries calculating monthly hourly rates. Those beneficiaries would have to change to annual hourly rates for the financial year 2020 if they want to take advantage of this possibility. In addition, we recall that beneficiaries must apply the same approach for all personnel costs declared for a financial year for all their ongoing H2020 grants.
How do I deal with furlough income in personnel costs?
*Personnel costs must fulfil the general and specific eligibility conditions set out in Article 6(2) of the H2020 model grant agreement, including that they must be actual (i.e. borne by beneficiaries). Therefore, any amount which has been partly or totally reimbursed from other sources (e.g. short-time work scheme, social security or public schemes), must be deducted from the annual personnel costs when calculating the hourly rate.
TimeSheets:
* How can beneficiaries support the hours worked in the Horizon 2020 action if the employees cannot sign or have their timesheets countersigned due to the COVID-19 pandemic measures?
According to Article 18 of the Horizon 2020 Model Grant Agreement, for personnel costs beneficiaries must keep time records for the numbers of hours declared (or sign a declaration of exclusive work for the action). The time records must be in writing and approved by the persons working on the action and their supervisors, at least monthly. If due to COVID-19 confinement measures, beneficiaries encounter difficulties in obtaining the monthly signature of their timesheet or if electronic signature is not possible, the Commission will accept any of the two following options:
- The signature of the timesheets can be delayed until the confinement is lifted, or
- An electronic version of the timesheet (scan or photo) can be sent by e-mail to the supervisor who approves it by replying by e-mail to the person. The beneficiaries must keep the original timesheet with the signature of the person plus the acceptance e-mail of the supervisor.
Equipment:
* In Horizon 2020 grants, what happens to costs for equipment purchased exclusively for the action implementation when it cannot be used due to the COVID-19 pandemic and the related confinement measures?
For equipment purchased for exclusive use for the action, beneficiaries are entitled to declare the full corresponding depreciation costs even if the equipment is not being actually used by researchers due to the COVID-19 pandemic.
Costs of new equipment that was not operational before the implementation of the COVID-19 confinement measures can only be charged to the project from the day on which its depreciation starts. Only depreciation costs for the equipment recorded in the accounts of the beneficiary can be charged to the action.
Travel Costs:
* In Horizon 2020 grants, will there be any flexibility given in relation to beneficiaries’ usual travel costs practices due to the COVID-19 pandemic?
Travel costs will be eligible if they fulfil the general eligibility conditions set out in Article 6 of the Horizon 2020 Grant Agreement (i.e. notably if they are necessary for the action). However, given this unprecedented pandemic situation, maximum possible flexibility will be given in relation to the beneficiaries’ usual travel costs practices.
Travel costs will be accepted even if the beneficiary has to depart temporarily from its usual travel costs practices to tackle exceptional individual situations. For example, due to the COVID-19 outbreak, a beneficiary might have to derogate from its normal purchase procedure in order to immediately book return flight tickets for its staff working abroad on the action.
Periodic Reporting Delays:
*Related to the COVID-19 outbreak, how will the funding bodies handle possible delays in submitting deliverables and reports in Horizon 2020 grants?
Given the COVID-19 situation, full flexibility will be given on scheduled due dates for deliverables, milestones and reports whose performance was impacted by the confinement measures.
In particular, for reports linked to payments, the coordinator will still be able to submit the report at the due date set in the grant agreement, but flexibility will be allowed as regards the 60 days period for the submission of the report (see also FAQ on ‘Interim and final payments’ and ‘possibility to extend the project duration’). However, any late report linked to payment will subsequently lead to later payment.
What happens to costs in Horizon 2020 grants when there are difficulties in implementing the action due to the COVID-19 situation?*
For actual cost-based H2020 actions & MSCA actions:
- Given this unprecedented pandemic situation, maximum flexibility will be given in relation to the action implementation.
- Whenever possible beneficiaries are encouraged to telework or to use other forms of remote working. Teleworking costs will be accepted as eligible under the confinement period even if it is not the beneficiary’s usual practice to telework.
Beneficiaries are also highly encouraged to shift their tasks whenever possible. For instance, tasks where physical presence is needed on the ground (e.g. experiments/lab work, etc.) may be postponed after confinement measures are over and meanwhile remote work could be done instead (desk work, drafting of reports, etc.) Costs will still be eligible for the work carried out under the action even if such shifting entails deviations from the initial timing set out in Annex 1.
Additional possibility for H2020 MSCA actions:
- Beneficiaries are reminded that periods in which a researcher was absent for 30 consecutive days or less (for reasons other than normal annual leave) can STILL be charged to the action and the costs will be eligible.
- Moreover, the budget is flexible on the use of the amounts received. Research, training and networking unit costs should be used primarily for the research, training and networking activities planned in Annex 1. Yet, beneficiaries may allocate some of these amounts to help maintaining the salary of the researchers that are prevented from implementing the action due to the COVID-19 situation.
- Beneficiaries have the same flexibility on deciding how to spend the institutional unit costs in order to complete their research. The only condition is that the Research, Training and Networking costs must be spent in support of the implementation of the project, as outlined in the Annex 1 to the grant agreement.
Additional clarifications for ERC actions:
- Telework arrangements are particularly recommended for Principal Investigators that are currently blocked from returning to the EU or Associated Countries. In such a case, specific arrangements need also to be anticipated and taken also for the team’s work supervision, and ERCEA must be notified accordingly.
- The time teleworked by these PIs during the time they are prevented from returning to the EU or the Associated Countries may count as time spent on the ERC project and in the EU or the Associated Countries for the purpose of the Principle Investigator’s time commitments. However, time records for the PIs should be kept even if no personnel costs are charged for him/her to the project.
Lump Sum Pilot Grants:
*Question: Will there be flexibility for beneficiaries in H2020 lump sum pilot grants, if the work packages cannot be completed at the end of the reporting period due to COVID-19 outbreak?
Answer: According to the H2020 Lump sum Pilot MGA, only the work packages that have been fully completed may be declared by the beneficiaries in periodic reports. Partly completed work package can be only declared at the final reporting period and will entail partial lump sum payments.
Therefore, beneficiaries are encouraged whenever possible to request an amendment in view of readjusting the reporting periods schedule and/or requesting an extension of the action duration.
If beneficiaries need to rearrange some tasks due to Covid-19 outbreak for work packages not yet declared as completed, they can request to transfer part of the work and associated lump sum share (in line with Article 4 of the Lump Sum pilot MGA) via an amendment either:
· within the same work package (i.e. to increase the share of a beneficiary and decrease the share of another) or,
· between work packages (i.e. to increase the share allocated to a work package and decrease the share of another).
Given these exceptional circumstances, the Commission will give maximum favourable and speedy treatment as regards beneficiaries’ requests for amendments.
COVID and Marie Curie Actions:
*Question: In case a H2020 Marie-Sklodowska-Curie Global Fellowships researcher decides to return to Europe during the outbreak, what will happen with the project? If teleworking is allowed, can the MSCA researcher telework either in a third country or in Europe?
Answer: Due to those exceptional circumstances, the funded researchers can pursue their research work notably through telework from a third country or from Europe, according to their personal choice.
The 3-month flexibility for GF can exceptionally be applied to allow time spent with the beneficiary not only before the outgoing phase but also throughout it. More precisely, the experienced researchers would be allowed to spend a maximum of 3 months with the beneficiary in MS/AC (or an entity with a capital or legal link and/or a partner organisation) during his/her outgoing phase.
*Question: One of the requirements under MSCA projects is the “mobility rule”. What happens if the mobility rule can no longer be fulfilled as a consequence of the COVID-19 related travel restrictions?
Answer: MSCA ITN, COFUND: In line with its efforts to support MSCA beneficiaries and researchers in this force majeure situations, REA will consider adopting a flexible approach whenever possible, based on a case-by-case analysis.
*Question: Can the beneficiary in Horizon 2020 Marie-Sklodowska-Curie Actions (MSCA) pay the MSCA researcher less during the COVID-19 period, such as not to pay a mobility allowance as the researcher cannot travel?
Answer: The beneficiary must pay to the recruited researchers at least the applicable allowances as set out in Annex 2. For MSCA ITN and IF, this means that the monthly living allowance, mobility allowance and family allowance (if applicable) must be transferred to the researcher even though the work is not ongoing as planned.
*Question: What happens to researcher costs in Horizon 2020 Marie-Sklodowska-Curie Actions (MSCA) when there are difficulties in implementing the MSCA action due to the COVID-19 situation?
Answer: MSCA ITN, IF, COFUND: A maximum flexibility is offered to the MSCA beneficiaries and researchers on this aspect, such as allowing teleworking, work outside their Host institution premises, etc. During this period the researcher allowances should be fully paid, even in those cases where the research work is not continuing as planned.
MSCA RISE: RISE staff is entitled to teleworking when they are already in the country of the host organisation and are prevented from accessing its premises. Teleworking from the country of the sending organisation (i.e. no mobility) is not allowed. The duration of secondment may be extended even beyond 12 months, if the concerned staff member is prevented from returning to the sending organisation.
Secondments interrupted before completing the one-month minimum duration due to the COVID-19 situation, may be eligible as full month, if the above-mentioned teleworking arrangements are put in place, and provided that the beneficiary has transferred to the seconded staff member the top-up allowance (category A). Costs incurred for secondments not implemented due to COVID-19 situation (e.g. travel and accommodation expenses), may be eligible under the conditions set out under Article 51 of H2020 MSCA grant.
*Question: Will the Commission/Agency be flexible if beneficiaries need to modify the researcher recruitment and working conditions due to the COVID-19 outbreak (e.g. suspend MSCA researcher’s contract or include part-time working arrangements)?
Answer: MSCA ITN, IF, COFUND: The obligations set out under Article 32 of the H2020 MSCA ITN and IF and Article 15 of MSCA COFUND grants will continue to apply in order to ensure best possible working conditions for researchers. Beneficiaries are highly encouraged to continue working on their tasks whenever possible by using teleworking (or other appropriate form of remote working), in order not to interrupt their research training activities and beneficiaries shall continue to pay researchers during their remote work.
However, if beneficiaries need to suspend the researcher’s contract or modify it to allow for part-time working arrangements, this may be accepted by the Commission/Agency under the following cumulative conditions:
· the researcher has explicitly agreed with the suspension/part-time working arrangements;
· the researcher has explicitly agreed with any resulting temporary suspension/reduction of the salary; the beneficiary may nevertheless consider to use unspent part of the Institutional unit costs (Research, Training and Networking costs (for MSCA ITN and IF only) and/or Management (for COFUND) and indirect costs) in order to support the researcher financially during the suspension period (in accordance with Article 4(2) of the H2020 MSCA grant). The recruiting beneficiaries may also cover these expenses from dedicated national or own resources.
· the researcher’s contract is extended accordingly to allow him/her to finalise the work.
MSCA RISE: RISE staff are entitled to receive only a top-up allowance (for travel, accommodation and subsistence costs relating to the secondment) and only during the secondment. A suspension of the action implementation may be possible under the condition that there are no secondments running. Coordinators are therefore required to use extra caution in applying for a suspension of the action implementation in the case where the duration of a secondment needs to be extended due to the general lockdown, Part-time working arrangements are not possible for RISE.
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