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2008
Polska Konfederacja Pracodawców Prywatnych Lewiatan
Employers representation within structural funds implementation system
There are very few European requirements concerning how implementation system should work.
Majority of rules/ restriction comes from national authorities
Efficient implementation in not equal to a complicated one
Enterprises applying for EU money guarantee absorption – they should be taken care of, not discouraged
Obvious things often forgotten
Support for entreprises in 2004-2006
Education and skills Advisory services
i.e. on foreign market, feasibility studies Technology transfer Investments
innovative elements required, i.e. introduction of a new product to the market, general modification of processes within company – production, marketing, administration etc.
Participation in fairs and exhibitions Increase of environmental protection standards in the
companies Basic initial investment for start - ups Access to seed funds, loans and guarantee funds R&D - pre-industrial research, creation of prototypes
Results
12 000 projects of enterprises 3 000 new investments 5000 participants of fairs and exhibitions 100 000 employees trained 200 environmental investments 90 R&D targeted projects
Strenghts of support structure
Diversification of support for enterprises: e.g. direct aid to investments, aid to upgrade skills and competences
Priority to SMEs’ projects measures with access restricted to SME measures where bonus points were granted to SME
Great interest in EU money (demand 6 times higher then supply)
Weaknesses of support structure
Segmentation of support Investments separated from advisory services and training (different
measures in different programs) R&D: creation of prototypes separated from introducing them to
production
No risk accepted in R&D projects (if prototype did not prove its market potential and beneficiary failed to introduce it to production, EU support would not be granted)
No support for strengthening general R&D capacities (e.g. purchase of laboratory equipment)
Training measures implemented exclusively by specialised companies (entrepreneurs were not allowed to directly apply to train their own employees, they had to look for intermediary)
Major changes in 2007-2013
Cross - financing: its possible to finance training and advisory services accompanying investment up to 10% of project’s total costs
R&D measures provide financial support for research phase and implementation of the prototypes to the production (even if research phase is unsuccessful, money properly spent are reimbursed)
New supporting measures: patent application, industrial design, purchase of laboratory equipment, clusters, ICT services developed by SMEs (B2B, B2C)
Enterprises can implement their own educational projects
Difficulties faced by enterprisesapplication
Bureaucracy and procedural restrictions Too complicated application forms (e.g. same question must
have been answered few times in different ways) Several copies of documentation to be delivered (up to 4) Formal mistakes such as lack of signature, lack of any
supporting document or improper form of it as major reason for application rejection
Mistakes on the list of qualified costs (even if negligible)as a second most common reason for application rejection
Long lists of attachments to support application (up to 20) Long verification procedures (up to 12 months)
Information No professional information services - administration not prepared
to inform entrepreneurs Unclear criteria of projects’ eligibility (e.g. innovation, social
importance)- cause of subjective evaluation Lack of proper coordination between institutions – difficulties to
receive right interpretations/ answers Transparency
Lack of professional experts to evaluate projects - many controversies over decisions of the institutions on the lists of beneficiaries
No formalised procedure of appeal against unjustified decisions No clear information on reasons for granting aid to chosen projects
(and rejecting others)
Difficulties faced by enterprisesapplication
Difficulties faced by entreprisesimplementation
No professional services to verify financial documents – unreasonable and unjustified requirements, highly inflexible approach
No clear procedure for taxes (VAT) reimbursement No detailed information on rules applicable to
granting state aid (majority of SMEs were not able to calculate de minimis thresholds)
Three kinds of reports to be delivered: every quarter, every half a year, every year (in January 3 reports to hand in).
The most important Polish problems 2004-2006
Rotation of employees in Management Authorities (average official dealing with structural funds was 27 and stayed within the institution for 7-8 months) constant outflow of experience from the system highly inefficient use of technical assistance money
Inadequate information systems (bad timing, lack of precision, no culture to communicate and explain institutional actions to the public
Legal framework (e.g. public procurement, procedures to obtain building permission) not adjusted to structural funds intervention, were timing is crucial Long procedures (it takes up to 18 months to receive building
permission)
PKPP’s achievements
We voiced very strongly and with great consequence more flexible application procedures and: Lists of attachments were shorten (in OP Human Capital
2007-2013 1 document is obligatory, which is financial report)
Margin of flexibility on qualified costs were granted (if there are unqualified costs not exceeding 10% of total budget of the project, it still might be accepted)
It was made possible to amend formal mistakes (under condition of delivering application 7 days before closing date)
Reporting was limited New information tools were introduced (FAQ, lists of
mistakes committed by applicants)
Monitoring Committees
All positive changes were possible thanks to our participation in monitoring committees…
…were we could officially propose modifications… …and find support of other participants. Sometimes we were backed by European
Commission… …and sometimes by one institution against the other Few times we failed, but do not stop trying
e.g. definition of a new product on targeted market e.g. on-line application forms
Monitoring Committees tasks
Art. 63 of General Regulation 1083/2006 Consider and APPROVE the criteria for selecting
projects financed by the OP Review progress made towards achieving specific
targets Examine results of implementation May propose to the managing authority ANY
REVISION or examination of the operational program likely to make possible the attainment of the funds’ objectives
In other words
It is committee that ultimately decide on what can be financed It is committee that can initiate changes in the OP, if proves it
necessary It is committee that has all the first hand information (e.g. MA,
EC) - right to ask questions and be answered might be crucial
PKPP has its representatives in all Monitoring Committees at national level both for 2004-2006 and 2007-2013 financial perspective and in majority of regional MC
MC is our first tool to influence implementation of structural funds
MC is a platform to represent our members views directly to the institution responsible
Other platforms used by PKPP
List of Black Barriers to Economy officially presented to the government once a year
Press conferences (we invited ministry of regional development 4 times for such a conference in 2006-2007 to publicly answer our questions and postulates)
Interviews, opinions (we cooperate on regular basis with journalists from top Polish dailies)
We gather entrepreneurs’ opinions during thematic conferences organized in all Polish regions (16 in 2007)
We include questions on access to structural funds into our major research published yearly: Competitiveness of SMEs, to support our opinions with statistical datas