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