Guidance notes on the Intevention Logic

and on Building a priority axis

27 September 2013

Introduction• Presentation of two guidance notes pertaining to

programming and aimed at desk officers in the Commission

• The two guidance notes are interlinked, hence should be read together – there are links also to other guidance, including the template for the operational programme

• This is an introduction of this guidance to the expert group, but feedback is welcome

• The guidance notes have been developed specifically for the ERDF, ESF and CF (they do not cover EAFRD and the EMFF)

Intervention logic

Aim of the guidance

• Intervention logic is at the heart of the programming process, but not clearly defined in legislation

• The guidance aims to set out the main elements of the intervention logic, with reference to applicable legal terms and setting out examples

• The guidance has been prepared taking into consideration the context of cohesion policy (e.g. the existence of thematic objectives, investment priorities), but in general reflects the basics of setting out an intervention logic for any strategy

Development needs and objectives

• The starting point of programming is the identification of development needs or challenges to be addressed, which should help to identify the funding priorities

• This is followed by:• the selection of thematic objectives and investment

priorities as set out in the CPR and Fund-specific rules;• the definition of at least one specific objective per

investment priority to target the latter appropriately in the specific national or regional context

• definition of result indicators linked to specific objectives

Actions and output indicators

• Only after the development needs, objectives and the result sought have been clarified, should one consider the types of actions to be supported, choosing (a mix of actions) which best achieves the objectives defined

• Output indicators should be logically linked to and reflect the types of actions planned. Outputs generated by actions should also contribute logically towards the results that one aims to achieve.

Testing of the intervention logic

• The programming process should allow for a reflection on and adjustment of the intervention logic proposed

• This is also one of the purposes of the ex-ante evaluation• The outcome should be a programme which includes a

consistent and coherent intervention logic • The authorities should also be open to change the

intervention logic in mid-period, if circumstances change or if the actions implemented are not sufficiently effective

Comments

Building a priority axis

Aim of the guidance

• Provisions under Article 87 (1) are essential for the purposes of programming and attaining a sound intervention logic

• However, they are rather complex, with multiple possibilities for derogations and multiple conditions for such derogations

• It is also not always evident from the legal text, what are the implications in terms of practical (financial) management

Initial proposal by the Commission for Article 87 (1) CPR

• Possibility to set up multi-fund and potentially multi-category programmes, BUT…• Priority axis = 1 Fund, 1 category of region, 1

thematic objective• Only derogation = ESF, to achieve proportionality in cases

where small amounts of ESF are used to complement ERDF and CF

• Objective driven programming and management –focus on achieving a clear intervention logic

• Simple approach – financial management and monitoring at the level of the priority axis

Agreement between co-legislators on Article 87 (1) CPR

• COM proposal maintained as a general rule• As a derogation from the general rule it is possible to set up

priority axes covering more than one Fund, category of region and/or thematic objective

• Derogations possible only where appropriate and in order to increase the impact and effectiveness in a thematically coherent integrated approach

• In addition, a priority axis covering more than one thematic objective requires a due justification

• Explanation and, where required, a justification for the set-up of such priority axes is required in the model of the operational programme

Priority axes covering more than one category of region

Can be justified where where identical objectives and actions are pursued across all regionsNB: the development needs of different categories of regions can diverge. In this case, the objectives and the intervention logic will also be different multiple priority axesRe-percussions:

• Co-financing rate and financial management by priority axis and by category of region

• Breakdown of performance framework and output indicators (and in case of ESF, also result indicators)by category of region

Priority axes covering more than one Fund

• Only justifiable where Funds pursue clearly complementary objectives and where actions need to be implemented in parallel to attain objectives – in most cases objectives can also be attained through mono-fund priority axes

NB: CF/ERDF and ESF investment priorities, scope and indicators are different, entailing a different intervention logic

Repercussions:• Creation of "sub –priority axes" - a description of the priority axis split

completely in two or three (possible exception for combination of the ERDF and CF contributing through the same intervention logic)

• Financing rate and financial management by priority axis and by Fund• Breakdown of the performance framework and output indicators by

Fund

Priority axes covering more than one thematic objective (1)

• The most complex case – risk of losing thematic coherence, focus on objectives and of compromising the intervention logic

• Thematic coherence must always be maintained• Combination of more than 2-3 thematic

objectives should not be necessary, not even in the case of axes based on territorial strategies

Possible exception: integrated actions for urban development

Priority axes covering more than one thematic objective (2)

• Thematic objectives and investment priorities are objectives, not lists of activities – any actions contributing to these objectives can be pursued

• If a priority combines more than 2-3 thematic objectives it is likely that the intervention logic is skewed = actions are put before objectives

Priority axes covering more than one thematic objective (3)

To be considered: •It should be verified that the intervention logic is sound – that investment priorities are put forward as objectives, not chosen on the basis of actions that the MS seeks to support•The financial allocation by thematic objective within a priority axis is subject to COM decision and cannot be changed without COM decision – significant rigidities may be introduced

Implications on financial management

Axes Financial plan of the OP

Axes covering multiple Fund

• Co-financing rate by Fund• Separate budget commitments - payment

applications/accounts by Fund

Axes covering multiple categories of regions

• Co-financing rate by category of region• Separate budget commitments –expenditure

broken down by category of region in payment applications/accounts

Axes covering multiple thematic objectives

• Allocation broken down by thematic objective and fixed in the financial plan

• No breakdown in payment applications and accounts

• Follow-up through the categorisation system

NB: Financial plan of the OP is adopted by the Commission and a Commission decision is needed to change it

Combination of derogations• In principle the CPR allows for the flexibility to set up

priority axes which cover multiple Funds, thematic objectives and categories of regions - all at the same time

• Where derogations are applied cumulatively, all conditions also apply cumulatively – all combinations need to be justified against the requirements of Article 87 (1)

• Such arrangements can lead to significant complexity in financial management, monitoring and reporting arrangements – to be considered very carefully

Financial instruments

• Article 110 CPR provides an incentive (higher co-financing rate) to set up priority axes implemented exclusively though FIs

• Article 87 (1) applies regardless of the form of support granted - priority axes must remain thematically coherent and the derogations under Article 87 (1) can be applied only where appropriate

Examples:• Pairings of complementary priority axes implemented through

grants and FIs• Seeking economies of scale though multi-regional or national

priority axes implemented through FIs

ETC

• The combination of Funds and categories of regions within a priority axis is not relevant for ETC

• The issues concerning the combination of thematic objectives within a priority axis ARE relevant also for ETC – the same conditions apply

Comments?