Reduction of administrative burdens of European funding schemes

In this position paper, suggestions are proposed to improve the European subsidy systems and make suggestions for the simplification of administrative rules. Download the position paper.
The Association of Universities in the Netherlands (VSNU) wishes to contribute to the discussion on the reduction of administrative burdens of European funding schemes. The remarks in this position paper can be deducted from our more detailed paper Reduction of Administrative Burdens and Consequences for Simplification which has been sent to Ms Da Graça Carvalho, reporter of the European Parliament on Reduction of Administrative Burdens, in June 2010.
In that paper we acknowledge the achievements of the European Commission and the European Parliament so far. We believe that the current subsidy system created in the European Union has a variety of success factors. We comment on these successes and put forward our ideas on how things could be further improved. Implementing these ideas would substantially reduce administrative cost without allowing misuse of regulation or public means.
The ideas to reduce administrative burdens and thereby improve the European subsidy system are summarized in the following statements:
1. The VSNU favours subsidy systems based upon high trust. Trust should be translated into regulations, including an ex ante proof of the institutions accounting methodology and processes, low ex ante cost for institutions that use a certified methodology, low ex post controlling cost for institutes that have proven to be trustworthy and intensive ex post control for those that have not.
2. In order to obtain fully financial responsible and sustainable universities, a full costing based subsidy system is needed. Universities have to bear both direct and indirect costs. For both internal and external awareness of costs, full cost based accounting is preferred over direct cost based accounting systems.
3. We promote a uniform framework of administration rules for all different subsidy programmes in Europe. This set can include various ways of subsidizing, but all individual programmes should be based upon those few different possibilities. Such a framework increases the knowledge, employability and productivity of our financial experts and reduces the possibility of mistakes caused by misunderstanding regulation.
4. Allow national accounting practices into the EU subsidy framework as a proper way to give account to expenditures in subsidized programmes. This avoids institutions from having two accounting systems for the same project.
5. Allow for a single information, single audit accounting system. In the Netherlands it is common practice to allow applicants to include subsidies in their annual accounts. Submitting the annual accounts would then be sufficient for intermediate accounting.
6. VSNU favours the use of lump sums, both for elements in a subsidy programme as well as for complete subsidies, as long as those lump sum subsidies are based on full cost calculations. We welcome experiments on result based programmes, as long as result in result based is explained as a scientific report on a certain topic. The report could conclude that the answer to a question cannot be found.
7. The timeline of subsidy schemes from application to final award should be reduced to raise certainty for scientists and the productiveness of employees.
8. Regulation should be clear and stable during the timeframe of a subsidy programme and singularly interpretable only. One of the current problems of universities in the Netherlands is uncertainty on the explanation of financial regulations by different stakeholders.
9. VSNU pleads for the acceptance of smaller consortia. Large consortia often increase the complexity and therefore the organizational costs.
10. Use sophisticated ICT-tools where possible to reduce administrative burdens, including systems that use previously provided information as a basis.
11. The introduction of a European community patent would significantly reduce the administrative burdens on and consequently the costs for businesses and universities. For further information you may contact Mr. Jeroen van Oort: vanoort@vsnu.nl / +31 (0)70 3021430.