"On-the-spot” checks during the pandemic COVID 19
Compliance with applicable legal standards remains a requirement. Therefore, the management verifications and audits carried out by the audit authorities must continue to verify compliance with the applicable rules. Please find below the Managing Authority (MA)’s main messages related to this matter:
- “…[It] is recommended that those audit authorities that have adopted remote working arrangements carry out the audit activities as far as possible through review of documents, including those available via information systems and those that can be submitted electronically by the auditees. Once the emergency is over, the audit authority will be able to assess whether it is necessary to complete the work by visiting the operation on the spot to verify the physical implementation of the project or obtain further clarifications.
- “… the Commission services are fully aware that, under the current circumstances of the pandemic, on-the-spot verifications may be impacted by the rules set up by the national authorities for protecting public health.”
- The outbreak is not necessarily understood as a force majeure event in all cases. The Commission considers that “careful case-by-case assessment in the light of relevant circumstances and in line with the applicable legal framework is always required.”
- Even if managing authorities have some flexibility on the declaration of expenditure and payments to beneficiaries under the current crisis situation, all Atlantic Area projects must be visited on-spot at least once during their lifetime. Hence, the MA strongly recommends that you include an addendum clarifying any exceptional circumstances and the impact on your verifications if you adopt a contingency solution due to the legal impossibility to proceed with the regular procedures caused by the sanitary situation (“careful case-by-case assessment”).
- Concerning the authorization of the final reimbursement claims, you should proceed within the recommended guidelines, also having the possibility to complete on-the-spot verifications when sanitary conditions in your country allow, following any irregularity and financially impact finding to be recovered from the beneficiary. If such a case comes up, you should immediately notify the MA of the Interreg Atlantic Area and we will proceed with the identification of such potential cases in the assurance package.
In sum, the MA accepts the opportunity for having procedures with a temporary character, adapted to the existing crisis, considering all elements above, the potential impact on beneficiaries and the risk involved by each project. Since all our projects must be visited on-spot, the MA recommends that you add an addendum clarifying the exceptional circumstances and the impact on your verifications. Once checks are carried out, a recovery order may be issued in case of an amount unduly paid.