ERDF Overheads - Neil Clatworthy, Northwest Universities European Unit Ltd
Director, Northwest Universities European Unit
24th April 2014
Increased scrutiny of overheads:
Recent DG Regio and ECA audits have highlighted the fact that in many cases, ineligible
costs have been included in the calculation of overheads for ERDF projects.
“The inability of the organisations concerned to provide an audit trail for overheads tested
through to defrayal, or use of apportionment methods not acceptable to the EU resulted in
significant percentage of allocated funds being clawed back”. “Due to the complexity of
calculating and accurately recording and reporting overhead costs, Grant Recipients are
strongly advised to consider whether their inclusion will add value to the ERDF project”.
National ERDF Handbook states:
DCLG is therefore minded towards adopting a flat-rate approach for 2014-20.
In our view there is a strong argument that for the HEI sector it is still worth the
cost of calculating an eligible ERDF overhead rate.
Direct charging or overhead?
Wherever possible it is simplest to charge as many items/types of
expenditure as direct costs:
Can provide a better cost recovery against some items.
Can provide a simpler and more direct audit trail.
However not all costs or services (for example finance office, HR, estates &
utilities, IT support etc.) can be easily charged on a direct basis especially when
costs need to be linked back to defrayment.
For HEIs, relevant indirect costs can however be charged against an ERDF project
via agreed methodologies for fair and equitable apportionment.
Why are Indirect costs important?
Indirect costs for HEIs are relatively significant and need to be
reflected in project costs. They are after all real costs!
Maintain consistency with in-house finance systems and audit
trails. The agreed methodologies for calculating indirect costs are all
based on the process for Full Economic Costing that all HEIs
undertake annually to calculate overhead rates for related activities
There is however additional effort required due to the need for extra ‘filtering’
of ERDF ineligible costs:
– you do need to make friends with your colleague(s) in Finance
responsible for TRAC!
Ability to alignment with in-house financial systems - TRAC
TRAC is designed to enable HEIs to demonstrate the ‘true cost’ of their
TRAC is a methodology that consolidates all central costs – e.g.
Finance, Estates, HR, IT services etc. – enabling the calculation of an
annualised indirect cost per FTEs.
TRAC rates are calculated annually by every HEI based on institutional annual
Current HE ERDF Overhead Methodology:
For ERDF activities HEIs derive a rate using the TRAC methodology as a basis and
then apply extra filters to remove ERDF ineligible elements – for example:
Amounts charged to ineligible or irrelevant cost centres/activities through the
Any direct staff and non-pay costs charged directly to projects
The charge for buildings depreciation funded from the release of deferred
The cost of Capital and Infrastructure adjustments
Any items that are deemed ineligible for ERDF grant support.
Any items which cannot be evidenced as relating to/consumed by the project.
‘Real’ cost or Flat rate - Key Pros / Cons
‘Real’ Cost Flat Rate
Annual Calculation One time calculation based on a single year
Subject to on-going audit Agreed and finalised on application
Typically derives higher recovery rates of 60-80%
direct (staff) costs.
Max rate of up to 20% of direct costs
Provides a potential source of significant
match-funding for ERDF (revenue) projects.
Does not tie back to TRAC and sits outside main
financial costing system
Lancaster University & NWUEU have helped a number of wider HEIs derive compliant
methodologies across the country – rates vary between HEIs, with some higher for
more urbanised HEIs (Greater London).
Once you have derived the internal filters it’s a relatively simple process to update
and re-run on an annualised basis.
Is it worth it?
The view by a number of HEIs is that the initial ‘pain’ is worth it – better recovery / ability
to use overheads as match should not be underestimated. For many Universities losing the
ability to match overheads at the ‘real’ rate would mean their ERDF projects/proposals
would be unviable.
It is recognise that for many institutions a fixed rate methodology suits them better and
is a viable option.
Under the current DCLG guidance HE has a choice of either option – this should be
There needs to be a better collective understanding of HEI indirect costs and minimisation
of potential future issues on audit.
We must to work more closely with our internal (Finance) colleagues and DCLG
Better interpretation and application of European regulations on the eligibility of
It’s all about better partnerships!
We welcome the drive for greater simplification however retention of existing
good practice is equally important.
Key message: let individual HEIs have the choice – let’s not get taken down a
single methodology option.