Dear Commissioner,

On behalf of DIGITALEUROPE members we would like to communicate the ICT industry’s appreciation regarding the European Commission’s adoption of the Communication on simplifying the implementation of the Research Framework Programmes on 29 April 2010.

The membership is pleased to see the Commission adopt the Communication, “More or less controls? Striking the right balance between the administrative costs of control and the risk of error,” dated 26 May 2010.

Both these Communications are important steps towards achieving a simplified and more efficient and responsive implementation process of future research Framework Programme.

To achieve effective simplification of implementation of Research Framework Programmes is vital for Europe as it will increase the participation of businesses in European Framework Programmes, strengthen the European innovation capacity, and contribute to meet the objectives set out in the EUROPE 2020 Strategy.

Simplification of future research Framework Programmes should not only ensure their attractiveness and accessibility, but also guarantee effective and efficient use of public funding. This in turn will reduce the administrative burdens; limit the need for the creation of complex procedures, and disproportionate controls.

At the current time a number of issues of concern remain:

1. The structure and timing of calls for proposals;
2. The variety of rules;
3. The introduction of more lump sum elements in the current cost-based approach;
4. The move towards result-based funding;
5. The method for determining indirect cost.

Issues one to four are very well addressed in the recent BusinessEurope position paper “Simplifying the implementation of Research Framework Programmes”. DIGITALEUROPE fully endorses BusinessEurope’s position.

With regard to “the method for determining indirect cost”, DIGITALEUROPE’s membership view the benefits, and understand its high impact on simplification of cost claims and audit process of using a single flat rate for charging indirect cost.

This proposed change has the potential to significantly reduce administrative burdens on small and medium size organisations. However, this approach may not be the preferred option for multi-national organisations which use sophisticated accounting systems.

Therefore, if the European Commission were to decide to implement the ‘Single Flat Rate’ method for indirect cost calculation, this should be only for those beneficiaries who prefer to use it; whereas, other beneficiaries should still be allowed to determine their actual indirect costs according to their usual accounting practices.

We look forward to working with you on this important policy matter.

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