Press release - LERU’s views on the EP proposals for Horizon 2020
22 June 2012
LERU response to the European Parliament’s draft amendments on the Rules of Participation for Horizon 2020, the H2020 Regulation and Specific Programmes and the EIT SIA and Regulation
Rules of Participation
LERU is pleased that the 100%+20% reimbursement rate as proposed by the European Commission is maintained for universities in the proposals of Christian Ehler. LERU also supports the idea of reimbursing not only research, but also close-to market actions for universities at the 100+20% rate, as we were concerned about the sustainability of university’s participation in these actions if they were to be reimbursed at only 70+20%. Next to this LERU strongly underpins the acceptance of VAT as an eligible cost for those institutions that cannot recover it elsewhere as is foreseen by the European Commission in their proposals for the next Multi Annual Financial Framework and supported by Mr. Ehler. As a number of universities have put a lot of efforts and resources in moving to using a full costing method for EC projects, and as full costing is important as a management tool for universities, LERU welcomes the reintroduction of an option for full cost declaration. LERU questions however the upper funding limit of 70% as this is a five percent decrease compared to FP7 and would lead to a financial loss of about 1,4% for the universities concerned compared to the current situation in FP7.
In general the reimbursement rates proposed by Mr. Ehler are favourable to universities, in particular the ones that are not using a full costing method. It is however also clear that having different rates for different partners will, again, result in more complexity and less simplification (compared to the EC’s proposal), although simplification was and is a key target of this new framework programme. This will in particular be the case for project coordinators.
LERU very much supports the proposal for a flat rate to cover management costs. We do however propose to change the amendment so that it is clear that the percentage of the flat rate is based on the total budget of the project and that 7% is a minimum instead of a fixed rate. In some cases, in particular for projects with a large number of partners, or projects including clinical trials, the coordinators' costs exceed 7%.
In general LERU is pleased with the increased use of the usual accounting practices of the beneficiaries and with the limitation of possible exceptions to the Rules of Participation.
Mr. Ehler proposes to limit the time to grant to 6 months, with a prolongation of one month in exceptional cases. First of all, LERU demands clarification of the definition of the term ‘time-to-grant’. At the moment it is not clear whether it is the time between the deadline for submission and award decision or the time between award decision and start of the project.
Although LERU certainly supports the idea of reducing the time to grant as much as possible, we would like to warn against limiting it too strictly. A short time frame could put at risk the EC’s ability to organise and manage a careful evaluation process for each proposal, thus potentially jeopardising the objective of funding scientific excellence in H2020. Another important worry is that a strictly limited time to grant will lead to too little time for grant agreement negotiations. Already in FP7 there is an increased pressure on universities to finish grant agreement negotiations in a very brief period, which is particularly problematic for projects with a large number of partners. LERU fears these problems would increase significantly when strictly limiting the time to grant to six months. In particular for institutions, such as, but not only, the LERU members, which are likely to manage a large number of H2020 projects these strict deadlines would be very burdensome and could lead to very disadvantageous grant agreements.
The 2020 regulation and specific programmes
In general, LERU is happy with the majority of the amendments proposed by Teresa Riera Madurell and Maria Da Graça Carvalho. We do however have some concerns as well.
LERU strongly supports the European Parliaments’ demand for a budget for Horizon 2020 of 100 billion EUR. We are however worried about the amendments to the budget division as proposed by Ms Madurell. In particular the percentage of the budget which would be attributed to the ERC is not acceptable as it is very likely to lead to a decrease of ERC funding compared to the EC proposal, depending on the final total budget. LERU on the other hand welcomes the percentage of the budget foreseen for the Marie Sklodowska-Curie Actions. We want to underline that both MSCA and ERC have proven to be very popular and successful programmes, motivating and attracting both junior and senior researchers for a research career in Europe. Both programmes therefore deserve and need the necessary means in H2020 to help build Europe as a stronger knowledge-intensive society and realise a European Research Area.
In general LERU strongly supports the confirmation of excellence as the main driver for Horizon 2020. LERU is also pleased with the explicit acknowledgment of the role of universities in the research-innovation chain. Next to this LERU very much welcomes the guarantees for bottom-up research approaches in the “Societal challenges" priority and of the specific objective "leadership in enabling and industrial technologies” in the “Industrial leadership” priority. LERU also upholds the changes to the FET, now FEST scheme.
LERU supports the provisions for Open Access, the emphasis on gender and the idea of allowing better synergies between Horizon 2020 and the Structural Funds. LERU underpins the idea of building a Stairway to excellences and agrees with the majority of Ms Carvalho’s proposals on this regard. We have however some concerns with the concept of the ERC return grants.
The EIT SIA and EIT Regulation
LERU is worried about some of Philippe Lambert’s proposals for amendments to the proposed EIT Regulation. In particular we are concerned at the possibility of an increase in excessive red tape especially with the proposed increased amount of monitoring and evaluations; the yearly competition for EIT funding by the KICs; and the increased number of requirements and categories of participants. LERU is also not in favour of the idea of having open calls for an unlimited number of KICs without predefined topics as this is very likely lead to massive oversubscription and wasted effort.
The Matias report contains some good elements, but the proposals formulated by Marisa Matias on the EIT IPR are quite worrying. More details can be found in the response itself.
More details on the LERU’s views can be found here: