In short
- The auditor walks back from the declared euro to the rate, the day-equivalents, the signed records and the payroll.
- Records reconstructed after the fact are the most common finding.
- The rate is actual cost ÷ 215, or ÷ the pro-rata maximum — one method for everyone.
- Declared must equal rate × day-equivalents, to the cent, capped at 215 a year.
- The same hour on two grants is double funding.
1The trail, backwards
An audit starts at the financial statement and walks back. For each person declared: the amount, the daily rate, the day-equivalents, the time records those day-equivalents rest on, and the personnel cost in the accounts the rate was computed from. Every step must be a document, and every document must agree with the next.
The agreement gives the Commission, its agencies, OLAF and the Court of Auditors the right to check, review and audit, during the action and for years after the balance is paid (Article 25 of the general model grant agreement). What you keep under Article 20 is what they will ask for.
2The time records
Are the records dated and signed at least monthly by the person and their supervisor? Were they signed at the time, or reconstructed later from memory, a calendar or a budget? Do they name the action and the work package? Do the days declared on this action, added to the days on every other EU grant and to absences, fit inside the person’s working time — and inside 215 for the year?
Reconstruction is the common finding. A record that was signed at the end of the period for every month at once, a record whose daily totals are always exactly the budgeted hours, or a person declared on two actions on the same day for more than a day: each one invites the auditor to reject the day-equivalents behind it.
3The daily rate
Is the rate the actual annual personnel cost divided by 215 — or, for a part year or part-time, by the pro-rata maximum? Does the cost in the numerator match the accounts: salary, employer’s charges and statutory costs, and nothing that the agreement excludes? Was the same method used for every person and every period?
A rate built on a standard cost, a budgeted salary or a previous year’s payroll without the agreement’s conditions for it is a finding; so is a cost that includes a bonus or an allowance the agreement does not accept.
4The arithmetic
Were hours converted to day-equivalents by one method applied consistently, and rounded to the nearest half-day once per reporting period rather than per month or per day? Does declared = rate × day-equivalents, to the cent? Are the day-equivalents on this action capped where the person’s total for the year passes 215?
5Double funding and double posting
The same hour declared on two grants, or a contractor’s hours priced as personnel while the contractor’s invoice is also claimed under personnel costs, are both findings. Auditors look across grants for the same person and across cost categories for the same supplier.
6What a clean file looks like
Every month a signed record with two signatures and their dates. Every rate a sum you can show in the accounts. Every day-equivalent a line you can trace to hours in a grid, locked on a date, by a named person, never edited after — and, if corrected, both the original and the correction with a reason. That is the record Beneficia keeps, with the audit chain to show nothing changed after the fact.