23 / 09 / 2019
EARTO Answer to the EC Consultation on Horizon Europe Implementation Aspects
As input to the European Commission’s consultation on Horizon Europe Implementation Strategy, EARTO published this paper to present its views on the topics covered by the consultation. EARTO especially calls on the European Institutions to:- Preserve continuity with the Horizon 2020 approach based on hourly rate for the reimbursement of personnel costs. Basing the calculation of personnel costs on daily rates would be a major change that would not reflect the reality of many beneficiaries and would not bring the simplification intended, leading to increased workloads.
- Enable the allocation of direct technical costs to projects using unit costs via allocation keys based on the usual cost accounting practices of the beneficiary. This would enable to better reflect the real costs of the beneficiaries, in particular for the use of technology infrastructures.
- Improve measures for ex-ante assurance by relying on System & Process Audits performed by national qualified auditors. This would enable to lower the ex-post audit burden and improve legal certainty, especially for the use of Usual Costs Accounting Practices.
- Evaluate and analyse the financial and operational impact of the lump-sum approach on H2020 projects prior to any extension of the lump-sum approach. EARTO members’ returns on experience on the H2020 lump-sum pilots are not conclusive so far: many issues have been encountered.
- Foster a balanced approach between Open Science and Intellectual Property (IP)’s policies. IP’s crucial role in innovation and in fostering knowledge co-creation needs to be further recognised. The policy focus should be on the optimum use of research data following the principle “as open as possible, as closed as necessary”.
