Zen and the Art of Procurement within ERDF projects

Art may seem an unusual approach to ERDF project management, but please stick with me here. We find different styles in art, such as Impressionism, Realism, and Minimalism. None of these really covers ERDF though, especially not Minimalism, and ERDF probably needs a whole new style of its own, something like Completeism.

My advice to any new ERDF project manager is, the only thing you should throw away is the waste paper basket. Every scrap of paper is part of the records of the project, to be indexed and kept on file for the next 20 years. It may seem a flippant remark, but the truth is not far from it.

It is in the public domain that a substantial proportion of ERDF audits find issues with procurement, and especially when concerning high-value contracts. My impression is that a decent number of these issues could be resolved if project managers follow the approach of not throwing any records away. Of course, there will be some audit findings where the correctness of the process followed is in question, and not just the records.

Currently, section 12 of Guidance Note (GN): ERDF National Procurement Requirements, ERDF-GN-1-004 covers Record Keeping (page 20). The following seeks to expand on this point with two operational examples, but obviously always refer to current guidance.

For what it is worth, I would suggest that the following file structure, or something similar, may be a useful checklist for project managers on the completeness of the records required for high-value procurements. Remember that these records will be Commercially Confidential, so secure storage and Non-Disclosure Agreements will be required. For details on OJEU thresholds please see www.ojec.com/Thresholds.aspx

  1. Explanation of procurement procedure selected with a justification
  2. Copy of OJEU Tender Notice with its reference number, or the relevant advertisement and OJEU Prior Information Notice (PIN) if applicable
  3. Blank PQQ including the Selection Criteria
  4. List of EOIs received and PQQs issued, or reasons why declined
  5. List of all completed PQQs received (time and date, signed), with copies of all the PQQs as received
  6. Copy of the PQQ completed score sheets, dated and signed by two people, including records of any moderation process
  7. Blank ITT form including the Award Criteria
  8. Copies of feedback letters with PQQ scores, and ITTs where successful
  9. List of all ITTs issued and received (time and date, signed), with copies of all the ITTs as received
  10. Copies of correspondence, including interview questions where used
  11. Copy of the ITT completed score sheets, dated and signed by two people, including any moderation process
  12. Copy of report on evaluation of ITTs
  13. Copies of letters to unsuccessful tenderers giving a standstill period (“Alcatel”)
  14. Copy of award letter, and the signed contract if used
  15. Copy of OJEU award notice with its reference number
  16. Copy of notes from any inception meeting
  17. Summary Timeline and archive details to assist future monitoring and audits.

For procurement values below-OJEU thresholds, such as: Free-Standing Call, or a Mini-Competition within a Framework; consider:

  1. Explanation of procurement procedure selected with justification
  2. Copy of contract advertisement (eg ContractsFinder if <£20k, otherwise eg myTenders to cover all Member States, and a 10+ days deadline), or copies of a mini-competition call to approved suppliers within an appropriate Framework
  3. List of EOIs and quotes received (<£20k) or tenders issued (>£20k),
  4. List of all completed quotes or tenders received (time and date, signed)
  5. Copies of correspondence, including interview questions where used
  6. Copy of quote or tender score sheets, dated and signed by two people
  7. Copy of report on evaluation of responses
  8. Copies of letters to unsuccessful applicants giving an appropriate standstill period (if appropriate)
  9. Copy of award letter, and the signed contract, purchase order form, etc
  10. Copy of notes from inception meeting, if any
  11. Summary Timeline and archive details to assist future monitoring and audits.

Key: OJEU – Official Journal of the European Union; PQQ – Pre-Qualification Questionnaire; EOI – Expressions of Interest; ITT – Invitation to Tender.

Disclaimers:

I am at times on contract to DCLG on ERDF Compliance, and nothing in this blog or post represents official policy, just my personal views.
This blog and post are in the interests of general and professional discussion and nothing constitutes particular advice for any project or person.

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