Investing in Skills Scheme

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The below frequently asked questions were provided by JobsPlus during a webinar entitled Training & Employment Scheme held on 21 May 2020.

1.  Eligibility Criterion (d) in Section 2.2 of the Guidance Notes states that:

Eligible Training Programme: Aid shall not be granted for training which Employers carry out to comply with National Mandatory Standards on training (in other words, it must be voluntary training as opposed to legally enforced training).

How is this to be interpreted in line with the Commission Regulation (EU) No 651/2014 of 17 June 2014 known as the General Block Exemption Regulation (GBER)?

The General Block Exemption Regulation (GBER) Frequently Asked Questions (https://ec.europa.eu/competition/state_aid/legislation/practical_guide_gber_en.pdf) provides the following guidance:

How is Article 31(2) to be interpreted?

Aid for training which is mandatory under national law lacks incentive effect as it would be pursued even in the absence of public funding, and, therefore, cannot be block exempted. In this regard, it is irrelevant whether the training is carried out to comply with national standards which are mandatory for the undertaking in question or for its employees and also whether the training is carried out by the undertaking itself or an external trainer. As long as the State is paying for this training, which is mandatory under national law, and the training benefits the undertaking directly or indirectly (in case the employees are trained outside the undertaking), the aid is covered by Article 31(2) and cannot be granted.

Which types of training would be covered by Article 31 and what does the Commission mean by 'national mandatory standards on training'?

The purpose of Article 31(2) is to allow for the support of training measures undertaken by enterprises with the purpose of developing and updating the knowledge of their workforce (e.g. management trainings, language trainings). However, trainings that are mandatory under the national system for example health and safety training would have to be pursued anyway, even in the absence of the aid. Aid for such trainings, thus, lacks incentive effect and can, therefore and in accordance with Article 31(2), not be block exempted.

2.  A new call with more advantageous rates has been launched on the 06th May 2020. I had applied for funding before this date. Can I benefit from the new rates and terms and conditions too?

No, only applications submitted on the 06th May 2020 onwards can benefit from the new rates and enhancements stipulated in Version 6 of the IIS Guidance Notes.

3. Section 2.4 of the Guidance Notes state that:

Under no circumstances can the IB reimburse more than 15 trainees for the same training under IIS, irrespective if these claims derive from separate and unrelated Beneficiaries.

How are grants pro-rated when more than 15 trainees from different beneficiaries apply for funding?

The total number of trainees is taken into consideration and the percentage pro-ration is derived by calculating the percentage required for one trainee (100% divided by the number of final trainees). The result is than multiplied by fifteen trainees. This percentage pro-ration is then applied to the 100% of each cost component, prior to the application of the applicable co-financing rate. The below is an example of such a pro-ration.

17 trainees = 100%, Therefore 15 trainees = 88.24%

*the percentage pro-ration is derived by calculating the percentage required for one trainee (100% divided by the number of final trainees). The result is than multiplied by fifteen trainees.

table 1

The above pro-ration does not apply to air travel.

4.  Our training programme is an online/distance learning course, how do I fill in the training schedule with regards to Venue?

In the case of online/distance learning, the link to the course MUST be provided for each and every session. This will enable Jobsplus Monitoring Officers to conduct their unannounced visits in the same manner as they conducted visits related to classroom style training.

5.  How do I fill in the Template B Attendance sheet for Online/Distance Learning?

The Beneficiary is to insert the following details and forward to the training provider:

1. Beneficiary Name

2. Course Title

3. IIS Grant Agreement Number

4. Name Surname and ID Card Numbers of the Trainees

The training provider then needs to fill in the dates, times and breaks and confirm attendance of trainees by inserting YES or NO. Any attendance left blank will be deemed to be an indication of the trainee’s absence. The training provider should also insert their name surname and identification number and sign the attendance sheet for each and every session.

Should trainees arrive late or leave early for a session, this is to be clearly documented on the attendance sheet and endorsed by the trainer.

Finally, when the training is over, the contact person or delegated person, acting in their capacity as the entity’s Legal Representative need to certify that the details in the Template B Attendance sheet are correct and true.

6.  Is it possible to submit my unsigned application/reimbursement documentation on [email protected] ? Also, since I am working remotely, I have no access to a scanner, would mobile photos be accepted?

Yes, it is. However, the email together with the supporting documentation MUST be sent by the contact person or delegated persons. If this is not possible, then the contact and or delegated persons MUST be cc’d in the correspondence.

Although we recommend the use of a mobile app that can replace a scanner, we will accept photos taken by mobiles as long as they are clear and legible.

7. I had applied for classroom/contact training, however due to restrictions by the Health Authorities, this was converted to online/distance learning following approval by Jobsplus. I was also asked to take screenshots of the ongoing training.

How many screenshots am I obliged to present at reimbursement stage?

A minimum of four screenshots per grant is acceptable. Such screenshots should preferably include timings and trainees. However, we reserve the right to request further clarifications should the need arise.

8.  Training was re-scheduled/postponed, what should we do?

Section 3.4 of the IIS Guidance Notes is clear about this:

‘No amendments or variations to the terms of the Grant Agreement and training schedule will be effective unless agreed to in writing by the IB.

Such requests are to be accompanied by a justification note stating the reason for the change. Notwithstanding this provision, should the reason for the delay or change be unacceptable, the IB reserves the right to refuse payment of the grant amount to the Beneficiary. Requests for changes in external training providers or training programmes will not be entertained. In such cases, new applications that abide by the conditions in Section 3 of these Guidance Notes should be submitted.’

9.  We are benefiting from other EU Funded Schemes; can we benefit from the Investing in Skills Scheme?

Funding/reimbursement of eligible cost for the same training programme, for the same employees, from any other sources or even from IIS is strictly prohibited. Accordingly, should the Beneficiary, in any way, gain financially from any National scheme, COVID-19 response measures or EU funded Aid scheme for the same cost component, funding for such cost will be ineligible. Any trainees wage costs financed through the COVID Wage supplement will be deducted from the claim for reimbursement.

10.  What documents could Monitoring Officers request during a visit (On-The-Spot Check)?

In case of direct contact training, the Monitoring Officers will ask the participant/s and the trainer/s to take photographic evidence of the training.

Furthermore, they may request the following documentation:

  • Copies of the attendance sheet/s which is/are issued by Jobsplus and have all Compulsory Publicity Features.
  • Copies of any training material used during the training.

The above list is not exhaustive and the IB may request additional checks on a case by case basis.

On the other hand, with regards to online training courses, the employer will be obliged to send us the link of the course and the training schedule prior to the commencement of the training. Jobsplus reserves the right to participate in the training session as observer and take screen shots of the participants receiving training.

Furthermore, the Monitoring Officer may request other supporting documentation such as:

  • Online attendance report prepared by the training service provider and endorsed by the legal representative.
  • Screenshots of telecommunications applications (such as Skype, WhatsApp and FaceTime) which confirm that there was communication between both parties, when the latter occurred and how much they lasted;
  • Recordings of the entire lessons;
  • Copies of any training material used during the training;
  • Copies of any trainee assessment submitted online at the end of the course (if applicable).

The above list is not exhaustive and the IB may request additional checks on a case by case basis.

Notwithstanding the type of training being delivered, Jobsplus reserves the right to ask during an On-The-Spot Check one of the participants to participate in a short interview to ensure that the latter is aware that the training is co-financed by ESF Funds. This interview also affirms that the participant is following / followed the same training programme that was approved for funding as per Grant Agreement.