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Center Amalipe took part in the Consultation on the Conclusions of the Fifth Cohesion Report announced by the European Commission.

The consultation aims to collect ideas and contributions on the question of how the Union's cohesion policy should adapt to new challenges and how its delivery can be improved in order to maximise its impact in the future. It is intended therefore to help shape the set of proposals on the future policy to be communicated by the Commission to the Council and Parliament. Furthermore, the results of the public consultation will feed into the Impact Assessment for the post-2013 legislative package.

In its answers Center Amalipe stresses the social inclusion of marginalised communities and vulnerable groups as one of the top-prioritries of the European cohesion policy for the next planning period. Suggerstions for simplification of precedures for European funds absorption are also raised in Amalipe statement

The entire statement is below:

How could the Europe 2020 Strategy and cohesion policy be brought closer together at EU, national and sub-national levels?

The Cohesion policy is a necessary means for achieving the main goals of Europe 2020 Strategy, it is part of the European Union priorities and identity. For further alignment of the cohesion policy with the Europe 2020 Strategy is necessary to incorporate in the new Operational programs, in the Development and investment partnership contracts and in the Common Strategic Framework certain cohesion proprieties. Social inclusion of marginalized communities and vulnerable groups (in particular – the inclusion of Roma) should be one of them

Should the scope of the development and investment partnership contract go beyond cohesion policy and, if so, what should it be?

The scope of the development and investment partnership contract should cover not only the cohesion policy but also the Common Agricultural Policy. In this way it should cover not only ERDF, ESF and Cohesion fund but also the European Agricultural Fund for Rural Development. Until now the EAFRD has stayed aside from the issue of social inclusion of Roma and other vulnerable groups that was one of the obstacles before Roma integration (the majority of Roma in most of the EU countries, especially in Eastern Europe, live in rural areas). This gap should be overcome.

How could stronger thematic concentration on the Europe 2020 priorities be achieved?

We strongly agree with the idea European Commission to propose to the Member States “a list of thematic priorities linked to the priorities of Europe 2020” through the cohesion policy regulations. This is a certain way to avoid “dissolving” the cohesion policy in too many priorities. We also strongly agree with the idea certain priorities to be obligatory. We suggest inclusion of marginalized communities and vulnerable groups (Roma and others) to be one of them.

How could conditionalities, incentives and results-based management make cohesion policy more effective?

Conditionalities and incentives for reforms are very important tool for fostering Member States implement the cohesion policy in efficient and effective way. We strongly agree with the idea Member States to be “required to introduce the reforms needed to ensure effective use of financial resources in the areas directly linked to cohesion policy, for example environmental protection, flexicurity policies, education or research and innovation.” We propose Roma inclusion to be explicitly added in this tentative list of areas directly linked to cohesion policy. The Member States should be required to reform and strengthen their administrative and normative infrastructure linked to Roma inclusion in order to use effectively financial resources. Since this is not popular measure for most of the national governments, strong requirements by the side of European Commission are necessary.

In addition, we propose administrative reform in the institutions that regulate EU funds absorption (Managing authorities and Inter-mediate bodies) at national level to be also fostered through conditionalitieas and incentives.

We strongly agree with the idea financial sanctions and incentives linked to the Stability and Growth Pact to cover not only the Cohesion Funds but also the rest of EU budget.

How could cohesion policy be made more results-oriented? Which priorities should be obligatory?

Proper indicators are of key importance for making the cohesion policy more result-oriented. They should move from output indicators (what is the prevailing tendency at present) to outcome and impact indicators. Such indicators should be included in all Operational programs.

In addition, it is of crucial importance to have specific indicators for the impact on the marginalized communities and vulnerable groups (for example Roma). This is necessary since the achievement of the EU 2020 targets itself does not guarantee progress in the integration of marginalised communities. For example if the general employment rate will be increased, there still may be no progress in the employment rate of the long term unemployed or unqualified people.

Social inclusion of Roma and other marginalized communities should be one of the obligatory priorities for the cohesion policy. European Commission should require stronger advance by the Member States in this direction.

How can cohesion policy take better account of the key role of urban areas and of territories with particular geographical features in development processes and of the emergence of macro-regional strategies?

We strongly agree with the cornerstone idea to “allow greater flexibility in organizing operational programs in order to reflect the nature and geography of development process better”. We consider three main aspects of this:

- opportunities for inter-regional and macro-regional programs: in this case it is important social inclusion of marginalized communities and vulnerable groups (including Roma) to be considered as cross-cutting issue and to be included through targeted measures in every program;

- better opportunities for interventions that combine financial resources from ESF and ERDF: such intervention (combination of improving access to education, qualification, jobs, infrastructure and housing) is the best possible way for social inclusion in the Roma neighborhoods;

- opportunities for operational programs aimed at social inclusion of marginalized communities and vulnerable groups: although the Conclusions of the Fifth Cohesion Report do not consider explicitly such an opportunity, it is a logical continuation of the trend for greater flexibility in organizing operational programs. We propose the Report to include this opportunity explicitly

How can the partnership principle and involvement of local and regional stakeholders, social partners and civil society be improved?

At present the participation of the civil society is often underestimated. For example, representatives of NGOs in Bulgaria could participate in the work of the Monitoring Committees of the National Strategic Reference Framework and the Operational Programs only as “observers” and not as “members”, i.e. they do not have the right to vote. Strengthening participation of the civil society organizations (particularly – of NGOs that represent vulnerable groups) is of high importance for the partnership principle. This should be done in three main directions:

- ensuring NGO participation in the planning process for the next planning period;

- requiring NGO representatives to be members of the Monitoring Committees;

- incorporating NGOs (and particularly – NGOs that represent vulnerable groups) as concrete beneficiaries in the new Operational programs: this would allow them to implement strategic projects

How can the audit process be simplified and how can audits by Member States and the Commission be better integrated, whilst maintaining a high level of assurance on expenditure co-financed?

The audit should focus more on outcomes and impact rather than on invoices, additional documents and outputs. At present beneficiaries invest too much time in paper work and concentrate their attention on providing dozens of supplementary documents in stead of on outcomes and impact.

How can financial discipline be ensured, while providing enough flexibility to design and implement complex programmes and projects?

Flat rate, lump sum and unit cost are good tools for simplification of the procedures. At the same time if the Commission decides to introduce them, it is important to take into consideration the scope and the nature of the project. For example social inclusion projects require higher flat rate as well as the smaller projects.

How can it be ensured that the architecture of cohesion policy takes into account the specificity of each Fund and in particular the need to provide greater visibility and predictable funding volumes for the ESF and to focus it on securing the 2020 objectives?

Special accent on vulnerable groups and marginalized communities (Roma and others) should be put in every Fund. This could provide a space for integrated approach for marginalized communities that should be one of the cornerstones in the architecture of the cohesion policy.

The changes in Art. 7 of ERDF Regulations from June 2010 allow 3 % of the ERDF funded operational programs to be used for housing within “integrated approach for marginalized communities”. This was strongly positive step that opened a space for integrated approach (i.e. combining “soft” and “hard” measures and measures from different fields – education, employment, housing) for social inclusion of Roma and other marginalized communities. We propose ESF Regulations to incorporate similar text requiring at least 5 %of ESF funded OPs to be used for measures within “integrated approach for marginalized communities”.