Dear Sir or Madam,
I would like to propose a more precise definition or the publication of an authentic interpretation of Article 29(5) of the Regulation on the use of European Cohesion Policy funds in the Republic of Slovenia for the 2014-2020 programming period for the Investment for growth and jobs objective (Official Journal of the Republic of Slovenia, No 29/15, 36/16, 58/16, 69/16 - am., The said Article stipulates: "The intermediate body or the implementing body shall check the completeness and correctness of the payment request in accordance with the second, third and fourth paragraphs of this Article within 30 days of receipt of a complete payment request and, in the event of a supplement, within 90 days at the latest. If the intermediate body or the implementing body, as the case may be, does not reject the application, it shall issue an order for payment of the funds from the national budget. In practice, the intermediate bodies understand this Article to mean that they have 90 days to examine the application. Beneficiaries therefore do not know between the 30th and the 90th day from the date of submission of the application whether the application is valid or under examination, and therefore do not know when we will receive the funds for the implementation of the operation. There is also a contradiction in the article itself. The completeness of the application is checked at the control stage, so the first sentence is completely illogical. I think it would be necessary to set a time limit for the CA to check the claims (e.g. 15 days for claims in the form of standard unit costs; 30 days for claims up to e.g. EUR 50 000, etc.). The article should also be aligned with the payment deadlines in the Budget Implementation Act. Under the current regime, it is completely unclear if a claim/invoice is due for payment within 30 days of the submission of the claim (in the absence of amendments), 30 days after the claim has been approved, 30 days after the order has been issued, etc. In practice, therefore, there is a lot of interpretation and beneficiaries are waiting for funds even after 120 days from the submission of (even complete) claims, which is extremely problematic for the implementers, because NGOs cannot really stock up on funds for four months of implementation of the operations.
Best regards