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The Governance of Educational Welfare Markets

A Comparative Analysis of the European Social Fund in Five Countries

Edited By Daniel Pop and Cristina Stanus

This book is a first exploratory inquiry into possible educational selectivity effects of the European Social Fund (ESF). It assesses the extent of the gap between the social policy objectives set through regulatory competences in multi-level governance and the structure of incentives it breeds in practice, with a broad range of implications for the capacity of the government to control for an equitable distribution of services at the community level. The chapters emphasize the educational selectivity involved in national policy decisions concerning ESF implementation in the five countries, the role of informal mechanisms in fine-tuning implementation, the negative effects of formalization and failures in accommodating the complexity of goals which characterizes the ESF, as well as the overall fairness of ESF implementation towards the most disadvantaged groups in society. The empirical analysis suggests that social-service delivery contracting as an instrument of governance is no longer regulating against risks for beneficiaries, but fuels increased social division in access to public services.
The book is the result of the Educational selectivity effects of the European Social Fund project (July 2012 and December 2013), developed with the support of the Education Support Program of the Open Society Foundations.
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2 Linking ESF implementation with low administrative capacity: The case of Bulgaria

← 20 | 21 → SASHKA DIMOVA

2 Linking ESF implementation with low administrative capacity : The case of Bulgaria

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Building sustainable and efficient administrative structures that will administer EU funds and establishing competitive markets are essential elements for ensuring successful implementation of the EU-funded programmes and a fair allocation of EU funds. Both national managing authorities and the main national policy documents play an important role in the European Social Fund implementation. Thus, it is necessary to have a closer look at how managing authorities work and how they were designed to work in order to identify potential problem areas in the disbursement of EU structural funds.

This chapter reviews the work of the managing authority and the broader policy framework of the Operational Programme Human Resource Development in Bulgaria (BG-OPHRD ), with a special emphasis on the educational sector. Thus, we evaluate the programming and the management of the calls for applications for educational projects alongside a review of different national strategies and programmes. We employ a step-by-step strategy to underline potential problematic areas in the initial stages of BG-OPHRD implementation, with potentially significant consequences for the overall effectiveness of the programme and for reaching the social and educational goals of ESF.

The key problem areas in ESF implementation in Bulgaria in 2010, as identified by the Committee for European Affairs and Oversight of ← 21 | 22 → European Funds (BG-CEAOEF) of the Bulgarian legislative body, concern the implementation of public procurement procedures for EU-funded projects and the capacity of the different administrative units involved in operational programmes’ management and implementation – managing authorities, or MAs, intermediate bod ies, or IBs, specific beneficiaries, and municipalities (CEAOEF 2012). The main institutional deficiency identified is the limited capacity of the managing authorities to implement and manage the operational programmes (CEAOEF 2012). The managing authorities play the most important role in transforming the strategic planning objectives into the desirable social outcomes of the particular programme. Therefore, in this chapter, we restrict our analysis to the capacity of this type of institutional unit.

Even though the MAs are important for the successful management of the ESF-funded operational programmes, and in particular for the efficiency of the commissioning process, there is lack of explicit criteria for assessing their administrative capacity . Furthermore, the existing literature provides scarce evidence of the key problem areas and even more limited discussion on how to tackle them. This chapter contributes to the existing literature by aiming to shed some light on key problematic areas of the ESF managing authorities in Bulgaria. The chapter looks at the efficiency of the managing authority in different stages of implementation of the operational programme, so as to assess its administrative capacity. More specifically, the tendering process and the design of the funding schemes are evaluated, with special emphasis on the efficiency of the calls in supporting fair competition among potential contractors.

First the programme under focus is introduced. This is followed by an evaluation of the capacity of the managing authority in two different respects: programming and management. From here the focus is turned to the capacity of the managing authority to implement an effective commissioning process. A specific section evaluates the structure and the potential drawbacks of the commissioning process, by looking at specific calls under a specific priority axis of the BG-OPHRD . Last but not least, we address potential opportunities and threats that should not be overlooked in the design and the implementation processes of future schemes under the ESF in Bulgaria.

← 22 | 23 → The Operational Programme Human Resources Development in Bulgaria

The strategic aim of this programme is to develop human capital in order to ensure higher employment, income, and social inclusion (BG-OPHRD 2007). The programme aims to improve the quality of life of people in Bulgaria through the enhancement of human capital, the achievement of high employment levels, productivity improvement, access to high-quality education and lifelong learning , and strengthening social inclusion . To achieve its aims, the operational programme is focused on the implementation of the seven different priority areas. Education is embedded within the fourth priority axis of the programme. The main goal of reform in this area is to help raise the skill levels of the workforce and to contribute to better interconnection with the modern development of society and with employers’ requirements and needs.

The implementation of the operational programme aims to fulfil the main horizontal p rinciples of the European Social Fund: gender equality and non-discrimination; innovation and mainstreaming; partnership and empowerment; sound programme and project management; and sustainable development. A 2007 peer review compared operational programmes combating discrimination across different countries.1 According to this review, Bulgaria does not have a specific programme on discrimination, but is rather implementing a horizontal approach to the problem of discrimination. Funding for BG-OPHRD , for the entire 2007–13 programming period, is set at EUR 1,031,789,137.

The capacity of absorbing EU funding in the local economy in Bulgaria is very low compared to other EU countries. At the end of 2011, the rate of absorption of structural funds in Bulgaria was 18.8 percent. The detailed situation of absorption for each operational programme indicates that the BG-OPHRD , at 23.3 per cent, has one of the highest absorption rates ← 23 | 24 → (MLSP 2012). In comparison with ESF-funded OPs in other countries, this is very low. Correspondingly, between 2007 and 2009, the number of signed contracts was very small, with the first contract signed in late 2008, and thirty-nine projects, with a total budget of EUR 37.4 million, running at the end of May 2009 (MLSP 2008, 2009, 2010).

Furthermore, the financial crisis has affected the ability of Bulgaria to provide matching funds for projects. According to MA data, by the end of 2010, 5,495 project proposals had been submitted, out of which, 1,754 contracts at a total value of approximately EUR 596.8 million were signed (MLSP 2011). Therefore, almost half of the total programme budget had been contracted. The 2010 implementation report shows that 47.36 per cent of the total programme budget had been contracted on 31 December 2010. Effective payments under the programme exceed EUR 108 million, accounting for an absorption level of around 10 per cent. Payments under the programme registered significant growth in 2010 compared to 2009. Until December 2010, the managing committee approved the selection criteria for ninety-four calls for applications, totalling EUR 1.2 billion in value. Thus, at the mid-term of the programming period, an accurate timeframe and financial framework for the effective absorption of 98 per cent of allocations to the programme was in place. According to the report of the MA, the higher absorption rates can be attributed to the capacity-building efforts undertaken in 2010 to improve the tendering process on several different dimensions (MLSP 2011, 2012). Namely, a trend to shorten the time necessary to give a final reply to a submitted application was observed.

At the start of the BG-OPHRD implementation, most of the calls for applications involved grant schemes. For example, only in 2007, the Ministry of Education and Science (BG-MES) announced four grant schemes, for a total amount of BGN 23,176,586.

Regardless of the success of the grant schemes, after 2008 the MES began to limit their share of the total number of calls for applications announced: only three out of nine operations were opened as grant schemes, the rest involved the direct financing of institutions previously nominated. For instance, the grant schemes that were opened in 2008 for Support of PhDs, post-doctoral students and young scholars and Developing school and university practices, as well as the programme for out-of-school activities ← 24 | 25 → (but this time with double the budget), were designed for direct financing. This pattern persisted in the following years, too. Most schemes are now open for direct financing without any public calls for applications. This has made the commissioning process in Bulgaria less competitive.

The management of the OP is centralized and belongs to the managing authority, although there are voices calling for more decentralization of the management of structural funds. One key concern in the 2007–13 cycle is that programme planning was incidental and not well structured. For instance, for various programmes in Bulgaria, small local organizations or NGOs were not eligible contractors, even though they had the required skills and expertise. At the programme level, NGOs are just associated members of the Monitoring Committee s of OPs, without voting rights.

Another important aspect of the BG-OPHRD is that, in comparison will all other OPs, it targets the most diverse beneficiaries. The evidence suggests that under the BG-OPHRD, the number of potential beneficiaries is around 100,000 and they fall into one of the following categories: Ministry of Education and Science; educational and training institutions; NGOs ; the Centre for Educational Integration of Children and Pupils from Ethnic Minorities; municipalities; resource centres; vocational training centres; and off-school pedagogic institutions.

The following section analyses the institutional dimension of ESF implementation in Bulgaria, based on an in-depth analysis of national policy documents, and attempts to highlight key problem areas.

The institutional set-up of ESF in Bulgaria

The analysis of national strategic documents is an important step in evaluating the management and programming aspects of domestic policy-making. Furthermore, such an analysis is essential in determining if there is a gap between the main goals summarized in the national and EU regulations. One of the main programming principles is complementarity. Therefore, a review of different national strategies and programmes, along with their ← 25 | 26 → interconnection with the OP priorities, is important for understanding the BG-OPHRD . In the next section we look at the national strategic reference framework, the main BG-OPHRD description, ex-ante and interim evaluation reports, and annual implementation reports. By analysing these documents, the chapter attempts to evaluate the policy discretion of the MA, as well as to what degree the MA can influence the final outcomes of ESF in Bulgaria.

Formal decision-making

The implementation of the EU-imposed mechanisms is directly related to the capacity of the national administrative units. Similar to the other EU member countries, in Bulgaria the national institutions have to be developed in accordance with the EU framework. However, in the implementation, financial arrangements, control and monitoring of the operational programmes, the direct involvement and control of the EU is limited. Namely, for each OP, the design and development of the managing institutions is entrusted to the national government. Even though the EU is promoting decentralization in the member countries, in the case of Bulgaria, the EC has not objected to the centralized mechanism for co-ordination. Moreover, to satisfy the Community Strategic Guidelines on Cohesion (Council of the European Union 2006), the BG-NSRF has created a mechanism to co-ordinate the Bulgarian public authorities on the central, regional, district and local levels (Government of Bulgaria 2007). This mechanism limits the participation of the municipalities in the programming process. Under such a mechanism, the municipalities can only be beneficiaries in the implementation of projects. It can be concluded that the inclusion of local and regional units in programming and commissioning is only formal.

The administrative units responsible for designing the procedures, as well as for the assessment process and the contracting of the projects are structured in a centralized way. Under the BG-OPHRD , these roles are performed by the Managing Authority (the Ministry of Labour and Social Protection) and by three other intermediate bodies : the Social Assistance Agency, the Employment Agency and the Ministry of Education. For each ← 26 | 27 → of the seven different priority axes under the BG-OPHRD, the Ministry of Labour and Social Protection has delegated authority within the area of competence to the respective intermediate body .

The adoption of multi-level governance approach in the regional development is an important measure for the establishment of the EU cohesion policy at national level. The EU had an incentive to adopt such an approach in order to design institutions that would be able to meet the common European objectives. According to existing research, in this way the EU indirectly influences the formation of certain institutional units. The EU creates a regulatory framework that forces the member states to comply with EU cohesion goals (Molle 2005, Baun and Marek 2008). The adoption of multi-level governance in Bulgaria has been specified within the National Development Plan (BG-NDP) and the National Strategic Reference Framework (BG-NSRF). These are the two major documents for the management of the structural funds in Bulgaria for the 2007–13 budget cycle. The strategic document, BG-NSRF is based on the BG-NDP and is approved by the European Commission. It defines the national parameters of the EU Cohesion policy: the operational programmes, some institutional specifics, and financial planning for the implementation of the structural funds in Bulgaria. The BG-NSFR accommodates the national strategies as defined within NDP and it aims to sustain growth in the following areas: infrastructure development; human potential; social inclusion ; and development of a better business environment (Government of Bulgaria 2007, Agency for Social Analysis and Forecasts 2005, Virtanen, Uusikylä and Chatzinikolaou, 2006). Furthermore, these areas are matched with planned actions that will be further developed at the operational level. The greatest asset of the BG-NSFR is that it contains a full description of the projected administrative structure, along with mechanisms for implementation, roles, and responsible institutions.

The role of intermediate bodies in implementation

Different intermediate bodies (IBs) are included in the programming process to a different extent. The BG-MES has been participating only as a consulting body for the BG-HRDDOP working group. The BG-MES ← 27 | 28 → has not been actively involved in the development of the BG-OPHRD . As defined by Milo (2007), the pace under which the terms for the different calls are set and then evaluated is of crucial importance for the programming stage. According to Molle (2008), a higher degree of involvement of the IBs will contribute to a more accurate and effective overall strategy. It is also very important how quickly the evaluation is performed. If the process of collecting and evaluation is shorter, the absorption rate will be higher. The work of the IB is very important in this stage. Their work has a direct influence on the pace of project selection.

The BG-MES was not an active designer of the key human resources development strategy. It carried out the country socio-economic analysis, the SWOT analysis, and financial planning but it did not frame clearly the main priorities of the different programme components (Jilkova 2009); instead, the BG-MES has delegated responsibility to the IBs. Moreover, the BG-MES started using existing administrative offices within the country after the BG-OPHRD launch. These bodies employ an expert in each of the regions and are part of the structure of the Directorate of Education. The main task of these experts is to monitor the project implementation process: however, they are not involved in the programming process.

In the decision-making process and in the programming of the OP, other institutions and public organizations can be involved in accordance with the principle of partnership. There is also a Central Co-ordination unit and Auditing unit. The government has direct control over their work, since the government appoints the executive branch of these units. Therefore, independent monitoring on the work of these units will be an important element in ensuring transparency of the entire implementation process.

The representation of stakeholders

Different stakeholders are represented on both the monitoring and evaluation boards of the BG-OPHRD . However, only a few stakeholders on the boards are NGOs , and they were only included after specific recommendations from the European Commission. Following these recommendations, NGOs became members of the Monitoring Committee of the National ← 28 | 29 → Strategic Reference Framework. However, in the first years of implementation they did not influence any of the decisions made by the committee simply because there were so few representatives of the NGO sector. The main reason for the small number of NGO representatives were the strict eligibility requirements imposed by the government. For instance, only three NGOs were selected to take part in the election of observers, on behalf of the so-called social organizations (a category that included ‘organizations working for the integration of minorities and migrants’). These were the EKIP Foundation, the International Society for Sustainable Development and Co-operation and the Amalipe Center. They were selected by a commission nominated by the Minister of Finance. Moreover, the Ministry of Finance defined the rules for the participation of NGOs in the Monitoring Committee of the NSRF. The procedure included two stages: expression of interest by NGOs to participate in the election of the observers, followed by the election of observers by NGOs selected on the basis of the criteria envisaged in the rules. These criteria included: the effective and efficient work of the organization during the last three years; participation in developing, implementing and monitoring of strategies and policies; and experience in implementing projects financed by the EU (Amalipe 2008). The candidates had to place themselves in one of the following three categories: organizations working in science, education and culture; environmental organizations; and social organizations (including minority organizations). Each category of organization had to elect its own observer. Although there were expressions of interest from many capable organizations, the commission established by Ministry of Finance selected only the three organizations mentioned above as covering all requirements within the group of the social organizations (Amalipe 2008).

The procedures for the election of an NGO observer in the Monitoring committee of the BG-OPHRD were discussed and the election of the NGO observer was only approved at the end of April 2008, during the regular meeting of the Committee. The aim of the procedure was to guarantee an open and transparent mechanism for the participation of the civil society in the process of managing and monitoring resources from the European Social Fund. The procedure is similar to the one already adopted by the Ministry of Finance regarding the National Strategic Reference ← 29 | 30 → Framework. The procedures target organizations in six fields: protection against discrimination; education; Roma integration; health care; science; and social issues. This procedure is favourable for ensuring higher representation of different stakeholders.

However, even though different stakeholders are represented, the direct influence of the monitoring committee on the implementation of the BG-OPHRD is very small and many of its responsibilities are purely a formality. It has only small influence in the programming and management stage of the OP. The board meets only when it is mandatory to meet in order to approve the annual report for the implementation of the BG-OPHRD and the Communication Plan of the Programme. During these meetings a report on the ongoing schemes is presented and forthcoming operations are introduced. However, the board does not have decision-making power on the call design for future schemes.

The availability of information

The main source of information for gathering, analysing and processing information on granted projects related to education under the Structural Funds in Bulgaria, is the managing authority of the BG-OPHRD . However, the directorates of operational programmes in Bulgaria, with the exception of OP Regional Development, do not collect and maintain information differentiating between different policy sectors, as the programmes have a horizontal principle of operation. The BG-MES is a beneficiary for some of the programme areas, but does not monitor and follow all the information related to the use of the structural funds in the educational sector.

One of the goals of the information and publicity measures outlined in the Communication Plan of the BG-OPHRD is to promote ESF and BG-OPHRD. These measures aim at gaining the support and active involvement of many different parties and the greatest possible number of people. This is done by guaranteeing the transparency of the management process. That is a fundamental step-stone in building trust in the responsible institutions.

← 30 | 31 → The printed and electronic media can play a very important role in familiarizing the general public with the goals of BG-OPHRD and its diverse range of schemes. They need to act as a partner of the Managing Authority for promoting the operational programme among the general public, potential beneficiaries, and target groups. However, the BG-MES is not actively co-operating with media; even though this can be an important warranty mechanism for the transparency of the implementation process and an additional channel for feedback and bridge for communicating the needs and expectations of the beneficiaries and society.

In order to facilitate direct access to information to the wide range of target groups, the MA and IBs have established a BG-OPHRD Information Center. This centre will stay open until the end of the programme implementation in 2015. The initial idea was to use this as a centre that can provide comprehensive information on all issues related to the BG-OPHRD, as well as a place to connect potential beneficiaries and beneficiaries with MA and IB representatives. Regardless of the establishment of the information centre, the practice of the MES has been to refrain from effective communication with the beneficiaries of the projects, in order to be perceived as independent in the public eye. Undoubtedly, the IBs need to stay unbiased, but development and improvement of the schemes is conditional on strong communication with the contractors and the beneficiaries.

The following section of the chapter moves on to the next step and analyses in-depth bureaucratic decisions concerning ESF implementation in Bulgaria in the area of educational inclusion.

Shaping the market for educational service delivery using calls for applications under BG-OPHRD

In this part of the chapter we attempt to analyse the call design of the schemes under BG-OPHRD . Specifically, this part focuses on calls for applications for projects that aim to enhance the education levels of vulnerable groups by supporting access to e ducational services and by improving ← 31 | 32 → educational attainment. The success of the interventions in this area is measured in terms of one or more of the following outcomes: decreasing the percentage of children dropping out from school; increasing the number of children that join the educational system; reducing the risk of exclusion of vulnerable groups in the educational system; increasing students’ motivation; increasing literacy rates among vulnerable groups; and providing better opportunities for these groups.

The priority axis that covers educational intervention with specific focus on vulnerable groups and increasing the quality of e ducation is the fourth priority axis, Improving the access to e ducation and training, with a total budget of EUR 194,219,132. This is about 16 per cent of the total OP budget for Bulgaria. Within this area, this analysis is restricted to two key areas of intervention, focused on children and youth, described in Table 2-1.

The expected outcomes of the above-stated interventions are measured by the direct effect of the interventions on the following result indicators: number of pupils with special educational needs integrated into general education; the number of drop-outs reintegrated in the educational system; the number of pupils participating in out-of-school activities; the number of students receiving scholarships. These outcome indicators are important measures of success of the calls for applications. However, it is equally important to go several steps backwards to look at the entire tendering process, since it affects the success of these calls and the OP.

The way the terms for commissioning are defined has a direct influence on who the potential contractors are. For many of the schemes, the call design indirectly renders potential contractors. It is important to understand the degree to which these calls shape a non-competitive contractor market, where only a few contractors have the power to carry out projects, and few eventually use the ESF funding. In the next sections, the chapter attempts to look at the level of competitiveness that is guaranteed by the call design. This can be assessed by looking at who are potential contractors, partners, and beneficiaries. Other important aspects are also the interventions and the call design itself. They are also analysed in the next section, since they are the tools that can enhance competitiveness and the fair and effective distribution of funds.

← 32 | 33 → Table 2-1. Key areas of intervention concerning the educational interventions with a focus on vulnerable groups, BG-OPHRD: Synthesis.

Key area of intervention 4.1. Access to education and training for disadvantaged groups

Key area of intervention 4.2. Children and youth in education and society

Target groups: persons with special educational needs, representatives of vulnerable ethic groups (Roma and Turkish), orphans, migrants, young children (3–6 year-olds) and their parents, dropouts, teachers, principals, pedagogical councillors.

Target groups: Children, students

Potential contractors: MES, educational and training institutions, kindergartens, NGOs, Centre for Educational Integration of Children and Pupils from Ethnic Minorities, municipalities, resource centres, vocational training centres, off-school pedagogic institutions.

Potential contractors: MES, educational and training institutions, municipalities, NGOs, community centres, off-school pedagogic institutions, Centre for Educational Integration of Children and Pupils from Ethnic Minorities, sports clubs and youth organizations.

Key activities: provision of the necessary conditions and resources for the implementation of the ethnic-minority groups’ integration process through the desegregation of children in schools with prevailing Roma pupils, and the reintegration of pupils into regular schools. Another key element is the provision of the necessary conditions and resources for the integration of persons with special educational needs. Furthermore, the calls under this scheme aim to provide educational services and activities for potential dropouts, and pupils not covered by the educational system.

Key activities: expansion of out-of-class and out-of-school forms of learning; setting up mechanisms and provisions for student scholarships and loans with the aim of facilitating access to higher education, This area of intervention is targeted at a more extensive coverage of children and adolescents into the educational system, establishing better conditions for their creative expressions, and developing their future potential for successful advancement.

← 33 | 34 → We analyse the commissioning process and associated bureaucratic decision-making for 13 calls for applications launched under BG-OPHRD to this date. Out of the 13, seven correspond to key area 4.1. and six to key area 4.2.

Who are the potential contractors?

The potential contractors vary for the calls. However, in most of the cases municipalities, schools, NGOs , central administration or other institutions that perform educational activities are listed as potential contractors. There is no significant difference in who the potential contractors can be under the two key areas of the fourth priority axis of the BG-OPHRD . Even though the main goal attainment of these calls can be very diverse there is a small difference in the eligibility requirements for potential contractors. The calls that are analysed cover the territory of Bulgaria.

For six of the analysed calls, the potential contractor is only the central administration, even though the participation of, or partnership with, other organizations or NGOs could be meaningful in understanding the real needs of the beneficiaries. Significant resources have been allocated to the Ministry of Education and Science, while other actors (schools, NGOs, municipalities) have been restricted from participation in many of the schemes.

This tendency can harm the efficiency of the BG-OPHRD for at least two reasons. First, the administration will not be able to perform efficiently if is responsible for many schemes at the same time. There are obviously schemes that should be implemented by national institutions, such as schemes designed for policy-making. But when it comes to providing different social services, distribution of information and so on, the guiding role of the administration is ungrounded. Most of the schemes for direct financial allocation approved by the BG-OPHRD include types of activities which should be realized among vulnerable groups. However, very often the NGOs or other organizations that have direct contact with the groups are neither potential contractors, nor allowed in the partnership structure. For example, in some of the calls targeting the Roma , the ← 34 | 35 → participation of Roma or pro-Roma NGOs is not allowed or is limited to the status of member in the partnership structure implementing a project. None of these organizations is ever listed as primary partner or main contractor. As a matter of fact, some of these schemes were not even designed as grant schemes and it is hard to explain why. This is because the participation of organizations aiming to serve some of the most vulnerable groups is highly recommended throughout the entire programming and implementation project cycle, from identifying priorities, contributing to operational programmes, and work plans, and the membership of monitoring committee s.

Second, the direct allocation of funds in most of cases puts the real implementers of activities in an unequal position. For instance, the Educational services for students lagging behind and gifted student scheme mostly includes organizing additional lessons with these children. It is obvious that these lessons will be organized by the schools or out-of-school branches. However, the contractor for this scheme is the Ministry of Education. If this measure were opened as a grant scheme, this would have provided the real implementers with the right for equal participation not only at the implementation stage, but also at the planning stage. Through the direct allocation of funds, the role of the schools is diminished without real reason.

The number of contractors that are eligible to apply for funds in the calls under KAIs 4.1 and 4.2, after the specific financial, partnership, and activities criteria are met, is small. The evidence on these calls suggests that their design is unspecific, but also is framed with strict criteria. Together, these do not create favourable circumstances for a fair competition.

It is important to ensure that the range of potential contractors is broad, and that they are chosen based on their expertise, sustainability, and ability and skills. However, in Bulgaria, the same organizations are contractors under different schemes, and very often organizations that can offer innovative solutions and have the needed expertise are not eligible to apply. For example, many small organizations can never apply due to financial or some other call requirements. Concerns about the limited availability of structural funds to small organizations and NGOs has been raised in Brussels too, with Commissioner Andor specifically stating that ← 35 | 36 → more attention to vulnerable groups should be given in programming 2014–20 structural instruments in Bulgaria. One of the most important things in the design of the OPs is to find the balance between administration and the structures of civil society, as well as to find the best possible role for each actor. The schemes for direct financial allocation might not be the right mechanism for finding this balance. Therefore, it will be good if they are limited to the cases when the role of the given institution should lead imperatively. In all other cases, it would be better to use schemes that will allow many organizations to act as main contractor, and not overload the administration with activities that should not be under its scope of responsibilities.

However, what the tendering process omits to recognize are the real needs of the educational system in Bulgaria. Clearly, there is a lack of communication between the managing authority, the intermediate bodies , and the potential contractors. Therefore, there is limited understanding of what are the least developed schools or regions and which are the actual vulnerable groups in the educational system.

Partnership structures

Applying the principle of partnership and empowerment is a key element of all structural-funds interventions. The main goal of this principle is to ensure the inclusion and access of the socio-economic partners and other stakeholders in the preparation, implementation, monitoring, and evaluation of ESF support.

In the BG-OPHRD , the partnership principle extends its scope over all actions and covers all project cycle phases. In addition, the principle of partnership is considered both centrally and locally. Applying this principle should improve the mechanisms for experience- and knowledge-sharing among stakeholders; it should build up opportunities for more creative ways to address problems; allow a more effective management of actions based on multiple dimensions (involving a wide range of stakeholders or perspectives) and multiple levels of intervention (national, regional and local); and guarantee a high level of compliance of selected actions with real needs.

← 36 | 37 → The partnership principle has been promoted in almost all calls. In many calls, partnership among local and central units has been encouraged. However, in several schemes, the partner is pre-set, even though there is not enough information and evidence to justify the exclusion of other potential partner organizations. In many of the schemes, project partnership is a compulsory element. For most schemes, schools are the most preferred partner. After schools, NGOs appear in the partnership structure in many of the submitted projects, mainly due to their expertise in terms of writing projects and their experience in dealing with ethnic minorities. In some calls, one of the partners has to be the municipality. Bearing in mind the nature of some calls, it is understandable to include the municipality as a partner, instead of other institutions, since it is able to enhance the needed institutional support. However, in many cases and comparatively speaking, other organization could offer more innovative programmes, due to their expertise. For example, for the schemes, whose main goal is to create an integrative environment for socially vulnerable children such as Roma and their preparation to enrol in desegregated schools, it will be important to have as a partner an NGO that has been working with this high risk group. However, they are never specified as being a primary or mandatory partner in any way.

There are 264 municipalities in Bulgaria, which means that roughly more than half of them were actively involved in ESF tendering processes. Out of 2,000 educational NGOs in Bulgaria, around one tenth participated in the disbursement of ESF funding for education and provided services. That is indicative for NGO sustainability in the country: most non-profit establishments have a lifetime as long as the project duration; others are simply not that active in tendering procedures due to not having a good network infrastructure or resources (technical, human or financial) to apply for funds.

Partnership can be formed either by geographical location, by area of expertise, or on the basis on the number of partners allowed in the call. From a geographical perspective, the most common partnerships are local, since for many schemes, the municipality has to be a partner. For some of the calls, cross-regional partnerships are also formed. However, the calls neither specify precisely what is considered a cross-national structure, nor ← 37 | 38 → are there bonus points for forming such partnership. In many cases, partnerships are formed in such way that smaller regions have little or no power in shaping the programmes. In cross-regional partnerships, the primary contractors are well-grounded organizations located in a big city, while the secondary contractors are local actors from different target regions. Such an example of a network, spreading over five target NUTS III regions, is that of a private secondary school in the capital, Sofia, which invited twelve partners to implement out-of-school activities. All the partners are academic and vocational schools from Sofia, Yambol, Burgas, Veliko Tarnovo, and Gabrovo.

It can be concluded that for most schemes, the main contractor has to partner with the municipality, an educational institution or an NGO. These partnership structures are common. In future, the specific partnership structure requirements should receive increased attention. Comparatively it would be an advantage to ensure that organizations that have expertise in working with the beneficiaries are involved, as they can address more easily the problem areas and offer innovative solutions. So far, the expertise of these partner institutions can vary but in most of the cases they are from the educational sector. Another forms of partnerships should be explored and encouraged. One good example of a partnership between many different entities with essentially the same expertise was the case when the Business Agency Varna association was the main contractor and had eight different partners: two sport clubs; one academic ISCED 2–3 school in Varna; two vocational schools in Varna and Burgas; one lower-secondary school in Varna; one professional association in Varna; and one NGO. Even though it is never clearly suggested in the scheme, a similar partnership network appears in most instances. When the NGO appears as the main contractor, in 40 per cent of the cases it partners with schools, and in 20 per cent of the cases with kindergartens. NGOs are less likely to form partnerships with other NGO. When two NGOs partner with each other, a school is also involved in the network. Similarly, when the main contractor is the municipality, schools appear as partners in most of the cases. In about 20 per cent of cases, municipalities invite an NGO (usually providing social services or working with minority groups).

← 38 | 39 → Who are the potential beneficiaries?

The main aim of the interventions of the Priority Axis 4 is to address the weaknesses of the educational system and pay special attention to the problem areas and to the most vulnerable groups. The analysis of the educational system reveals a poor performance and more pronounced educational-­attainment problems among the ethnic minority groups. The minority groups have relatively insignificant participation and are still not integrated into the educational system. The problem is rather serious among children of Roma origin, as the psychological and socio-economic living conditions have a big influence on educational outcomes. To give these high-risk groups support in their opportunities for future work and educational attainment, it is important to foster their higher integration in the educational system from the youngest ages. Additionally, the high rate of early school dropouts is worrying. The administrators of these interventions also need to look into the educational needs of children with special educational needs . The students with learning deficiencies, including those with physical disabilities, require permanent care to attain progress in education. In order to assist children who are absent from school at the very beginning of the education and are lagging behind students of the same age, various programmes have been designed to provide regulatory, financial and organizational conditions for supplementary education. However, the beneficiaries are not always specified.

In order for the EU Structural Funds to be used effectively to support Roma education, Roma need to be identified as a priority group in the operational programmes. However, many of the calls analysed here use very broad definitions of the potential beneficiaries. Roma children are defined as a priority group in only two of the calls for applications: the grant schemes Creating a favourable multicultural environment for the practical implementation of intercultural education and upbringing and Let’s make school attractive for young people. Both are targeted towards the educational integration of the most vulnerable social groups, with an emphasis on Roma children. The approval of projects within these two schemes is an important step towards the process of educational integration of Roma children.

It is even more important to enlarge the scope of the organizations that will deal with the problems of this minority group. For years, the circle ← 39 | 40 → of those promoting the educational integration of vulnerable groups such as Roma children has been limited to a few NGOs and a few individual experts. Therefore, there is a general feeling that there is lack of innovative ideas . Many of the interventions towards Roma children have been exhausted and have been mechanically replicated over the years and are of questionable quality.

Unfortunately, it would be hasty to expect that the two above-named schemes designed under the BG-OPHRD have the financial capacity and innovative design to guarantee the educational integration process of Roma children. First, the maximum amount of EUR 50,000 for a single project is rather small if the purpose is to achieve full educational integration in any municipality.

Second, both calls do not have a clear draft of prioritized activities, supposed to assist the entire process of educational integration of these groups. In the first call, support for desegregation activities is embedded. However, the call either does not provide definitions, or it provides very unspecific ones. The experts from the BG-MES made a very interesting clarification during the application process, stating that even a school with 1 per cent Bulgarian students and 99 per cent Roma students is considered to be integrated and ethnically mixed.

Third, there is a lack of active policies of the BG-MES for the educational integration of Roma children. There are no specific measures for Roma children specified among the activities of the MES for renewing the Bulgarian educational system. Both calls insist that the projects under the schemes should implement the national educational policy in the given municipality. So, the project should apply the BG-MES policy at the local level without any possibility for innovative models or the prospect for these to be multiplied at a national level. This vicious circle is not promising for the significant educational integration of vulnerable groups.

A fourth problem accompanying these schemes is the trend to allocate money to projects for schools for children with special needs . This trend causes concern for two different reasons. Firstly, one such school is currently participating in three projects, the goals of which are to integrate children from the special-needs school into mainstream schools. This example is evidence that the tendering process is not very competitive if ← 40 | 41 → the same organization wins grants over and over again. However, it is fair to admit that it could only mean that this school has the needed expertise and has been applying with innovative projects.

Second, and more importantly, it is a public secret that the special schools still continue to enrol Roma children without any disabilities . Thanks to the BG-OPHRD projects and the finance allocated to the special schools, the parents of Roma children have even higher incentives to send their children to these schools, even though they should attend mainstream schools. The practice of sending children without special educational needs to the special schools is thus reinforced.

Finally, when looking at the beneficiaries, is important to mention that the calls almost never specify a primary target amongst potential beneficiaries. For instance, in one of the calls, whose main goal is to help disadvantaged students who are lagging behind, potential beneficiaries can be students, children, parents and teachers; a primary beneficiary is never specified. This broad definition of potential beneficiaries will not guarantee in any way that the funds are going to be used by the groups that need them most. However, it can be noted that this problem was understood by the MA and was addressed by creating more specific calls where the circle of potential beneficiaries was very small. For instance, under the call that aims to support integration of children and students from ethnic minorities in the education system, only children from the minority groups and their teachers can be beneficiaries. Also, under the grant scheme Support for the education of children and students with special educational needs, the funds are directed towards children with special educational needs, with an emphasis on younger children in this group and personnel in the special schools.

Designing educational services

The calls for applications analysed here seek to develop interventions that will facilitate higher access and motivation for participation in education of the vulnerable groups. The main beneficiaries under these schemes are drop-outs , students at risk of early school-leaving , minority groups and children with special educational needs. However, the scope of these calls ← 41 | 42 → is not so wide, and their number seems insufficient to substantially reduce the number of drop-outs and sustain higher education participation and integration of the minority groups.

One caveat of the way that most calls are designed is that there is broad specification of the eligible activities under one scheme. Consequently, funds are not utilized in the best possible way. The gain of the most vulnerable group is not always high. How effective the listed activities are, and to what extent they can help tackle the weak points in the educational system is questionable. On average, according to the calls for applications, the projects can cover 20–35 per cent of possible activities. Therefore diverse sets of projects targeted towards many groups can meet the eligibility requirements.

The benefit of having long lists that target many different activities is that the applicant can play an important role in the design of the projects, and can be innovative. The danger with having a list of very broad activities is that this can be manipulated in the allocation of funds. Funds can be allocated to activities that will not directly help the most vulnerable groups, but rather the schools or some other organization. For instance, in the scheme BG051PO001/07/4.1-01, whose main aim is higher integration of the ethnic groups, any activity that aims to contribute to achieving the horizontal principles of the BG-OPHRD is eligible.

The conclusion from the analysis of the calls issued under the Priority Axes 4.1 and 4.2 of the BG-OPHRD is that there is not much differentiation between calls issued under the same key area of intervention. The number of activities that differ between different schemes is very small. In order to ensure that specific groups will benefit from one scheme is important in order to define very specific list of activities. For example, under the Support for children lagging behind education scheme, the main measures contemplated are very broad and include research activities into school drop-out rates, the training of teachers working with children from the target groups, and information campaigns, all at the same time. This is just one of the many schemes for which the MA issues catch-all calls.

Another point of concern is the quality of the activities mentioned in these calls. There is no solid explanation or monitoring system that will secure the quality of the proposed activities.

← 42 | 43 → Call design

The call design is structured in similar way for all schemes. In the first section the call introduces the operational programme its scope and goals. Furthermore, each call comprises the general implementation conditions of the BG-OPHRD . This section is almost identical in all calls. Unfortunately, the practice of drafting the calls in the same manner is easily noticeable, even in the call-specific sections of each scheme.

Even though the eligibility requirements differ for each scheme, it is not a significant difference. The specification of the responsibilities of the main contractor, as well as the potential conditions and requirements for partnership, is very long, but the content can be sometimes misleading. One of the reasons for this is the fact that a clear line between the specific and general requirements is not always drawn. The outline of the financial requirements is lengthy but not very detailed. Furthermore, none of the calls set out specific rules concerning how much of a project’s budget should be directly allocated to the primary target group; for example the minimum amount that needs to be allocate to Roma causes is never defined. Therefore, from the call design itself, it is unclear how much each vulnerable group will benefit.

While trying to create a more inclusive spectrum of activities, the calls very often fail to make specific mention of priority groups who face a higher risk in the educational system. The document defines broad sets of activities, whose main goal is improving education amongst the vulnerable groups, but does not set specific target groups or expected outcomes. Likewise, other sections of the calls are very lengthy but very broad.

Other aspects of the commissioning cycle

Even though there are still problems in the commissioning process and the absorption rate of funds is still low, there have been certain reforms and these are reflected in the design of the calls. Important measures are those that help to shorten the time for conclusion of projects. Since 2010, the time the IB has to review applications has decreased. Furthermore, ← 43 | 44 → since 2010, more precise documentation for the project proposal evaluation was introduced and the MA has made additional efforts to help more potential contractors to be successful in the tendering process. It can be seen that the schemes that have been opened for applications from 2010 onwards require a smaller number of documents to be submitted by the applicant. Also, since 2010, the MA has offered the potential contractors the possibility to have their documentation checked prior to submission. This measure has prevented the rejection of a significant number of project proposals in the administrative compliance-assessment phase. Furthermore, in order to facilitate a more efficient tendering process, the requirement for the submission of monthly reports by contractors has been removed. The information is now submitted in the interim and final reports only.

At the start of BG-OPHRD , most of the schemes announced were grants. For example, in 2007 the Ministry of Education and Science announced four grant schemes for a total amount of BGN 23,176,586. In total, 157 applications were submitted within the grant scheme 4.1 (Creating a favourable multicultural environment) and of these, sixty-seven were selected. The largest share of projects were managed by NGOs (twenty-seven) followed by twenty-one school projects, fifteen municipal projects, and four others. Within the second grant scheme, 4.2. (Let’s make school attractive to youth) interest has been higher. In total, 689 project proposals were submitted and 256 of these were approved: eighty-three NGO projects, 149 school projects, eighteen municipal projects, and six others. Together, these covered around 85,000 children. These grant schemes involved the participation of many different organizations and allowed different stakeholders to be involved in many different projects.

Regardless of the success of the grant schemes, after 2008, the BG-MES has started to limit their share in the total number of calls for applications announced: only three out of nine operations were opened as grant schemes; the rest were reserved to directly finance previously nominated institutions. For instance, the grant schemes that were opened in 2008 for Support of PhDs, post-doctoral students and young scholars, Developing school and university practices, as well as the programme for out-of-school activities, were designed for direct financing. This pattern persisted in subsequent ← 44 | 45 → years, too. In general, most of these schemes are open for direct financing without formal announcements of calls for proposals. This has made the tendering process in Bulgaria less competitive.

Conclusion: Ups and downs in the commissioning cycle

The main goal of this chapter was to assess the founding processes of domestic policy implementation and the capacity of the managing units in Bulgaria to accommodate the EU Cohesion policy objectives. The programme under focus is the BG-OPHRD , while the area of particular focus is education. The chapter assessed the capacity of the managing authority, the design of the calls, as well as the national policy documents. The analysis suggests that in order to enhance the success of the structural funds in Bulgaria, by increasing the managing capacity of the national institutions, it is important to take action across different stages of the commissioning cycle.

Some conclusions are provided by a tentative analysis of the sunset/sunrise areas (Bradley 2005), which looks specifically at the two key areas of BG-OPHRD which targeted the educational sector in Bulgaria. During implementation, several sunset areas were identified. First, municipalities are beneficiaries for all operational programmes in Bulgaria, but are not actively involved in the decision-making and distribution of funding for cultural projects on local and regional levels. The centralization of the operational programmes is an important problem, as is the full exploitation of the potential of different regions and efficiently using local resources. Second, the overall strategic position of the MES related to the utilization of the ESF for education is still unclear. The Ministry is mainly a beneficiary of the programmes and not an active initiator of directions of funding, strategies, tools and funding priorities under the BG-OPHRD. Third, the BG-OPHRD aims to support minority groups and the most vulnerable groups in the educational system; yet it does not contain specific plans to motivate organizations whose main aim is to ← 45 | 46 → help these groups to apply. Also, BG-OPHRD does not seem designed to reflect the specificities of the educational sector. Fourth, the existing curricula of education and training across the country does not focus well on the regional dimensions of the educational policy in the country, nor on the EU integration process (including the connections between the Structural Funds and other EU-funded programmes). Fifth, there are missing links between the administrators working in the cultural sector and institutions responsible for the elaboration of the operational programmes for the next planning period. The development of the national cultural policy does not seem well synchronized or connected with the opportunities provided by the priorities of the EU Structural Funds for the next planning period.

During implementation, there were also positive developments. Also, some areas require little interventions in order to attain significant improvement. First, projects in the field of intercultural education and training, cultural diversity, building understanding between different ethnic groups, and the integration of minority groups into the educational system through cultural events, and intercultural events for youth and children, have been supported under the BG-OPHRD , which suggests some progress is being made in reaching the social and educational inclusion goals of the ESF. Second, investment strategies connecting education with culture indirectly support the overall concept of ‘intercultural education’, which is one of the major topics in Europe, especially related to the education of youth and children. The need to invest in intercultural projects, especially in areas of diverse population and ethnic groups, and focusing on youth and children, is considered a priority. Third, the overall information related to the aims, procedures and deadlines of the Operational Programmes can be made more transparent, and be better announced across the country and accessible to all organizations. This can be maintained by regular communication and control on the activities of the selected contractors and service providers regarding the implementation of the schemes. Also, communication with other stakeholders (institutions, social and economic partners, non-governmental organizations, etc.) should be ensured, with regard to the implementation of joint initiatives aimed at the ESF and BG-OPHRD promotion.

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1<http://www.romadecade.org/cms/upload/file/9684_file1_eu-structural-funds-for-roma-in-bulgaria.pdf>.