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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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6 ESF as a substitute for national education funding: The case of Slovakia

← 130 | 131 → MAREK HOJSIK

6 ESF as a substitute for national education funding: The case of Slovakia

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This chapter focuses on how the Operational programme Education (SK-OPE ) manages to approach the issues of access to education for vulnerable groups, especially Roma, in Slovakia. Based on an in-depth analysis of policy documents and the guidelines for applicants issued under the above-mentioned programme, it argues that the institutional framework for the implementation of structural funds in Slovakia can be characterized as extremely complicated and unstable, with serious consequences (especially financial) for the contractors.

After presenting the operational programme under focus, the chapter details the context of ESF implementation in Slovakia and presents some data about the progress in implementation. Later on, it analyses the institutional set-up of ESF-funded programmes in Slovakia as reflected in national policy documents. Then, it details the bureaucratic decisions associated with ESF implementation and showcases their potential to induce increased educational selectivity.

← 131 | 132 → The Operational Programme Education

The Operational Programme Education (SK-OPE ), which is in the focus of this study, is one of eleven operational programmes implemented in Slovakia between 2007 and 2013. The global objective of SK-OPE is to ensure the long-term competitiveness of Slovakia by adapting the educational system to the needs of the knowledge society, in line with the strategic priority Human Resources set up in the National Strategic Reference Framework 2007–13 (SK-NSRF 2007). The SK-OPE is part of the European Social Fund (ESF), together with the Operational programme Employment and Social Inclusion (SK-OPESI), within the same Human Resources strategic priority, and with the global objective to contribute to the ‘growth of employment, reduction of unemployment, social inclusion and capacity building’. While the former is focused on formal and informal education within the educational system, the latter includes (re)training the labor force (employees or job-seekers). These two areas overlap to some extent and the borderline between the two operational programmes is unclear. Also, the SK-OPE is complementary to the ERDF-funded Regional Operational Programme (managed by the Ministry of Transport, Construction and Regional Development), which supports the reconstruction, renewal and enlargement of existing school premises and their equipment.

Within the SK-OPE , the overall financial allocation for 2007–13 is EUR 600 million for the Convergence Objective (the territory of Slovakia except for the Bratislava Region) and EUR 17.8 million for the Regional Competitiveness and Employment Objective (Bratislava Region). The SK-OPE is managed by the Ministry of Education, Science, Research and Sport (SK-MESRS, which is also the Managing Authority of the ERDF-funded Operational Programme Research and Development). SK-OPE has five priority axes, each with several key areas of interventions (KAIs or measures).

The KAIs 3.1. Raising the Educational Level of Members of Marginalized Roma Communities and 3.2 Raising the Educational Level of Persons with Special Educational Needs, the focus of this chapter, are part of the Horizontal P riority Marginalized Roma Communities (SK-HP MRC), which is one of four horizontal priorities established within the SK-NSRF.1 Its target is defined as increasing the employment and education levels of marginalized Roma communities and improving their standard of living, and should be directly achieved through implementation of six relevant operational programmes, including SK-OPE .

However, the horizontal p riorities were set up only in the very final phase of programming of the SK-NSRF (SK-NSRF 2007), as a result of negotiations with the EC. Therefore, the objectives of the horizontal priorities were not the basis for programming of the OPs. Existing relevant programmes, Priority Axes and KAIs had already been formally assigned to them (Ad-hoc hodnotenie horizontálnej … 2011: 8). As a consequence, the activities relevant and necessary for the fulfillment of the SK-HC MRC were not included in the OPs and the co-ordinator of the SK-HP MRC, Office of the Governmental Plenipotentiary for Roma Communities (SK-GPRC), has only a minimal influence on the assessment, selection and commissioning of projects (Strategické hodnotenie … 2012: 9). The participation of the civil society in the programming of the SK-NSFR was very problematic and ineffective, and culminated with a boycott of the programming process by NGOs (Grambličková, Mojžiš and Zamkovský 2011: 13–14). Additionally, at the end of programming, the government changed. Discontinuity in the strategic approach of the old and new administration had an impact on both the content and the implementation mechanism of the SK-OPE and SK-HP MRC.

The SK-OPE basic programming documents refer to, among others, the Concept of Integrated Education of Roma Children and Youth, including Secondary and Higher Education, adopted by the Slovak government in 2004 as the national strategy of Roma integration in the sector of education (Ministry of Education of the Slovak Republic 2004).2 The ← 133 | 134 → Concept was replaced by a new one in 2008. The new document contains an analysis of the situation, problems and needs of Roma pupils in the Slovak Republic, strategic objectives and indicators for their achievement. The document claims to ‘propose topics to be attained through national projects and calls’ within the KAI 3.1 of the SK-OPE (Ministry of Education of the Slovak Republic 2008). However, the SK-OPE had been established and launched before the adoption of the new Concept and therefore does not fully match the proposed measures. This chapter argues that the reform policies aimed at the inclusion of Roma and other disadvantaged groups are implemented through centrally planned and commissioned national projects, which tend to substitute national funding for school operations and modernization, rather than demand-driven projects.

Progress in SK-OPE implementation

The SK-OPE was approved by the EC Decision No. K(2007)5476 on November 7, 2007, totalling a budget of EUR 726,825,389 (the EU contribution being EUR 617,801,578) for 2007–13. Of interest to this project are the originally planned allocations for the Priority Axis 3 of EUR 76,470,589 (the EU contribution EUR 65,000,000); the planned allocation for KAI 3.1 of EUR 57,294,118 (the EU contribution of EUR 48,700,000); and the planned allocation for KAI 3.2 of EUR 19,176,471 (the EU contribution was EUR 16,300,000).

← 134 | 135 → Table 6-1. Financial allocations for the education of vulnerable groups, SK-OPE, 2007–2012.

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* The call was cancelled.

** Including the call cancelled in 2010.

Source: Overview of launched calls. Webpage of the Central Co-ordination Authority. www.nsrr.sk/download.php?FNAME=1358759401.uplandANAME=prehlad_vyziev_31_12_2012.xls

In the second half of the programming period 2007–13, we see an increase in the contracting of national projects in the Priority Axis 3, thanks to large national projects (see Table 6-1). That could be motivated either by concerns that demand-driven projects would not ensure the planned absorption of the allocated funds, or that demand-driven projects are not effective in reforming the education of vulnerable groups and bringing the expected results.

By June 22, 2012 the SK-OPE was the second-least performing operational programme in Slovakia, from the point of view of spending of the planned allocation for 2007–13. The level of absorption (as expenditures certified by the EC) was only 15.82 per cent. Due to the weak financial implementation of the SK-OPE and concerns about the real capacity to absorb its allocated funds for 2007–13 until the end 2015 (rule n+2), on May 16, 2012 the Slovak government decided on the reallocation of funds from the SK-OPE into SK-OPESI. The EC approved the proposed revision on September 19, 2012. The total budget of the SK-OPE was reduced ← 135 | 136 → by EUR 70 million and the new budget of the operational programme was EUR 656,825,389 (the EU contribution after the reallocation was EUR 558,301,578). The reallocation did not affect the KAI 3.1, but the budget of the KAI 3.2 was increased by more than EUR 1.9 million.

Table 6-2. Aggregated contracted number of projects, contracted amounts and share of the total allocation for 2007–2013, SK-OPE.

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* The Annual Report for 2008 indicates only the amount contracted from EU sources. Without national co-financing; which financing differs by type of contractor, it is not possible to calculate from available data the actual total contracted amount including the national co-financing).

The SK-OPE and national education policy

The SK-OPE was prepared during a period of important political change, when a reformist right-wing government was replaced in 2006, after eight years of rule, with a new coalition led by social democrats. The new ← 136 | 137 → government engaged in completely redrafting the basic documents of the programming period 2007–13, including the SK-OPE (among the consequences were delays in beginning the SK-NSRF implementation). Similar to other sectors in Slovakia, in education policy there is also a lack of strategic continuity across political cycles. According to experts, the substantial problem of the Slovak educational system is a ‘lack of vision and consensus across the whole society on what educational system we want to build-up’ (Krčmárik 2012). An agreement on targets and strategy going beyond the governmental changes is missing and each administration adopts new long-term ‘strategies’, which are immediately replaced by new ones.

Typically, the redrafted SK-OPE approved in 2007 by the EC refers in its strategic part mostly to the Policy Statement of the Government 2006–10 and Priority Tasks of the SK-MESRS for 2006–10. The following objectives are formulated for the regional system of education: drawing up a concept of foreign-language teaching in primary and secondary schools; assessing the qualifications status of pedagogical staff in regional schools and the standard of training of graduates from teacher-training colleges; drawing up a draft concept of professional teacher development within the career system; preparing a draft act on the situation of pedagogical staff of schools and school facilities; drawing up a new draft act on education and upbringing (school act) to address changes in the content of upbringing and education in regional schools; drawing up a concept of two-tier educational programme model in vocational education ; and drawing up a concept of the education information system.

As noted above, the operational programme was drafted at a time when the existing concepts and acts in education and upbringing were amended, or new ones were drafted and thus, they could not be sufficiently taken into account in its drafting. Therefore, all relevant concepts would be spelled out later, during the preparation of calls for applications (i.e. incremental strategy formation of using the ESF/OP Education) (SK-OPE 2007: 28–9). This means that the SK-OPE draft did not contain detailed descriptions of the needs that it was supposed to address. Instead of this, it included a mechanism of incremental strategy formation, meaning repeated and interim analysis and evaluation when preparing the various calls, focusing specifically on programming, channels of intervention, financial structure, ← 137 | 138 → as well as the intervention impacts and variants. The incremental strategy formation should consist of the following steps:

(a) establishing an efficient partnership of the Managing Authority (MA) with the relevant stakeholders involved, including a certain form of participation of the target group representatives;

(b) a participative scoping phase co-ordinated by the MA, in which identification of possible priority areas would be complemented and confirmed, on the basis of pre-agreed criteria including their geographic dimension;

(c) a strategic decision by the MA concerning the selection of priority areas based on outputs from the previous stage;

(d) implementation of short (three to six months) partnership projects procured from a single source for which analyses of needs, key disparities and development factors would be prepared in the priority areas according to pre-defined clear specifications;

(e) selection of alternative instruments (activities) by which the needs would be addressed;

(f) modelling and quantification of objectives and determining the financial allocation – performed by the MA. In the event of insufficient external capacities, consultants can be involved in the process or the strategic process as a whole can be transferred to a suitable partner;

(g) an ex-ante evaluation of the effects of the different variants including an empirical verification of the intervention mechanisms in the 2004–06 programming period and/or pilot verification of instruments (t months); this can be done by single-source procurement or by a call with sufficiently specific conditions;

(h) strategic selection of the most beneficial variant by the MA;

(i) preparing documentation for the call (in ideal cases, in co-operation of the IB/MA and partners, and co-ordinated by the MA, including model cost estimates, methodologies for the implementation of activities, methodologies of monitoring, etc.) (SK-OPE 2007: 163–64).

However, how this procedure actually worked in practice, at least in case of the Priority Axis 3, is not known to us.

← 138 | 139 → The problems and policy priorities in the field of education of Roma children were elaborated only in 2008 in the Concept of Integrated Education of Roma Children and Youth, including secondary and higher education, adopted by the Slovak government in 2008 (Ministry of Education of the Slovak Republic 2008). The defined policy priorities include: the creation of adequate conditions for access to e ducation and opportunities to provide quality education for pupils from a socially disadvantaged environment ; to improve pre-school preparation in kindergartens and readiness of Roma children to enter elementary schools; to improve the school performance of Roma pupils; to increase the share of Roma students in secondary schools and universities; to decrease the share of Roma children in special education for mentally disadvantaged children; and to support lifelong learning for Roma adults with no completed education from the perspective of labor market.

These objectives were to be achieved through a set of measures, which should be created through national projects funded from the SK-OPE ’s KAI 3.1. These include measures in several areas, of special interest to us being those focused on pre-school and primary education. Concerning pre-school preparation the aim is to support motivation of parents to place their children into kindergartens, to extend the network of kindergartens into municipalities with a high number of Roma children, to improve the methodological support to kindergartens’ staff, and to develop and introduce programmes for involvement of parents and improvement of their co-operation with kindergartens. For primary education the aim is to extend the network of preparatory ‘zero’ grades; to decrease the number of pupils in classes; to implement a day-long educational system; to create an attractive educational environment respecting the social, cultural and linguistic specificities of children; to take into consideration the educational needs of Roma children in the preparation of school educational programmes; to support programmes of multicultural anti-prejudice education; to develop school-readiness tests and differential diagnostics independent from social and cultural background of the child; to increase a number of special pedagogues in elementary schools to facilitate the individual integration of pupils; and to legally facilitate the schooling of minor mothers .

← 139 | 140 → The institutional set-up of ESF implementation in the Slovak Republic

The institutional framework for the implementation of structural funds in Slovakia can be characterized as extremely complicated and unstable, with several institutions issuing a high number of diverse (sometimes ambiguous or contradictory) obligations, rules, and their interpretations, which are often updated. At the same time, all the documents are binding and their application rigidly controlled. Any violation of the rules (sometimes arbitrarily interpreted) can lead to financial damages, when funds already spent by contractors are considered as ineligible by the authorities. The rules of the game are often modified during the game. As the system of managing documents is hierarchical, any modification in higher document leads to modification of all subordinate documents. Such an environment de-motivates contractors to get involved in innovations, which would create novel situations from the point of view of application of the rules. At the same time, the intermediate bodies , which are subject to many controls and audits from the part of supervisory authorities, are afraid to interpret or create procedures to accommodate the novel situations.

Moreover, how ESF addresses educational vulnerabilities in Slovakia is largely dependent on how certain key notions are (not) defined in national policy documents. Thus, the operational programme, or any other document, does not contain descriptive or normative conceptual definitions of such frequently used terms as ‘social inclusion ’, ‘integration’, or ‘social exclusion’, despite explicitly using these notions in programme objectives. The programme documents refer to the Anti-discrimination Act (2004). However, its application in the context of implementation of the EU structural funds is not developed (although the concepts of preventive and affirmative measures, banning of segregation, and Roma mainstreaming would be worth operationalizing in the context of project development).

Instead, the operational programme rather focuses on the definition of eligible target groups, which include ‘pupils with special educational needs ’ as defined by the Article 3 (2) of Act No. 29/1984 Coll. on the ← 140 | 141 → system of primary and secondary schools. Pupils with special educational needs refers to pupils with mental, hearing, sight or physical disabilities, pupils with poor health, pupils with disturbed communication capability, autistic pupils, pupils with development disorders in learning or behavior, pupils with heavy mental disability placed in social care homes, pupils with disorders of mental or social development, and intellectually talented pupils. The pupils’ special educational needs should receive special education services corresponding to their needs, which would develop their individual capacity, according to the law. However, researchers conclude that in the case of Roma pupils placed in special education, their individual capacity is in reality not developed, and enrolment in special education rather dramatically limits the pupils’ prospect for secondary education and access to the labor market (Friedman et al. 2009: 35–49). The definition of pupils with special educational needs does not include the ethnicity or mother tongue of the pupil.

The SK-OPE additionally quotes a definition of ‘a child from socially disadvantaged environment’ from the Concept of integrated education of Roma children and youth, including the development of secondary and higher education:

… a child with learning and attitude difficulties occurring on the basis of dysfunctional social conditions resulting from social exclusion (e.g. poverty, unemployment, alcohol addiction, violence, inadequate education of parents, non-standard housing and hygienic conditions and the like). Socially disadvantaged environment shall mean an environment, which – with regard to its social and language conditions – leads to the assumption that a child would not master the schoolwork of the first grade of primary school over one academic year. As the definition of a [socially disadvantaged environment] suggests, those are mainly such difficult children who live in unfavorable social conditions. Their parents are not able to bring up their children and are not capable of understanding the children’s basic needs. (Ministry of Education of the Slovak Republic 2004)

Although the definition does not refer explicitly to ethnicity, it is mostly used as a proxy term for children from marginalized Roma communities. The SK-OPE does not develop this concept, but calls within the Priority Axis 3 explicitly refer to children from socially disadvantaged environment as beneficiaries (SK-OPE 2007: 63).

← 141 | 142 → Formal decision-making and institutional role-orientation

The SK-OPE is managed by SK-MESRS, which is also the Managing Authority for Operational programme Research and Development. The SK-MESRS entrusted, via formal delegation agreements, tasks related to demand-driven projects of both operational programmes to the intermediate body , the Agency of the Ministry of Education, Science, Research and Sport of the Slovak Republic for EU Structural Funds (SK-ASFEU). This is an independent organization established by the ministry and managed by a general director appointed by the Minister of Education, Science, Research and Sport. One SK-OPE key area of intervention (2.2 Support to Lifelong Learning in the Health Sector) has a different intermediate body, the Ministry of Health. The intermediate bodies are responsible for programming, administration of calls for applications, assessment, the administration of contracts, financial management and control of projects, communication, and other tasks in relation to demand-driven projects. The intermediate bodies are co-ordinated, methodologically guided, and supervised by SK-MESRS’ specialized departments.

The SK-ASFEU prepares an annual indicative schedule of calls for the submission of demand-driven projects, which must be approved by the SK-MESRS. The calls for submission of demand-driven projects are drafted by the SK-ASFEU at the request of the ministry, which defines eligible applicants, activities and expenditures for the call, as well as the assessment and selection criteria for project proposals. The intermediate body should theoretically create working groups for drafting of calls, which are issued after approval by the SK-MESRS. Calls to be prepared within the KAI 3.1 must be consulted upon with the SK-GPRC. However, the information on actual preparation of calls in working groups or their composition is unavailable. An evaluation report states:

In some instances, the lack of consideration given to the selection of members for working groups engaged in preparing calls (where it was a question of calls which, in terms of their character were repeated, the entire process was not repeated in its full scope), i.e. the absence of some of the parties concerned, has had an impact on the quality of draft calls; the draft calls are subsequently submitted to a Managing Authority to be approved in a very short period of time prior to their issue, which may ← 142 | 143 → have a direct impact on the draft call quality assessment by a Managing Authority. (Ernst and Young 2010: 28)

The monitoring of demand-driven projects is ensured by intermediate bodies and aggregated by the Managing Authority, which also monitors the national projects. Evaluations of the SK-OPE are procured centrally by the SK-MESRS’ specialized departments responsible for respective OPs; they are typically subcontracted to external consultancies via public procurements. There is no specialized body or committee supervising the evaluations of the operational programmes (terms of references, public procurement, reports). The evaluations’ terms of references are not published, only the final reports are available, after a process of review by the managing authority and intermediate bodies. This fact has been criticized by a member of the SK-OPE’s Monitoring Committee , who requested that the terms of references are made available to both the members of the Monitoring Committees and the public on the ministry’s webpage.3

The SK-OPE is managed by the SK-MESRS, which is the central administrative authority for national education policy. The ministry is responsible for policy-making and implementation, including the development of the national educational strategy; state educational programmes and educational standards; authorization of curricula and schoolbooks and educational materials; experimental testing of innovative managerial, organizational, and educational processes and educational contents; establishment and management of system of educational fields; accreditation of projects and organizations providing training for teachers; and others.4 The SK-MESRS became Managing Authority for the SK-OPE in 2006.5 The ministry charged its Section of EU Structural Funds with the tasks of the Managing Authority. The SK-MESRS entrusted its tasks related to demand-driven projects to the two above-mentioned intermediate bodies .

← 143 | 144 → We can therefore conclude that the SK-MESRS is at the same time the policy-maker for general educational policy in Slovakia and implementing institution for national projects. This should facilitate co-­ordination of the national education policy and use of the ESF for its purposes. Implementation of the demand-driven projects was entrusted to other institutions. While the KAI aimed at education of personnel in the health sector is directly implemented by the other central authority responsible for the health policy, the Ministry of Health; other KAIs are delegated to the implementing agency, SK-ASFEU, which is independent (although linked) from the policy-making. This could be the reason why demand-driven projects can be more disconnected from the reform policies in education, compared to the national projects managed directly by the SK-MESRS.

Promotion of partnership

The SK-OPE declares that it applies the partnership principle in implementation: ‘participation of social partners and regional and local government authorities is foreseen in the gradual shaping of strategy, in progress monitoring, evaluation and selection from the submitted grant applications and in ensuring publicity’ (SK-OPE 2007: 9). The defined eligible activities of all KAIs specifically mention the notion of partnership.

However, in practice, as described in previous sections, the application of the partnership principle in programming on the operational level was weak and rather formal. Application of the partnership principle in the programming of the calls, at least in case of the priority axis under focus of this study, and promotion of partnership principle in project development and implementation is also absent.

Key aspects of the commissioning cycle

One aspect worth mentioning in the context of commissioning is the inequity in contracts between the MA (or the intermediate bod y ) and the contractor. The contract template is issued by every MA and published ← 144 | 145 → together with every call. The contract is extensive (sixty-two pages long – eight pages of contract and fifty-six pages of binding General Contract Conditions to the Contract on Provision of Non-Refundable Financial Grant). Moreover, the contract includes provisions stipulating that the contractual relation is regulated also by the Guide for Contractors issued by SK-ASFEU and other documents (Management system … 2013; Financial Management system … 2013), which can be modified unilaterally. The contractor must accept these modifications or request termination of the contract. This fact is criticized by watchdog NGOs :

… the contracts between [Managing Authorities] and [contractors] are very unbalanced in what concerns the rights and obligations of the contractor on one hand and of the state on the other. In the past, there were published cases, when contractors, without being at fault, were not receiving payments for activities delivered exactly according to the project and reported in line with guidelines and rules. Contractors are not protected against arbitrary actions from the side of the [Managing Authority], which can terminate the contract for any minor violation of the contract [by the contractor] with serious financial consequences for the contractor. On the other side, the contractors must, in case of violation of the contract by the [Managing Authority], circuitously seek the protection of their rights in court. (Grambičková, Havlíček and Nemcová 2010: 8)

Availability of information

The information concerning SK-OPE implementation is available on the webpage of the Managing Authority and the intermediate body under the Managing Authority. The SK-ASFEU webpage includes the SK-NSRF, the full SK-OPE description, the programme Manual of the SK-OPE, other basic documents at the national and EU levels, guides for applicants and contractors, all current and past calls for submission of demand-driven projects and lists of approved projects and contractors.6 However, the list ← 145 | 146 → of contractors is unsearchable and not very user-friendly. Moreover, there is no information available to the general public on unsuccessful applications or on the names of people involved in the assessment of applications.

However, the documents are dispersed in diverse places of the webpage and it is difficult to find the needed information if the user is not familiar with the site. Moreover, the documents are written in very technical language and are unintelligible for those persons without good knowledge of the structural funds machinery.

Open and critical information on problems in programming and implementation of the SK-OPE cannot be found in the evaluation reports either; problems are usually indicated indirectly or in technical terms. According to the owner of one consultancy involved in OP evaluations, if an evaluation report would be openly critical the company would never be contracted again. The best information sources on actual problems are the minutes from the meetings of the monitoring committee , where members representing non-governmental actors (self-governments, social partners) and, especially, the EC, express them openly. However, the minutes are very long and probably the public and journalists do not pay attention to them.

Other relevant aspects of the institutional settings

The main features of the use of the EU Structural Funds in Slovakia and their effectiveness are: extreme formalism; rigidity of rules; and a lack of result-oriented logic. The progress in implementation is monitored and reported in terms of spending of funds and in regularity, rather than the results and impacts that the spent funds have brought. Similarly, the audits and evaluations focus on the financial aspects, rather than assessment of achievement of results and impacts and their effectiveness and efficiency. Typically, with very few exceptions, Slovakia has not implemented any of the financial simplifications, proposed by the EC (flat rates, unit costs and lump sums) with the aim of ensuring smooth delivery (reduction of administrative burden), positive impact on results, legal certainty for contractors, and reducing errors in the system. According to the author’s personal experience with other Slovak operational programmes, the reasons ← 146 | 147 → for not adopting the simplifications consist in rigidity of the Certifying Authority and Auditing Authority (Ministry of Finance), which underline the risks of misuse of funds. Consequently, the Managing Authorities of respective operational programmes lack methodological guidance for the introduction of financial simplification and are afraid of possible irregularities within ex-post checks by the Ministry of Finance.

Calls for applications and their educational selectivity impact

In this section, we analyse the calls for applications launched under SK-OPE in an attempt to assess their educational selectivity impact.

Who are the potential contractors?

According to Slovak rules, ESF interventions can be delivered through two types of projects: national projects and demand-driven projects. The former, commissioned by the Managing Authority (SK-MESRS) are to be used for the implementation of education reforms (in line with legal or national strategic documents) for the entire country; the Ministry of Education directly commissions such projects to specific entities.7 The latter are submitted by diverse eligible entities following calls published by the intermediate body working under the Managing Authority, the Agency for EU Structural Funds of the Ministry of Education, Science, Research and Sport of the Slovak Republic (SK-ASFEU) and awarded on a competitive ← 147 | 148 → basis. The assessment and selection criteria for demand-driven projects are formally extremely rigorous and constrictive. Such formalism, on one hand, limits the access of many potential applicants to the funding and requires the assistance of professional consultants or for-profit consultants, specialized in writing applications for and administering structural-funds projects. On the other hand, it does not prevent – but, together with a lack of transparency and public control, rather facilitates – the biased and corrupt commissioning of projects. Moreover, the formalism in the assessment process leads to the commissioning of relatively conventional and standardized projects8 rather than projects made to the measure the target groups and innovative projects, which can be more effective and efficient in dealing with the social inclusion of disadvantaged children.

Potential eligible applicants within the analysed Priority Axis are both from the public and private (non-for-profit and for-profit) sector. The former includes state, regional and municipal authorities and organizations established by them, the Slovak Academy of Sciences, state and public universities, and public media. The latter includes NGOs , social partners, private and church schools, non-for-profit counseling organizations, and for-profit companies.

However, the actually launched calls were much more restrictive. Out of four published calls for the submission of demand-driven projects within the KAI 3.1, which focused on educating children from marginalized Roma communities, three calls (SK-OPV-2009/3.1/01-SORO, SK-OPV-2011/3.1/02-SORO and SK-OPV-2012/3.1/04-SORO) limited the eligibility of applicants to public and private primary or secondary schools and school authorities (and their subordinate institutions). The remaining call within the KAI 3.1 launched in 2011 (SK-OPV-2011/3.1/03-SORO) was also open to regional authorities and NGOs . The reason for such an extension of eligible applicants was that the call was linked to the implementation of the Local Strategies for Comprehensive Development ← 148 | 149 → (SK-LSKxP) of Roma communities, which had been prepared by municipalities and micro-regions and approved by the SK-GPRC between 2008 and 2010. These could contain project aims to be delivered by other entities involved in SK-LSKxP; and without an enlargement of the scope of eligible applicants, the approved SK-LSKxPs could not be implemented. The single call for submission of demand-driven projects within the KAI 3.2 (SK-OPV-2009/3.2/01-SORO), aimed at the secondary education of persons with disabilities, was open for special secondary schools established and run by state, regional governments, churches or private secondary special schools, public counseling and prevention centres, NGOs, and other private non-for-profit entities providing services in the field of education and special education . The concentration of calls on schools can lead us to a hypothesis that the use of the ESF resources is intended, at least partially, as a substitute for funding schools by the state (in Slovakia, all primary and secondary schools, including private and church schools, receive equal funding from the State per pupil).9 Although such a practice can be perceived as positive from the point of view of sustainability of the ESF investment, it seems to be in contradiction with the principle of additionality of the EU Structural Funds.

A second factor shaping the market is the contractors’ obligation to financially contribute to the implementation of the approved projects. The applicant has to provide a sworn statement on the availability of financial resources for compulsory co-financing, as well as a stable and sufficient cash-flow for smooth project implementation. Moreover, the SK-OPE managing authority or the intermediate bod y can request the applicant to prove its financial capacity. No financial contribution is requested of contractors ← 149 | 150 → directly funded from the state through the state budget, or the budget of central authorities (such as central authorities and organizations established and funded by them, state universities, state elementary and secondary special schools, School Regional Authorities, pedagogical and psychological guidance centres, special pedagogical guidance centres founded by school regional authorities, diagnostic centres, re-education homes, curative and childhood sanatoria, public media, and the Slovak Academy of Sciences). The logic of this rule is that in the case of state-funded organizations, the co-financing would be paid from the state budget resources anyway. Other contractors, both public (regional and municipal authorities and organizations established and funded by them, public universities) and private (NGOs , social partners, church and private schools, and others), have the obligation of 5 per cent co-financing. While this can seem an equal approach to diverse types of contractors, the consequences handicap potential not-for-profit contractors. Unlike public entities (regional or municipal authorities, schools and other organizations established and funded by them, public universities), and churches10 (including church schools or other organizations established and funded by churches), not-for-profits are not connected to any public financial resource. At the same time, not-for-profits often provide services of public interest (social services, work with marginalized populations, and others) and, in many cases, substitute missing or insufficient public services which should be provided by public authorities according to the Slovak law.

Long delays of payments and reimbursement from the SK-OPE and other OPs in Slovakia create additional problems for contractors (Košťál and Plesch n.d.). According to the law and the implementation rules (interpreted by the Ministry of Finance as Certifying Authority for the Structural Funds), entities, which have debts to the public budget, are not eligible for funding from the Structural Funds. At the same time, delays in payments ← 150 | 151 → (of several months, in extreme cases of several years), often due to over-complicated administrative structures and procedures at the national level and the unceasing instability of rules, make many contractors unable to fulfil their fiscal obligations (typically to pay social and health insurance for their employees involved in the project implementation). As an extreme paradox, we identified a state agency, which was established and funded by the SK-MESRS, that received delayed payments from the SK-MESRS.11

Additionally, the contractor’s contribution must be financial (in-kind contributions are not accepted) and applies on each expenditure within the project. This rule is seen as very restrictive by many, as some entities, typically private not-for-profits, which are dependent on grants, are not able to ensure the co-funding of certain types of expenditures. For example, while a corporate donor would be willing to financially support a direct activity with children even at a higher intensity than the obligatory co-financing, it would not support the co-financing of ESF publicity or other indirect project activities requested by the SK-ASFEU.

A third factor limiting the access of possible contractors of projects is the minimum project budget required by the calls for applications, which is at least EUR 100,000. Such a high threshold limits the access of worse-off entities, for example small or low-budget schools,12 or private non-for-profits with more complicated access to funds for co-funding of the project. Higher budgets lead to higher requirements in terms of project management and administrative procedures. Additionally, smaller entities cannot effectively and efficiently spend high project budgets for eligible activities.

The SK-OPE calls for applications do not place any restrictions on the territorial scope of the projects submitted by different types of applicants. Projects can have any territorial coverage if they are in line with provisions concerning eligible activities . For example, a regional authority is allowed to ← 151 | 152 → apply with a single project, which includes several or all schools established and financed by the regional authority (in such cases, individual schools included in the project cannot submit individual projects). NGOs (which were eligible applicants within only calls SK-OPV-2009/3.2/01-SORO and SK-OPV-2011/3.1/03-SORO) can plan activities in several regions or within the whole territory of the country (except the Bratislava Region, which is not eligible under the Priority Axis 3) within a single project.

In addition to calls for demand-driven projects, the SK-MESRS has commissioned three national projects with country-wide coverage to two state organizations. According to Slovak rules, calls for national projects had to be published, even if there was only one potential eligible applicant. The Methodology and Pedagogy Center, responsible for the continuing education and training of teachers of pre-school, primary and secondary schools within the whole country, was commissioned with two national projects aimed at supporting the education of Roma children in elementary schools (SK-OPV/K/NP/2011–1) and the pre-primary level of education (SK-OPV/K/NP/2012–2) to be funded from the KAI 3.1, with respective allocations of EUR 28.5 million and 7.4 million. The remaining call for submission of a national project (SK-OPV/K/NP/2012–4), addressing The Research Institute for Child Psychology and Patho-psychology, has a budget of EUR 15.8 million and concerns counseling activities for and the prevention of social pathologies in schools.

Partnership structures

All scrutinized calls, both for national and demand-driven projects, specify that the ‘partnership principle is not applied under this call’. However, the partnership principle in the design and delivery of projects is envisaged in the SK-OPE . Its SWOT analysis states among the weaknesses of the current Slovak educational system the ‘low level of partnership between sectors, self-governments, employers, labor offices, educational institutions and other social partners in creating the content of education’ (SK-OPE, 2007: 76). At the same time, among the opportunities we find references to:

← 152 | 153 → … facilitating the involvement of the private sector and businesses in drawing up of learning programmes, creating partnerships for the development of education on the regional level, with an emphasis on the relationship between the regional development strategies and the structure of branches of studies and training. (SP-OPE 2007: 79)

The partnership principle is developed in both Roma-oriented KAIs 3.1 and 3.2, focusing on the education of persons with special educational needs and including eligible activities which could benefit from these partnership structures: ‘on-the-job vocational education and training’; ‘design of programmes to develop co-operation between schools; pedagogical and psychological guidance centres; special pedagogical-guidance centres; children-integration centres; re-education homes; curative and childhood sanatoria; specialized facilities reporting to the Health Ministry (e.g. children’s psychiatric department in hospitals, curative and upbringing facilities); and other professionals’ and ‘programmes supporting international co-operation in sharing experience (best practice)’ (SK-OPE 2007: 110–11). Also, other eligible activities defined in the SK-OPE could bring added value if designed and implemented in an effective partnership. However, this never materialized, as the calls for submission of projects never included the possibility to apply in partnership. Paradoxically, the assessment criteria of submitted projects award applicants with extra points for ‘partnership, participation in international networks and level of involvement’ within the assessment category Administrative, Expert and Technical Capacity of Applicant.

Although the SK-OPE rules do not encourage formal partnerships of applicants and contractors and the actual launched calls disable them, informal, even illegal, partnerships between applicants/contractors and for-profit companies, which specialize in Structural Funds operations, are common practice. Most potential applicants do not have the technical capacity for SK-OPE project preparation and the management of successful projects. Additionally, many activities cannot effectively be implemented by the contractor itself (for example, training of teaching staff). Instead of the transparent formal involvement of other entities capable of delivering such activities (for example, entities with proven skills in ESF project management or with a certified effective training programme for teachers, whose capacities could be scrutinized within the project application assessment), ← 153 | 154 → these are procured by contractors through manipulated tenders.13 The common practice is that a consultancy helps the applicant to write the project (often for free) and ‘ensures’ that the application is successful. After receiving the funding, the contractor subcontracts via manipulated public procurement the same or other previously agreed entity for the delivery of certain services (management, training) or goods, often overpriced. Many, including several interviewees, believe that without such ‘assistance’ or without political backing, it is almost impossible to be successful in applying for the funding. Therefore, potential applicants who are not involved in clientelistic networks, or are not willing to participate in corruption are discouraged, or even disadvantaged in accessing EU funding in Slovakia. An academic survey among 520 municipalities in Slovakia, shows that 93–7 per cent of municipalities believe that ‘over-standard relations with persons or organizations directly or indirectly involved in the distribution of EU funds (authorities, evaluators, consulting agencies connected to political parties controlling respective ministries’) are indispensable or crucial for the success of a project. Within the same survey, 45–54 per cent considered that a bribe must be offered in order to have a successful project (approximately 20 per cent of municipalities did not want to answer this question) (Mindová 2012).

Who are the potential beneficiaries?

The SK-OPE defines the persons with special educational needs , who are the target group of Priority Axis 3, as: ‘1. Pupils with a special upbringing and educational needs; 2. Pupils coming from a socially disadvantaged environment; 3. Persons with disabilities; 4. Members of the marginalized Roma communities’ (SK-OPE 2007: 63).

← 154 | 155 → However, the SK-OPE and other programmatic documents do not contain any methods for the identification of individuals from marginalized Roma communities (or any other ethnic minority), who are among the target groups. There are no guidelines for ethnic identification and data processing (including rules for data protection) on beneficiaries from the target groups, which could be used for monitoring and evaluation. The general formal rule in Slovakia is ethnic self-identification of individuals. However, within the projects, this principle is not operationalized and project contractors alone report on the number of participants (beneficiaries) from marginalized Roma communities and ethnic minorities in the monitoring reports. They do not have to sustain these numbers with any consent forms or self-identification acts made by beneficiaries . Interestingly, in the case of beneficiaries with disabilities, the contractors must document the belonging of beneficiaries to the eligible target group by written declarations and copies of documents certifying the disability.

The only available data source used in relation to the identification of marginalized Roma communities is the Atlas of Roma Communities (2004). This contains only hard data on all identified Roma communities in Slovak municipalities. The degree of marginalization, segregation or social exclusion of any identified community should be assessed based on available indicators in the Atlas. In policy practice, any of the Roma communities included in the Atlas is considered a marginalized Roma community. Moreover, there is no operational mechanism for linking an individual (project participant/beneficiary) with an identified (marginalized) Roma community. The other three target groups of this priority axis are legally defined and their operational identification is possible.

The calls under focus of this analysis refer to potential beneficiaries that can be grouped into two categories: personnel of providers of educational services (teachers, employees of school authorities, NGOs and others) and clients of the educational services (pupils, students, trainees, parents). While identification of the former is relatively easy, the latter is very problematic, as described above. The first call (SK-OPV-2009/3.1/01-SORO) required that pupils from marginalized Roma communities must be at least 15 per cent of all pupils in the schools where the projects’ activities were to be delivered. Two other calls (SK-OPV-2011/3.1/02-SORO ← 155 | 156 → and SK-OPV-2011/3.1/03-SORO) required that pupils from marginalized Roma communities comprise at least 50 per cent of all beneficiaries of projects. In all three cases, the participation of Roma children from marginalized communities in project activities must be proven only by the sworn statements of the applicants and later, if the application is successful, by declarations of contractors in narrative reports. However, the information provided cannot be objectively verified. Thus, it is hard to assess whether vulnerable children from marginalized Roma communities are actually benefiting from the projects. The remaining call under the KAI 3.1 (SK-OPV-2011/3.1/03-SORO) scrutinized here does not contain any requirements concerning the share of beneficiaries from vulnerable groups. The single call under the KAI 3.2 is reserved for special secondary schools, which are, by definition, attended by disadvantaged students with disabilities.

An additional problem to the very weak monitoring of the participation of disadvantaged beneficiaries in the projects results in improper SK-OPE monitoring and its inadequate and incorrect set of indicators. According to an independent evaluation commissioned by the SK-GPRC, the outputs, results, and impact indicators are incorrectly categorized (for example, most SK-OPE indicators are labeled as result indicators, but in reality they are either input or output indicators) and do not the fulfil criteria of SMART indicators14 (all indicators have low relevance, most are not specific enough).

Designing services

All launched calls include among their eligible activities the preparation and development of teaching materials, innovative methods and forms of teaching, the development and implementation of educational programmes, and teacher training . Additionally, all calls allow the procurement of educational equipment, including computers and software, textbooks, and other school ← 156 | 157 → equipment used within the educational process. This suggests the explicit use of ESF funding to substitute national funding for the day-to-day operation of schools. In the opinion of several people interviewed by the author of this chapter, the possibility of gaining modern and expensive equipment is the main motivation for many schools to apply for ESF grants. Activities aimed at the training of teachers and development of teaching methods, materials and programmes, which the schools should implement according to Slovak law, often serve to reward teachers (the training increases their formal qualifications and consequently their wages) and are often subcontracted through manipulated public procurement to consultancy companies, which help the schools obtain funding (and are supposedly involved in corruption in the commissioning of projects). The perception of ESF projects as primarily opportunities for the renewal and supply of equipment of schools, rather than for innovation s in the education of disadvantaged pupils (as several experts from private consultancies specialized in project development for schools have admitted), is strengthened by the attitudes of many teachers, who do not believe that a more effective education of Roma children from marginalized communities is possible at all.

Alongside eligible activities aimed at training of teachers and development of teaching methods, materials and programmes, and the purchase of equipment and technologies, which are always included, individual calls for applications also contain distinctive eligible activities such as: tutoring, education in Roma language and culture; the further education of persons with disabilities; alternative forms of education, counseling, prevention of social pathology; and the establishment and operation of detached classes of secondary schools.

Some of the above-mentioned activities have proven to be effective tools in education of Roma children (for example, tutoring within several NGO pilot projects of education in the Roma language and culture curriculum has developed since pre-accession PHARE programmes). These are not, however obligatory activities and applicants can decide to pot for other eligible activities , which are less specific for the needs of Roma children. Taking this into account with an ineffective monitoring system (it is not possible that Roma children can actually benefit from the project, and project’s impact on them is not measured), and a biased assessment ← 157 | 158 → and selection of submitted projects, the scrutinized calls for submission of projects do not guarantee that supported projects actually respond to particular problems of education and the inclusion of vulnerable children in the Slovak educational system and provide additional (complementary) support to them. Eligible activities enumerated in the published calls are too extensive and insufficiently specific, and therefore the substitution of national funding is highly probable.

Stumbling blocks in the commissioning cycle

The calls for applications have a standardized design, with a very complicated structure and technical language. Therefore, they are almost unintelligible for persons with no experience in the Structural Funds technical aspects and jargon. A call in itself (for example, SK-OPV-2012/3.1/04-SORO) is fourteen pages long, but encompasses seventeen annexes, including among others the entire SK-OPE with its nine annexes and Management system of Structural Funds and Cohesion Funds with its thirty annexes. Most of the texts of the calls are identical and copy-pasted from the SK-OPE or other programming documents. Approximately only two pages (aggregated) contain specific information on the call: eligible activities, eligible applicants and eligible target groups. These parts are also copy-pasted from the OP documents (SK-OPE and the programme Manual) and are therefore not specific enough, which can lead to ambiguities. The calls do not contain any definition of concepts or requirements related to terms like desegregation , educational inclusion, vulnerable groups, Roma integration/inclusion, anti-discrimination, equal opportunities, equal access or other features which are crucial for inclusion and development policy. SK-OPE documents often use these terms normatively. It seems that these terms are used without any understanding of the concepts behind them.

The formal procedures of commissioning are described in detail in the internal procedure manuals of both the SK-ASFEU, as intermediate body under the Managing Authority (which manages demand-driven projects) and SK-MESRS, as Managing Authority of the SK-OPE , which manages the national projects. The project must be submitted both online via an IT ← 158 | 159 → Monitoring System (SK-ITMS) and in hard copy (the application deadline requires both an online and a hard-copy submission). The SK-ITMS is perceived as user-unfriendly and many applicants fail to input the project properly, with the consequence that the application is not assessed at all. Hard copy submissions also have detailed requirements, which increase the risk of rejection for formal reasons (for example, requirements for the envelopes).

The first step of assessment is a formal check of the application . The SK-ASFEU or SK-MESRS’ staff check the eligibility of applicant, the project’s location in an eligible territory, compliance with the call’s objective, financial limits, time frameworks, the eligibility of the target group, the use of compulsory programme indicators (however, the indicators are not properly set up at the level of the SK-OPE itself), the applicant’s financial contribution, and the completeness of the application (absence of some of the eleven mandatory annexes leads to applications being rejected; others, if missing, can be requested by the SK-ASFEU), and eligibility of the budget items. This phase of the commissioning cycle is exercised by administrative staff of the SK-ASFEU. Project managers within the SK-ASFEU are often not experts in the topic being addressed by the projects (i.e. education of disadvantaged pupils), but rather in administrative procedures, and therefore their ability to assess innovative or non-conventional project’s compliance with formally defined objectives, target groups and, to some extent the eligibility of some budget items, is limited.15

Only project applications successful in the first stage become the subject of expert assessment exercised by internal or external evaluators. The applications are assessed according to a set of criteria approved by SK-OPE ’s monitoring committee and published together with the calls. There are five groups of criteria with different weights: project relevance (22 per cent), methodology of implementation (32 per cent), budget and efficiency (20 per cent), administrative, expert and technical capacity of applicant ← 159 | 160 → (20 per cent) and project sustainability (6 per cent). Finally, the projects are selected based upon scores received within the expert assessment and available financial allocation. The final decision on selected projects is in the hands of the Minister of Education, Science, Research and Sport.

The requirement of approval by OPs’ monitoring committee s (Government of the Slovak Republic – Central Co-ordinating Authority 2013a) of the assessment and selection criteria, leads to lack of flexibility. Consequently, approved assessment criteria do not take into consideration the specificities of calls and refer to concepts not used in the respective calls or in the OP at all. In case of the scrutinized calls of the Priority Axis 3, the partnership principle in project design and implementation is not applied; however, it can be rewarded within the assessment. Similarly, the pilot testing of new approaches at the national/international levels, and the transfer of knowledge from abroad can be rewarded, although such activities are eligible only in one call (SK-OPV-2011/3.1/03-SORO). Or, the assessment includes a question on the principle of equal access and equal opportunities, and the prevention of all forms of discrimination, although these important concepts are not at all developed and operationalized in the Structural Funds’ implementation in Slovakia.

Another important aspect is linked to the issue of integrated approaches to social problems identified in calls. The call SK-OPV-2011/3.1/03-SORO is part of the implementation of a comprehensive approach, so only municipalities with SK-LSKxP approved by SK-GPRC are eligible applicants for this call. Otherwise, the contribution of proposed projects to integrated approaches is not assessed at all (the evaluation criteria do not include questions about whether the proposed project is linked to any strategic development document relevant for the field/territory covered by the project).

Conclusion

Some of the main features of the use of the EU Structural Funds in Slovakia are extreme formalism, rigidity of rules and the lack of a result-oriented logic. More specifically, this chapter finds that the reform policies aimed ← 160 | 161 → at the inclusion of Roma and other disadvantaged groups are implemented through centrally planned and commissioned national projects, which tend to substitute national funding for school operation and modernization, rather than innovative demand-driven projects bringing an added value to the mainstream educational system.

References

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(2012). Strategické hodnotenie Horizontálnej priority Marginalizované rómske komunity [Strategic evaluation of the Horizontal Priority Marginalized Roma Communities]. Bratislava. <http://www.minv.sk/?hodnotenie_MRKandsubor=161016>.

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← 161 | 162 → Ernst and Young. (2010). Evaluation of Effectiveness of the Management System implemented in the Operational Programme Education. Final Evaluation Report. Bratislava: Ministry of Education of the Slovak Republic.

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Grambičková, M., Havlíček, R. and Nemcová, R. (2010). Správa o dodržiavaní opatrení proti netransparentnosti, zneužívaniu a konfliktu záujmov v rokoch 2009 a 2010 [Report on observation of measures against non-transparency, misuse and conflict of interest in years 2009 and 2010]. Bratislava: Cepa – Priatelia Zeme. <http://www.eufondy.org/pdf/Sprava_protikorupcne%20opatrenia.pdf>.

Grambličková, M., Mojžiš, M. and Zamkovský J. (2011). Uplatňovanie princípu partnerstva: účasť mimovládnych organizácií na kontrole fondov EÚ v programovacom období 2007–13 [Application of the partnership principle: Participation of NGOs in acting as watchdog over the EU funds in theprogramming period 2007–13]. Bratislava: Cepa – Priatelia Zeme. <http://www.eufondy.org/pdf/Sprava_ucast%20MVO.pdf>.

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Košťál, C. and Plesch, M. (N.d.). Mimovládne neziskové organizácie na Slovensku a štrukturálne fondy EÚ [Non-governmental, non-for-profit organizations in Slovakia and EU Structural Funds]. Bratislava: Slovak Governance Institute. <http://www.governance.sk/assets/files/publikacie/MNO_SF_final2.doc>.

← 162 | 163 → Krčmárik, R. (2012). Aké školstvo chceme? Každá vláda iné [What educational system we want? Each government is different]. Pravda, 22 Oct. <http://spravy.pravda.sk/domace/clanok/251458-ake-skolstvo-chceme-kazda-vlada-ine/>.

Mindová, L. (2012). Skúsenosti a problémy slovenských obcí pri využívaní prostriedkov fondov EÚ. [Experiences and problems of Slovak municipalities in use of EU funds]. Paper presented at the International Conference FIN STAR NET 2012, University of Economics in Bratislava. <http://www.derivat.sk/files/fsn%202012/Mindova.pdf>.

Ministry of Education of the Slovak Republic. (2004). Koncepcia integrovaného vzdelávania rómskych detí a mládeže, vrátane rozvoja stredoškolského a vysokoškolského vzdelávania [Concept of Integrated Education of Roma Children and Youth including Development of Secondary and Higher Education]. Bratislava: Ministry of Education of the Slovak Republic.

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Ministry of Education of the Slovak Republic. (2008). Návrh koncepcie výchovy a vzdelávania rómskych detí a žiakov vrátane rozvoja stredoškolského a vysokoškolského vzdelávania [Draft Concept and Education of Roma Children and Pupils, including Development of Secondary and Higher Education]. Bratislava: Ministry of Education of the Slovak Republic.

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1Other horizontal p riorities are: Equal Opportunities, Sustainable Development, and Information Society.

2The document, however, declares problems with the collection and processing of ethnically disaggregated data and subsequent problems with targeting, monitoring and evaluation of interventions focusing Roma . Instead of the missing ethnic data, it uses a proxy category of children from socially disadvantaged environments (which do not include all Roma children and also include disadvantaged non-Roma children).

3Minutes from the 5th regular meeting of the Monitoring Committee for the Operational programme Education. June 6, 2011. Available at: <http://www.minedu.sk/data/att/2570.pdf>.

4By-laws of the SK-MESRS.

5Slovak Government Resolution no. 832/2006 (October 8, 2006).

6However, information on one cancelled call is missing and neither the SK-MESRS nor SK-ASFEU provided the text of the respective call for applications, despite several requests.

7The calls for submission of national projects are formally issued and published, and they specify the entity that they address and who is authorized to submit the proposal. Both calls and proposals are usually prepared in close co-operation between the Managing Authority and the entity, which would later be eligible to submit the national project.

8In the case of the scrutinized KAIs, a typical project contains the elaboration of a new educational programme in a given school and the purchase of new teaching equipment.

9The so-called normative funding includes resources for the wages of school employees, the educational process, heating, operational costs and teacher training . The funding depends on the type of school, weather conditions in the area where the school is located, and the qualifications of teachers. In 2013, the funding ranges from EUR 768.48 (for centers of practical education in mildest climatic conditions and with the lowest qualification of teachers) up to EUR 4,448.04 (for centers in harshest climatic conditions and with better-qualified staff) per pupil and year. (Source: <http://www.minedu.sk/data/att/4373.pdf>).

10Churches recognized by the State receive yearly contributions for the remuneration of priests and operational costs of church administration (head-quarters) and they are exempt from several tax obligations. Additionally, the state restituted large properties to churches after the fall of the communist regime.

11See: National Institute for Education, <http://www.educj.sk/buxus/generate_page.php?page_id=168>.

12It is also the case of better-off schools where, due to the poor economic situation, pupils’ parents cannot afford to support the school through the otherwise common practice of diverse semi-obligatory/semi-voluntary contributions approved by parents’ council.

13This leads to high numbers of audit findings resulting in ineligible expenditures at project level and financial irregularities at the OP level (leading to financial corrections applied by the EC at the national level).

14Specific, Measurable, Available, Relevant, Timebound.

15This risk is not so high in case of national projects, as they are developed within the SK-MESRS with participation of specialized departments and before the official submission, all ministries’ departments comment it; the national project’s assessment is rather formal.