COMMISSION STAFF WORKING PAPER EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT
Date: 2011-11-23
Institutions: European Commission
Subjects: EU programme, continuing education, cooperation in the field of education, sport, university, youth policy

EUROPEAN COMMISSION 

Brussels, 23.11.2011 
SEC(2011) 1403 final 

COMMISSION STAFF WORKING PAPER 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying document to the  

Proposal for a  

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

establishing a single Education, Training, Youth and Sport Programme for the period 
2014-2020 

SUMMARY AND INTEGRATED CONCLUSIONS 

{COM(2011) 788} 
{SEC(2011) 1402} 

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Lead  Service:  DG  Education  and  Culture  (EAC)  supported  by  the  Education,  Audiovisual 
and Culture Executive Agency (EACEA) 

Disclaimer: This report commits only the Commission's services involved in its preparation 
and does not prejudge the final form of any decision to be taken by the Commission. 

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TABLE OF CONTENTS 

Introduction ................................................................................................................................ 4 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

Problem description ..................................................................................................... 4 

Justification of EU intervention ................................................................................... 6 

Objectives of the future intervention............................................................................ 7 

Options ......................................................................................................................... 9 

Main impacts of the options....................................................................................... 12 

Comparison of options ............................................................................................... 15 

Description of the preferred option ............................................................................ 21 

Monitoring and evaluation ......................................................................................... 24 

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INTRODUCTION 

This  document  provides  a  summary  of  the  four  impact  assessments  covering  Education,  Training, 
Youth and Sport. 

The four impact assessments examine the operations of three existing programmes and, in the case of 
sport, preparatory actions voted by the Budgetary Authority. Overall, the four following options have 
been examined into depth: Discontinuing the existing actions or programmes; continuing them in their 
current  form;  strengthening  the  objectives  of  the  current  programmes;  and  a  single  Programme  for 
Education, Training, Youth and Sport to strengthen objectives and impacts through concentration and 
a streamlined architecture. 

The preferred option identified in each of the four IAs is the merger into a single programme, which is 
in line with the Decision of the Commission on the Multiannual Financial Framework adopted on 29th 
June  2011.  This  preferred  option  would  be  the  most  coherent  and  cost-effective,  for  the  main 
following reasons: 

1. 

2. 

3. 

4. 

5. 

It responds to the need for increased EU investment in Education and Training in these times 
of  financial  and  economic  crises,  as  a  growing  economy  depends  on  the  supply  of  highly 
skilled workers and on the mobilisation of the skills and competences of the unemployed; 

It focuses on and develops those actions identified in the current programmes as having the 
highest European added value and the strongest multiplier effects, leading to tangible impact 
on  European  education  and  training  systems  and  thus  considerably  improved  returns  on 
investment;  

The concentration of efforts within the new streamlined programme architecture will allow 
for  greater  synergies  among  existing  programmes  and  across  different  educational  sectors, 
thus  bolstering  the  lifelong  learning  approach  to  education,  increasing  coherence  and 
improving  access  to  potential  beneficiaries  through  a  streamlined  set  of  key  transversal 
actions; 

Beyond  cooperation  between  education  institutions  themselves,  it  puts  a  stronger  focus  on 
the  crucial  role  of  education  and  human  capital  for  innovation  by  promoting  education-
business  partnerships,  targeting  excellence  in  teaching  and  learning,  employability  and 
entrepreneurship; 

Finally,  it  entails  a  rationalisation  and  simplification  of  delivery  and  management 
procedures, offering considerable potential for reducing implementation costs - by up to 40% 
as compared to the sum of the implementation costs of the current programmes (i.e. Lifelong 
Learning, Youth in Action and the cooperation programmes in Higher Education with non-
EU countries.) 

This summary brings together the key elements of the four IAs; full details are provided in 
the individual impact assessments. 

1. 

PROBLEM DESCRIPTION 

Without  substantial  investment  in  human  capital,  education  and  in  the  talent  of  European  citizens, 
none  of  the  Europe  2020  objectives  and  headline  targets  will  be  met.  The  current  economic  climate 
and increasing global competition for highly skilled people, value-creation and growth require radical 
and widespread reform of education and training systems focused on competences. 

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A  report1on  sources  of  growth  presented  by  the  Polish  Presidency  of  the  Union  recommends  an 
increase  of  the  funding  for  programmes  supporting  mobility  of  students,  young  researchers  and 
employees (e.g. Erasmus, Marie Curie), stating that raising the ratio of people with higher education to 
40% would contribute to increasing GDP per capita in the EU by 4%. 

The  experience  of  the  current  programmes  demonstrates  that  EU  budget  support  can  contribute 
significantly to improving the preparedness of EU citizens for the labour market and professional life, 
and  to  tackling  the  key  problems  of  education  and  training  systems:  high  levels  of  early  school 
leaving,  low  achievement  in  basic  skills  and  key  competences,  insufficient  participation  in  higher 
education  and  vocational  training,  insufficient  participation  of  adults  in  education  and  training, 
insufficient  opportunities  for  the  training  of  education  staff,  and  low  levels  of  entrepreneurship  and 
creativity among young people. EU support can also help reduce inequality in the provision and access 
to learning, notably vis-à-vis people with disadvantaged backgrounds, people with special needs, and 
gender inequalities in E&T. Similarly, EU support can contribute to the development of social capital 
among  youth,  to  the  empowerment  of  young  people  and  to  their  ability  to  participate  actively  in 
society in line with the new Treaty. 

Taking  into  account  the  lessons  from  the  current  programmes,  the  competences  of  the  EU  and  the 
strengths and limits of intervention through EU financial instruments, as well as the views expressed 
in the consultation of stakeholders, EU support to education and training, youth and sport in the 
2014-2020 MFF should focus primarily on a series of key issues and problems:  

– 

The need to develop transnational mobility and the European area of education and training: 

The system for recognition and transferability of qualifications and competences, needed for 
building-up  the  European  area  in  E&T,  is  not  yet  sufficiently  developed.  Participation  in 
E&T programme’s mobility actions is not fully linked to the E&T policy priorities as defined 
in  the  Europe  2020  Strategy  and  in  the  ET  2020  Education  and  Training  strategy-  for 
example to the need to contribute to the adoption of the tools for recognition and transfer of 
learning  outcomes.  Similarly,  there  is  an  insufficient  link  between  mobility  and  the 
institutional framework e.g. as part of a wider internationalisation effort. And there are other 
obstacles  to  learning  mobility,  in  particular  regarding  languages.  Moreover,  in  the  area  of 
non-formal  learning  and  youth  work,  there  is  a  fragmented  and  uneven  provision  of 
opportunities for young people. 

– 

The need to  promote  cooperation between institutions, and strengthen Europe’s position in 
the global competition for excellence and equity in education and training: 

The  development  of  joint  transnational  curricula  for  E&T  institutions  is  not  sufficiently 
advanced. The EU as a global study destination is not attractive enough and is losing ground 
to other industrialised and emerging countries. There is a limited recognition of non-formal 
learning  and  youth  work  activities  and  outcomes  and  a  limited  sharing  of  practices  in  this 
area.  Pedagogical  innovation  and  exchange  of  best  practices,  including  the  exploitation  of 
ideas coming from the EU RTD programmes, is not sufficient. Business and research are not 
well linked to the E&T area to ensure their mutual contribution to the definition of education 
policy and tools 

– 

The need to support the modernisation process of non-EU universities: 

The EU needs its partners to be productive, healthy economies, both as sources of innovation 
but also as markets for European goods and services. Poor quality of their Higher Education 
systems limits their capacity for growth and cooperation with the EU. 

1 

"Towards a European consensus on growth", October 2011 

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– 

– 

– 

– 

The need for evidence-based analysis to support the reform and modernisation of education 
systems as well as youth work development: 

The  collection  of  data,  their  analysis  and  their  use  – including  within  the  Open  Method  of 
coordination  and  the  governance  of  Europe  2020  –  for  evidence-based  policy  making  and 
reform  are  insufficient.  The  provision  of  policy  tools  and  peer  comparison/pressure  for 
programming  smart  investments  in  the  areas  of  education  and  training  as  well  as  youth  is 
insufficient. 

The need to reduce inequality in the provision and access to learning opportunities, relating 
to gender, people with disadvantaged background and with special needs. 

The need to ensure that young people participate actively and constructively in society and in 
democratic life.  

The  need  to  increase  awareness  and  knowledge-sharing  on  how  to  address  sport-related 
problems,  mainly  at  local  and  grassroots  level,  notably  in  the  fields  of  good  governance, 
health-enhancing  physical  activity,  social  inclusion,  violence  and  intolerance,  dual  careers 
and doping 

While  these  problems  refer  to  the  scope  and  content  of  EU  support,  it  is  also  essential  to  tackle,  in 
parallel,  the  key  issue  of  European  added  value,  management  and  simplification.  Even  if  the 
results  of  the  interim  evaluations  of  current  programmes,  as  well  as  the  online  consultations  of 
stakeholders, reflect relatively high levels of satisfaction, there is considerable room for improvement, 
particularly in light of the current difficult budget constraints.  

Current  programmes  in  the  field  of  education,  training  and  youth  are  too  complex,  with  too  many 
objectives  and  actions  which  limit  the  systemic  impact  and  thus  the  European  added  value  and 
potential  investment  value  of  EU  interventions.  By  way  of  illustration,  the  Lifelong  Learning 
Programme (LLP) has 6 sub-programmes, more than 50 objectives and over 60 actions. The Youth in 
Action  Programme  focuses  on  the  mobility  and  (non-formal)  learning  of  young  people,  while 
approximately  80%  of  the  LLP’s  funding  also  benefits  youth.  Some  actions  simply  lack  the  critical 
mass  required  for  long-lasting  impact.  International  cooperation  in  higher  education  is  also 
characterized by the fragmentation between different EU instruments implementing similar objectives 
and actions. 

This  fragmentation  of  current  EU  support  hampers  the  exploitation  of  various  policy-based  and 
operational synergies and the elimination of overlaps, both across different educational sectors from a 
lifelong  learning  perspective,  between  the  Education,  Training  and  Youth  Sectors  themselves  and 
between the latter and other vital policy fields and funding sources such as Employment, Research and 
Innovation  and  the  Structural  Funds.  It  also  unnecessarily  increases  complexity  and  administrative 
burden  for  stakeholders  and  EU  bodies  alike,  while  limiting  the  scope  for  simplification  and 
economies of scale.  

2. 

JUSTIFICATION OF EU INTERVENTION 

EU action in Education, Training, Youth and Sport has its legal base in Articles 165 and 166 of the 
Treaty on the Functioning of the European Union. 

Without  prejudice  to  the  subsidiarity  principle,  EU  intervention  should  aim  to  complement  Member 
States'  actions  by  supporting  policy  reform  and  modernisation  and  by  helping  to  deliver  systemic 
impact  under  the  agreed  objectives  of  the  Europe  2020  and  ET  2020  strategies.  In  this  respect,  the 
European  added  value  of  the  new  EU  programme  supporting  education,  training,  youth  (as  well  as 
sport) rests on four main aspects: 

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– 

– 

– 

The  transnational  and  innovative  character  of  its  activities  and  the  outputs  it  helps 
develop:  The  existing  actions  of  Member  States  remain  at  national  level.  The  EU  added 
value  lies  in  that  the  Community  budget  promotes  and  supports  individual  mobility, 
cooperation, collaboration  and  partnerships  across  participating  countries  and with  non  EU 
partner countries (notably for higher education cooperation and mobility), to enable learning 
and  transfer  of  knowledge  and  innovation  between  education  and  training  and  youth 
stakeholders, institutions, organisations and systems. 

The way it supports cooperation between Member States, particulary through the Open 
Method of Coordination. EU supports the priorities outlined in EU strategies, to help create a 
consensus  among  the  various  stakeholders  on  the  role  of  education,  training  and  youth 
support  for  economic  and  social  development,  and  to  contribute  to  improvements  in  the 
knowledge  of  policy  makers  and  education  and  training  specialists  regarding  international 
good practices, including in the field of sports. With the aim to influence systemic changes in 
the  field  of  education  and  training,  the  programme  should  act  as  a  driving  force  for  the 
implementation of general European tools for mobility and recognition of qualifications2.  

The  way  it  complements  national,  international  and  EU  programmes:  The  specific 
added value of EU support, as compared with other (national and international) programmes, 
lies also in the broader geographical coverage of its activites and in the fact that it promotes 
consistent  cooperation  in  the  fields  of  education,  training,  youth  and  sports,  as  well  as 
mobility  and  the  internationalisation  of  education  and  training.  The  initiatives  of  other  EU 
programmes,  mainly  the  EU  structural  funds,  in  the  area  of  education  and  training,  are 
different.  Activities  of  the  European  Social  Fund  are  generally  linked  to  the  provision  of 
assistance with a focus on jobs and the labour market integration of participants, whereas the 
future programme will provide opportunities for mobility, and for the development of new 
projects, ideas and techniques - which can subsequently be supported and mainstreamed by 
the ESF. The European Regional Development Fund can invest in educational infrastructure 
–  which  help  to  strengthen  communities  and  improve  access.  The  Socio-economic  science 
and humanities research programme (DG RTD – FP7) play an important role in supporting 
educational  research,  by  funding  research  projects  on  lifelong  learning,  skills  needs, 
education,  youth  and  social  inclusion,  involving  the  whole  research  community  in  Europe 
and beyond. There is thus at the same time a clear-cut distinction and scope for synergies and 
cooperation amongst these programmes. 

– 

The way it contributes to achieving systemic impact: An EU-wide tool can achieve strong 
systemic impact, notably by acting as a laboratory to test new approaches, which can inspire 
national/regional schemes or help them develop a transnational dimension. 

EU intervention should conform to the principle of proportionality established by the Treaty 
as it should not go beyond what is necessary to achieve the objectives pursued. It must be 
implemented within member states' existing policy frameworks. 

3. 

OBJECTIVES OF THE FUTURE INTERVENTION 

The problems identified in the different IA reports highlight that the European Union and its Member 
states  have  set  out  clear  common  objectives  and  policy processes  in  the  field of  education,  training, 
youth  and  sports:  The  Education  and  Training  strategic  framework  2020  (ET2020),  the  renewed 
framework  for  European  Cooperation  in  the  Youth  field  (2010-2018),  and  the 2011  Communication 
"Developing the European Dimension in Sport". These policy frameworks are fully relevant also for 

2 

For example the Europass, Youthpass, European Qualifications Framework (EQF) or European Credit 
System for vocational education and training (ECVET). 

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the 2014-2020 MFF; therefore, EU budget support in these areas should have as the overarching aim 
to  contribute  to  these  EU  strategies;  the  main  associated  impact  indicators  should  be  the  relevant 
headline targets of Europe 2020. 

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General objectives 

The overall general objective of the programme is to contribute to the objectives of the Europe 2020 
strategy  and  of  the  Education  and  Training  strategic  framework  2020  (ET2020),  including  the 
corresponding  targets,  to  the  renewed  framework  for  European  Cooperation  in  Youth  field  (2010-
2018), to the sustainable development of third countries in the field of higher education and to develop 
the European dimension in sport. 

In  the  individual  Impact  Assessments,  the  following  general  objectives  have  been  set  for  future 
support: 

Lifelong Learning/education and training: To empower individuals of all ages and social backgrounds 
by  contributing  to  the  development  of  quality  education  and  training  systems,  as  part  of  the  Europe 
2020 strategy of smart, inclusive and sustainable growth and of the ET 2020 strategic framework. 

International cooperation in Higher Education: To strengthen openness, innovation and excellence in 
education,  with  a  view  to  producing  long-lasting  systemic  impact,  building  capacity  and  supporting 
reform of higher education institutions in the EU and in partner countries. 

Youth non-formal education: To contribute to young people's employability, active participation in 
society and sense of belonging to the EU, as a means to foster human and social capital development 
and promote growth and social cohesion in support to the Europe 2020 Strategy and the EU Youth 
Strategy. 

Sport: To develop the European dimension in sport. 

Related specific and operational objectives are developed in each IA report, with indicators at different 
levels.  For  illustrative  purpose  a  summary  of  indicators  can  be  found  in  Annex  to  the  Impact 
Assessment on Lifelong Learning. 

4. 

OPTIONS 

The research carried out in support of the impact assessments has enabled identifying "what works and 
what  doesn't  work"  at  the  baseline.  The  results  have  been  applied  in  the  process  of  defining  the 
preferred option, and thus guided the distribution of funding between the different actions covered on 
the basis of the Commission's proposal for a Multiannual Financial Framework 2014 – 2020; 

For  the  IA  reports  on  the  current  LLP  and  Youth  programmes,  the  four  options  described  hereafter 
have been considered. The two IA reports for International Cooperation in Higher Education and Sport 
take  into  account  the  structure  of  the  two  other  IA  reports,  and  in  particular  the  objectives  and 
streamlined  architecture  of  their  preferred  option  (i.e.  a  single  programme  for  education,  training, 
youth and sports). 

Option 3 and to a higher extent Option 4 offer the possibility of achieving a significant critical mass of 
beneficiaries  and  systemic  impact  through  a  discontinuation  of  current  actions  with  insufficient  EU 
added  value.  Option  4  will  in  addition  offer  a  higher  potential  impact  through  the  streamlining  into 
three key actions and exploring in full the synergies between the education sectors and youth. 

Certain  policy  choices  on  content  were  explored,  but  were  rejected  as  they  contradicted  research 
findings  and/or  would  not  be  in  line  with  Member  States  and  EU  priorities.  Furthermore,  options 
based on other policy instruments could be theoretically envisaged. However, such options would fall 
outside the mandate for EU action in the areas concerned, and were thus discarded at an early stage. 

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Policy option 1: Status quo (baseline option) 

The  current  programmes  and  sub-programmes  would  broadly  retain  their  current,  independent 
objectives,  actions,  structures  and  management  systems,  as  well  as  their  current  budget  allocations. 
Therefore, these programmes would essentially be the same as the ongoing: 

• 

• 

• 

Lifelong Learning Programme 

Erasmus  Mundus  Programme  and  other  external  cooperation  programmes  in  Higher 
Education 

Youth in Action Programme 

There would be no programme specifically devoted to Sport.  

Policy option 2: ‘No action’ 

Under  this  option  there  would  be  no  EU  spending  programmes  in  the  areas  concerned  after  2013. 
Policy coordination and mutual learning processes (i.e. the Open Method of Coordination in Education 
and  Youth  policies,  policy  coordination  in  Sport)  would  continue.  The  EU  would  continue  its 
obligations under Article 165 and Article 166 of the Treaty, which would necessitate some expenditure 
on the provision of information and analysis and human resources in order to fulfil its mandate. Some 
sport-related projects might be funded within other EU programmes and related instruments, such as 
Public  Health  or  via  the  ESF.  Otherwise,  spending  on  education,  training  and  non-formal  learning 
mobility,  youth  work  and  transnational  cooperation  activities  would  be  entirely  reliant  on  non-EU 
resources (in particular, from the Member States). 

Policy option 3: Strengthening the objectives of the current programmes 

Building  on  the  strengths  and  eliminating  the  weaknesses  of  the  current  programmes,  this  option 
would consist of refocusing the objectives of the existing separate programmes to better support the 
Europe 2020 strategic framework and the new EU political context relative to Education, Training and 
Youth.  The  administrative  structures  and  the  architecture  of  the  different  (sub)  programmes  of 
education,  training  and  youth  would  not  be  altered  for  the  sake  of  continuity.  A  small  Sport 
Programme with a modest budget would be created separately. The changes to the current programmes 
would be led by the following guiding principles: 

(a) 

(b) 

Focussing  each  separate  programme  on  activities  with  the  highest  added  value,  where  a 
critical  mass  can  be  mobilized,  and  on  strong  conditionality/incentives,  to  achieve  the 
Union’s policy objectives targeting systemic change; 

Simplifying and rationalising the actions supported by each programme, while respecting the 
separation  of  the  programmes  by  categories  of  beneficiaries  with  different  operational 
objectives, activities, etc. 

A number of actions currently funded by the programmes would be discontinued, i.e. those that do not 
have sufficient links to policy priorities, potentially overlap with other EU financial instruments, have 
high  management  costs,  or  present  insufficient  EU  value  added.  More  specifically,  the  programmes 
would aim at: 

• 

Improving spending related to mobility, including:  

o 

"multiplier" mobility (staff, teachers, youth workers),  

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o 

o 

focus on mobility with strong systemic impact, in particular higher education 
students,  

traineeships  in  enterprises  to  support  the  transition  between  education  and 
work and foster entrepreneurship; 

•  Supporting  mutual  learning  guided  by  excellence  and  modernisation  of  systems  both  in  the  EU 

and its partner countries, including:  

o 

o 

o 

o 

o 

peer learning activities,  

exchange of good practices,  

development of joint projects and innovative methods,  

stronger cooperation with the world of work,  

incentives 
entrepreneurship; 

to 

reward  excellence 

in  education 

for 

innovation  and 

•  Supporting OMC policy networks with Member States and to the joint testing of innovative policy 

approaches, e.g. on  

o 

o 

o 

o 

o 

development  of  EU  tools  for  transparency/  transferability/recognition  of 
qualifications,  

analysis  directly  linked  to  the  Europe  2020  and  Annual  Growth  Survey 
priorities, as well as the Bologna and Copenhagen processes, 

policy exchange between education authorities and other stakeholders on the 
modernisation agenda, 

policy exchange between youth authorities and other stakeholders within the 
European framework of cooperation in the youth field, 

policy dialogue with third countries, focusing on strategic partners. 

A  separate  Sport  programme  would  facilitate  the  generation,  exchange  and  dissemination  of 
knowledge  and  good  practices  in  the  fields  identified,  and  the  awareness-raising  of  key  issues.  It 
would  also  build  the  evidence  base  for  policy  making,  and  provide  capacity  building  for  sport 
organisations. 

Policy  option  4:  A  single  Programme  for  education,  training,  youth  and  sports:  strengthening 
objectives and impact through concentration and streamlined architecture.  

This option takes the rationale of Option 3 one step further, by exploiting the scope for concentration 
and simplification within existing programmes, but also across the various existing programmes which 
share similar broad objectives, types of action and delivery mechanisms. This option would therefore 
increase  the  potential  for  improvements  contained  in  Option  3  as  concerns  the  EU  added  value  and 
systemic impact of actions, by integrating all Education, Training and Youth activities into a single 
programme  The  main  rationale  for  this  is  that  the  types  of  actions  presently  supported  within  each 
programme and by separate sub-programmes can be readily harmonised and streamlined since they are 
similar in nature, and that simplification of actions and delivery can increase both the impact and the 
cost-effectiveness of EU support.  

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The Programme would include a separate chapter and budget for Sport activities.. This would avoid a 
proliferation of individual legal bases – in line with the overall MFF approach towards streamlining 
and simplification – whilst still exploiting both the common general objectives and the potential for 
economies of scale and harmonisation of administrative and management procedures. 

The  single  programme  would  inherently  deepen  the  scope  for  systemic  impact  and  returns  on 
investment  through  a  concentration  of  activities  with  European  added  value  and  through  increased 
synergies and reduced duplications across sectors, policies and . The architecture of, and access to, the 
programme  will  be  greatly  simplified  and  delivered  through  three  types  of  actions:  mobility, 
cooperation and policy reform –oriented activities. It would be improved mainly by: 

(a) 

(b) 

(c) 

As illustrated for Option 3, concentrating on activities with the highest added value, where a 
critical  mass  can  be  mobilized,  and  on  strong  conditionality/incentives  to  achieve  the 
Union’s policy objectives targeting systemic change.  

Identifying  those  areas  of  activity  where  the  programme  has  a  competitive  advantage  as 
compared to other EU instruments or initiatives, and identifying and exploiting already in the 
design  phase  the  opportunities  for  synergies  and  complementarities  between  different 
sectors, policy fields and other funding sources. 

Reducing radically the complexity of the architecture of the programmes, and identifying the 
scope for economies of scale and for simplifying the programme management and increasing 
the programme user-friendliness.  

Regarding  the  delivery  mechanism,  the  programme  would  build  on  the  present  strengths  of  the 
National Agency system, as specified under section 6 of this document. 

This policy option would aim at providing more flexibility and incentives to promote EU added value, 
so that budget allocation between actions, beneficiaries and countries can take better account of actual 
quantitative and qualitative performance. It would also allow for making wider use of research results 
and  transferring  mature  innovations/best  practices  that  are  ready  for  mainstreaming  at  lower  level 
programming. 

The  sport  actions  within  the  programme  would  benefit  from  the  existing  delivery  mechanisms, 
allowing economies of scale (with respect to creating a new, separate programme alongside the current 
ones as in Option 3) and the use of good practices.  

5. 

MAIN IMPACTS OF THE OPTIONS 

Because of the nature of the initiative, the environmental impacts are deemed negligible for all options 
explored, and have therefore not been examined into further depth. 

Option 1: Status Quo 

Social Impacts 

The programmes would continue being a driving force for the implementation of European tools for 
mobility,  support  to  youth  work  development  and  for  the  internationalisation  of  Education  and 
Training. They would also allow for a continued contribution to policy processes such as the Bologna 
and the Copenhagen process, the European framework of cooperation in the youth field and, to a lesser 
extent, the OMC. 

However, only a relatively limited number of participants from disadvantaged socio-economic groups 
would be reached, as the costs of mobility would prevent their participation in mobility experiences. 

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Economic Impacts 

The programmes would improve to a limited extent the functioning of the single market by increasing 
the number of people willing to work abroad, and it would facilitate the transparency of qualifications. 
Thus there would be a mid- and long-term positive impact on competitiveness at the European level, 
thanks  to  the  improvement  of  the  skills  levels  of  the  population  and  to  a  better  allocation  of  human 
capital in Europe through mobility. 

Fundamental Rights 

The programmes would have positive impacts in relation to a number of fundamental rights, such as 
the right to education and right to freedom of movement. Mobility flows would also consider linguistic 
diversity, as countries with less widely spoken languages are involved in mobility flows. 

Option 2: No action 

Social Impacts 

Future  developments  in  the  area  of  mobility,  cooperation  and  policy  development  would  be  much 
more  fragmented  and  bilateral,  would  take  place  at  a  smaller  scale  and  would  not  develop  as 
consistently across EU Member States.  

It  would  result  in  missed  opportunities  in  terms  of  development  of  European  citizenship  and  the 
understanding  of  European  integration.  As  some  of  the  most  popular  EU  actions  in  the  eyes  of  the 
citizens would disappear, this would create a negative image of the Union. 

Economic Impacts 

It  could  aggravate  future  shortages  of  labour-market  relevant  skills  such  as  linguistic  skills, 
communication skills and technical skills resulting in loss of productivity and competitiveness. 

The  discontinuation  of  the  programmes  would  not  contribute  to  the  creation  of  the  necessary 
conditions for European citizens to actively enjoy the right to move and work across the EU. 

Fundamental Rights 

It  would  not  contribute  to  the  creation  of  the  necessary  conditions  for  European  citizens  to  actively 
enjoy the right to move and work across the EU. Mobility flows would respect linguistic diversity to a 
lower extent, as countries with less widely spoken languages would be less involved in mobility flows. 

Policy option 3: Strengthening the current programmes 

Social Impacts 

The social impacts would increase in relation to the most significant problems faced by Europe in its 
skills development. In terms of social cohesion, it is likely that the concentration of activities would 
favour  those  countries  and  groups  that  are  worse  off  in  terms  of  skills  development,  in  particular 
through the new emphasis on basic skills.  

A more significant impact would be achieved on a smaller set of priorities that count the most, such as 
youth employability. This would increase the relevance of the programmes' impact in relation to wider 
policy developments and benchmarks. Greater partnership work with other organisations and sectors 
outside education – such as the productive and voluntary sector - would take place.  

This  option  is  expected  to  result  in  the  improvement  of  the  skills  supply  in  the  short-term  through 
mobility and in the medium term through international learning at the practitioner and policy level. It 

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would  enhance  the  perception  of  beneficiaries  of  being  European  citizens  and  empower  them  to 
contribute to economic and social life. A focus on hard-to-reach and disadvantaged groups could also 
favour  the  development  of  European  citizenship  among  those  participants  who  are  traditionally  not 
engaging in any transnational activity. Furthermore, enhanced cooperation in promoting participation 
in sport would lead to potential impacts e.g. in the field of health. 

Economic Impacts 

Economic impacts are likely to be positive as the future programme would tackle, in a more effective 
way, problems which generate considerable costs in terms of unemployment benefits and active labour 
market  measures,  as  well  as  hidden  costs  in  terms  of  loss  of  productivity.  Even  with  a  moderate 
contribution  to  the  reduction  of  these  problems,  the  future  programme  would  ensure  significant 
savings and generate growth in the long-term. By improving its skills supply, Europe would become a 
more  attractive  business  location,  which  has  positive  consequences  for  the  smart  growth  of  the 
European economy. 

Fundamental Rights 

Compared  to  Option  1  (Status  Quo),  this  option  would  provide  a  further  positive  impact  on 
fundamental rights, as it would put greater emphasis on ensuring the right to education of all in the EU 
– in particular for disadvantaged groups. 

Policy  option  4:  A  single  Programme  for  education,  training,  youth  and  sports:  strengthening 
impact through concentration of objectives and a streamlined architecture.  

Social Impacts 

The social impacts listed for Option 3 also apply for this option, but on a higher level, given that the 
fragmentation of programmes and actions limits the scope for increasing the impact, simplification and 
effectiveness of current programmes. Furthermore, the integration and considerable simplification of 
the  programme  would  generate  a  positive  impact  in  terms  of  administrative  expenditure  and 
accessibility: more individuals, education and training institutions and youth organisations could be in 
a position to apply for funding, with the establishment of mobility ‘one-stop-shops’ (integrated NAs). 
The  new  structure  of  the  programme  would  also  facilitate  the  development  of  activities  across 
different  education  sectors  and  thus  help  promote  the  development  of  lifelong  learning  in  a  more 
efficient way. 

Similarly, a merger of the current Erasmus-type of activities with the similar ones currently carried out 
through  separate  cooperation  programmes  in  higher  education  with  non-EU  partner  countries 
(Erasmus Mundus, Tempus, etc) would imply a greater coherence of cooperation with such countries, 
a strong incentive towards the internationalisation of higher education, and a significant simplification 
of  management  and  procedures.  Activities  would  benefit  from  the  merger  with  Youth  in  Action  by 
fostering  the  interaction  with  other  actors  from  the  non-formal  education  sector  and  would  aim  at 
better recognition by education and training stakeholders and employers of the knowledge, skills and 
competence acquired in non-formal contexts. 

Economic Impacts 

The same as for Option 3, but on a higher scale, as in the case of social impacts. On top of that, the 
integration  of  different  programmes  would  involve  significant  economies  of  scale,  compared  to  the 
current separate management structures of the LLP, Erasmus Mundus and Youth in Action, allowing 
for more targeted and impactful spending in areas with strong European added value. 

Fundamental Rights 

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The same as for Option 3. 

6. 

COMPARISON OF OPTIONS 

The following table provides a comparison of the options identified. 

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Legend: 

Comparison of options 

Comparison to baseline scenario 

Positive 

slightly positive 

neutral 

slightly negative 

negative 

++ 

+ 

0 

- 

-- 

Criteria 

Option 1  

Option 2 

Option 3 

Explanation of given ratings: 

Status quo 

No action 

Policy option 3: 
Strengthening 
the current 
programmes 

Policy option 4: 
A single 
Programme for 
education, 
training, youth 
and sports  

Effectiveness in terms of achieving specific objectives: 

1.  To  empower  individuals  of  all 
ages  and  social  backgrounds  by 
contributing  to  the  development  of 
quality 
training 
systems,  as  part  of  the  Europe  2020 
inclusive  and 
strategy  of  smart, 
sustainable  growth  and  of  the  ET 
2020 strategic framework. 

education 

and 

0 

-- 

+ 

++ 

Option  1:  Only  a  limited  number  of  participants  from  disadvantaged  groups  would  be 
reached. Certain countries would continue having a low participation in the initiative. The 
current fragmentation of EU action and lack of focus and critical mass would persist. 

Option  2:  The  identified  problems  would  not  be  addressed,  causing  fragmentation  and 
back-sliding of EU competitiveness. 

Option 3: The increased focus on skills and added value would contribute to increasing 
competitiveness of the EU. The increased volume would allow mobilising a critical mass 
for achieving the desired impacts. The problems identified at the baseline would be well 
addressed,  but  the  potentials  of  synergies  between  the  different,  separate  programmes 
would remain unexploited. 

Option  4:  As  for  Option  3.  Furthermore,  merging  the  programmes  into  one  would 

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Criteria 

Option 1  

Option 2 

Option 3 

Explanation of given ratings: 

Status quo 

No action 

Policy option 3: 
Strengthening 
the current 
programmes 

Policy option 4: 
A single 
Programme for 
education, 
training, youth 
and sports  

0 

-- 

+ 

++ 

systemic 

openness 

Strengthen 

2. 
and 
excellence  with  a  view  to  producing 
long-lasting 
impact, 
building  capacity  and  supporting 
education 
reform 
institutions  in  the  EU  and  in  partner 
countries. 

higher 

of 

0 

-- 

+ 

++ 

3.  To  contribute  to  young  people's 
employability, active participation in 
society and sense of belonging to the 
EU  as  a  means  to  foster  human  and 
social  capital  development,  support 
in 
growth  and  social  cohesion 
support  to  the  Europe  2020  Strategy 

promote the development of Lifelong Learning in a more effective way. 

Option  1:  Fragmentation  of  EU  action  would  persist,  resulting  in  insufficient  EU 
contribution  to  quality  of  HE  and  the  realisation  of  a  European  area  of  HE.  Certain 
partner  countries  would  not  have  the  capacity  in  HE  to  establish  mutually  beneficial 
partnerships with the EU. 

Option  2:  The  identified  problems  would  not  be  addressed,  causing  fragmentation  and 
back-sliding of EU competitiveness. 

Option 3: The divide between the different EU external cooperation programmes in HE 
would be addressed, and this in combination with increased volumes would significantly 
strengthen systemic impacts. 

Option 4: In addition to the benefits of Option 3, this option would facilitate further the 
exploitation of synergies between Erasmus and the international cooperation programmes 
in higher education, which would strengthen impacts. 

Option 1: This option would not address in the most effective way the priorities of the 
new policy  context  and  the recommendations  of  the YiA interim  evaluation, notably  as 
regards  the  possibility  to  strengthen  focus  on  youth  employability  without  losing  the 
participation  dimension;  the  need  to  further  clarify  support  to  disadvantaged  young 
people;  the  need  to  improve  and  streamline  the  programme  rationale  and  structure;  the 
possibility to simplify administrative requirements. 

Option  2:  The  identified  problems  would  not  be  addressed,  causing  fragmentation  and 

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Criteria 

Option 1  

Option 2 

Option 3 

Explanation of given ratings: 

Status quo 

No action 

Policy option 3: 
Strengthening 
the current 
programmes 

Policy option 4: 
A single 
Programme for 
education, 
training, youth 
and sports  

and the EU Youth Strategy. 

back-sliding of EU competitiveness. 

4.  To  develop 
dimension in sport. 

the  European 

0 

N/A 

+ 

+ 

Option  3:  This  option  would  involve  focusing  on  actions  with  the  highest  added  value 
and creating the strongest multiplier effects. Furthermore, a better alignment with policy 
priorities would be achieved. However, these improvements would be limited to what can 
be done within each separate programme. 

Option  4:  In  addition  to  the  benefits  of  Option  3,  this  option  would  further  provide 
synergies  and  cross-fertilisation  with  the  formal  education  area,  which  would  bring 
positive  impacts  in  relation  to  promotion  and  recognition  of  youth  work  and  learning 
pathways for young people. 

Option  1:  The  problems  identified  in  the  areas  of  awareness  and  knowledge  sharing 
would remain unaddressed. 

Option 2: N/A (new actions, thus identical to Option 1) 

Option  3:  This  option  would  address  the  identified  problems  by  promoting  the 
establishment  of  a  framework  for  stakeholders  for  cooperation  on  the  substantial 
problems  identified  in  the  area  of  sport,  such  as  doping  and  low  participation  rates  in 
sport activities. The measures planned are expected to have a great leverage effect and a 
high EU added value. 

Option 4: As for Option 3. 

5. Efficiency/cost-effectiveness, in terms of: 

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Criteria 

Option 1  

Option 2 

Option 3 

Explanation of given ratings: 

Status quo 

No action 

Policy option 3: 
Strengthening 
the current 
programmes 

Policy option 4: 
A single 
Programme for 
education, 
training, youth 
and sports  

Implementation  costs 

A) 
(taking 
account of simplification measures); 

0 

N/A 

+ 

++ 

B) EU budget 

0 

N/A 

+ 

++ 

Option 1: As there is room for improvements of effectiveness related to the structure of 
the  current  programmes  and  as  well  to  their  management  structures/costs,  the  cost-
effectiveness of this option is average.  

Option  2:  Although  implementation  costs  of  this  option  would  be  negligible,  the 
effectiveness of this option is so low that an assessment of cost-effectiveness is futile and 
very difficult. 

Option  3:  This  option  involves  a  relatively  high  level  of  cost-effectiveness  concerning 
implementation  costs,  as  the  effectiveness  is  increased  compared  to  the  baseline. 
However, as the current fragmented management structure is to a large extent maintained 
(apart  from  the  integration  of  the  external  cooperation  programmes),  there  is  still  room 
for improvement. 

Option 4: Since the simplification of management structure improves economies of scale 
and thus considerable savings, the cost-effectiveness of its implementation very high. 

Option  1:  Considering  the  fragmentation  of  EU  action,  the  baseline  offers  only  an 
average level of cost-effectiveness in terms of the EU budget. 

Option  2:  Although  implementation  costs  of  this  option  would  be  negligible,  the 
effectiveness of this option is so low that an assessment of cost-effectiveness is futile and 
very difficult. 

Option  3:  Considering  the  increased  focus  on  actions  of  high  added  value  and  the 
mobilisation  of  a  critical  mass  due  to  increased  volumes  of  those  actions,  the  cost-
effectiveness in terms of EU budget is considered as high. 

Option 4: On top of benefits under Option 3, the exploitation of synergies between Youth 

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Criteria 

Option 1  

Option 2 

Option 3 

Explanation of given ratings: 

Status quo 

No action 

Policy option 3: 
Strengthening 
the current 
programmes 

Policy option 4: 
A single 
Programme for 
education, 
training, youth 
and sports  

6.  Coherence 
objectives, etc.): 

(with 

strategic 

0 

-- 

+ 

++ 

international  cooperation 

and Lifelong Learning, and between the LLP (Erasmus) and the current EU programmes 
for 
in  higher  education,  will  allow  simplification  of 
management  and  economies  of  scale  in  the  delivery  mechanisms,  resulting  in  a  higher 
cost-effectiveness in terms of the EU budget. 

Option  1:  The  baseline  offers  certain  incoherence  with  EU  policy  objectives  and  MS 
actions. 

Option  2:  Coherence  would  suffer  significantly:  it  would  be  left  to  MS  to  decide  how 
they implement the EU2020 and ET 2020 strategic objectives and priorities. Furthermore, 
the feasibility of this option would be very limited, as it  would go against the views of 
most stakeholders. 

Option 3: Would allow for stronger coherence with EU policy priorities and MS actions. 

Option  4:  As  for  Option  3.  Furthermore,  the  internal  coherence  would  be  considerably 
strengthened through integration of the four programmes and reduction of overlaps, and it 
addresses the Commission's strategy to simplify the structures of EU programmes. 

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Conclusion: On the basis of the above comparison, Option 4 comes out clearly as the best option; a 
detailed description of this option is provided in the next section. 

7. 

DESCRIPTION OF THE PREFERRED OPTION 

The  Lifelong  Learning  Programme,  the  current  international  cooperation  programmes  in  higher 
education such as Erasmus Mundus, Tempus, Alfa and EduLink and the Youth in Action Programme 
all provide support for structures which deliver either formal or non formal learning, and do so through 
a variety of activities, projects, etc, which can be summed up in three key types of actions:  

• 

• 

• 

support for learning mobility of individuals;  

support for institutional cooperation for innovation and good practices; and  

support for policy reform.  

The  existing  actions  on  sport  have  focused  primarily  on  policy  dialogue  and,  more  recently, 
cooperation projects in the framework of the on-going preparatory actions. 

The  integration  of  all  the  current,  fragmented  EU  programmes  into  a  common,  simplified  and 
transparent  architecture  will  allow  the  new  programme  to  create  enhanced  synergies  between  both 
formal and non-formal education at all levels, reinforcing therefore the lifelong learning perspective, 
as  well  as  with  other  policies.  An  integrated  programme,  focusing  on  a  limited  number  of  key 
transversal  actions,  would  structurally  deepen  the  scope  for  systemic  impact  and  high  returns  on 
investment  through  a  concentration  of  activities  with  European  added  value.  It  will  also  include  an 
important international dimension, reinforcing Europe as an excellence destination, as a promoter of 
modernisation  of  systems  and  institutions  and  as  an  important  player  in  the  field  of  education 
worldwide, while promoting teaching and research on European integration. The programme will also 
support activities in the field of sport which will benefit from the continuity of existing management 
structures and know-how.  

As detailed in the impact assessment report related to education and training within the current LLP, 
the  future  programme  should  be  implemented  through  three  key  types  of  actions,  namely:  learning 
mobility of individuals, cooperation for innovation and good practices, and support to policy reform.  

All  the  relevant  activities  funded  by  the  current  programmes  covered  by  the  merger  fall  into  one  of 
these  three  key  types  of  actions3.  Bringing  them  together  will  allow  simplification  and  greater 
visibility of the EU support. For example, a university which organises in and out mobilities for both 
European and non-European students and teachers will be able to present a single dossier, following a 
single guide and set of rules instead of currently 4 or 5. 

The option would also offer the greatest value for money in term of administrative costs to manage the 
programme.  The  cumulative  effect  of  refocused  concentration,  streamlining  and  exploitation  of 
economies of scale would lead to greater efficiency and effectiveness in the delivery system along the 
complete chain, from the Commission down to final beneficiaries passing through National Agencies 
and  the  Executive  Agency.  The  cumulative  savings  in  administrative  costs  could  be  tentatively 
estimated at 40 % for the Commission and National Agencies compared to the current situation.  

The resulting simplified and streamlined architecture would be easily scalable with low marginal costs 
and an increase of the budget in the order of 70%, as proposed by the MFF Communication, could be 

3 

Except for the activities related to Sport currently included in preparatory actions and to Jean Monnet 
which will deserve specific architectural design. 

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accommodated with the current level of resources. For the currently existing programmes, 1 FTE (full-
time  equivalent)  manages  around  EUR  20  millions.  With  the  merge  of  the  programmes  and  the 
envisaged improvements, it could manage 32 millions. For each of the foreseen actions, the following 
principles should apply: 

1. 

Learning mobility of individuals 

•  The  mobility  action  will  aim  at  supporting  the  mobility  of  learners  and  learning  providers 
(including  to  and  from  non  EU  countries)  in  order  to  undertake  periods  of  study,  training, 
teaching, placement, volunteering or youth activity at a partner institution/organisation abroad.  

•  Education  and  training  institutions  and  youth  organisations  will  apply  for  mobility  grants  to  the 
National  Agency4  in  their  country.  NAs  will  give  mobility  grants  only  via  institutions  and  no 
longer  to  individual  staff  or  students.  The  grant  will  cover  the  actual  mobility  grants  as  well  as 
support to the institution for organising high quality mobility. 

•  To  qualify  for  mobility  grants,  the  organisation  will  have  to  prove  that  the  conditions  for  high 

quality mobility are in place.  

•  For  mobility  between  institutions  in  a  participating  and  in  a  third  country,  the  grant  will  be 
managed by the institution in the participating country for both incoming and outgoing mobility. 
No National Agencies will be set up in third countries.  

Benefits:  

o 

o 

o 

National Agencies will become the "one-stop shop" for EU mobility, easy to 
understand and access.  

National Agencies will manage only contracts with institutions (as opposed to 
individual persons now). 

Beneficiary  institutions  will  have  to  improve  the  quality  of  mobility,  as  this 
will become a condition for participation. 

2. 

Institutional cooperation for innovation and good practices 

•  Trans-national  cooperation  projects  will  aim  at  1)  developing  innovation,  and/or  2)  transferring 
and implementing innovative practices, including development of web platforms building on the 
successful  example  of  e  twinning  for  schools  and/or  3)  modernising  systems  and  institutions, 
notably in the field of higher education, in and outside the EU. 

•  The coordinating organisation will apply on behalf of the project partnership as a whole for a grant 
to the National Agency in its own country or to the Executive Agency. The grant will cover the 
development  work  and  mobility  other  than  for  study,  training,  teaching,  placements  (see  1. 
Learning mobility of individuals above). 

•  To  qualify  for  a  project  grant,  the  coordinating  organisation  will  have  to  prove  that  it  has  1) 
established  the  necessary  cooperation  agreements  with  its  partner  organisations  and  that  2)  they 
have the capacity to undertake the envisaged project activities. 

4 

National Agencies already exist in each participating countries 

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•  Depending  on  the  sector,  cooperation  of  business,  regional  authorities  and  other  relevant  actors 
may  be  a  condition  for  participation.  Cooperation  across  sectors  will  be  strongly  favoured. 
Participation of third country partners will be encouraged.  

•  Management should be shared between national agencies and EU level, with possible outsourcing 

of management to an executive agency. 

Benefits: 

o 

o 

Easy  access  thanks  to  harmonisation  of  actions  that  address  the  same  target 
public  (e.g.  universities)  but  are  now  managed  by  different  bodies  with 
different rules and tools 

Participation of organisations from third countries will ensure that E&T in EU 
can benefit maximum from innovation and good practices in the wider world. 
Intense cooperation with business will help institutions develop teaching and 
training for the skills and competences that are needed on the job market. 

3. 

Support for policy reform 

•  The policy support action will aim at 1) developing and steering policy and innovation top down; 
2)  developing  and  experimenting  EU  tools  to  support  policy;  and  3)  providing  for  international 
comparison and exchange of best practice. 

•  The policy support action will finance OMC activities and policy initiatives such as the Bologna 
and Copenhagen processes, the Youth Strategy as well as support tools such as ECTS, ECVET, 
Youthpass, EU wide networks etc. 

•  Financial  support  will  be  provided  via  service  contracts  or  grants.  Both  service  contracts  and 

grants can be given to consortia/partnerships and individual organisations. 

•  Management  will  be  centralised  at  EU  level,  with  possible  outsourcing  of  management  to  an 

executive agency. 

Providing leverage through an innovative financial instrument for Masters’ students 

An  extensive  assessment  of  the  specific  situation  of  Masters’  students  in  the  Member  states,  an 
analysis  of  EU  and  non-EU  funding  schemes  for  these  students,  as  well  as  a  comprehensive 
independent  feasibility  study,  point  to  the  opportunity  of  developing  a  new,  innovative  financial 
instrument, within the preferred option of a single programme.  

The  EU  Student  Loan  Guarantee  Facility,  as  synthetically  described  in  Annex  to  the  Impact 
Assessment on the Lifelong Learning Programme, would contribute to greatly increasing the leverage 
of investment (calculated at a factor of between 6 and 8). By way of illustration, €100 million per year 
from the EU budget could generate loans totalling at least €600m per year, representing around 55,000 
borrowers. The critical success factor for any loan scheme, national or transnational, is the repayment 
rate: student mobility leads to increased labour market mobility, and recovery of loans is more difficult 
once borrowers leave the lender's Member State. To reduce default to a minimum, the Facility would 
focus exclusively on Masters level students (i.e. with higher earnings potential), and use peer pressure 
(a  central  register  and/or  alumni  associations)  and/or  incentivisation  (notification  to  national  credit 
reference agencies).  

The  simplified  architecture  of  the  single  programme  described  above  would  facilitate  the  smooth 
administrative implementation of the Loan Guarantee. 

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8. 

MONITORING AND EVALUATION 

Monitoring and evaluation should be a core element of a future programme which should emphasise 
EU added value and performance. Therefore, in order to ensure the EU added value of the programme, 
throughout  the  entire  period  of  programming,  the  Commission,  in  cooperation  with  the  Member 
States, should regularly monitor and evaluate the performance and results against the objectives. 

Regarding  monitoring,  the  intention  is  to  publish  an  annual  activity  report  which  will  include  both 
statistics and qualitative assessment, based in particular on performance indicators. A generic common 
framework of indicators is provided in Annex to the Impact Assessment on Lifelong Learning. Both 
reports from the beneficiaries and extensive surveys will be used to assess the impact at three levels: 
individuals (increase in skills), the institutions (internationalisation) and the systems (improvement of 
the quality, including the implementation of recognition and transparency EU tools). 

In  addition  to  the  continuous  monitoring,  the  Commission  shall  arrange  for  regular  independent 
external  evaluations  in  order  to  assess  the  effectiveness  and  efficiency  of  the  programme.  The 
evaluations  should  also  contribute  to  the  assessment  of  the  programme's  EU  added  value  and 
contribution  towards  the  general  and  specific  objectives.  A  mid  term  evaluation,  including  also  the 
results  of  the  ex  post  evaluations  of  the  current  programmes,  should  be  carried  out  at  EU  level. 
Member States shall submit to the Commission reports on the implementation and the impact of the 
programme, at least twice (in 2016 and 2019). 

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