When it comes to national funds allocated by Ministries of the Government of Montenegro, there has been a lot of criticism regarding the new funding system. In 2018, when this system was firstly introduced, 12 out of 17 ministries announced calls for project proposals for CSOs. The Law on CSOs stipulates that all calls must be announced by March 1st of the current year for projects that will be implemented in that year. In 2018, none of the ministries respected that deadline and on average, they were 101 days late with announcing the call. Furthermore, almost 3.6 million EUR were set aside for CSOs’ projects, but 93.77% were actually allocated, which means that 221.861,79 EUR were not allocated. In 2019, the situation was a bit different, as several ministries did respect the Law in this part.
On the other hand, the Law on NGOs nor any other act does not stipulate the deadline for announcing the Decision on the allocation of funds, which was heavily misused in 2018, since the average time between announcing the call and the decision was 153 days. However, the Law does prescribe the deadline for completing administrative check phase, which is 15 days after the deadline for submitting projects is finished.
All Ministries that announce calls for funding projects of CSOs should announce them on their websites. The Call is to be published publicly and open for 30 days starting from the day it was announced. All calls should contain information on: the call title, within which priority area it is published, what are specific objectives of the call, what supporting documentation is required, what is the total budget of the call, what is the minimum and the maximum amount that can be allocated, deadline for submitting project proposals, address to which proposal should be submitted. In 2018, all 12 ministries that published calls respected these criteria, which was also the case in 2019 when all 14 ministries abided by the criteria.
0 – 20 Fully disabling environment20 – 40 Disabling environment
40 – 60 Partially enabling environment60 – 80 Enabling environment
80 – 100 Fully enabling environment
After the deadline for submitting projects has passed, the Administrative Check-list is published and CSOs whose documentation is not complete have five working days to submit additional documents. After that, the evaluation of projects is conducted, the Commission decides on projects that received the most points from independent evaluators. After the list of supported projects is determined, it is publicly announced on ministry’s website, along with number of points that each project received.
The Ministry of Human and Minority Rights reported there were five cases initiated before the Administrative Court for the Decision on allocation of funds. There were no complaints for the existence of conflict of interest reported by the Ministry of Culture, Ministry of Science, Ministry of Justice, Ministry of Transport and Maritime Affairs as well as Ministry of Labor and Social Welfare. Yet, 64.58% of organizations that participated in the online questionnaire stated that they disagree or strongly disagree that Decisions on allocation of funds are fair. Only 8.33% agree with this statement.
47.91% of the surveyed organizations stated they agree or strongly agree that state institutions respect the procedure for allocating funds, while 52.08% disagree or strongly disagree. 47.91% agree or strongly agree that criteria for allocating funds are clear and precise, while 45.88% disagree or strongly disagree. Moreover, 66.66% of organizations disagree or strongly disagree that requests for applying are simple, as they stress that many additional documents are asked.
There were many complaints by CSOs that the criterion that organization must submit evidence of a project or program conducted in the previous year in the field the project is announced is too burdensome, as evaluators of one ministry may accept submitted evidence, while evaluator of another may not. Also, ministries propose that one of the following evidence are acceptable: project contract, annual report of the organization, press clipping, narrative report, etc. However, there were cases where commissions or evaluator wouldn’t accept only one evidence, but they asked for several more.