Contract Support Costs Policy Updates. Indian Health Manual Part 6 Chapter 3

Transcription

1 Cntract Supprt Csts Plicy Updates Indian Health Manual Part 6 Chapter 3 Nvember 16, 2016 Rhnda Butcher rbutcher@ptawatmi.rg

2 IHS CSC Plicy Changes/Updates Prvides guide fr IHS and Tribes Intensive cllabratin Federal/Tribal Highly detailed, cmplex plicy Substantial agreement n many items Areas f disagreement are ftnted

3 Indian Health Manual Part 6 Chapter Intrductin (Guiding Principles and Definitins) Determining CSC Amunts CSC Payments Rles and Respnsibilities CSC Reprts EXHIBITS A. ISDEAA Sectins n Cntract funding and Indirect Csts B. Calculating IDC n Tribal Shares Detailed Analysis C. Calculating IDC n Tribal Shares-- 80/20 methd D. Calculating IDC n Service Unit Shares Detailed Analysis E. Calculating IDC n Service Unit Shares 97/3 methd F. CSC Negtiatin Template G. Standards fr Review

4 Categries f CSC Pre-Award (ne time) Start Up (ne time) Direct Cntract Supprt Csts Indirect Csts Indirect-Type Csts

5 IHS CSC Plicy Determining CSC Amunts Pre-Award and Start-Up Paid n ne-time basis nly Requires Prir ntificatin Negtiated amunts paid during initial 12-mnth perid Within 90 after the initial year r 12 mnths, Awardee certifies that all funds were spent

6 IHS CSC Plicy Determining CSC Amunts Direct CSC Medical Inflatin Rate Apply the inflatin rate by the end f the first quarter (final percent issued in Nvember) Cnditins fr renegtiatin f CSC Tribal Request DCSC Csts are mved t the IDC Pl Withdrawal frm a cnsrtium Cnversin f IPA/MOA t Tribal direct hires New r Expanded PSFAs

7 IHS CSC Plicy Determining CSC Amunts Indirect CSC Estimate f IDC need Recnciliatin Utilizes the ACC Tl EXHIBIT F Use f rate up t three years ld Final Amunt-- Determine if prir year CSC funds were expended 90 day clseut after cntract term Use f Negtiated IDC Rates Fixed w/ Carry Frward current r ne year ld rate Prvisinal final 2 year, final rate Allws fr grace perid fr Overpayments: Pay back r withhld future CSC payment Indirect-Type Cst Tribes with IDC rates lder than 3 years Current IDC rates may negtiate additinal Indirect-Type csts Must be renegtiated every 3 years

8 IHS CSC Plicy Determining Duplicatin 6-3.2E3 Alternate Methds fr Calculating IDC Assciated with Recurring Service Unit Shares (Duplicatin) Applies t all New & Expanded. Only applies t nging cntractrs under the few circumstances identified: Tribal request, new r expanded PSFA (r JV), new type f cst in IDC pl resulting in a 5% change in the value f the IDC pl Alternative A IHS and Awardee Negtiate Duplicatin Offset Alternative B 97/3 Apprach Alternative Methds fr Calculating IDC Assciated with Recurring Tribal Shares (Duplicatin) Alternative A IHS and Awardee Negtiate Alternative B-- 80/20 Split Methd

9 IHS CSC Plicy Payments, Rles & Respnsibilities, and CSC Reprts CSC Payments Withdrawal, Initial Funding, and Onging Awards Rles and Respnsibilities New and Expanded Requests Negtiate with Area Directr r designee Onging CSC Requests negtiate using ACC tl with AD r ALN Other Respnsibilities include Disputes, Appeals, Pilt Prjects, etc. CSC Reprts IHS CSC Funding Reprt t Tribes prvided by May 30 th Annual CSC Reprt t Cngress per ISDEAA

10 Check ne bx: Estimate f CSC need Final CSC Recnciliatin Check ne bx: FA Amendment FA Cumulative Funding Reprt (CFR) Date Cmpleted: Tribe/Tribal Organizatin (T/TO): Cntract Supprt Csts (CSC) Negtiatin Template (FY 20XX) Number # # Example T/TO Subttals Ttals Surce f Inputs Recurring and Nn-Recurring Eligible Funding fr the T/TO's Prgrams, Functins, Services, r Activities (PFSA) at the Service Unit Level. Depending n the structure f an awardee's indirect cst (IDC) rate, this may include buybacks. A Prgram (Service Unit) Funding $655, Expenditures frm carryver funds (fr which CSC was nt funded previusly), Net f passthrughs Pursuant t Sectin E.1.b.1.b.i. This is determined by whether the parties included the funds in the CSC and exclusins A.1 $0.00 calculatin in the year awarded and nt by hw the T/TO allcates funding in its accunting recrds. B Ttal Area Tribal Shares $75, C Ttal Headquarters Tribal Shares $30, Recurring and Nn-Recurring Eligible Funding fr the T/TO's PFSA at the Area Level (Area Office Tribal Shares, r AOTS). Recurring and Nn-Recurring Eligible Funding fr the T/TO's PFSA at the Headquarters Level (Headquarters Tribal Shares, r HQTS). D Ttal Secretarial Amunt $760, Items A + B + C (Ttal Recurring and Nn-Recurring eligible funding awarded under the Secretarial Amunt E.1 IDC Assciated With Recurring Service Unit Shares $0.00 Negtiated and calculated pursuant t Sectin E.3 either: (a) case-by-case analysis, r (b) 97-3 methd. E.2 IDC Assciated With Tribal Shares $21, Negtiated and calculated pursuant t Sectin E.4, either: (a) case-by-case analysis, r (b) methd. Ttal IDC Identified As Assciated With the E.3 Secretarial Amunt $21, This represents PFSA funded in the Secretarial amunt determined t be duplicative f T/TO IDC Pl. F Direct Csts Funded thrugh Secretarial Amunt $739, Item D - E.3 G Prir Year Direct CSC (DCSC) Need $76, Per prir-year agreement. H Inflatin Factr 1.6% T be prvided by IHS when final inflatin rate fr previus year becmes available (usually in Nvember). Final rate wuld be used t update this amunt, and award T/TO inflatin n DCSC at the end f IHS's first quarter. See Sectin D.3. I.1 $77, I.2 Current Year DCSC Need $0.00 $77, I.3 Startup and Pre-Award Need $ D21-22 will autmatically incrprate either the prir-year DCSC need (reflected in D21) r, if there is a currentyear renegtiatin, the renegtiated amunt (reflected in D22). Summarizes the negtiatin fr Nnrecurring Pre-Award and Startup csts fr new r expanded PSFAs in the upcming year. J Ttal Direct Csts $818, Items F + I, but subject t Sectin 6-3.2, Paragraph E.1.a, Estimate f Indirect CSC Need and Funding Prir t the Cntract Year and E.1.b, Determinatin f Final Amunt fr Indirect CSC Need and Funding. K Less: Passthrughs and Exclusins $14, The amunt f passthrughs and exclusins funded by IHS. L Direct Cst Base $803, Item J - K Current IDC rate. If T/TO has multiple IDC rates, enter blended rate and submit detailed calculatin f the blended M Mst current IDC rate 15.00% rate. N IDC Need (Nn-Recurring) Based n IDC Rate $120, Item L * M (Direct Cst Base x IDC Rate) O Credit fr IDC Assciated with the Secretarial Amunt $12, Equals Item E.3 if the T/TO has higher than a 25.00% IDC rate; if T/TO has a rate f 25.00% r lwer the credit in Item O is based n the ttal IDC need fr Tribal Shares generated by the T/TO's rate plus the IDC Assciated with Recurring Service Unit Shares (Item E.1) P Current-Year Indirect CSC Need $107, Item N - O (Ttal IDC need less credit fr IDC assciated with the Secretarial amunt Q IDC-Type Csts $0.00 As negtiated, pursuant t Sectin 6-3.2E.2; see als Exhibit G, ftnte 10. Enter $0 if the T/TO negtiates indirect CSC slely based n its IDC rate. R Current-Year Ttal CSC Need $186, Items I.2 + I.3 + P + Q (Ttal need fr DCSC, indirect CSC, and Pre-Award and Startup) S Current-Year DCSC Need $77, Item I.2 T Ttal DCSC Paid Year-t-Date $0.00 Ttal DCSC funding paid t the T/TO year-t-date. U Current-Year Indirect CSC Need $107, Items P + Q V Ttal Indirect CSC Paid Year-t-Date $100, Ttal indirect CSC funding paid t the T/TO year-t-date. W Current-Year Startup and Pre-Award Need $ Item I.3 Ttal Startup and Pre-Award CSC Paid Year-t- X Date $0.00 Ttal Startup and Pre-Award CSC funding paid t the T/TO year-t-date. Nte Regarding Sub -Awards: The template awards CSC n the direct cst base incurred by the T/TO. If the T/TO has an agreement(s) with a sub-awardee whse csts are eligible t be cnsidered in the CSC need f the T/TO AND the T/TO treats sub-awards as a passthrugh cst when determining its direct cst base, the ttal CSC negtiated can be adjusted t incrprate eligible csts specifically identified fr each sub-awardee (while recgnizing sub-awardee passthrughs and exclusins and the sub-awardee's indirect cst rate). Ftnte: This Template is a tl used by the Indian Health Service (IHS) fr calculating and negtiating CSC. Neither this Template nr any ther negtiatin dcuments creates a cntractual bligatin n behalf f either IHS r a T/TO. The CSC amunt that the parties agree is required under any Indian Self-Determinatin and Educatin Assistance Act (ISDEAA) agreement will be identified in the agreement itself. 10

11 IHS CSC Plicy Outstanding Issues Duplicatin Issue MOST SIGNIFICANT ISSUE REMAINING All: Agree statute requires CSC must nt be duplicated IHS: Unduplicate by categry such as HR, facilities, IT Tribes: Unduplicate dllar fr dllar by amunt Plicy language neutral Tribal/Federal differences ftnted in Plicy CSC Funding fr third-party revenues Carryver f CSC r incurred cst apprach CSC fr CHEF, MSPI, and DVPI Salaries in DCSC Disclsure f Draft Natinal Tribal Data (frmer shrtfall reprt)

12 IHS CSC Plicy Plicy includes new Statute citatins Be mindful f the updated Exhibits CSC Negtiatin Template (previusly called ACC) is incrprated as Exhibit F Standards fr Review and Apprval is nw Exhibit G Ftntes at the end f Exhibit G IHS CSC Cntact: Rselyn Ts, Rselyn.Ts@IHS.gv

13 Questins