Indirect Cost Rates For Nonprofit Organizations

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1 Indirect Cost Rates For Nonprofit Organizations Bag Lunch Webinar October 10, 2012 All slides and handouts copyright 2012, Rubino & Company, Chartered Presenter: Paul H. Calabrese Rubino & Company, CPAs & Consultants Senior Manager Tel: paul_h_calabrese/view 2 1

2 4 Basic Indirect Rate Principles Goal To provide an open architecture to design and develop indirect cost rates within the framework of OMB Circular A-122 Documentation to ensure: Uniform measurement Consistency year to year comparison Cost accounting period - accrual Concept of ALLOCABILITY 5 Importance of Federal Rates Service and Not For Profit (NFP) Non-Profit org s OMB Circular A-122 Dept. of Labor & DHHS models Outside forces on NFPs IRS 990 SFE, FASB 117 SFE 6 2

3 Cost Accounting Definitions Adequate project costing Segregate cost for each government grant Distinguish between direct and indirect cost Consistent cost allocation of indirect cost Identify unallowable, non-recoverable cost Assign cost to the appropriate accounting period Sufficient accounting controls to ensure compliance with government grant regulations OMB Circular A-122 for Non-Profit Organizations Capable of performance measurement, such as provisional vs. actuals for indirect burden rates Facilitate the development of indirect cost rates 8 Direct Expenses Direct Cost are costs specifically identified or traceable to a final cost objective (program service group, activity, cost center, department, grant). Examples: direct labor, direct material, supplies, consultants, sub-awards, and travel. 9 3

4 Reasons for Indirect Rates Develop cost estimates for grant proposals used in the SF 424a Manage within cost measurement and performance requirements Full Cost Recovery Difficult to achieve Certain grants restrict administrative cost Certain NEA vehicles exclude indirect State and local units of gov t limit rates 10 Conditions Clauses Limitation on Indirect Costs Award specific rate (predetermined) Limitation on indirect cost recovery, i.e. if awardee did not provide an indirect rate percentage in 6j of the SF 424-a, the awardee is barred from claiming and recovering indirect cost for this grant 11 Indirect Rates Indirect rates synonymous with: Burdens Loading Overhead Types Fringe G&A (Indirect, Management & General from IRS Form 990) 12 4

5 Indirect Cost Definitions Indirect Cost are costs not directly identified with a single final cost objective (grant), but rather relates to two or more final cost objectives, or a service center, like occupancy department. Indirect costs cannot be economically traced to each grant so they must be placed in a cost pool to be allocated on a causal-beneficial basis to the final cost objective or grant. 13 Indirect Rate Negotiation and Administration No indirect rate system fits all OMB Circular A-122, Attachment A, C. Due to diverse characteristics and accounting practices of nonprofits, it is not possible to specify the types of cost which may be classified as indirect in all situations. 15 5

6 Advance Understandings OMB Circular A-122, Attachment A, A.6 Under any award, the allocation of certain expenses may be difficult to determine Purpose is to avoid subsequent disallowance or dispute Seek a written agreement with cognizant awarding agency in advance of incurrence of cost 16 Indirect Cost Allocations OMB Circular A-122, Attachment A, D.1.e Period for allocating and accumulating incurred indirect cost to grants Base period equals the org s fiscal year Grants cross over two fiscal years Two different indirect rates 17 Indirect Rate Administration Negotiation and Approval of Indirect Rates per OMB Circular A-122, Attachment A, E Agency with largest dollar value = cognizant agency Indirect rate proposal submitted 90 days after new award to an organization May not happen if you have program restrictions, HRSA Part B, CFDA limits adm. to 10% Issues when agency is not proactive in the negotiation and settlement of indirect rates 18 6

7 Indirect Rate Administration Negotiation and Approval of Indirect Rates Existing org s submit new rate proposals within 6 months after the end of their fiscal year Predetermined rate is based on estimate of costs to be incurred for the current or future fiscal year. The predetermined rate is not subject to adjustment. 19 Indirect Rate Administration Fixed (ceiling) rates are similar to predetermined rates except: The difference between the estimated and actual costs of the period are carried forward as an adjustment to the subsequent period s indirect rate computation Final rate Based on actual cost for period Once negotiated, not subject to adjustment 20 Indirect Rate Administration Provisional Rate Temporary indirect cost rate pending final rate Used for funding, interim billing or cost reporting If future rate in FY 2012 is substantially higher than historical rate in FY 2011, consider preparing a separate budgeted rate for FY 2012 to negotiate the provisional rate in addition to the FY 2011 historical indirect rate proposal 21 7

8 Indirect Rate Administration The results of any negotiation is distributed to other participating agencies Many clients complain they cannot find the office for negotiating indirect rate Look at conditions clauses attached to grant 22 Basic Indirect Rate Mechanics Fringe as a Service Center For example, fringe cost includes pension, medical insurance and payroll taxes for direct personnel, working on multiple programs, that cannot be economically assigned to each of those grants. 24 8

9 Fringe Cost Pool & Base Each of the fringe expenses reside in a cost pool to be allocated on a causal-beneficial basis to the final cost objective or grant. Fringe expenses is the numerator and total labor dollars is the denominator to develop a % via a fraction. Total labor has a functional relationship with fringe expense where total labor is the independent variable and fringe is the dependent variable. 25 Fringe Rate Computation Fringe Pool & Base Example: Fringe Indirect Cost Pool: $1,500 Pension 1,500 Medical Insurance 500 Payroll Tax $3,500 Total Fringe * $ 2,000 Direct Labor (D/L) Grant A 8,000 D/L Grant B $10,000 Total Grant D/L* (Allocation Base) * $3,500/$10,000 = 35% Fringe Indirect Burden Rate *Missing indirect labor applied to G&A. 26 Fringe Applied to Grants Fringe Application Example: Grant A: $ 2,000 D/L 700 Fringe ($2,000 D/L x 35% fringe rate) 1,400 Other Direct Costs (ODCs) $ 4,100 Total cost for Grant A-final cost objective Grant B: $ 8,000 D/L 2,800 Fringe ($8,000 D/L x 35% fringe rate) 9,600 ODC $20,400 Total cost for Grant B-final cost objective 27 9

10 Indirect Cost Example General fund = administrative costs Executive director s office Finance, HR, IT, Purchasing, Facility Mgmt. Office Space, Utilities, Audits, Insurance Value = $150,000 (A) Programs, Value = $1,000,000 (B) $900,000 in non-federal: programs, fundraising, membership, promotion, P/R $100,000 federal grant Fractional relationship between general fund (M&G) and Programs = 15% 28 Example of Total Cost Total Cost of Grant $100,000 direct costs $ 15,000 applied indirect (15% x $100,000) $115,000 = total value of grant Total Cost Definition The sum of direct and indirect costs allocable to an award less credits, refunds, rebates; and excluding unallowable costs. OMB Circular A-122, Attachment A, A.1 29 Analysis of Indirect Expenses 10

11 Indirect Rate Multiplier Indirect Rate Loading Factor: Fringe (1.35) x G&A (1.25) = For every D/L $1.00 spent, there will be an additional cost of 69 in burden cost. 31 Percent of Base Analysis Fringe Pool Example: FY 2011 FY 2012 Account $1,500 15% $1,500 20% Pension 1,500 15% 2,500 33% Medical 500 5% 500 7% Payroll $3,500 35% $4,500 60% Fringe Pool $10,000 $7,500 Total Labor Base 32 Isolate G&A (numerator) Indirect cost classified into two broad activities: A-122, Attachment A, C.3 Facilities: buildings, equipment and capital investments, maintenance and operation expenses Administration: general administration, director s office, accounting, HR, library expenses and other types of expenditures not mentioned under facility 33 11

12 Isolate Admin. From Facility If an organization has more than $10 Million in federal funding of direct costs in a fiscal year, a breakout of indirect cost into two components: facility and administration, having indirect cost rates. OMB Circular A-122, Attachment A, C.3.e 34 Is there an ideal indirect rate? 15% Total G&A includes: 10% Administrative Functions 5% Occupancy Private Foundation Grant permits: 9% Total G&A Limitation Occupancy is a direct line item cost What is the best allocation base? What is the best rate, low or high? G&A Bases (denominator) General & Administrative MTDC Base Allocate on Modified Total Direct Cost (MTDC) Direct labor, applied fringe, non-labor direct Exclusions from MTDC base shown on next slide G&A Salaries and Fringe Base Direct labor and applied fringe only G&A Salary Base Only direct labor 36 12

13 Distribution Basis for MTDC A-122, Attachment A, D.3.f Salaries and wages (direct labor) Fringe benefits on direct labor Materials and supplies, services & travel Sub-grants and subcontracts up to the first $25,000 of each sub-grant or subcontract, regardless of period covered by sub-grant Amounts excluded from MTDC: Sub-grants/subcontracts > $25,000 Equipment, capital expenditures Participant support cost, generally excluded 37 Direct Cost under A-122/SFE OMB Circular A-122, Attachment A, B.3 Cost of Certain Activities Direct Functions Fundraising Membership Promotion, lobbying, & public relations Treated as direct costs for purposes of determining indirect cost rates And allocated their share of the org s indirect costs agency interpretation 38 Allocate occupancy direct 13

14 Charge Rent Direct & Indirect Rent example of allocability: 1. Rent charged directly for a separate office devoted to one grant 2. Rent (G&A) applied via square footage (SF) to various departments/programs based on SF or some other basis (next slide) 3. Allocating rent for executive director or director of finance, no direct relationship to grant or direct activities 40 Charge Rent Direct & Indirect Rent example of allocability: 2. Rent (G&A) applied to various departments/programs based on SF or payroll dollars a. If site devoted to grant is 1,000/10,000 SF for 10% of total rental cost ($5,000 = $500) b. If $5,000 in total rent is allocated via D/L dollars over $20,000/$80,000 = 25% for this program/grant (total rent = $1,250), i.e. Direct Allocation Method 41 Direct Allocation Method Joint costs depreciation, rental cost, repair & maintenance, telephone, and the like (utility, property insurance, etc) Prorate on a base that accurately measures benefits provided to each direct award and indirect departments Direct and indirect FTE positions Hours worked direct and indirect Direct and indirect labor dollars 42 14

15 Direct Allocation Method Square footage for direct and G&A areas is difficult to measure and keep up to date In order to use the Direct Allocation Method, make sure the grant proposal has a line item for joint costs or occupancy Set up a separate department to track and allocate joint costs to direct and indirect cost objectives OMB Circular A-122, Attachment A, D Multiple Cost Pools Multiple Allocation Method Indirect costs benefit major functions in varying degrees Indirect costs accumulated into separate cost groupings Constitute a pool of expenses that are of like character as they relate to base Allocated to functions by means of a base which best measures relative benefits 45 15

16 College Radio Station - Functional Areas 46 Step Allocation / Order A-122, Attachment A, C.1 & D.3.d(1) First, direct costs are assigned to awards Fringe allocated to all cost centers including G&A Occupancy allocated to all cost centers including G&A Overhead allocated to Music programs, and Studio Structure Special allocation of engineering to G&A allocated to through College Radio: Applied Burdens 48 16

17 Service Center: Technical Production 49 College Radio: Allocated Tech. Prod. 50 When is Overhead necessary Grouping administrative costs for cost centers under a department or functional area Departmental executive or VP Receptionist or other admin personnel Functional work benefits local cost centers Governmental group w/ multiple grants Burden is necessary to recover adm. $ 51 17

18 Indirect Rate Agency Models Templates for ICRP U.S. Department of Labor Indirect Cost Rate Determination Guide oc/costdeterminationguide/main.htm#t oc {Exhibit A Bifurcated G&A Rates} DHHS ICRP Template html 53 Special Indirect Cost Rates A-122, Attachment A, D.5 A single rate for all functions may not take into account factors that may impact a particular segment of work Factors might include: Site location: geographic or gov t site Level of administrative support required Level of facility or other resources used 54 18

19 Special Indirect Cost Rates A-122, Attachment A, D.5 Bifurcated G&A example, Exhibit A Same G&A rate % for segments Some segments have different facility cost due to different geographic locations Some segments have no facility cost since the effort is performed at a government site 55 DHHS Indirect Template Any Questions 57 19

20 The materials contained herein or discussed in the seminar or shown in the MS Powerpoint slides, are for illustrative and academic purposes only and should not be considered appropriate for your organization without careful adaptation by experts in the appropriate field of endeavor. DISCLAIMER 20

21 SAMPLE INDIRECT COST PROPOSAL FORMAT FOR NONPROFIT ORGANIZATIONS

22 SAMPLE INDIRECT COST PROPOSAL FORMAT FOR NONPROFIT ORGANIZATIONS A. INTRODUCTION Name of Organization (nonprofit) is a nonprofit located in Anytown, USA. The nonprofit administers a variety of programs funded by Federal, State, and Local agencies. These programs include Community Service programs, Head Start programs, State Weatherization, and Food Service programs. This example assumes a June 30 year end. Nonprofits can have different year ends and should use the year end of their nonprofit when preparing indirect cost proposals. B. COST ALLOCATION METHODOLOGY This proposal is for an indirect cost rate based on the nonprofits actual costs for its fiscal year beginning July 1, 200X and ending June 30, 200X. The proposal is based on the nonprofit organization's audit report (Statement of Functional Expense Statement) for the year ended June 30, 200X. This proposal addresses all elements of cost incurred by "Name of Organization" and identifies shared costs that require allocation. The nonprofit treats all costs as direct costs except general administration and general expenses. Joint costs are prorated individually as direct costs to each category and to each award using a base most appropriate to the particular cost being prorated. Therefore, the direct allocation method has been used in allocating indirect costs. C. DIRECT COSTS Direct costs are costs that can be identified specifically with a project and therefore are charged to that project. The accounting system records these costs as they are incurred within the series of accounts assigned for that purpose and further distribution is not required. D. INDIRECT COSTS Indirect costs are costs incurred for common or joint objectives and therefore cannot be readily and specifically identified with a particular project or activity. These costs are grouped into common pool(s) and distributed to benefiting activities by a cost allocation process. (1)

23 SAMPLE INDIRECT COST PROPOSAL FORMAT FOR NONPROFIT ORGANIZATIONS E. COST POOL AND BASE FOR DISTRIBUTION The nonprofit has created an Administrative Services Pool consisting of salaries, fringe benefits, and non-salary costs. The Administrative Services Pool is charged with all the indirect costs as defined above. The pool is distributed to the various program activities on the basis of direct salaries, including vacation, holiday, and sick pay but excluding other fringe benefits expended on those activities. Volunteers for the Head Start program are included in the direct salaries total. The total direct salaries and wages on which this proposal is based is $1,111,343 which includes $99,230 of volunteer salaries and wages for the Head Start program. Volunteers involved in any direct activity of the organization should be included in the direct salaries base assuming they meet the requirements outlined in Circular A-122. Circular A-122 can be found at: F. SUPPORTING FINANCIAL STATEMENTS The Schedule of Total Expenditures (Schedule C) contained in this proposal is assumed to agree to the nonprofits audit report Statement of Functional Expenses. - Audit report, Statement of Functional Expenses: $2,632,449 - Indirect Cost Proposal: $2,632,449 NOTE: Nonprofit must include a complete copy of the audited financial statements with their proposal submission. (2)

24 SAMPLE INDIRECT COST PROPOSAL FORMAT FOR NONPROFIT ORGANIZATIONS G. SALARIES Listed below are the positions, functions, and budgeted annual salaries for the people who comprise the Administrative Services Pool. These positions are charged 100% to Administrative Services. Position Function Salary Executive Director Deputy Director Administrative Assistant to Executive Director General Management $48,754 General Management $30,664 General Management $21,566 Administrative Secretary / Personnel Officer Finance Officer Bookkeeper Bookkeeper Bookkeeper / Payroll Clerk Custodian Receptionist Clerical support to the Executive Director and Administrative Assistant Responsible for personnel information Accounting and related activities Accounting Accounting Payroll accounting and general disbursements Cleaning Switchboard / Clerical $17,087 $26,484 $20,797 $17,215 $16,560 $2,936 $14, Total Administrative Services Pool Salaries: $216,295 ========== (3)

25 SAMPLE INDIRECT COST PROPOSAL FORMAT FOR NONPROFIT ORGANIZATIONS H. FRINGE BENEFITS Fringe benefits associated with the positions within the Administrative Services Pool are as follows: Payroll taxes: FICA (actual paid) $16,546 State Unemployment (actual paid) $1,145 $17,691 Health and Life Insurance (actual paid) Retirement Plan (actual paid) TOTAL $22,474 $3, $43,215 ========== The nonprofits fringe benefit policies should be included with proposal submission. I. NON-SALARY COSTS Each category on non-salary expenditures has been analyzed based on the facts, and Schedule B shows the allocation between the Direct and Administrative Services Pool. Total non-salary direct costs excluding indirect cost reimbursements are $984,656 of which direct is $861,966 and indirect is $122,690. (4)

26 SAMPLE INDIRECT COST PROPOSAL FORMAT FOR NONPROFIT ORGANIZATIONS J. COMPUTATION OF BASE AND POOL COSTS Schedule A (attached) shows the computation of the indirect cost rate for the year ended June 30, 200X. A summary of the rate calculation follows: K. RATE Direct Costs (Base - Salaries and Wages): Community Service $140,831 Head Start $950,615 Weatherization $18,305 Memberships and Fundraising $1, Total Direct Salaries: $1,111,343 ========== Indirect Costs (Pool): Administrative Services Salaries $216,295 Administrative Services Fringe Benefits $43,215 Administrative Services Non-salary costs $122, Total Administrative Services: $382,200 ========== Adjusted indirect costs (above - pool): $382, Total direct salaries (above - base): $1,111, % L. FUNDING OF RATE When the above rate is applied to the direct salaries paid from the State Department of Human Resource funds (Community Services Block Grant) and funds from the U.S. Department of Health and Human Services (Head Start Grant), the eligible reimbursement is $374,365 ($140,831 + $950,615 = $1,091,446 x 34.4% = $374,365). However, the allowable budgeted funding for indirect costs was significantly less than the eligible reimbursement. The Department of Energy programs and other local funds will have to absorb their fair share of the difference, within their funding limitations. The nonprofit can apply to outside sources to absorb any difference in indirect costs paid by other programs. (5)

27 SAMPLE INDIRECT COST PROPOSAL FORMAT FOR NONPROFIT ORGANIZATIONS SCHEDULE A Functional Groupings: Direct Costs (Base - Salaries and Wages): Community Services Total Salaries $140,831 Head Start Salaries $851,385 Volunteers $99,230 $950,615 Weatherization Memberships and Fundraising Total Direct Salaries: $18,305 $1, $1,111,343 ========== Indirect Costs (Pool): Labor Costs Non-Labor Costs Adjusted Administrative Services Pool: $259,510 $122, $382,200 ========== RATE Adjusted indirect costs (above - pool): $382, Total direct salaries (above - base): $1,111, % (6)

28 SAMPLE INDIRECT COST PROPOSAL FORMAT FOR NONPROFIT ORGANIZATIONS SCHEDULE B Elements of Cost Methodology of Allocation Contractual Services Depreciation / Use Allowance Emergency assistance payments Equipment rental and maintenance Equipment / Capital Equipment / Minor Food costs Insurance Occupancy Office supplies Other expenses Actual usage. Indirect cost. Direct cost. Rental and maintenance on equipment used in central office finance office. Purchasing of office furniture for use in performing administrative services. Actual usage. Direct cost. Actual usage. Central office repairs and utilities on basis of square footage used for administrative services. Office and janitorial supplies for administrative and program services. Based on administrative services actual use. (7)

29 SAMPLE INDIRECT COST PROPOSAL FORMAT FOR NONPROFIT ORGANIZATIONS SCHEDULE B (continued) Elements of Cost Methodology of Allocation Postage Professional fees Program supplies Printing Renovations and improvements Telephone Travel Actual usage. Accounting and audit services, payroll processing services, charged on work performed for administrative services. Programs are charged to project as costs are incurred. Costs are direct costs. Actual usage. Direct cost. Basic services allocated on number of instruments, toll calls charged on basis of logs of such calls for administrative services. Charged based on actual administrative and program use of vehicles. Costs include mileage, transportation, per diem, gas, oil, repairs, and insurance on vehicles. The methodologies used in this example are not recommended methodologies. They are used for purposes of example only. Allocation of costs should be accomplished on a cost benefit basis. This cost benefit can be different from one nonprofit to the next. (8)

30 Sample Indirect Cost Proposal Format for Nonprofit Organizations Total Expenditures for the year ended June 30, 200X Schedule C DIRECT PROGRAMS and ACTIVITIES (A) (B) (C) (D) FINANCIAL COMMUNITY ELEMENTS OF COSTS STATEMENT ADJUSTMENTS SERVICE (E) (F) (G) MEMBERSHIP & HEAD START WEATHERIZATION FUND RAISING (H) (D)+(E)+(F)+(G) TOTAL DIRECT COSTS (I) INDIRECT COSTS Salaries and wages $1,327,638 a $0 $140,831 $950,615 $18,305 $1,592 $1,111,343 (1) $216,295 Fringe benefits $245,434 $0 $28,138 $170,107 $3,657 $317 $202,219 $43, Subtotal labor $1,573,072 $0 $168,969 $1,120,722 $21,962 $1,909 $1,313,562 (2) $259,510 ============ ============== ============= ============= ================== =============== ==================== ============ Contractual Services $245,420 $0 $3,493 $207,770 $34,157 $0 $245,420 $0 Depreciation/Use allowance $41,582 $0 $0 $0 $0 $0 $0 $41,582 Emergency asst. payments $72,859 $0 $52,809 $0 $20,050 $0 $72,859 $0 Equipment rental and maint. $11,448 $0 $592 $5,197 $0 $281 $6,070 $5,378 Equipment / Capital $58,215 ($58,215) b $0 $0 $0 $0 $0 $0 Equipment / Minor $546 $0 $0 $0 $546 $0 $546 $0 Food costs $124,616 $0 $0 $124,616 $0 $0 $124,616 $0 Insurance $12,554 $0 $92 $8,209 $85 $373 $8,759 $3,795 Occupancy $129,314 $0 $24,637 $100,956 $459 $233 $126,285 $3,029 Office supplies $32,540 $0 $1,794 $13,317 $3,649 $842 $19,602 $12,938 Other expenses $36 ($36) c $0 $0 $0 $0 $0 $0 Postage $3,901 $0 $476 $301 $125 $2,467 $3,369 $532 Professional fees $34,211 $0 $0 $0 $0 $0 $0 $34,211 Program supplies $109,663 $0 $7,603 $55,241 $40,659 $6,160 $109,663 $0 Printing $65,697 $0 $5,140 $7,022 $1,345 $44,838 $58,345 $7,352 Renovations and improv. $16,470 ($16,470) d $0 $0 $0 $0 $0 $0 Telephone $29,013 $0 $5,788 $13,331 $349 $600 $20,068 $8,945 Travel $71,292 $0 $7,298 $56,553 $2,513 $0 $66,364 $4, Subtotal non-labor $1,059,377 ($74,721) $109,722 ============ ============== ============= $592,513 $103,937 $55,794 ============= ================== =============== $861,966 $122,690 ==================== ============ TOTAL $2,632,449 ($74,721) $278,691 ============ ============== ============= $1,713,235 $125,899 $57,703 ============= ================== =============== $2,175,528 (3) $382,200 ==================== ============ Calculation of the Rate Explaination of Adjustments (1) If the nonprofit organization uses Direct Salaries & Wages excluding fringe benefits as their Base their rate would calculate as follows: Indirect costs = $382,200 Base (Direct S&W) = $1,111,343 = 34.4% (2) If the nonprofit organization uses Direct Salaries & Wages including fringe benefits as their Base their rate would calculate as follows: Indirect costs = $382,200 Base (Direct S&W + FB) = $1,313,562 = 29.1% (3) If the nonprofit organization uses Modified Total Direct Costs (MTDC) as their Base their rate would calculate as follows: Indirect costs = $382,200 Base (MTDC) = $2,175,528 = 17.6% a) b) c) d) - - Includes salaries and wages of $99,230 for volunteers of the Head Start program. Excludes capital equipment purchases. Remove unallowable costs - $22 Interest + $14 Bad Debt = $36. Excludes capital renovations and improvements. General Notes This is a sample proposal only. It is not intended to prescribe a particular method for allocating costs. An organization should choose the Base that they feel will most accurately reflect the true allocation of their indirect costs to each program. An organization can use any ONE of the three bases shown. Regardless of what Base (1,2 or 3) is chosen the total indirect costs ($382,200) do not change. The only thing that changes is the distribution Base. (9)

31 SAMPLE INDIRECT COST PROPOSAL FORMAT FOR NONPROFIT ORGANIZATIONS 1. The Indirect Cost Proposal is supported by: (Include a copy of this document with proposal.) Audited financial statements. If not available include one of the following documents: Federal Form 990 Internal Financial Statements Other 2. A reconciliation of item 1. (above) to the Indirect Cost proposal has been made and is included in this proposal. 3. Unallowable expenses have been eliminated from the indirect cost pool (e.g., donated or contributed salaries and services, bad debts, fund raising, advertising, Independent research and development (IR&D), depreciation of Federally funded assets and lobbying costs, etc.). 4. The direct cost base is complete (i.e., it includes all activities that benefit from the indirect cost pool). For example, fund raising, IR&D, project cost sharing, voluntary (e.g., donated or contributed labor and services are included where applicable). 5. A functional analysis of salaries and wages included in the indirect cost pool. If any function is less than 100% show the percent. 6. Treatment of Paid Absences and Fringe Benefits statements have not changed since the last indirect cost rate agreement. 7. We have not made any significant changes, during the proposal fiscal year, (i) to our accounting system, or (ii) to the definition or to the accounting treatment of any expense category (e.g., a change in building/equipment costing methodology, a change in charging an expenses from direct to indirect or visa versa). 8. We have not changed the equipment capitalization threshold during the proposal fiscal year. The capitalization level is $. If there is a change made during the proposal fiscal year, indicate the effective date of the change and the new capitalization level. 9. The required "Lobbying Cost Certificate" is attached. Please explain any boxes not checked on a seperate sheet. Signature Date Title Organization (10)

32 SAMPLE INDIRECT COST PROPOSAL FORMAT FOR NONPROFIT ORGANIZATIONS LOBBYING COST CERTIFICATE I hereby certify that the (name of organization) has complied with the requirements and standards on lobbying costs in OMB Circular A-122 for the fiscal year ended (fiscal year covered by indirect cost proposal) Signature Name Title Date (Signed by the official having the authority to negotiate indirect cost rates for the organization or by a higher level official) Note: The above certification is a requirement of OMB Circular A-122. We will not be able to process your indirect cost proposal without this certification. (11)

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