Caltrans, Audits & Investigations (A&I) Indirect Cost Allocation Plans (ICAP)/Indirect Cost Rate Proposals (ICRPs)

Transcription

1 Caltrans, Audits & Investigations (A&I) Indirect Cost Allocation Plans (ICAP)/Indirect Cost Rate Proposals (ICRPs) Topics to be Covered Roles & Responsibilities Elements of an Adequate Financial Management System Elements of an ICAP/ICRP Types of Audits Performed Resources and Contacts

2 A&I s Roles and Responsibilities Fiduciary responsibility 1994 FHWA delegated cognizant agency responsibility to Caltrans A&I to review or approve ICAP/ICRPs Title 2 Code of Federal Regulations (CFR) Part 200 Caltrans A&I is responsible for the review and approval of ICAP/ICRPs of local agencies as sub-recipients of federal funds passed through Caltrans

3 Local Government Agency (LGA) Roles and Responsibilities To develop an ICAP/ICRP in compliance with federal requirements and maintain supporting documentation To timely submit ICAP/ICRP to A&I for acceptance/approval To bill Caltrans for indirect costs using an accepted/approved indirect cost rate

4 Elements of a Financial Management System What is an Adequate Financial Management System and why do I need one? It s a system that tracks, identifies, and segregates costs as direct or indirect, allowable and unallowable, and by cost objective. Cost Objective An item for which costs are accumulated or measured, e.g. a project. It is required in order to support your costs.

5 Elements of a Financial Management System Elements of an adequate Financial Management System Identifies direct and indirect costs, allowable and unallowable costs, and cost objectives properly Allocates costs consistently Does not duplicate costs Includes all costs whether reimbursable or not

6 Elements of a Financial Management System Elements of an adequate Financial Management System Include: General Ledger Job Cost Ledger Labor Distribution Financial Statements Time Records Subsidiary Journals Chart of Accounts Audit Trail Written policies and procedures.

7 Elements of a Financial Management System Supporting Costs Billed Costs must be Allowable Allocable Reasonable Necessary See Cost Principles 2 CFR 200 Subpart E

8 Elements of a Financial Management System Direct vs. Indirect Costs Direct Costs Any cost that can be specifically identified to a cost objective Indirect Costs Costs incurred for a common purpose and not readily assignable to a cost objective

9 Elements of a Financial Management System Examples of Direct Costs Labor/time charges performing technical work on the regional transportation plan Regional Planning Model/Software Other costs that are directly related to projects/work elements Consultant Direct Costs

10 Elements of a Financial Management System Examples of Indirect Costs Office/Admin Salaries Rent Utilities Printing Telephones Office Supplies Office Software

11 Exercise Labor Audrey Hale, Executive Director Planning Activities 102 Projects Attending Board Meeting Evan Philips, Project Engineer Design Work on 101 Project Robert Levine, Director of Finance Preparing Financial Statements Ronda McKinney, Project Manager Chairing Taxpayers Q&A Meeting Arthur Taylor, Transportation Planner Planning Activities on 103 Project Jerome Cordes, Accountant Reconciling G/L Direct or Indirect? Direct Indirect Direct Indirect Indirect Direct Indirect Allowable or Unallowable? Allowable Allowable Allowable Allowable Allowable Allowable

12 Exercise Services and Supplies Office Rent Project Mapping Program Computers Postage Attorney Fees Utilities Lobbying Fees Travel to Transportation Conference Travel to Job Site Lunch for Staff Meeting Direct or Indirect? Indirect Direct Indirect Indirect Indirect Indirect Indirect Indirect Direct Depends Allowable or Unallowable? Allowable Allowable Allowable Allowable Depends Allowable Unallowable Allowable Allowable Unallowable

13 Exercise Labor Amount Project 101 Project 102 Project 103 Evan Philips $8,000 20% 50% 30% Ronda McKinney $5,000 40% 60% 0 Arthur Taylor $4, % 90% Services and Supplies Mapping Program Travel to Job Site Amount Project 101 Project 102 $2,000 50% 50% $3,000 30% 30% 40% Project 103

14 Exercise Project Cost Records Perfect Planning Project Description Cost Pompous Planning Project Description Cost Evan Philips 1,600 Ronda McKinney 2,000 Mapping Program 1,000 Travel 900 Total Direct Costs $ 5,500 Evan Philips 2,400 Arthur Taylor 3,600 Mapping Program 1,000 Travel 1,200 Total Direct Costs $ 8,200 Pitiful Planning Project Description Cost Evan Philips 4,000 Ronda McKinney 3,000 Arthur Taylor 400 Travel 900 Total Direct Costs $ 8,300

15 Elements of a Financial Management System Elements of Time Reporting Signed and approved time sheets Record all actual hours, including unpaid OT Identify direct and indirect hours, and PTO

16 Elements of a Financial Management System Financial records need to trace back to source documents. Leave an audit trail! Properly identify and segregate hours on time sheets. Assign unique accounting codes to cost objectives, e.g. project codes. Reconcile subsidiary systems/spreadsheets with your G/L. Maintain written policies and procedures train staff.

17 Elements of a Financial Management System Without an adequate financial management system you will not be able to accurately bill for direct costs or have an ICAP/ICRP.

18 Elements of an ICAP/ICRP Purpose of an ICAP/ICRP (ICAP) Purpose of an ICAP is to equitably allocate allowable indirect costs to all projects/work elements (cost objectives) through an annual indirect rate.

19 Elements of an ICAP ICAP Considerations Consider if you need to have an ICAP: Do a cost benefit analysis. Cost vs reimbursement. Costs associated with the preparation of an ICAP, which may include contracting out or using in-house personnel. Costs associated with the time working with the auditor for the ICAP can be extensive. Determine whether you should submit an ICAP package, request a De Minimis Rate or continue funding indirect costs with local funding. State and federal funding consideration Do you have funds remaining after you bill direct costs? Reimbursed Indirect costs are not additional funding. Indirect costs are reimbursed from your current funding allocations.

20 Elements of an ICAP/ICRP ICAP Considerations Cont d How many employees do you have, 2 or 20? Or do you contract out all your employees? Are you a separate entity or part of the County? Do you record your indirect costs in your General Ledger? Or does the County pay for your indirect costs?

21 Elements of an ICAP List of Frequent ICAP Submission Issues Prior fiscal year labor costs incurred in one year but recorded in another fiscal year, which affected the base LGA does not bill actual Fringe benefit costs, instead bills an estimated fringe benefit rate, however LGA does not have an approved fringe benefit rate separate from the ICAP rate The ICAP submission package did not include required financial data such as audited financial statements, general ledger and single audit The ICAP supporting subsidiary work sheets were no cross-referenced and reconciled to financial data The ICAP submittal includes figures that are not explained, referenced and/or require supporting documents The ICAP methodology is not consistent with LGA s billing methodology and records The ICAP did not reflect the LGA s actual costs and records LGA does not prepare proper timesheets to support labor costs in ICAP The contractual relationship between local agency and consultant may create a conflict of interest when the executive director has a financial interest in the consultant contract

22 Elements of an ICAP/ICRP Type of Submission Processes Complete ICAP package De minimis rate Certification only Extension request of current negotiated rate(s) Other federal cognizant agency (For full details of all processes See Attachment A through E, of A&I ICAP Submission Process, A&I Webpage)

23 Elements of an ICAP/ICRP Complete ICAP package: The ICAP Checklist (Attachment C) The ICAP schedule (Attachment E) including subsidiary work sheets cross-referenced to supporting financial data Supporting financial data: Financial Statements Single Audit Comprehensive Annual Financial Report Executive Budgets Accounting Reports Signed Certification (Attachment D) If package is complete and in compliance with 2 CFR 200, A&I will issue an acceptance letter within 30 business days.

24 Elements of an ICAP/ICRP De Minimis Rate Submission Send a letter signed by an official to A&I requesting to charge a de minimis rate. Submit to A&I the 10% De Minimis Indirect Cost Rate Certification. Found at the website: A&I will notify you if you do not qualify for the use of a de minimis rate.

25 Elements of an ICAP/ICRP De Minimis Rate You may elect to charge the de minimis rate of 10% of modified total direct costs if the following conditions are met: Have never received a negotiated indirect cost rate Receive less than $35 million in direct federal funding A De Minimis rate may be used indefinitely. ( f)

26 Elements of an ICAP/ICRP Modified total direct cost = De minimis Rate Cont. All direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award). Modified total direct cost excludes equipment, capital expenditures, rental costs, and the portion of each subaward in excess of $25,000. Other items may only be excluded when necessary to avoid a serious inequity in the distribution of indirect costs, and with the approval of the cognizant agency for indirect costs. (200.68)

27 Elements of an ICAP/ICRP De minimis Rate Cont. Records Costs must be consistently charged as either indirect or direct but may not be double charged or inconsistently charged as both. ( f) You must still have an adequate financial management system when using a de minimis rate.

28 Elements of an ICAP/ICRP Records cont d Financial management system Account numbers identifying allowable direct, indirect, and unallowable cost accounts. Ability to accumulate and segregate allowable direct, indirect and unallowable costs into different cost accounts. Ability to accumulate and segregate allowable direct costs by project, funding source, and type of cost (e.g.: labor, consulting, pass-thru, or other). Internal controls to maintain integrity of financial management system. Ability to consistently record and report costs as described in 2 CFR Ability to ensure costs billed are in compliance with 2 CFR Part 200. Ability to ensure costs billed reconcile to general ledgers and job costing ledgers. Ability to ensure costs are in compliance with contract terms and federal and state requirements.

29 Elements of an ICAP/ICRP De minimis Rate Cont. Records Cont d Records that support the Financial Management System: General ledger and job costing ledgers. Subsidiary general ledgers. Chart of accounts. Time keeping records. Documents supporting actual costs (e.g. invoices, canceled checks). Accounting policy and procedure manuals specific to the agency.

30 Elements of an ICAP/ICRP Certification only Submission ICAP Checklist (Attachment C) Signed Certification (Attachment D) You may be Eligible if you Did NOT meet any of the following: This is the first submission Received more than $35 million in direct federal funding Designated high risk Changed ICAP calculation methodology Revised most recent ICAP due to an improper, inaccurate, or unsupported rate calculation Had a major change to the Financial Management System If LGA is eligible, A&I will sign the certification and issue an acceptance letter within 10 business days.

31 Elements of an ICAP/ICRP Extension request of current negotiated rate(s) This is an option for agencies that already submit an ICAP, if you are interested please see A& I website for ICAP submission process.

32 Elements of an ICAP/ICRP Other federal cognizant agency LGAs with an ICAP approved by a cognizant federal agency other than FHWA/CT will submit a copy of the cognizant federal agency s approval to A&I. A&I will issue an acknowledgement letter.

33 Audits Performed Audits are selected on a risk-based approach based on factors such as Audit history Past and current issues Amount of federal or state funds received Special requested audits (Federal Govt/Caltrans Programs) Typical audits performed ICAP/ICRP Incurred Cost Pre-award

34 Types of Audits ICAP/ICRP audit of financial management system, testing direct and indirect accounts, ICAP/ICRP development methodologies. Incurred Cost - audit of financial management system, procurement, and costs billed to Caltrans Pre-award audit of financial management system

35 References and Resources Title 2 Code of Federal Regulations Part 200 Uniform Administrative Requirements, Cost Principles, And Audit Requirements for Federal Awards Title 48 CFR Chapter 1 Part 31 Federal Acquisition Regulation Caltrans A&I ICAP/ICRP Submission Processes Caltrans Local Assistance Procedures Manual RTPA Administrative Guidebook

36 A&I Contacts Teresa Greisen Amada Maenpaa Audit Manager Audit Manager (916) (916) Carvin Seals MarSue Morrill, CPA Auditor Chief, External Audits Local Governments (916) (916)