What Happens to Indirect Rates under the Uniform Guidance Bag Lunch Webinar November 19, 2015
|
|
- Simon Patrick
- 6 years ago
- Views:
Transcription
1 What Happens to Indirect Rates under the Uniform Guidance Bag Lunch Webinar November 19, 2015
2 Presenter: Paul H. Calabrese Rubino & Company, CPAs & Consultants Senior Manager Tel: Copy of this presentation: 2
3 Sources 2 CFR 200 Uniform Administrative, Cost Principles & Audit Requirements for Federal Awards Includes COFAR FAQ dated 9/9/2015 Indirect Cost Rate Proposal formats for DOL, DOJ and NSF
4 Overview Impact of Uniform Guidance on Indirect Rates What is new with Indirect Rates Negotiation & Administration of Rates Types of Allocation Bases Simple, Multiple, Direct & Special Rates Overview of the Indirect Cost Rate Proposal formats for DOL, DOJ & NSF
5 Impact of the Uniform Guidance
6 Uniform Guidance: Structure at a Glance Subpart A: Definitions Subpart B: General Conditions Subpart C: Pre-Award Conditions Subpart D: Post-Award Requirements Subpart E: Cost Principles Subpart F: Audit Requirements Appendix IV: (4) Allocation Methods for Nonprofit Entities 6
7 Uniform Guidance 2 CFR 200 When is it effective? COFAR FAQ: (8/29/14) Negotiated F&A Indirect Rates (NICRAs) and Cost Allocation Plans (CAP) for all recipients FAQ Existing NICRAs remain in power until they are due to be renegotiated based on old OMB Circulars. For new rules to apply, the NICRA or CAP Fiscal Year has to begin as the first full FY on 12/26/14 or later. Example: Under old rules, use allowances were allowable as a part of depreciation cost principle and are still in effect post 12/26/14 until the F&A NICRA is due to be re-negotiated 7
8 Uniform Guidance 2 CFR 200 When is it effective? COFAR FAQ: (8/29/14) Effective Date for Indirect Cost Rate Proposals (ICRP) using new rules FAQ Applicable for the first full FYs beginning after 12/26/14 8
9 Uniform Guidance 2 CFR 200 COFAR FAQ Update: (8/29/14) FAQ There is no requirement to have an indirect rate. Claiming reimbursement for indirect costs is never mandatory. However, once you submit annual ICRPs for a NICRA, they re required 6 mos after yearend. COFAR recognizes There are some entities that are able to charge 100% of their cost direct and so need for an indirect rate. A non-federal entities may conclude that the amount of indirect cost they might recover may be too immaterial to justify the effort to obtain a negotiated indirect rate. 9
10 Uniform Guidance 2 CFR 200 COFAR FAQ Update: (9/9/15) FAQ.19-1 Cognizant Agency for Indirect Cost Even though a cognizant agency does not allow the NFE to recover indirect cost Such cognizant agency is still responsible to negotiate indirect cost 10
11 Uniform Guidance 2 CFR 200 COFAR FAQ Update: (9/9/15) FAQ.19-1 Cognizant Agency for Indirect Cost Example: Under a RWHAP grant, NFE charges the 10% administrative cost direct to the award, thus cannot recover any indirect on grant, but HHS still has to negotiate NFE s indirect rates for other grants (adm $ can be charged direct or indirect) Grant administration and monitoring (labor) of their subrecipients under RWHAP Part B is subject to the 10% administrative cap per PCN & R/W fiscal monitoring stds Indirect labor charged direct to award is removed from the indirect cost pool and may avoid double-charging 11
12 Uniform Guidance 2 CFR 200 COFAR FAQ Update: (9/9/15) FAQ.68-1 Number of sub-awards under a MTDC allocation base If the period of performance of an award requires the renegotiation of a sub-award 2 or more times Each new sub-award up to $25,000 can be included multiple times in the MTDC base The allowance of $25,000 in the MTDC base is for the life of the award, or each performance period 12
13 Uniform Guidance 2 CFR 200 COFAR FAQ Update: (9/9/15) FAQ The requirement to have a current Federally negotiated, final indirect rate for Extension To be current, NFE must comply with the following: Extensions can only happen after 12/26/14 If NFE has 12/31 year-end Must have final rates through 12/31/14 & completed Single audit completed by 9/30/15 Submit final indirect rates for 12/31/15 + audit by 9/30/16 Then, NFE could request an extension of their FY 15 final indirect rate for FY s 2016 up to FY 2019, applicable to grants Rate extensions do not apply to cost reimbursable contracts
14 Uniform Guidance 2 CFR 200 COFAR FAQ Update: (9/9/15) FAQ Voluntary under-charging, or waiving the recovery of 100% of applied indirect costs If a NFE (prime or sub) voluntarily (without coercion) decides to charge less than the established negotiated rate or waive the NICRA entirely, is a permissible practice Sometimes the NFE requires more funds for direct program efforts and thus reduces the amount of applied indirect or no indirect rate though they have a negotiated indirect rate 14
15 Uniform Guidance 2 CFR 200 COFAR FAQ Update: (9/9/15) FAQ NFE s Applying for De Minimis Rates having a break in Federal relationship If a NFE has a previously negotiated indirect rate but all Federal awards under that NICRA have expired as well as the NICRA Can the NFE apply for a 10% de minimis rate? NO. The 10% de minimis rate is only for those who have never had a negotiated indirect rate. The Government expects org s that have had experience developing & negotiating rates in the past, will have the adequate resources to prepare new indirect rates 15
16 Uniform Guidance 2 CFR 200 COFAR FAQ Update: (9/9/15) FAQ % De Minimis Rate (DMR) & Period of Applicability The DMR may or may not apply to the entire Period of Performance (PoP) The NFE may start with a DMR and later during the PoP elect to obtain a negotiated rate DMR and negotiated indirect rates align with a NFE s fiscal year, not with a grant s PoP Grants don t start and end with a NFE s fiscal year, thus 2 fiscal years are involved, and 2 different indirect rates are involved in 1 grant yr 16
17 Uniform Guidance 2 CFR 200 COFAR FAQ Update: (9/9/15) FAQ % De Minimis Rate (DMR) & Single Function NFE The DMR cannot be used for a single function NFE who charges 100% of their cost direct The DMR is intended to be used to pay for overhead or indirect costs that are not directly assignable to a Federal award As prescribed in (d) a cost for the same purpose charged as a direct cost to a Federal award cannot be also be charged for the same purpose as an allocated indirect cost 17
18 What s New with Indirects
19 Subpart E Cost Principles Uniform Guidance : New Optional Rate 10% de minimis rate: per (f) Never received a negotiated indirect rate Charge on a modified total direct cost base May use indefinitely until negotiate an indirect rate Direct and indirect costs charged consistently but not as both causing double-charging Use consistently on all Federal awards 19
20 Subpart E Cost PrinciplesFAQ Uniform Guidance: State, Local&Tribal Units State, Local, Tribal Governmental units can have a 10% de minimis rate per prior slide The amount of Federal awards for that unit of government has to be less than $35 Million per fiscal year They must document decision on file to select the 10% de minimis rate Never have received a NICRA indirect rate Per Appendix VII, D(1)(b) 20
21 Subpart E Cost Principles Uniform Guidance: New NICRA Extension NFE has existing negotiated indirect rate: One-time extension of current indirect rate For a period of up to 4 years If granted, cannot request a rate review until extension period ends At end of 4 year period, must re-apply to negotiate a new rate 21
22 Subpart E Cost Principles Uniform Guidance: FAQ The extension period can be 1, 2, 3, or 4 years The extension period is once for each negotiation cycle Once the extension period is over, org negotiates a new rate and then that NICRA can be extended again for up to 4 years Can only be done for predetermined and final rates not for provisional or fixed 22
23 Subpart E Cost Principles Uniform Guidance: (11/26/14) FAQ & 3 Is there special documentation requirements for an extension? No, the extension process is designed to reduced administrative burden What about the time of the request for an extension. No later than 60 days prior to due date for proposal of indirect costs, or if after, on a case-by-case basis the agency can accept requests 23
24 Subpart E Cost Principles Uniform Guidance: New Options Direct cost allocation principle (d) 1. If cost benefits two or more direct programs 2. In proportions that can be determined without undue effort or cost (summer workshops) 3. Costs must be allocated to projects If 1 and 2 cannot determine proportions based on interrelation of work involved, then allocated on benefited projects on a reasonable documented basis Purchase of equipment or capital assets for a specific award are assignable to that award only regardless of use on other projects or no longer needed as acquired 24
25 Subpart E Cost Principles Uniform Guidance: New Options Direct charging of admin staff wages may be appropriate when all items are met: (c) Administrative services are necessary to a project Individuals involved can be specifically identified to a project, such as time reports Administrative wages are included in the budget or prior written approval from agency Such costs are not recovered as indirect cost 25
26 Subpart E Cost Principles Uniform Guidance: New Requirements Unallowable activities and donated services receive allocation of indirect costs (b) Costs allocable to a Federal award may not be charged to cover fund deficiencies to avoid restrictions in the regulations (c) Limitation on allowable costs If maximum amount allowable under a limitation is less than total amount determined, the delta is not recoverable and cannot be charged to another award 26
27 Subpart E Cost Principles Uniform Guidance: New Requirements Payments made for costs determined to be unallowable must be refunded including interest to Federal government Unallowable by Federal awarding agency Cognizant agency for indirect cost Pass-through entity Either direct or indirect unallowable cost 27
28 Subpart E Cost Principles Uniform Guidance: New Requirements Adjustments of previously negotiated indirect cost rates containing unallowable costs Negotiated indirect cost rates later found to have costs: 1. Unallowable specified by Federal statutes, regulations or terms and conditions of a Federal award 2. Unallowable as not allocable to Federal award(s) Must be adjusted for a refund Adjustments are used to correct established negotiated rates Will not re-open for rate negotiation Applied to all types of rates: fixed, final, predeter, prov. 28
29 Subpart E Cost Principles Uniform Guidance: New Requirements Adjustments of previously negotiated indirect cost rates containing unallowable costs For projected rates of a future year, the costs are removed from cost pools and rates appropriated adjusted downward For historical rates of a past period, the unallowable costs will be computed by fiscal year and a cash refund including interest For current year rates, either a rate adjustment or refund per cognizant agency 29
30 Subpart E Cost Principles Uniform Guidance: New Requirements Adjustments of previously negotiated indirect cost rates containing unallowable costs For multiple years, the proportional amount of unallowable costs in the base year will be extrapolated to the out-year rates 30
31 Subpart E Cost Principles Uniform Guidance: New Certifications Assure proper expenditures (a) Certifying project budgets, annual and final fiscal reports or vouchers requesting payments By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may be subject to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. 31
32 Subpart E Cost Principles Uniform Guidance: New Certifications Certification of indirect rates (b) An Indirect Cost Rate Proposal (ICRP) must have a Certificate of Indirect Costs signed at a level not lower than VP or CFO Cost are not unallowable and not in-allocable If an ICRP does not include a certification The agency can unilaterally disallow all indirect costs The agency can unilaterally establish their own rate based on historical cost or other such data, to ensure that unallowable costs won t be reimbursed. 32
33 Indirect Rate Negotiation and Administration
34 No indirect rate system fits all 2 CFR (b) 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. 34
35 Advance Understandings Prior Written Approval Under any award, the allocation and reasonableness 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 Examples provided such as pre-award costs 35
36 Indirect Cost Allocations Appendix IV B.1.e to 2 CFR 200 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 36
37 Indirect Rate Administration Appendix IV C to 2 CFR 200 Negotiation and Approval of Indirect Rates Agency with largest dollar value = cognizant agency Appendix IV C.2 Indirect rate proposal submitted 90 days after new award to an organization App. IV C.2.b 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 37
38 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 Appendix IV C.2.c Note: Cognizant agency has the option of deciding how often a NICRA is required. 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. Appendix IV C.2.d 38
39 Indirect Rate Administration Fixed (ceiling) rates are similar to predetermined rates except: App. IV C.2.e 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 Appendix IV C.1.d & C.2.f Based on actual cost for period Once negotiated, not subject to adjustment 39
40 Indirect Rate Administration Provisional Rate Appendix IV C.1.e & C.2.f Temporary indirect cost rate pending final rate Used for funding, interim billing or cost reporting The results of any negotiation is distributed to other participating agencies Appendix IV C.2.g Negotiating rates must be accepted by ALL Federal awarding agencies (c)(1) Many clients complain they cannot find the office for negotiating indirect rate Look at conditions clauses attached to grant 40
41 (4) Allocation Methodologies
42 Simplified Allocation Method App. IV B.2 Single purpose entity, small or large nonprofit with small amount of awards Separate allowable indirect less credits from direct cost Divide indirect by direct cost base (w/unallowable $) Facility cost is combined with administrative pool Facility cost supports direct and indirect personnel 42
43 Construction of an F&A Rate Indirect cost classified into two broad activities: Appendix IV B.3.b Facilities: buildings, equipment and capital investments, maintenance and operation expenses and interest Administration: general administration, director s office, accounting, HR, library expenses and other types of expenditures not mentioned under facility 43
44 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 (a) last sentence of, Appendix IV B.2.e 44
45 G&A Bases (denominator) General & Administrative MTDC Base App. IV B.2.c 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 Appendix IV B.2.c G&A Salary Base (per HHS indirect template) Only direct labor Results of special cost studies must not be used to determine and allocate indirect cost to Federal awards per Appendix IV B.3.c (last sentence of paragraph) 45
46 Distribution Basis for MTDC Appendix IV B.2.c 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 (rent removed) Participant support cost must be excluded 46
47 Direct Cost (e) Cost of Certain Activities Direct Cost Functions Remain in MTDC base though unallowable, must be treated as direct costs to determine ind. rates Fundraising Membership Promotion, lobbying, & public relations Bid & Proposal allowable B&P is not fund raising per 45 CFR Proposal Costs new cost principle
48 Allocate occupancy direct
49 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 49
50 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 a proportion of an office space is devoted to grant is 1,000/10,000 SF for 10% of total rental cost ($5,000/month = $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 50
51 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 Appendix IV B.3.c(1)(c) & (d) Direct and indirect FTE positions Hours worked direct and indirect Direct and indirect labor dollars 51
52 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 budget 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 Appendix IV B.4 Direct Allocation Method 52
53 Multiple Cost Pools Step Allocations & Overhead
54 Multiple Allocation Method Appendix IV B.3.a and 3.b 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 54
55 55
56 Step Allocation / Order Appendix IV B.3.d Order of Distribution Costs assigned to direct programs + adm dept s Fringe allocated to all dept s including G&A Occupancy allocated to all dept s including G&A Program Administration (PA) can be allocated PA is not G&A PA cannot be recovered under OMB Special allocation of studio G&A allocated to through
57 Special Rates & Double-Charging
58 Special Indirect Cost Rates Appendix IV B.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 58
59 Special Indirect Cost Rates Appendix IV B.5 Bifurcated G&A to avoid double-charging Same administrative 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 59
60 60
61 Any Questions 61
62 The materials contained herein or discussed in this webinar 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
Indirect Cost Rates & What Happens Under. Paul H. Calabrese Rubino & Company, CPAs & Consultants Senior Manager
Indirect Cost Rates & What Happens Under the New Super Circular Presenter: Paul H. Calabrese Rubino & Company, CPAs & Consultants Senior Manager Tel: 301-214-4137 pcalabrese@rubino.com www.linkedin.com/pub/paul-calabrese/20/293/645/
More informationHow to Develop Indirect Rates Under the New Super Circular. Part 1 Webinar 1 or 2 Slide Decks Rubino & Company, Chartered May 8, 2014
How to Develop Indirect Rates Under the New Super Circular Part 1 Webinar 1 or 2 Slide Decks Rubino & Company, Chartered May 8, 2014 Click Update to / Impact edit Master of Super Circular text styles Definitions
More informationIndirect Cost Rates For Nonprofit Organizations
Indirect Cost Rates For Nonprofit Organizations Bag Lunch Webinar May 8, 2013 All slides and handouts copyright 2013, Rubino & Company, Chartered Presenter: Paul H. Calabrese Rubino & Company, CPAs & Consultants
More informationIndirect Cost Rates For Nonprofit Organizations
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
More informationDeveloping Indirect Cost Rates for Non Profits: Practical Approaches
Presenting a live 110 minute teleconference with interactive Q&A Developing Indirect Cost Rates for Non Profits: Practical Approaches WEDNESDAY, JUNE 6, 2012 1pm Eastern 12pm Central 11am Mountain 10am
More informationHow to Develop Indirect Cost Rates For Nonprofit Organizations
How to Develop Indirect Cost Rates For Nonprofit Organizations 2010 Government and Not-For-Profit Conference UMD University College Adelphi, Maryland April 30, 2010 Presenter: Paul H. Calabrese Rubino
More informationIntroduction to Indirect Costs
Introduction to Indirect Costs GMS Summit St. Petersburg, FL June 12 16, 2016 Presented by: Jason D. Brooks, CPA 1 About the Author Jason D. Brooks, CPA is a partner with Watkins, Ward and Stafford, PLLC
More informationBasics of F&A: A University Perspective. Alex Weekes Principal ML Weekes & Company, PC
Basics of F&A: A University Perspective Alex Weekes Principal ML Weekes & Company, PC 203-458-0872 alex.weekes@mlweekes.com Agenda Accountant s reconciliation of the old to new rules Overview of F&A General
More informationIndirect Cost Rates A Non-Profit Perspective. Alex Weekes Principal ML Weekes & Company, PC
Indirect Cost Rates A Non-Profit Perspective Alex Weekes Principal ML Weekes & Company, PC 203-458-0872 alex.weekes@mlweekes.com Agenda Old School versus new regulations Review of 2CFR 200 (not so new
More informationU.S. Department of Housing and Urban Development Office of Housing Counseling
U.S. Department of Housing and Urban Development Office of Housing Counseling Understanding Indirect Cost Rates, De Minimis Rate, and Cost Allocation Plans Booth Management Consulting 7230 Lee Deforest
More informationThe Basics of F&A and How the Uniform Guidance Impacts Indirect Costs
The Basics of F&A and How the Uniform Guidance Impacts Indirect Costs Alex Weekes Principal ML Weekes & Company, PC 203-458-0872 alex.weekes@mlweekes.com Indirect Costs / Facilities and Admistrative Cost
More informationMark W. Stout, MBA DOI Interior Business Center Indirect Cost Services - Sacramento April 2017
Mark W. Stout, MBA DOI Interior Business Center Indirect Cost Services - Sacramento April 2017 About ICS General Principles Uniform Guidance Direct, Indirect, Unallowable, Exclusions Distribution Base
More informationT-203 F&A Cost Rates and the Uniform Guidance, A Non-Profit Perspective
T-203 F&A Cost Rates and the Uniform Guidance, A Non-Profit Perspective Alex Weekes Principal ML Weekes & Company, PC 203-458-0872 alex.weekes@mlweekes.com Agenda Regulations (Current and New) Rate Types
More informationIndirect Cost Rate Development for Non-Profits Navigating Accounting Standards and Best Practices to Calculate and Assign Expenses
Presenting a live 110-minute teleconference with interactive Q&A Indirect Cost Rate Development for Non-Profits Navigating Accounting Standards and Best Practices to Calculate and Assign Expenses TUESDAY,
More informationIntroduction to Indirect Costs
Introduction to Indirect Costs Questions to be Answered What are indirect costs? How are they documented? How are they recovered? Points to Keep in Mind Indirect costs tend to be support costs (e.g., telephone,
More informationCOST ISSUES PART 2: INDIRECT COST RATES, WHAT THEY ARE & WHAT YOU NEED TO KNOW
COST ISSUES PART 2: INDIRECT COST RATES, WHAT THEY ARE & WHAT YOU NEED TO KNOW Edward (Ted) Waters, Esq. Scott Sheffler, Esq. August 4, 2016 1 AGENDA Cost Allocation and Indirect Costs Direct Costs vs
More informationIndirect Cost Allocation
Indirect Cost Allocation FGFOA School of Governmental Finance November 2, 2015 2:00pm 2:50pm 1 Agenda Why Perform Cost Allocation? Terminology & Definitions Types of Cost Allocation Plans Cost Allocation
More informationAllocating Direct and Indirect Costs for Nonprofits
Allocating Direct and Indirect Costs for Nonprofits Carol Barnard April 18, 2018 Agenda Allocating Indirect Cost Why allocating costs is important to nonprofits Identifying indirect costs Different methods
More informationInitial COGR observations on definitions are intertwined with the applicable sections below.
COGR Preliminary Assessment of Selected Items OMB Uniform Administrative Requirements, Cost Principles, and Administrative Requirements for Federal Awards January 14, 2014 Below is COGR s preliminary assessment
More informationTexas Association of Community Action Agencies (TACAA) 2016 Conference. May 18 20, 2016 San Antonio, TX Holiday Inn Riverwalk Hotel.
Texas Association of Community Action Agencies (TACAA) 2016 Conference May 18 20, 2016 San Antonio, TX Holiday Inn Riverwalk Hotel Cost Allocation Thursday, May 19, 2016 8:30 am 10:00 am Presented by:
More informationAdministrative Procedure
Division of Finance and Administration AP F&A-02 Administrative Procedure Title: Responsible Office: Adopted: June 1, 2017 Revised: Effective: June 1, 2017 Indirect Cost Rate Instructions for DEO Subrecipients
More information6/5/2014. Cost Allocation Overview. Overview (continued) Overview. Overview (continued) Overview (continued)
Cost Allocation Overview OHIO ASSOCIATION OF PUBLIC TREASURERS Public Finance Officer Training Institute June 2014 MAXIMUS Robert Fink, Sheri Smith, & Linda Hlebak Learning Objectives Cost Allocation Plan
More informationUniform Guidance vs. OMB Circulars
Cost Allocation 101 Uniform Guidance vs. OMB Circulars Prior to the Uniform Guidance, requirements Designed for governing DOL-ETA cost direct principles, recipients and administrative their subrecipients
More informationAmy Roberts, Appalachian State University
Amy Roberts, Appalachian State University Originally referred to as A-81, the Super Circular, or the Omni Circular Consolidates 8 previous Circulars All Federal funding agencies are required to implement
More informationWebinar: Are you Prepared for the Supercircular? February 2014
Webinar: Are you Prepared for the Supercircular? February 2014 BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee,
More informationCost Pools, Indirect Rates & Allocation Plans: Demystified
Cost Pools, Indirect Rates & Allocation Plans: Demystified Maryland Workforce Association 2017 Raising the Bar Conference: Preconference Workshop May 3, 2017 1:00-2:30pm Baker Tilly refers to Baker Tilly
More informationOMB. Uniform Guidance
2014 OMB Uniform Guidance Assessing the OMB Uniform Guidance: Major Changes and Impacts The Office of Management and Budget (OMB) consolidated the federal government s guidance on Uniform Administrative
More informationImplementation and Readiness Guide for the OMB Uniform Guidance Prepared by the Council on Governmental Relations (COGR) Introduction
Implementation and Readiness Guide for the OMB Uniform Guidance Prepared by the Council on Governmental Relations (COGR) DECEMBER 12, 2014 VERSION Introduction The Implementation and Readiness Guide for
More informationIns and Outs of Super Circular II: Cost Principles & Audit Requirements
Ins and Outs of Super Circular II: Cost Principles & Audit Requirements CAPLAW Strategic Issues Facing CAAs Webinar Series April 23, 2014 CAPLAW www.caplaw.org 617.357.6915 Subpart E Cost Principles 2
More information2 CFR 215 (A-110) or 2 CFR 230 (A-122) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.
Significant Changes for Selected Items of Cost Office of Management and Budget Guidance PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS Item of
More informationHRSA/HAB Site Visits: Top Findings
Ryan White HIV/AIDS Program Fiscal Health Series Systems to Sustainability TM HRSA/HAB Site Visits: Top Findings INTRODUCTION Sound fiscal management is critical for organizations to improve access to
More informationDo You Get Federal Funds? Find out What s Changing with Uniform Guidance
Minnesota Council of Nonprofits 2015 MCN Annual Conference October 1 2, 2015 St. Paul, MN St. Paul RiverCentre Find out What s Changing with Uniform Guidance Thursday, October 1, 2015 3:45 pm 5:00 pm Presented
More informationNonprofit Financial Management Network
August 14, 2015 1 Nonprofit Financial Management Network Gregory Demetriades, CPA CFO, Community Partners David J. Thomas, CPA, CGMA Managing Partner, 2 1 8:30am-9:00am Registration & Breakfast 9:00am-9:10am
More informationIns and Outs of Indirect Costs Under the Super Circular Webinar Series
Ins and Outs of In Costs Under the Super Circular Webinar Series March 4: Does Our CAA Effectively Estimate and Reconcile In Costs? Miss a webinar? View it On Demand www.caplaw.org/conferencesandtrainings/webinars.html
More informationThe COGR Perspective on the OMB Uniform Guidance: A First Look
The COGR Perspective on the OMB Uniform Guidance: A First Look COGR Meeting Thursday, February 27, 2014 Washington Marriott Hotel Washington, D.C. Agenda for this Session The Big Picture and the Next 12
More information10 Frequently Asked Questions on Indirect Costs
1 10 Frequently Asked Questions on Indirect Costs Bonnie Graham, Esq. bgraham@bruman.com (202) 965-3652 www.bruman.com First, some background 2 Total Cost of Federal Awards Indirect 10% Direct Indirect
More informationIns and Outs of Indirect Costs Under the Super Circular Webinar Series
Ins and Outs of In Costs Under the Super Circular Webinar Series Miss a webinar? View it On Demand www.caplaw.org/conferencesandtrainings/webinars.html What Impact Does the New Guidance Have on the Treatment
More informationFacilities & Administrative Costs: Balancing Sponsor Requirements and Institutional Needs
Facilities & Administrative Costs: Balancing Sponsor Requirements and Institutional Needs Kimberly Read, PhD, CRA Assistant Director Florida Center for Inclusive Communities University of South Florida
More informationPreparing your AAA Area Plan Budget & Cost Allocation Plan. Fiscal Track AM Workshop Session May 29, :30 AM - Noon
Preparing your AAA Area Plan Budget & Cost Allocation Plan Fiscal Track AM Workshop Session May 29, 2014 10:30 AM - Noon 1 Why is Cost Allocation Important? What are the State and Federal requirements
More information2 CFR Part 200 Uniform Guidance
2 CFR Part 200 Uniform Guidance Lisa Mosley Executive Director, Research Operations Michele Wrapp Associate Director, Research Operations December 15, 2014 200.110 Effective/applicability date Applies
More informationIllinois Coalition Against Domestic Violence. Understanding the Uniform Guidance and Indirect Cost Rate March 16, 2016
Illinois Coalition Against Domestic Violence Understanding the Uniform Guidance and Indirect Cost Rate March 16, 2016 1 Understanding the Uniform Guidance and Indirect Cost Rate Presented by: Teri L. Taylor,
More informationDecember Facilities and Administrative Costs Primer The Research Foundation for The State University of New York
December 2014 Facilities and Administrative Costs Primer The Research Foundation for The State University of New York Table of Contents Introduction... 3 Direct vs. Facilities and Administrative (F&A)...
More informationONR Guidance for Indirect Cost Rate Proposals for Non-Profits with less than $10M Federal Funding of Direct Costs in a Fiscal Year
ONR Guidance for Indirect Cost Rate Proposals for Non-Profits with less than $10M Funding of Direct Costs in a Fiscal Year A non-profit organization will submit an indirect cost rate proposal primarily
More informationUniform Guidance Update
National Head Start Association 44 th Annual Head Start Conference and Expo April 7 10, 2017 Nashville, TN Hyatt Regency Chicago Uniform Guidance Update Sunday, April 9, 2017 4:00 pm 5:00 pm Presented
More informationFACILITATED BY: Robin Booth, CPA
U.S. Department of Housing and Urban Development Office of Housing Counseling Applying and Computing the 10% De Minimis Rate November 22, 2016 2:00 PM (EST) Facilitated by Booth Management Consulting,
More informationU.S. Department of Housing and Urban Development Office of Housing Counseling
U.S. Department of Housing and Urban Development Office of Housing Counseling Facilitated by Booth Management Consulting 7230 Lee Deforest Drive, Suite 202 Columbia, MD 21046 Preparing a Budget October
More informationUnderstanding the Cost Accounting Standards. Bag Lunch Webinar May 9, 2018
Understanding the Cost Accounting Standards Bag Lunch Webinar May 9, 2018 1 Co-Presenter: Paul H. Calabrese Rubino & Company, CPAs & Consultants Senior Manager n Tel: 301-214-4137 n pcalabrese@rubino.com
More informationUnderstanding F&A Rates. OPTIONAL SUBHEAD HERE Sara Tarkington January 23 rd, 2018
OPTIONAL SUBHEAD HERE Sara Tarkington January 23 rd, 2018 Why an F&A Cost Rate? It is federal policy to provide for the reimbursement of F&A costs except when specific limitations and prohibitions exist
More informationOMB Uniform Guidance Hot Topics and Implementation. July 18, 2014: The University of Alabama in Huntsville
Special attention will be paid to those sections of the that carry the most uncertainty and that may require significant institutional planning and preparation. The purpose of this session is not to provide
More informationFrequently Asked Questions
Frequently Asked Questions Updated: July 2017 For The Office of Management and Budget s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards At 2 CFR 200 The
More informationPART 3 COMPLIANCE REQUIREMENTS
PART 3 COMPLIANCE REQUIREMENTS INTRODUCTION The objectives of most compliance requirements for Federal programs administered by States, local governments, Indian tribal governments, and non-profit organizations
More informationF&A Methodologies- Short Form Schools with Long Form Consideration. August 15, 2017
F&A Methodologies- Short Form Schools with Long Form Consideration August 15, 2017 1 Agenda Overview of F&A Short Form (SF) Methodology Long Form (LF) Methodology Differences between Short Form & Long
More informationVGFOA Spring Conference
VGFOA Spring Conference Impact of the New Uniform Guidance on Cost Allocation Plans Nelson Clugston and Jason Jennings May 5, 2016 nelsonclugston@maximus.com jasonjennings@maximus.com 1 Overview and Key
More information2017 Single Audit Update
2017 Single Audit Update July 25, 2017 Webinar Presented in association with Presented by: Stephen W. Blann, CPA, CGFM, CGMA Director of Governmental Audit Quality Rehmann 2 Outline Components of a Single
More informationOMB Super Circular Proposed Uniform Guidance. RAC Forum April 10, 2013
OMB Super Circular Proposed Uniform Guidance RAC Forum April 10, 2013 Change is Coming Good news A-21 is gone! Bad news It s back and bigger than ever Circular Consolidation Super Storm? Extreme Makeover:
More informationU.S. Department of Housing and Urban Development Office of Housing Counseling
U.S. Department of Housing and Urban Development Office of Housing Counseling Facilitated by Booth Management Consulting 7230 Lee Deforest Drive, Suite 202 Columbia, MD 21046 Best Practices & Lessons Learned,
More informationThe Uniform Guidance: Changes and Strategies for Implementation
The Uniform Guidance: Changes and Strategies for Implementation Mark Davis Attain LLC Cindy Hope University of Alabama Kim Moreland University of Wisconsin Madison Jeffrey Silber Cornell University Topics
More informationONR SUBMISSION REQUIREMENTS FOR NONPROFIT INDIRECT COST RATE PROPOSALS - INITIAL CHECKLIST
ONR SUBMISSION REQUIREMENTS FOR NONPROFIT INDIRECT COST RATE PROPOSALS - INITIAL CHECKLIST 1. Transmittal Letter: State the type of rate requested (e.g. predetermined, fixed, provisional, or final) and
More informationCITY AND COUNTY OF SAN FRANCISCO UNDERSTANDING THE UNIFORM GUIDANCE & NONPROFIT UPDATE
CITY AND COUNTY OF SAN FRANCISCO UNDERSTANDING THE UNIFORM GUIDANCE & NONPROFIT UPDATE Agenda Understanding the Uniform Guidance Katherine V. Lai, Assurance Leader, MGO Mark Tillotson, Nonprofit Industry
More informationFLORIDA DEPARTMENT OF ECONOMIC OPPORTUNITY WEATHERIZATION ASSISTANCE PROGRAM
FLORIDA DEPARTMENT OF ECONOMIC OPPORTUNITY WEATHERIZATION ASSISTANCE PROGRAM NON-PROFIT GUIDANCE FOR DOCUMENTATION AND SUPPORT OF PROGRAM SUPPORT AND ADMINISTRATION EXPENDITURES Version 1 March 2013 NON-PROFIT
More informationUniform Guidance Super Circular 2 CFR Part 200
Uniform Guidance Super Circular 2 CFR Part 200 MSU First Looks and Future Plans May 27, 2014 Dan Evon, Contract & Grant Administration The Rules Contracts Federal Acquisition Regulations (FAR) Grants and
More informationContract Support Cost 101
Contract Support Cost 101 May 2014 Vickie Hanvey, CPA, MBA Cost Classification Administrative Direct CSC Indirect CSC Indirect Admin Direct Admin Start up Indirect Program Direct Program Indirect Program
More informationIndirect Costs, Cost Allocation, and Resource Sharing
November 30 December 2, 2016 Indirect Costs, Cost Allocation, and Resource Sharing Bonnie L. Graham, Esq. bgraham@bruman.com Michael Brustein, Esq. mbrustein@bruman.com www.bruman.com 1 Why Indirect Costs?
More informationNavigating the OMB Super Circular
Navigating the OMB Super Circular New Mexico Association of Community Partners 2014 Conference June 5, 2014 Eleanor Evans, Esq. CAPLAW (617) 357-6915 eleanor.evans@caplaw.org www.caplaw.org Navigating
More informationU.S. Department of Housing and Urban Development Office of Housing Counseling
U.S. Department of Housing and Urban Development Office of Housing Counseling Financial Grant Reporting April 21, 2015 12:00 PM Eastern Standard Time Facilitated by Booth Management Consulting, LLC 7230
More informationAdministrative Policy
Administrative Policy POLICY NUMBER 86 Title: Program: Indirect Cost Rate Proposal Preparation for Local Workforce Development Boards Division of Finance and Administration, Bureau of Financial Management
More informationINDIRECT COST POLICY
INDIRECT COST POLICY The National Fish and Wildlife Foundation (NFWF) recognizes that in some instances, award recipients may have costs that are not directly attributable to projects or activities being
More informationFederal Grant Administration Guidelines
Federal Grant Administration Guidelines The following documents internal controls that are required to be in writing for federal grants in accordance with the Uniform Administrative Requirements, Cost
More information2018 Single Audit Update
2018 Single Audit Update July 24, 2018 Webinar Presented in association with Presented by: Stephen W. Blann, CPA, CGFM, CGMA Director of Governmental Audit Quality Rehmann 2 Outline Components of a Single
More information3 rd Annual Symposium for Research Administrators
3 rd Annual Symposium for Research Administrators Budgeting for Proposals John Sites, Interim Director for Pre-Award Services, Office of Sponsored Research Email: johj@email.unc.edu July 29, 2016 Who am
More informationOmni Circular Key Area #5 Indirect Costs and the Omni Circular: What to Expect. Total Cost of Federal Awards. Costing Options:
Omni Circular Key Area #5 Indirect Costs and the Omni Circular: What to Expect Leigh Manasevit, Esq. lmanasevit@bruman.com Spring Forum 2014 Total Cost of Federal Awards Indirect 10% Direct Indirect Direct
More informationEffective Cost Allocation Strategies
Effective Cost Allocation Strategies Kay Sohl Head Start Fiscal Conference April 5, 2011 kay@kaysohlconsulting.net Cost Allocation Systematic method for determining the portion of specific costs which
More informationPROCEDURE Determination of Allowable vs. Unallowable Expenses
PROCEDURE Determination of Allowable vs. Unallowable Expenses Background and Purpose In order to comply with Uniform Guidance Section 200.302(b)(7) which requires Written procedures for determining the
More informationEverything You ve Always Wanted to Know. About Indirect Costs. But Were Too Confused to Ask.
Everything You ve Always Wanted to Know About Indirect Costs But Were Too Confused to Ask. Presentation to RADG Harry W. Orf, PhD 10 June 2014 Page 1 2 What We Will Cover Federal Statutes That Govern Indirect
More informationPART 3 COMPLIANCE REQUIREMENTS
PART 3 COMPLIANCE REQUIREMENTS INTRODUCTION Overview The objectives of most compliance requirements for Federal programs administered by States, local governments, Indian tribes, institutions of higher
More informationService Center Policy and Procedures University at Albany
Service Center Policy and Procedures University at Albany Prepared by: Office of the Controller University at Albany Review Date: March 24, 2017 Table of Contents 1. Regulations 2 2. Definitions.. 3 3.
More informationUniform Guidance for Federal Awards Key Changes and Lessons
Uniform Guidance for Federal Awards Key Changes and Lessons Learned Kinman Tong, Senior Manager Moss Adams LLP 1 PRESENTER Kinman Tong, Senior Manager Kinman has been in public accounting since 2003. He
More information10/30/2015 OBJECTIVES. CPAs & ADVISORS. Present an overview of the Super Circular. Contents of the Super Circular. Discuss Administrative Requirements
CPAs & ADVISORS experience direction // 2 CFR 200 UNIFORM GRANT GUIDANCE Presented by Andy Richards, CPA, Partner October 30, 2015 OBJECTIVES Present an overview of the Super Circular Contents of the Super
More informationJanuary 16, DATES: Effective date: This interim final rule is effective on December 26, 2014
COGR Summary of Background and Technical Corrections to the OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards January 16, 2015 The interim joint final
More informationBUDGETARY DETAILS INFORMATION May 2015 With Uniform Guidance Changes NIFA reviews proposed project costs to make certain those costs are reasonable to the project and allowable per Title 2: 2 CFR Part
More informationChild Care Associates
FINANCIAL STATEMENTS For the Year Ended December 31, 2017 Table of Contents December 31, 2017 REPORT Independent Auditors Report 1 FINANCIAL STATEMENTS Statements of Financial Position 3 Statements of
More informationProject Managers are expected to apply this guidance document when charging direct or indirect costs to grants.
HOW TO DISTINGUISH BETWEEN DIRECT AND INDIRECT CHARGES Vincennes University Purpose As a recipient of federal funds, the Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational
More informationFlorida MIECHV Initiative Provider Fiscal Policy Manual
2018 Florida MIECHV Initiative Provider Fiscal Policy Manual Florida MIECHV Initiative This project is supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health
More informationCreating A Program Budget
Creating A Program Budget Defining a Program Budget ORGANIZATIONAL BUDGET: Applies to an entire organization's activity, including everything that the organization does. Therefore all the programs and
More informationCOGR Guide to the OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards VERSION 1: APRIL 17, 2014
COGR Guide to the OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards VERSION 1: APRIL 17, 2014 Introduction The OMB Uniform Administrative Requirements,
More informationDOI Self Governance Requested Reports. Vickie Hanvey, Program Policy Analyst
1 DOI Self Governance Requested Reports Vickie Hanvey, Program Policy Analyst Requested Reports/Data Mandatory reporting provisions are not included in Self-Governance regulations (25 CFR 1000) Self-Governance
More informationINDIRECT COSTS. A Direct Explanation. July 18, What Federal Regulations Govern?
INDIRECT COSTS A Direct Explanation July 18, 2017 What Federal Regulations Govern? Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
More informationHow Much Does It Cost?
How Much Does It Cost? Eileen G. McLoughlin, Assistant Vice President of Finance and Budgeting, Rensselaer Polytechnic Institute Charles Tegen, Associate Vice President for Finance and Comptroller, Clemson
More informationIndirect Cost Allocation. August 22 nd, 2013
Indirect Cost Allocation August 22 nd, 2013 Why is Cost Allocation Important? What are some of the Federal requirements governing indirect cost allocation plans? Allowable and unallowable costs? What is
More informationSuperCircular and Budget and Accounting PIN
SuperCircular and Budget and Accounting PIN Presented by: Gil Bernhard, CPA October 31, 2015 HMA Overview New Federal Grants Management Requirements OMB SuperCircular Budget and Accounting PIN 2 New Federal
More informationIndirect Cost Recovery: What You Need to Consider. August 2017
Indirect Cost Recovery: What You Need to Consider August 2017 BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee,
More informationGOVERNMENT CONTRACT COSTS, PRICING & ACCOUNTING REPORT
Reprinted with permission from Government Contract Costs, Pricing& Accounting Report, Volume 12, Issue 1, K2017 Thomson Reuters. Further reproduction without permission of the publisher is prohibited.
More informationFacilities and Administration Rate Proposal
Facilities and Administration Rate Proposal Fiscal Year Ending June 30, 2008 Facilities and Administration Rate Proposal Fiscal Year Ending June 30, 2008 Facilities and Administration April 6, 2009 Ms.
More informationReport of Independent Auditors and Financial Statements with Supplementary Information. Madera County Workforce Investment Corporation
Report of Independent Auditors and Financial Statements with Supplementary Information Madera County Workforce Investment Corporation June 30, 2017 Table of Contents REPORT OF INDEPENDENT AUDITORS... 1
More informationChild Care Associates
FINANCIAL STATEMENTS For the Year Ended December 31, 2016 Table of Contents December 31, 2016 REPORT Independent Auditors Report 1 FINANCIAL STATEMENTS Statements of Financial Position 3 Statements of
More information2018 V2. Federal Costing Principles
2018 V2 Federal Costing Principles Federal Regulations: Uniform Guidance The Office of Management and Budget's (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal
More informationCost Allocation and Federal Compliance
Cost Allocation and Federal Compliance Fiscal Training March 20 th, 2008 10:00 a.m. 4:00 p.m. Why is Cost Allocation Important? What are the Federal requirements governing the funding received? What are
More informationUniform Guidance: Key Points of the UNC Implementation - Getting to the Real Impacts of 2 CFR Part 200
Uniform Guidance: Key Points of the UNC Implementation - Getting to the Real Impacts of 2 CFR Part 200 Sharon Brooks Director of Award Management Services and Cash Management Robin Cyr Associate Vice Chancellor
More informationGLOBAL DEVELOPMENT INCUBATOR, INC.
GLOBAL DEVELOPMENT INCUBATOR, INC. Financial Statements (With Summarized Financial Information for the Year Ended December 31, 2016) and Report Thereon Reports Required in Accordance with the Uniform Guidance
More informationAUDIT OF THE FUND ACCOUNTABILITY STATEMENT OF USAID RESOURCES MANAGED BY MERCY CORPS AND IMPLEMENTED BY PUBLIC AID ORGANIZATION ( PAO ) UNDER
AUDIT OF THE FUND ACCOUNTABILITY STATEMENT OF USAID RESOURCES MANAGED BY MERCY CORPS AND IMPLEMENTED BY PUBLIC AID ORGANIZATION ( PAO ) UNDER COOPERATIVE AGREEMENT NUMBER AID-267-A-00-12-00001, CFDA #
More information