Indirect Cost Rate Development for Non-Profits Navigating Accounting Standards and Best Practices to Calculate and Assign Expenses

Transcription

1 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, MAY 7, pm Eastern 12pm Central 11am Mountain 10am Pacific Today s faculty features: Tab Tsukuda, Senior Manager of Assurance Services, Ernst & Young, San Francisco Joseph Scudese, Partner, WithumSmith+Brown, New Brunswick, N.J. John Griffin, Assurance Senior Manager, BDO USA, Bethesda, Md. For this program, attendees must listen to the audio over the telephone. Please refer to the instructions ed to the registrant for the dial-in information. Attendees can still view the presentation slides online. If you have any questions, please contact Customer Service at ext. 10.

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5 Indirect Cost Rate Development for Non-Profits Seminar May 7, 2013 John Griffin, BDO USA LLP Tab Tsukuda, Ernst & Young LLP Joe Scudese, WithumSmith+Brown

6 Today s Program Purpose Of Indirect Cost Allocation [John Griffin] Direct Vs. Indirect Costs [John Griffin] OMB Circular A-122 Cost Principles [Tab Tsukuda] Indirect Rates [Tab Tsukuda] Financial Management For Indirect Rates [Joe Scudese] Organization Example [Joe Scudese] Indirect Rate Checklist [John Griffin] Slide 8 Slide 11 Slide 12 Slide 22 Slide 23 Slide 31 Slide 32 Slide 45 Slide 46 Slide 51 Slide 52 Slide 55 Slide 56 Slide 59

7 Notice ANY TAX ADVICE IN THIS COMMUNICATION IS NOT INTENDED OR WRITTEN BY THE SPEAKERS FIRMS TO BE USED, AND CANNOT BE USED, BY A CLIENT OR ANY OTHER PERSON OR ENTITY FOR THE PURPOSE OF (i) AVOIDING PENALTIES THAT MAY BE IMPOSED ON ANY TAXPAYER OR (ii) PROMOTING, MARKETING OR RECOMMENDING TO ANOTHER PARTY ANY MATTERS ADDRESSED HEREIN. You (and your employees, representatives, or agents) may disclose to any and all persons, without limitation, the tax treatment or tax structure, or both, of any transaction described in the associated materials we provide to you, including, but not limited to, any tax opinions, memoranda, or other tax analyses contained in those materials. The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser.

8 John Griffin, BDO USA LLP PURPOSE OF INDIRECT COST ALLOCATION

9 Why Are Indirect Cost Allocations Necessary? Federal, state or local governments require an indirect cost rate. - OMB Circular A-87 (cost principles for state, local and Indian tribal governments) - OMB Circular A-21 (cost principles for educational institutions) - OMB Circular A-122 (cost principles for non-profit organizations) Not practical, or is impossible, to allocate all direct costs Management needs the calculations to file future proposals. Indirect Cost Webinar Page 9

10 Why Are Indirect Cost Allocations Necessary? (Cont.) Required to ensure federal, state or local governments pay their fair share of the costs Indirect cost allocation is an efficient method to charge costs that benefit a large number of projects. Allows the option to develop different rates for different locations, based on costs applicable to them each specifically Indirect Cost Webinar Page 10

11 Reasons For Indirect Rates Indirect costs are necessary and important for every organization; reimbursement of these costs through use of indirect cost rates is an efficient method to recover such costs. Develop cost estimates for grant proposals Manage within cost measurement and performance requirements Full cost recovery - Difficult to achieve - Certain grants restrict administrative cost. - State and local governments often limit rates. Indirect Cost Webinar Page 11

12 John Griffin, BDO USA LLP DIRECT VS. INDIRECT COSTS

13 Definition: Direct Cost Direct cost means those costs that can be identified specifically with a particular project, program or activity (i.e., a particular award, project, service or other direct activity of an organization). A cost may not be assigned to an award as a direct cost, if any other cost incurred for the same purpose has been allocated to an award as an indirect cost. Indirect Cost Webinar Page 13

14 Direct Cost Direct cost of a minor amount may be treated as an indirect cost, provided it is treated consistently and applied to all final cost objectives. Unallowable costs are treated as direct costs, for purposes of determining the organization s indirect cost rates. Indirect Cost Webinar Page 14

15 Identification Of Direct Costs Review detailed budget obtained with the award Discuss with program managers and ensure understanding of grant and the types of costs to be incurred. Track cost separately for each award by cost center Ensure that the identification of direct costs is documented and appropriate Indirect Cost Webinar Page 15

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17 Charge Cost Direct Full cost recovery - charge as much costs on a direct basis Certain awards may contain cost limitations on recovery of indirect costs, resulting in award-specific rates. Certain costs that are generally indirect can be charged as a direct cost, using an appropriate base. - Rent - Depreciation Rent example of allocability (under direct allocation method): - Rent charged directly for a separate office devoted to one grant - Rent applied via square footage to various departments/programs, based on square footage or fulltime equivalents Indirect Cost Webinar Page 17

18 Charge Cost Direct (Cont.) Rent example of allocability: - Rent (G&A) applied to various departments/programs based on square footage (SF) - If site devoted grant is 1,000/10,000 SF, then 10% of total rental cost can be charged as a direct cost ($5,000 = $500) Depreciation example of allocability: - Depreciation (G&A) applied to departments based on payroll dollars - If program personnel working on a grant represent 15% of total payroll dollars. - If $100,000 in total depreciation expense is allocated via direct labor dollars (total depreciation = ($100,000 * 15% = 15,000) Indirect Cost Webinar Page 18

19 Definition: Indirect Cost Indirect costs are those costs that have been incurred for common on joint objectives and cannot be readily identified with a particular sponsored project, program or activity but are necessary to the operations of the organization. Indirect costs generally include costs of central administration, technical services, operation and maintenance of buildings and grounds, building and equipment depreciation and administrative salaries. Indirect Cost Webinar Page 19

20 Indirect Cost (Cont.) Indirect costs cannot be economically traced to each grant, so they must be placed in a cost pool and be allocated on a causal-beneficial basis to the final cost objective or grant through the use of an indirect rate. Indirect cost rate means the ratio, expressed as a percentage, of an organization s total indirect costs (numerator) to its direct cost base (denominator). Indirect Cost Webinar Page 20

21 Indirect Cost Rate Proposals (ICRPs) Documentation prepared by a recipient to substantiate its claim for the reimbursement of indirect costs - Exception: If a fixed rate is negotiated in the grant agreement, the indirect rate calculated may be higher than the fixed rate. The ICRPs should be based on the most current financial data, supported by the organization s accounting system and audited financial statements, if available. The ICRP provides the basis for review, audit and negotiation leading to the organization s indirect cost rate Indirect Cost Webinar Page 21

22 ICRPs (Cont.) Organizations are generally required to submit their ICRP within six months of the fiscal year end to their cognizant, or oversight agency. Once the indirect cost rate has been negotiated, all related agencies must use the negotiated indirect cost rate agreement (NICRA), unless otherwise negotiated as part of the grant agreement. Indirect Cost Webinar Page 22

23 Tab Tsukuda, Ernst & Young LLP OMB CIRCULAR A-122 COST PRINCIPLES FOR NON-PROFIT ORGANIZATIONS

24 Cost principles OMB Circular A-122 Not-for-profit (non-profit) organizations OMB Circular A- 122 (now 2 CFR Part 230) Hospitals (OASC-3) Colleges and universities - OMB Circular A-21 (now 2 CFR Part 220) State and local governments - OMB Circular A-87 (now 2 CFR Part 225) Commercial entities (FAR Part 31) Administration Administrative requirement (OMB Circular A-110, now 2 CFR Part 215) Audit requirements (OMB Circular A-133) 24

25 OMB Circular A-122 (Cont.) OMB Circular A-122 on cost principles for non-profit organizations, (now codified as 2 CFR, Part 230) prescribes principles for determining the costs of grants, contracts and other agreements with non-profit organizations. Federal Agency Non-Profit Organization Federal awarding agencies are responsible for advising recipients of requirements imposed by federal laws, regulations and the provisions of grants/contracts. 25

26 OMB Circular A-122 (Cont.) OMB Circular A-122 also applies to all cost-reimbursement sub-awards (subgrants, subcontracts, etc.) to non-profit organizations. State Government Federal Agency Local Government Non-Profit Non-Profit Organization Primary recipients (e.g., states, local governments and non-profit organizations) are responsible for identifying awards and advising subrecipients of requirements imposed by federal laws, regulations and the provisions of grants/contracts as well as any supplemental requirements. Primary recipients are generally responsible for monitoring awards. 26

27 OMB Circular A-122 (Cont.) The cost principles in OMB Circular A-122 are used by federal agencies in determining the costs of work performed by nonprofit organizations under grants, cooperative agreements, cost-reimbursement contracts and other contracts (also collectively known as awards ) in which costs are used in pricing, administration, or settlement. the principles are designed to provide that the federal government bear its fair share of costs except where restricted or prohibited by law. 27

28 OMB Circular A-122 (Cont.) The circular is organized as attachments: Attachment A General principles Basic considerations Direct costs Indirect costs Allocation of direct costs and determination of indirect rates Negotiation and approval of indirect cost rates Attachment B Selected items of cost Attachment C Non-profit organizations not subject to this circular OMB circulars, including OMB Circular A-122, can be found on the White House Web site at: 28

29 OMB Circular A-122 (Cont.) For a cost to be recoverable under a federal award (subject to the cost principles), it must be allowable. Factors affecting cost allowability: Reasonable for the performance of the award and be allocable thereto under the cost principles Allocable Incurred specifically for the award (direct cost) Benefits the award and other work and can be distributed in reasonable proportion to the benefits received (indirect cost) Is necessary for the overall operation of the organization (indirect cost) Conforms to the limitations or exclusions in the cost principles Consistent with policies and procedures uniformly applied to federal awards as well as other activities of the organization Generally accepted accounting principles (GAAP) are used in the determination of cost. Not included as a cost or used to meet cost sharing or matching requirements Be adequately documented 29

30 OMB Circular A-122 (Cont.) Attachment B Selected items of cost provides principles to be applied for 53 types of cost when ascertaining allowability. Unallowable cost examples: a. Alcoholic beverages (2.) b. Bad debts (3.) c. Contingency provisions (8.) d. Contributions (9.) e. Legal expenses for prosecution of claims against the government(10.b.) f. Entertainment costs (14.) g. Fines and penalties (16.) h. Goods and services for personal use (18.) i. Fund raising (23.b.) j. Lobbying (25.) k. Losses on other awards (26.) l. Organization costs (31.) m. Selling and marketing (48.) How will you identify your unallowable costs? What changes to your processes might be needed to be able to properly categorize expenses? What is needed to minimize the incurrence of unallowable costs? 30

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32 Tab Tsukuda, Ernst & Young LLP INDIRECT RATES

33 Indirect Rates In the preceding section, we introduced OMB Circular A-122 (2 CFR Part 230) Relative to indirect rates, OMB Circular A-122, Attachment A General Principles, paragraphs C and D provide guidance on indirect rates: C. Indirect costs D. Allocation of indirect costs and determination of indirect cost rates 33

34 Indirect Rates (Cont.) Before discussing indirect rates, it is important to note that misunderstandings can arise because of different interpretations as to what is an indirect cost. Direct Cost Indirect Cost Characteristics Examples Characteristics Examples Activities that benefit a single project (e.g., grant) The activity can be easily traced to a project. The activity cost is charged directly to the project (e.g., grant) LABOR Project director, project staff, MATERIAL Supplies used for the project. TRAVEL Travel required to carry out the project. Activities that benefit multiple projects The activity cannot be easily traced to particular projects. The activity cost is allocated to multiple projects. LABOR Controller, administrative staff MATERIAL Office supplies TRAVEL Travel to general purpose training events 34

35 Indirect Rates (Cont.) Because of the diverse characteristics and accounting practices of non-profit organizations, it is not possible to specify the types of cost which may be classified as indirect cost in all situations. OMB Circular A-122, Attachment A, C.2. To minimize misunderstandings and assure consistency in the categorization of costs as direct or indirect, organizations should define, in writing, what is considered a direct vs. indirect cost. Project staff labor Project travel Project supplies Direct Depends Indirect (Usually) Telephone Computer Clerical personnel Postage and shipping Administrative staff labor Rent Utilities Office supplies 35

36 Indirect Rates (Cont.) OMB Circular A-122, Attachment A, paragraph B - Direct costs, states: 4. The costs of activities performed primarily as a service to members, clients, or the general public when significant and necessary to the organization s mission must be treated as direct costs whether or not allowable and be allocated an equitable share of indirect costs. Some examples of these types of activities include: a. Maintenance of membership rolls, subscriptions, publications, and related functions, b. Providing services and information to members, legislative or administrative bodies, or the public, c. Promotion, lobbying, and other forms of public relations, d. Meetings and conferences except those held to conduct the general administration of the organization, e. Maintenance, protection, and investment of special funds not used in the operation of the organization, f. Administration of group benefits on behalf of members or clients, including life and hospital insurance, annuity or retirement plans, financial aid, etc. 36

37 Indirect Rates (Cont.) Specific instructions for allocating indirect costs and computing indirect cost rates, along with the conditions under which each method, should be used are described in OMB Circular A-122, Attachment A, paragraph D, subparagraphs 2 through 5. Allocation methods Simplified allocation method used when an organization s major functions benefit from its indirect costs to approximately the same degree Multiple allocation base method used when an organization s indirect costs benefit its major functions in varying degrees Direct allocation method used when each joint (direct) cost is pro-rated, using a base that accurately measures the benefits provided to each award or other activity 37

38 Indirect Rates (Cont.) Direct allocation method Some non-profit organizations treat all costs as direct costs except for general administration and general expenses. These organizations generally separate their costs into three basic categories: (i) General administration and general expenses, (ii) Fundraising and (iii) Other direct functions (including projects performed under federal awards). Joint costs such as depreciation, rental costs, operation and maintenance of facilities, telephone expenses and the like are pro-rated individually as direct cost to each category and to each award or other activity using a base most appropriate to the particular cost being pro-rated. Re: OMB Circular A-122, Attachment A, D. 4. Direct allocation method 38

39 Indirect Rates (Cont.) Direct allocation method (Cont.) Examples of directly allocated costs: Cost Rental costs (facilities) Operation and maintenance of facilities Telephones Square footage Square footage Cost of services Examples of Allocation Bases Headcount Number of telephones Using this method, the indirect costs remaining consist exclusively of general administration and general expenses. The indirect rates are computed using that manner described under the simplified allocation method. 39

40 Indirect Rates (Cont.) Simplified allocation method After ascertaining the direct costs of an award, to ascertain total costs, we need to determine the allocable indirect costs. After categorizing costs as direct or indirect, the total allowable indirect costs (net of applicable credits) are divided by an equitable distribution base to determine an indirect rate. = Indirect Rate The allocation base may be total direct costs (adjusted), direct salaries and wages, or other base (excluding participant support costs) that results in an equitable allocation. NOTE: Non-profit organizations that receive more than $10 million in federal funding of direct costs in a fiscal year must categorize the indirect costs into two broad categories: Facilities and administration. 40

41 Indirect Rates (Cont.) Multiple allocation base method Indirect cost groupings are established so the allocation of each grouping can be made on the basis of benefits provided to the major functions of the organization. Each grouping represents a pool of expenses that are of like character, in terms of the functions they benefit. These groupings are categorized into two broad categories: Facilities and Administration. Cost pools: The indirect cost pools (groupings) are: Depreciation and use allowances Interest Operation and maintenance expenses General administration and general expenses 41

42 Indirect Rates (Cont.) Multiple allocation base method (Cont.) Allocation bases If facilities-type costs: Support a single function, they are allocated to that function Support multiple functions, they are allocated to individual functions on basis of usable square feet. Support multiple functions, and the space is shared between functions, they are allocated to employee/users on either An FTE basis or salaries and wages of the individual functions. Organization-wide FTEs or salaries and wages. For general administration and general expenses: Allocated to benefiting functions, using modified total direct costs (MTDC) 42

43 Indirect Rates (Cont.) U.S. Department of Health & Human Services publishes various guidance documents, including Sample Indirect Cost Proposal Format For Nonprofit Organizations np_exall.pdf 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: Direct Costs (Base - Salaries and Wages): Community Service $140,831 Head Start $950,615 Weatherization $18,305 Memberships and Fundraising $1,592 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 $122,690 Total Administrative Services: $382,200 K. RATE Adjusted indirect costs $382,200 = 34.4% Total salaries $1,111,343 43

44 Indirect Rates (Cont.) Types of indirect rates Predetermined rate means an indirect cost rate, applicable to a specified current or future period, usually the organization's fiscal year. The rate is based on an estimate of the costs to be incurred during the period. A predetermined rate is not subject to adjustment. Fixed rate means an indirect cost rate that has the same characteristics as a predetermined rate, except that the difference between the estimated costs and the actual costs of the period covered by the rate is carried forward as an adjustment to the rate computation of a subsequent period. Provisional rate or billing rate means a temporary indirect cost rate applicable to a specified period and which is used for funding, interim reimbursement, and reporting indirect costs on awards pending the establishment of a final rate for the period. Final rate means an indirect cost rate applicable to a specified past period and which is based on the actual costs of the period. A final rate is not subject to adjustment. 44

45 Indirect Rates (Cont.) Predetermined and fixed rates carry the lowest relative risk, as the rates cannot change; whereas provisional rates carry the risk that changes in the base, or the pool can materially affect the cost of programs. When dealing with indirect rates, other management risk areas to consider when preparing your policies and procedures (internal controls) are: Consistent application of the rate to the correct allocation base Consistent categorization of costs as direct vs. indirect Preparation and retention of documentation in support of costs Timely submission of rate proposals 45

46 Joe Scudese, WithumSmith+Brown FINANCIAL MANAGEMENT FOR INDIRECT RATES

47 Financial Management How does an entity start to prepare its indirect costs calculation? Contact your federal cognizant agency and determine what, if any, special requirements the agency has (i.e., format of indirect cost proposal) Utilize/follow the parameters of filing for the federal agency Start with an audited schedule of G&A expenses General ledger needs to capture general and administrative (G&A) costs. Make sure that ALL of the operations of the entity receive their fair share of the indirect costs. 47

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49 Financial Management (Cont.) How does an entity start to prepare their indirect costs calculation? (Cont.) Analysis of G&A costs to determine if the costs contain unallowable costs per the appropriate Federal or State regulations. (Cannot back door unallowable costs). any Determine what the indirect cost base will be. Salaries and Wages. Modified Total Direct Costs (MTDC) total direct costs less deductions for equipment, subcontract costs over $25,000, participant support costs. Adhere to OMB Requirements contained in OMB A

50 Financial Management (Cont.) What about direct costs? Make sure that all direct cost allocations are documented and appropriate. Prepare a written document that delineates/explains the various methods the agency has in place to allocate costs. This document would contain, as a minimum, what is the basis of allocation for: 1. Salaries and wages and fringe benefits. 2. Non-personnel costs. 3. General and administrative costs 50

51 Financial Management (Cont.) Other tips or advice: Prepare a document that identifies: 1. The process and the methodologies the entity utilizes in the allocation of costs (this would include how each type of cost is allocated, the basis of the allocation and the appropriate support) 2. The process of accounting for indirect costs 3. Meet with staff that will be involved and/or affected by the allocation of cost 51

52 Joe Scudese, WithumSmith+Brown ORGANIZATION EXAMPLE

53 Indirect Costs: Sample Calculation On the following pages is a sample indirect cost computation for a not-forprofit organization. This organization has a multi-faceted program operations, including social service programs and a charter school. The indirect cost calculation only applies to the social service programs (which a portion is funded by the federal government). The charter school has no federal, state or local funding, so it does not require an indirect cost calculation. 53

54 ABC AGENCY, INC. INDIRECT COSTS SUMMARY AND RATE CALCULATION FOR THE PERIOD JULY 1, 2010 TO JUNE 30, 2011 Cost Category Unadjusted Indirect Costs Adjustments/Eliminations Explanation Adjusted Indirect Costs Salaries $ 452,178 $ - $ 452,178 Employee benefits & payroll taxes 115, ,100 Total personnel costs 567, ,278 Community support 4,858 (4,858) ( A ) - Professional fees 27,932 27,932 Consultants 97,221 97,221 Supplies 36,080 36,080 Telephone 21,337 21,337 Postage and shipping 8,659 8,659 Equipment 16,370 16,370 Occupancy 54,432 54,432 Travel and meals 27,813 (9,168) ( B ) 18,645 Conferences and events 2,820 2,820 Interest 47,885 (47,885) ( C ) - Bank charges 2,895 2,895 Depreciation and amortization 10,528 10,528 Dues and subscriptions 1,943 1,943 Advertising 1,938 1,938 Staff recruitment 1,322 1,322 Insurance 24,951 24,951 Taxes and permits 2,551 2,551 Miscellaneous 11,316 11,316 Staff meeting expenses 6,515 6,515 Total non-personnel costs 409,366 (61,911) 347,455 Subtotal 976,644 (61,911) 914,733 Less: Management fee revenue - (108,000) ( D ) (108,000) Total Indirect Costs $ 976,644 $ (169,911) $ 806,733 Modified total direct costs: Total direct costs $ 6,752,662 Plus: Fund Raising 111,762 Less: Rental Complex (840,704) ( E ) Charter School (2,823,134) ( F ) Subtotal 3,200,586 Less: Equipment purchases (130,853) Subcontracts over $25,000 (25,000) Participant support costs (138,124) Modified Total Direct Costs $ 2,906,609 Indirect Cost Rate Calculation: Total Adjusted Indirect Costs $ 806, % Modified Total Direct Costs $ 2,906,609 54

55 ABC Agency Inc. Indirect Costs Summary And Rate Calculation For The Period July 1, 2010 To June 20, 2011 Explanation of adjustments/eliminations: Indirect costs pool: A. Community program costs not includable in indirect costs pool B. Management travel/automobile costs not includable in indirect costs pool C. Interest expenses not allowable in indirect costs pool D. Management fee revenue received for administrative services provided to affiliated companies Direct costs base: E. Affiliated company that oversees building facilities and operations F. Affiliated organization which maintains its own administrative staff 55

56 John Griffin, BDO USA LLP INDIRECT RATE CHECKLIST

57 Indirect Rate Checklist Audited financial statements and single audit report, if applicable Description of accounting system/chart of accounts Written policy for allocating and identifying direct and indirect cost cost allocation methodology Most recent signed negotiation agreements Indirect salaries by position title, amount and indirect percentage A list of sub-awards or subcontracts generally excluded from the direct cost base Lobbying certificate 990 tax form and copy of IRS letter granting non-profit status Indirect Cost Webinar Page 57

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59 Indirect Rate Checklist: Sources Federal Agency U.S. Department of Health and Human Services U.S. Department of Interior Source ervices/nonprofit_orgs.cfm U.S. Department of Labor Environmental Protect Agency Indirect Cost Webinar Page 59