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1、Indirect Costs Overview,Washington, D.C. - August 2008 USDOL/VETS Competitive Grantees Training ConferencePresented by Damon Tomchick Cost Negotiator Division of Cost Determination/OAMS/OASAM/BOC 202-693-4105; tomchick.damondol.gov,Topics We Will Cover,and most importantlyAnswers to your questions!,
2、Topics We Will Cover,Definitions/Terms Who needs a rate and why Recovery of costs OMB Circular A-122 (2 CFR Part 230) general concepts Allowable, Allocable and Reasonable costs Direct versus Indirect Rate types Indirect Cost Rate Negotiation Process Submission of ICR Proposals Example of an ICR agre
3、ement,Some cost allocation terminology,Total Costs =,Direct CostsPlus Indirect Costs Less Applicable Credits,What are direct costs?,Costs that are readily identified with a particular cost objective. Examples (program specific):Salaries VETS program staffSpace sq. ft. occupied by direct staffSupplie
4、s used by direct staffCommunications used by direct staff,Costs that are not readily identifiable with a particular cost objective. Examples: Salaries Executive Director, Accountant, etc. Space sq. ft. occupied by indirect staff Supplies used by indirect staff Communications used by indirect staff,W
5、hat are indirect costs?,What are Applicable Credits?,Receipt or negative expenditure type transactions, which offset or reduce expense items that are allocable to grants or contracts as direct or indirect costs. Examples include: Purchase discounts, refunds, rebates or allowances Sales of scrap or i
6、ncidental services Adjustments of overpayments or erroneous charges,Which organizations need to have an approved indirect cost rate?,$ Single Funding Source Indirect cost rate not needed$ Multiple Funding Sources Indirect cost rate needed,Which Federal agency is Cognizant?,HUD,DOL,HHS,Education,Agri
7、culture,DOJ,EPA,For nonprofit organizations, the largest dollar volume of direct Federal funding is normally used to determine the cognizant Federal agency. (This may be negotiated between Federal agencies.),www.whitehouse.gov,OMB Circulars:,http:/www.dol.gov/oasam/programs/ boc/costdeterminationgui
8、de/main.htm,DCDs Website:,Attachment A: General PrinciplesAttachment B: Selected Items of CostAttachment C: NPs not subject to this Circular,Structure of A-122 (2 CFR Part 230),Feds bear “fair share” of costs Provide guidelines for organizations concerning reimbursement requirements Provide uniform
9、standards of allowability Provide uniform standards of allocation Do not supersede limitations imposed by law Simplify intergovernmental relations Encourage consistency in treatment of costs,Objectives of the Circular(s),Basic premise of the Circulars: To be chargeable to a Federal grant/contract, i
10、ndirect costs must be:,Reasonable,Allocable,Allowable,To be Allowable, costs must:,Be reasonable and allocable Conform to any limitations or exclusions set forth in the cost principles or the award Be consistent with policies and procedures afforded all activities of the organization Be accorded con
11、sistent treatment Be determined in accordance with GAAP Not already be included in a cost sharing or matching requirement Be adequately documented,A cost is allocable to a Federal award if it is treated consistently with other costs incurred for the same purpose in like circumstances and if it: Is i
12、ncurred specifically for the award Benefits the award and other work and can be distributed based on benefits received, or Is necessary for the overall operation of the organization, although a direct relationship to a particular cost objective cannot be shownShifting of costs between awards to over
13、come funding deficiencies is not allowed,Allocable Costs,A cost is allocable to a particular cost objective in accordance with the relative benefits received.An allocable cost benefits a cost objective - either directly, or indirectly. Examples: VETS staff salaries, occupancy costs, Fiscal Officers
14、supplies.,Allocable Costs (contd),“A cost is reasonable if, in its nature or amount, does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the costs.” Some considerations might be: Effect on Federal program doll
15、ars Prudence under the circumstances Deviations from established practices,Reasonable Costs,Unallowable Costs,Specifically identified in the grant/contract as being unallowableSpecifically identified in Circular A-122 as being unallowableDoes not meet the criteria listed in Circular A-122 to be allo
16、wable,Documentation for Compensation,Because its usually the largest item of administrative direct/indirect cost under any given DOL grant/contractBecause it is so often the subject of audit questioned costs,Why emphasize this?,Must be reasonable and in accord with established practiceMust be suppor
17、ted in accordance with applicable Circular subsections (support of salaries and wages),Compensation for Personnel Services,Charges to Federal awards must be:Based on documented payroll, approved by a responsible, or an authorized, official of the organizationSupported by Personnel Activity Reports (PAR, aka, time distribution report),