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OMB Circular A-21. Cost Principles for Educational Institutions found in 2 CFR Part 220The Federal Government guidelines for calculating the facilities and administrative rate using either Long Form or Short Form methodologies.Educational institutions that receive federal awards subject to A-21
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1. The Facilities and Administrative Rate Calculation Process – Simplified Method Presented by
Ginger Baker
Eileen Campbell
2. OMB Circular A-21 Cost Principles for Educational Institutions found in
2 CFR Part 220
The Federal Government guidelines for calculating the facilities and administrative rate using either Long Form or Short Form methodologies.
Educational institutions that receive federal awards subject to A-21 of less than $10 million are required to calculate their F&A cost rate using a simplified method known as a short form (Section H).
Educational institutions that wish to be reimbursed for institutional wide administrative and facility costs associated with federal contracts and grants need to develop an F&A cost rate.
The government has allowed institutions with more than $10M to also use short formThe government has allowed institutions with more than $10M to also use short form
3. Objectives of the A-21 Cost Principles Sets uniform standards of allocation
Sets uniform standards of allowability
Allows schools to identify full cost of federal programs
Provides that the federal government bear its fair share of total costs
Simplifies intergovernmental relations
Encourages consistent costing
4. What the Cost Principles Require: The six “B’s” for costs:
Be allowable
Be allocable
Be reasonable
Be treated consistently
Be necessary to perform the program
Be permissible under the law
5. What is the F&A Rate Proposal? The documentation prepared by an institution in accordance with the federal cost principles in OMB Circular A-21 to substantiate its claim for the reimbursement of F&A costs.
If you don’t want to be reimbursed for F&A costs, you don’t have to prepare a proposal.
The proposal should to be submitted six months after the fiscal year end.
6. What is the F&A Rate Proposal? The proposal needs to be reconciled to the audited financial statements.
Needs to be clear explanation of adjustments and reclassifications.
Base period normally coincides with fiscal year.
Short form institutions follow Section H of OMB Circular A-21.
7. What is the F&A Rate Proposal? The proposal and supporting documentation becomes the basis for negotiating your institution’s F&A rate.
Remember, this is your proposal and you must defend it.
8. What are Facilities and Administrative (F&A) Costs? Costs that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored project, instructional activity or any other institutional activity.
Often referred to as indirect or overhead costs.
9. What are Facilities and Administrative (F&A) Costs?
10. The Short Form Advantages
Relatively easy to prepare and negotiate
Uses institutional financial statements
Uses formula approach -1 pool and 1 base (OH)
Does not need a space study
Does not need a library allocation
Does not need a DCE calculation
Does not need sub-pooling for GA or O&M
Administration is not subject to the 26 point cap that is imposed on long-form institutions
11. The Short Form Disadvantages
Does not always result in optimizing F&A cost recovery.
Establishes one rate for all sponsored activity, rather than on and off campus rates and special rates where appropriate.
12. The F&A Calculation Process Download operating expenses
Functional expenses need to be broken into salaries, fringe, and other expenses
Reconcile
Expenses to the Financial Statements by NACUBO functional category
Decide on Distribution Basis
MTDC
Salaries and Wages
Reclassify financial expenses
Into the function groups and ultimately indirect cost pool and direct cost base
13. The F&A Calculation Process Exclude certain costs
MTDC exclusions
Unallowable costs
Make adjustments to ensure consistency
Calculate the rate
15. Reconcile Extract current fund operating expenses
Reconcile to expenditures reported in the notes to the financial statements by NACUBO category
Can take longer than you think
16. Reclassification Short form institutions need to reclassify their financial expenses into the F&A function groups and ultimately either the indirect cost pool or direct cost base needed to compute the F&A rate under the simplified method.
This initial review of expenses for F&A classification purposes can be done at the department, object code, or account level.
Costs are often included in one type of function category for financial statement purposes and a different function group for F&A purposes.
Costs are often included in one type of function category for financial statement purposes and a different function group for F&A purposes.
17. Reclassification Reclassifications Include:
Scrub Expenses
Unallowable Activities
Sponsored Accounts
Catalogs, Commencement, and Convocations
Department Paid Operations and Maintenance
Library
Department Administration
Specialized Service Facilities Look for campus telecommunications and other activities that are normally considered specialized service facilities.
Government usually makes adjustments here because they want these charged to users on a unit cost basis. (See A-21, Section J.47)
Look for campus telecommunications and other activities that are normally considered specialized service facilities.
Government usually makes adjustments here because they want these charged to users on a unit cost basis. (See A-21, Section J.47)
18. Reclassification Auxiliary Assessments for Institutional Support and/or Operations and Maintenance
Academic Support
Student Services Administration
Institutional Support
19. Exclusions Exclusions Include:
College Work Study
Modified Total Direct Cost Exclusions
Capitalized Equipment
Subcontracts > $25K
Financial Aid
Long Term Facilities Rental
Patient Care Costs
Unallowable Expenses
Bad Debt
Entertainment
Cost of Goods Sold in Auxiliaries
20. Adjustments Adjustments Include:
Applicable Credits
O&M Expenses
Allowable Building Depreciation
Allowable Equipment Depreciation
Interest Expense
Gain/Loss on Disposal of Depreciable Assets
21. The F&A Calculation Process
22. How is the Rate Developed? Step 1. Develop the F&A cost pool:
- Administrative salaries/wages $350,000
- Associated fringe benefits 75,000
- Finance and accounting costs 25,000
- Supplies, materials and expenses 17,000
- Space related (O&M) 27,000
- Administrative travel 6,000
- Total pool costs $500,000
23. How is the Rate Developed? Step 2. Develop the base costs:
Cost Objectives Direct S&W
- Federal NIH grants $300,000
- Federal NASA grants 350,000
- Ford Foundation grants 400,000
- State Contracts 250,000
- Other university subcontracts 300,000
- Endowment funded programs 400,000
- Total base costs $2,000,000
24. How is the Rate Developed? Step 3. Calculate the rate:
F&A cost pool $ 500,000
Direct cost base $2,000,000
25. How is the Rate Developed? Step 4. Apply the rate:
Federal NIH grants $300,000 x 25% = $75,000
Federal NASA 350,000 x 25% = 87,500
Foundation grants 400,000 x 25% = 100,000
State contracts 250,000 x 25% = 62,500
Subcontracts 300,000 x 25% = 75,000
Endowment 400,000 x 25% = 100,000
Total reimbursement $500,000
26. Questions? Resources:
DCA Short Form Sample:
http://rates.psc.gov/fms/dca
A-21:
http://www.whitehouse.gov/omb/circulars_a021_2004
27. Contact Information Ginger Baker
Senior Manager
(702) 994-2999
VirginiaBaker@maximus.com
Eileen Campbell
Manager
(435) 770-5225
EileenPCampbell@maximus.com