BG -All Hands Unallowable Labor and Cost Refresher

1. BG -All Hands Unallowable Labor and Cost Refresher

2. Table of Contents • Objective • Commonly Occurring Allowable & Unallowable Costs • Unallowable, Reimbursable & Non-reimbursable • Tradeshow and conferences • Training • Direct Travel cost • Business meals & alcohol • Questions Concerning Unallowable Costs/Expense

3. Objective • To help employees identify and properly classify legitimate CACI business expenses that the government will pay for (allowable) and others it will not pay for (unallowable). • To inform employees of available CACI Policy and Procedures that provide guidance on these concepts.

4. Unallowable, Reimbursable & Non-reimbursable • Unallowable cost: Cost for which the government will not reimburse CACI, either directly or indirectly.  Such cost is excluded from any billing or claim to the Government.  The term “unallowable” does not imply that it is inappropriate for CACI to conduct this activity or incur this cost; instead, it dictates how cost is to be reported.  Unallowable cost must be segregated, per the FAR 31, Section 205. CACI has special charge numbers that segregate unallowable cost and prevent it from being billed to the government. • Reimbursable: Cost that CACI policy and procedures regard as reimbursable to the employee who incurred the cost. • Non-reimbursable: Specific cost found in CACI policy and procedures for which CACI will not reimburse employees if incurred by employees. Also, includes other non-business related costs for which CACI will not reimburse employees. Remember - An unallowable expense may be reimbursed to the employee with appropriate management approval, but if reimbursed must be recorded as unallowable, and excluded from any billing/claim to the government.

5. Labor and Expenses Associated with Trade Shows and Conferences • FAR 31.205-1, 31.205-43 – Trade Shows and Conferences • Some employees may attend a conference (allowable) and work in the CACI tradeshow booth (unallowable). In these situations, the employees will need to account for authorized and required hours, material and other associated expense consistently. • Expenses and materials associated with Allowable Labor, whether direct or indirect, should be charged as allowable. • Expenses and materials associated with Unallowable Labor should be charged as unallowable. • Remember, expenses need to follow how labor is charged.  Here is an example: • If you attended a tradeshow and worked 6 hours in the CACI booth (75% of your hours worked) and 2 hours as an attendee at the tradeshow (25% of your hours worked), your time card should indicate that 75% of your labor charges are unallowable and 25% are allowable, and your expense report should indicate that 75% of your expenses are unallowable and 25% are allowable. Note – This will be an upcoming automated change to workflow. At the moment , this will need to be done manually in workflow. • For more complex timekeeping situations, please contact the Compliance Department for assistance.

6. Training • FAR 31.205-44 – Training expense – • The training class expense that is related to the field in which the employee is working is allowable. • Training is normally charged as indirect as the purpose is usually to enhance your job skills • These job skills are transferable from project to project and therefore since they are not specific to one project, they should not usually be charged direct. • There may be instances where a client has asked that you attend training in support of the program • First, check with your Program Manager and/or Contracts Manager to confirm that training is chargeable under the contract. • Should the client only agree to pay for your time, but not the course itself, understand that the charges cannot be split between direct and indirect. In this scenario, the training course expense should be charged to direct non-billable and the hours for attending the course should be charged to direct billable • Remember – Expense follows labor. If labor is direct, expense needs to be direct or direct non-billable. If labor is indirect, expense needs to be indirect.

7. Travel Expenses • FAR 31.205-46 – Travel costs – • Travel is a direct charge to the project if the trip is project directed. It is an indirect charge if it is not project directed. Some contracts may explicitly state that travel costs incurred in the performance of the project are not reimbursable as contract costs (i.e. not covered by contract funding). In these cases, the direct charge employee should charge travel expenses incurred in the performance of the project as direct non-billable. See Procedure 04.01.01.11 – Travel for additional information. • Remember - If an employee of CACI travels for a specific contract and the contract did not establish funding for travel – The travel cost must be recorded to direct non-billable.

8. Business Meals and Alcohol FAR 31.205-14 , 31.205-51 – Business Meal and Alcohol – • To be considered allowable the following items are required: • List of attendees • Meeting purpose and agenda • Detailed receipt • Justification for necessity of meeting during mealtime • Business meal costs must also be reasonable to be considered allowable: • The Per Diem M&IE rates used by the Federal Government are the standard of reasonableness used by CACI • Generally, weekly or semi-monthly Business meals are considered excessive and unreasonable • Also, if alcohol is more that 25% of the total bill, then the entire bill is unallowable. • Remember – Business Meals will be considered unreasonable and therefore unallowable, if held weekly or semi-monthly. A Business Meal in which alcohol is more than 25% of the total bill is unallowable.

9. Questions concerning unallowable costs/expenses - Direct questions or concerns to: • Your manager • CACI Government Compliance Department • Unallowablecostsquestions@caci.com • Kathy James • kjames@caci.com; (703) 841-7862 • Kim Culotta • kculotta@caci.com; (703) 841-7967