NEW BUDGET REQUIREMENTS
HIVCS CAG
1/12/11
New Budget Requirements
• Annual budgets are required for all contracts including
performance-based (PB) contracts.
• Contracts that request “Indirect Costs” on budgets must have
a US Department of Health and Human Services (DHHS)approved Negotiated Indirect Cost Rate Agreement (NICRA).
Reasons for new Budget Requirements
• Recent guidance from the Health Resources and
Services Administration (HRSA)
– Since the guidance from HRSA comes from the US
Department of Health and Human Services (DHHS), which
oversees both (Prevention) Center of Disease Control
(CDC) and Ryan White (HRSA) funding, these
requirements will apply to both Ryan White and CDCfunded HIV Prevention contracts.
DHHS-Approved NICRA – What has
Changed?
•
Indirect Costs may only be included in the budget if the
agency has a current DHHS-approved NICRA.
DHHS Approved NICRA – How Does
This Change Affect Contractors?
• Contractors who do not currently have a DHHSapproved NICRA must reallocate the funds previously
under Indirect Cost to individual direct administrative
cost budget line items.
DHHS Approved NICRA – How Does
This Change Affect Contractors?
•
In order to budget indirect costs, contractors without a DHHSapproved NICRA will have to apply for one.
•
Contractors who successfully apply for a NICRA will be able to
submit contract modifications retroactively to the beginning of
the current fiscal year, allowing them to modify budgets and to
reallocate funds to indirect cost (cost-based contracts).
Modifications for performance-based contracts are not required,
however, HIVCS will need a copy of the DHHS-approved NICRA
in order to “allow” charges to Indirect Cost shown on the agency
General Ledger during the Mid-year Cost Report review.
•
For contractors who do not wish to obtain a DHHS-approved
NICRA, the shift to direct administrative budget lines will be a
permanent change.
Annual Updated Budgets – What has
Changed?
• All contracts, including performance-based
contracts, will be required to submit budgets
annually.
Annual Updated Budgets – How Does
This Change Affect Contractors?
• This is not a change for Ryan White or Prevention costbased contracts since HIVCS already requires updated
budgets from cost-based contracts annually.
• Affects Ryan White and Prevention performance-based
contracts. In the past, Ryan White and Prevention
performance-based contractors were not required to submit
itemized budgets to HIVCS during the renewal process.
• Some contractors may have additional budgets changes
because they are also affected by the new NICRA
guidelines.
Annual Updated Budgets – How Does
This Change Affect Contractors?
• For performance-based contracts, once the budget is approved, HIVCS will
not be monitoring your contract adherence to your budget.
• To avoid delays in contract executions, HIVCS will implement a staggered
approach for the budget submissions and approvals.
• For cost-based contracts and certain performance-based contracts, the
budgets will be submitted along with renewal documents, and will be
approved prior to contract execution.
• For the remaining performance-based contracts, the majority (75%) of our
portfolio, an approved budget will not be required for contract execution.
HIVCS will request budget submissions for these programs after the contract
term begins (February for Prevention and April for Ryan White).
Questions