Cost Allocation Challenges for Governments FGFOA Annual Conference June 3, 2014 Presented by Lynda M. Dennis; CPA, CGFO, PhD Overview Why cost allocation? Internal uses of cost allocation Cost allocation basics Cost allocation – grant reporting Why Worry about Cost Allocation? Systematic allocation produces better decision making information Documented allocation process provides basis for reliable financial reports for external parties Ratios & indicators from these reports provide Data to assess financial sustainability Basis to deal with scrutiny by grantors/donors & oversight agencies Today’s Concerns for SLGs Budget cuts in administrative positions Previous allocation models may require revision Allocation of indirect costs to Stimulus programs Other grants Consideration of indirect costs to fees & charges SLG Characteristics Affecting Cost Allocation Services difficult to measure Provision of public goods often required Labor-intensive operations Limited staff Expertise Available time Regulatory oversight Governments are different Users & Uses of Cost Allocation Information External users Financial statement users Oversight organizations Federal, state, and local agencies • Compliance Internal users Financial information Operating information Grant administration Governmental Oversight Organizations Federal OMB GAO Specific departments/agencies providing funding State Auditor general Department of revenue Secretary of state Department of law enforcement Specific departments/agencies providing funding Citizen groups External Financial Reporting of Costs Expense/expenditure Cost during period from delivering/producing goods, rendering services, carrying out other major/central activities Functional expense Cost reported by function/activity Financial Statement Analysis - SLGs Regulatory or statutory requirements Building function User expectations Governmental vs. business-type activities Financial Statement Analysis - SLGs Government-wide statement of activities Expenses net of program revenues Difficulties in allocating indirect costs To functions GAAP • interest expense • Depreciation Financial Statement Analysis Allocation of indirect costs affects Ratio of functional expenditures to total expenditures Ratio of intergovernmental revenues to total revenues Interfund transfers ISF reimbursements Operating results Comparisons Benchmarks Internal External • Similar in scope & objectives • Use to identify potential improvement areas • Issues to using • Occupancy • Geographic location • Services provided & area competition Internal Uses of Cost Allocation Uses of Internal Cost Data Capture cost data for decision making purposes Program administration Budget compliance Grant administration Internal Cost Basics Types of internal costs Variable Fixed Costs changing with level of activity Costs not changing with level of activity in a specified time period Differential Costs changing in response to particular course of action Similar to “incremental” costs Internal Cost Basics Types of internal costs Discretionary fixed Costs that can be avoided in short run Sunk R&D, R&M, travel, training Costs resulting from expenditure made in past that present or future decisions can not change Encumbrance Earmarking of available financial resources Usually via purchase order Internal Cost-Based Decisions Programs Start Terminate Decreases allocation base/allocable costs Expand Increases allocation base/allocable costs Increases allocation base/allocable costs Reduce Decreases allocation base/allocable costs Internal Cost-Based Decisions Locations Add Expand Increases allocation base/allocable costs Relocate Increases allocation base/allocable costs May increase or decrease allocation base or allocable costs Close Decreases allocation base/allocable costs Internal Cost-Based Decisions Other Level of service Program pricing Cost recovery Internal service funds Inter-agency billings Grant reimbursement Internal Costs & Grant Administration May affect Amount & timing of purchasing decisions Grant specific & in total Amount of costs allocable to other grants &/or for other purposes Decisions to apply for other grants Allocation of indirect expenses to grants discussed in depth later Cost Allocation Basics Cost and Cost Concepts Cost object Any item/purpose for which costs need to be measured Direct cost Can be clearly identified with/directly related to a single cost object Economically feasible manner Indirect cost Cannot be clearly identified with/directly related to a single cost object Cost Accounting Terms Cost recording Cost accumulation Collecting all costs of a specific activity Cost assignment Entering costs in accounts Tracing direct costs to a cost object/purpose Cost allocation Relating indirect costs to cost objects or purposes Cost Assignment and Allocation Purposes • Need to determine based on various demands – Assigned costs = direct – Allocated costs = indirect Cost Allocation • NOT cost assignment – Direct costs • Allocation criteria for indirect costs – Cause and effect • Most preferred – Benefits received – Equity – Ability to bear • Least preferred Cause & Effect • AKA causal criterion • Identification of activity causing costs to be incurred • Difficult for indirect costs • Statistical relationships vs. assumed relationship • Best to use Benefits Received • AKA beneficial relationship • Identification of users of outputs from activity • Costs allocated among users proportional to benefit • Direct costs – proxy for benefits Equity • Use when cost allocation used for reimbursement – Grants • Reasonable/fair means of establishing reimbursement basis – Fairness not an operational criterion Ability to Bear • Cost allocation in proportion to some user attribute – Attribute presumed to support charging costs to user Allocation Guidance • Objective methods preferable to subjective methods • Base may be financial or nonfinancial data • Allocation methods should be reviewed periodically & revised as needed to reflect significant changes – Nature or level of current activities – Jurisdictional limits Allocation Methods Allocation Methods • Stand-alone • Relative sales value (direct cost) • Physical units Stand Alone Allocation Method • Closest to “ability to bear” • Allocates indirect costs to each final cost objective – Proportional to SAC to independently accomplish one objective Stand Alone Allocation Method • Disadvantages – Allocation can change - SAC does not – SAC changes, total basis changes – SAC may not exist – Assumes indirect costs functionally related to SAC Stand-Alone Method Activity A: 1,000 X 1,500,000 = $750,000 2,000 Activity B: 800 X 1,500,000 = $600,000 2,000 Activity C: 200 X 1,500,000 = $150,000 2,000 Problems: • An allocation of indirect costs can change • Stand-alone costs may not exist Relative Sales Value Method (Direct Cost Method) • Close to “ability to bear” & “cause & effect” – Improvement over stand alone • Sales value/direct cost as allocation basis Relative Sales Value Method (Direct Cost Method) • Assumes indirect costs incurred in same proportion & for same reason as direct costs (OMB “simplified method”) – No change to expense for each objective compared to total direct costs – Increases total reported for each objective Direct Cost Method Cost Objective Total Direct Costs Relative Share Indirect Costs Total Costs $375,000 1,875,000 Activity A: 1,500,000 1,500 2,000 x 500,000 Activity B: 200,000 200 2,000 x 500,000 = 50,000 250,000 Activity C: 300,000 300 2,000 x 500,000 = 75,000 375,000 $2,000,000 = Allocated Costs $500,000 $2,500,000 Physical Units Allocation Method • Consistent with “cause & effect” • Allocate costs to objectives proportional to units of activity/output for each objective • May not reflect total effort needed to produce output • Assumes indirect costs incurred proportional to some unit measure of activity/purpose Cost Determination Allocation Steps 1. 2. 3. 4. 5. 6. 7. Reason(s) for cost information Cost objects or purposes Types of relevant costs Assign direct costs to cost objects Select allocation base(s) or cost drivers Allocate indirect costs Ensure appropriateness Step 1 - Cost Determination • Reason(s) for cost information – Process depends on info needed • Internal – Accumulation only – Accumulation/assignment/allocation • External – Assignment – Allocation Step 2 - Cost Determination • Cost objects or purposes – Reason may require 1+ cost objects • Activities – departments, programs, etc. • Objects highly likely to be different Step 2 - Cost Determination • GAAP cost objects • GWS – Statement of net position – Statement of activities • Fund level – Governmental vs. proprietary & fiduciary funds » Position statements » Activity statements Step 3 - Cost Determination • Types of relevant costs – Requires judgment & estimates – Use cause & effect criterion – Direct • Readily traced to/identified with cost object or purpose – Indirect • NOT readily traced to/identified with cost object or purpose Step 4 - Cost Determination • Assign direct costs to cost objects – Cost driver = assignment process • Relates cost incurred to purpose for which incurred • Example – Cost object includes labor » (time used * rate) = cost driver Step 5 - Cost Determination • Select allocation base(s) or cost drivers – Use cause & effect criterion – Most common in SLGs • Direct labor • Square footage for occupancy Step 6 - Cost Determination • Allocate indirect costs – Single stage • Straight forward situations • Single or multiple drivers – Multiple stage • More complex situations – Multiple assignments & allocations • Single or multiple drivers Single Stage Allocation Single Driver Natural Expense Purpose Labor Labor Hours Cost Driver A Rent Labor Hours Cost Driver B C Cost Assignment Cost Allocation (Based on Labor Hours) Two Stage Allocation Two Drivers Natural Expense Purpose Labor Hours Labor Labor Hours Space Rent A Cost Driver (1) Cost Driver B Equipment Rental C Data (2) Processing Cost Assignment Stage 1 Allocation (Based on Labor Hours) Stage 2 Allocation (Based on Computer Time) Computer Time Cost Driver Step 7 - Cost Determination • Ensure appropriateness – Approach should fully relate all costs to cost objects – Care needed to ensure all appropriate costs assigned • UBIT & allowable lobbying • Unallowable costs – Bad debts, alcohol, etc. Activity Based Costing Really Think This One Through Resources Labor $1,600k Facilitator $1,000k EquipRent $400k Contracting $200k Material $600k Storage $400k .25 Stage 1 Cost Drivers .2 Activity Cost Pools Deliver $1,800k Stage 2 Cost Drivers Cost Objectives .3 .25 Setup $700k .25 .6 .3 Contract $450k Process $1,250k .7 .75 .167 .4 Basic $1,973k Enhanced $2,227k .833 Cost Allocation for Grant Reporting OMB Cost Principles Provides cost principles – government contracts & awards Allowable Allocable Direct & indirect Indirect cost proposals OMB Cost Principles Uniform administrative requirements Cost principles New changes from OMB New guidance for indirect costs De minimus 10% Supplies increased to $5,000 Budgeting for contingencies for certain awards Documentation of cost accounting practices Salaries & benefits charged to awards Must be based on records that accurately reflect work performed • Supported by IC system • Incorporated into entity records • Reasonably reflect total activity performed Allocation based on budget estimates only not acceptable Time records for exempt employees Allowable Costs General Guidelines MUST BE Reasonable & allocable Allocable Conform to any limitations or exclusions Consistent with policies & procedures Allowable Costs General Guidance Accorded consistent treatment Determined in accordance with GAAP Not included as a cost or used to meet cost sharing or matching requirements Adequately documented Allocable Costs General Guidance MUST BE Treated consistently with other costs incurred for same purpose in like circumstances AND • Is incurred specifically for the award • Benefits both the award and other work • Is necessary to the overall operation of the organization Applicable credits • Offset/reduce expenditures • Purchase discounts, rebates, etc. Cost Determination Direct costs Specifically identified Unallowable activities subject to indirect cost allocation even though not direct Member services may/may not be allowable • Services to members typically direct costs to which indirect costs are allocated Indirect costs Common/joint objectives Not readily identifiable with specific objective Indirect Cost Rates Methods considered by OMB Simplified allocation Multiple allocation base Direct allocation Indirect Cost Rates Simplified Allocation Method One major function OR All major functions benefit same from indirect costs Steps Segregate all activities & costs • Direct & indirect Deduct capital expenditures & unallowable costs Compute indirect cost rate Indirect Cost Rates Multiple Allocation Method Indirect costs benefit major functions differently Cost groupings – permit allocation on benefits provided Facilities Administration Indirect cost pools & order of allocation Depreciation & use allowance Interest Operation & maintenance – physical plant General administration & general expenses Indirect Cost Rates Multiple Allocation Method Special indirect cost rates Single rate not appropriate Separate applicable indirect cost pool(s) first Indirect Cost Rates Direct Allocation Method All costs considered direct except G&A General administration & general expenses Fund raising Other direct functions Joint costs allocated directly to functions using indirect cost rates Reasonable & consistent Supported by current organizational data Based on benefits received Indirect Cost Rates Direct Allocation Method Indirect cost rates Eliminate capital & unallowable costs Calculate rate • Rate base = program services & fund raising costs G&A allocated to federal award activity eligible for reimbursement