Understanding Basics of Indirect Rates NCMA March 20, 2014 Roland Wick Roland Wick Consultant OVERVIEW 1. 2. 3. 4. Understanding description of indirect costs. Understand bases, pools, rates. Understand basics of indirect rate development from accounting records for final costs. Understand a basic submission format Roland Wick Consultant Why Need Indirect Rates? Proposals Final Indirect Rate Submissions Provisional Billing Rates (not same as proposals) Main Reason: Survival. Recover indirect costs on direct work effort. One significant reason small business fails? No proper recovery of indirect costs!!!! Roland Wick Consultant Indirect Rates are Difficult for New Contractors What are Indirect Rates and Indirect Costs? An indirect cost is any cost not directly identified with a single, final cost objective (contract), but identified with two or more final cost objectives or an intermediate cost objective. It is not subject to treatment as a direct cost. In simple terms, indirect costs are those costs not readily identified with a specific contract but incurred for the joint benefit of all contracts. An indirect cost rate is simply a method for determining fairly and expeditiously the proportion of general (non-direct) expenses that each project will bear. It is the ratio between the total indirect costs and some equitable cost base. Indirect Costs Ratio Indirect Cost Pool Cost Base Roland Wick Consultant =Indirect Cost Rate % What are Indirect Rates and Indirect Costs? How To Develop To develop a logical and consistent method for allocating indirect costs: Start Develop indirect costs grouped into common pools. Then Pick a common cost or costs that appear to have a causal relationship to the pool costs. The method for allocating a pool of indirect costs is determined by what caused the costs and/or what benefits from the costs. That is, what is the most likely reason the indirect costs are incurred? What effort do the indirect costs support? The selected driver of the indirect cost pools will be the base. That is also called the benefiting objective. Roland Wick Consultant Examples of Common Indirect Pools and Allocation Bases Fringe pool costs / total labor cost base Overhead costs/ direct labor base G&A Costs/ total cost input base Roland Wick Consultant FAR Part 31 Impacts Pools and Bases!!! “Unallowable cost” means any cost which, under the provisions of any pertinent law, regulation, or contract, cannot be included in prices, cost-reimbursements, or settlements under a Government contract to which it is allocable. Roland Wick Consultant Unallowable Cost Requirements All items properly includable in an indirect cost base shall bear a pro rata share of indirect costs irrespective of their acceptance as Government contract costs. For example, when a cost input base is used for the allocation of G&A costs, the contractor shall include in the base all items that would properly be part of the cost input base, whether allowable or unallowable, and these items shall bear their pro rata share of G&A costs. Roland Wick Consultant What??? Example: Have $100 of unallowable direct labor (unusual) For discussion, have 10% overhead and 10% G&A rates (assume direct labor base for everything). How much do you exclude from bill??? Roland Wick Consultant Unallowable Question Must exclude $100 of direct labor Exclude $10 of overhead Exclude $10 of G&A Each indirect base still keeps the $100 of direct labor cost Roland Wick Consultant G&A Unallowables? Just remove from the pool. They are not in an allocation base. No adjustment to the base. Luckily, most small contractors only have G&A unallowables. Roland Wick Consultant How Does this Work? Starting Point for Cost Pools – Trial Balance (Source NCMA presentation PowerPoint 2010) Direct Labor w/ B&P Labor($10,000) G&A OH Fringe 300,000 X Subcontractor Expense 300,000 X Direct Materials 250,000 X Payroll Taxes 30,000 X Insurance Expense 50,000 X Sick, Holiday & Vacation Expense 65,000 X Pension Contribution 25,000 X IT Support Labor 35,000 Overhead Labor 72,500 Overhead Travel- Unallowable $ Direct X 5,000 X 16,000 X G&A Labor 170,000 X Legal & Professional Fees 10,000 X G&A Travel Expense 8,000 X G&A Travel Expense – Unallowable 3,000 $ 1,339,500 12 Consultant Roland Wick U/A X Rent Expense (75% G&A) Total Cost IT SC X X Fringe Rate Example Pool: Payroll Taxes $ 30,000 Insurance Expense 50,000 Sick, Holiday & Vacation Expense 65,000 Pension Contribution 25,000 Total Fringe Pool $ 170,000 $ 300,000 Base: Direct Labor/w B&P IT Support Labor 35,000 Overhead Labor 72,500 G&A Labor 170,000 Total Labor Base $ Fringe Rate: 577,500 29.44% 13 Consultant Roland Wick IT Service Center Pool: IT Support Labor $ Fringe on IT Support Labor @ 29.44% 35,000 10,303 Total Service Center Pool $ 45,303 Base: Overhead Personnel 5 Personnel G&A Personnel 3 Personnel Total Headcount Base 8 Service Center Rate: $ 14 Consultant Roland Wick 5,663 Overhead Rate Pool: Books Overhead Labor $ 72,500 Overhead Travel- Unallowable (excluded from pool) Allowable $ 72,500 5,000 0 Fringe on Overhead Labor @ 29.44% 21,342 21,342 IT Service Center Allocation 28,314 28,314 Rent Expense 4,000 4,000 Total OH Pool $ 131,128 $126,156 Base: Direct Labor $ 300,000 Fringe on Direct Labor @ 29.44% 88,312 Total OH Base $388,312 Overhead Rate: 33.77% 15 Consultant Roland Wick $ 388,312 32.49% G&A Rate Pool: $ G&A Labor 170,000 10,000 BP Labor 4,205 Allowable OH on B&P 2,944 Fringe on B&P Fringe on G&A Labor @ 29.44% IT Service Center Allocation Legal & Professional Fees Travel Expense G&A Travel Expense – Unallowable (excluded from pool) Rent Expense Total G&A Pool $ 50,048 16,989 10,000 8,000 0 12,000 284,186 Base: $ Direct Labor Less BP labor Less BP OH at total rate 33.77% Less Fringe on B&P Fringe on Direct Labor @ 29.44% Direct Materials Subcontractor Expense Unallowable OH costs Overhead Pool (including fringe on OH labor ) 300,000 (10,000) (4,371) (2944) 88,312 250,000 300,000 5,000 126,126 $1,052,123 Total Cost Input Base Rate 27% 16 Consultant Roland Wick Reconciliation $1,052,123 284186 Total Cost Input G&A $1,336,309 Subtotal 166 BP not in G&A 3000 add unallowable G&A $1,339,475 $1,339,500 $25 rounding Roland Wick Consultant Format for Submission (source Health and Human Services) The Government likes its own formats. Here is a format example from DHHS for provisional billing rates and proposal rates. Note –This is a format example only. Do not use for allocation method. Follow FAR Part 31. See DCAA Pamphlet “Information for Contractors” for DoD rate formats. Roland Wick Consultant Schedule A Lead Schedule Roland Wick Consultant Roland Wick Consultant Schedule B Indirect Pool Roland Wick Consultant Roland Wick Consultant Schedule C Fringe Pool Roland Wick Consultant Roland Wick Consultant Schedule D Bases Roland Wick Consultant Roland Wick Consultant Summary/Questions Roland Wick Consultant