Presented by Ginger Baker Eileen Campbell 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. 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 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 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. 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. 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. 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. Executive Management Building and Equipment Depreciation/ Use Allowance Budgeting Accounting & Financial Management Not directly assignable to any one activity. Payroll or Purchasing Repair & Maintenance Human Resources Utilities 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 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. 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 Exclude certain costs MTDC exclusions Unallowable costs Make adjustments to ensure consistency Calculate the rate 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 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. Reclassifications Include: Scrub Expenses Unallowable Activities Sponsored Accounts Catalogs, Commencement, and Convocations Department Paid Operations and Maintenance Library Department Administration Specialized Service Facilities Auxiliary Assessments for Institutional Support and/or Operations and Maintenance Academic Support Student Services Administration Institutional Support Exclusions Include: College Work Study Modified Total Direct Cost Exclusions Unallowable Expenses Capitalized Equipment Subcontracts > $25K Financial Aid Long Term Facilities Rental Patient Care Costs Bad Debt Entertainment Cost of Goods Sold in Auxiliaries Adjustments Include: Applicable Credits O&M Expenses Allowable Building Depreciation Allowable Equipment Depreciation Interest Expense Gain/Loss on Disposal of Depreciable Assets Financial Statement Functional Category Instruction F&A Function Group Department Administration Instruction Indirect or Direct Indirect Direct Research Department Administration Research Indirect Direct Public Service Department Administration Public Service Indirect Direct Academic Support Student Services Administration Department Administration Library Specialized Service Facilities Other Direct Costs Other Direct Costs Indirect Indirect Direct Direct Direct Institutional Support General Administration Indirect Operation and Maintenance of Plant Operations and Maintenance of Plant Indirect Scholarships and Fellowships Eliminated from Proposal Auxiliary Enterprises Auxiliary Enterprises Direct Building Depreciation Indirect Equipment Depreciation Indirect Interest Expense Indirect Step 1. Develop the F&A cost pool: - Administrative salaries/wages - Associated fringe benefits - Finance and accounting costs - Supplies, materials and expenses - Space related (O&M) - Administrative travel - Total pool costs $350,000 75,000 25,000 17,000 27,000 6,000 $500,000 Step 2. Develop the base costs: Cost Objectives - Federal NIH grants - Federal NASA grants - Ford Foundation grants - State Contracts - Other university subcontracts - Endowment funded programs - Total base costs Direct S&W $300,000 350,000 400,000 250,000 300,000 400,000 $2,000,000 Step 3. Calculate the rate: F&A cost pool Direct cost base $ 500,000 $2,000,000 = 25% Step 4. Apply the rate: Federal NIH grants $300,000 Federal NASA 350,000 Foundation grants 400,000 State contracts 250,000 Subcontracts 300,000 Endowment 400,000 Total reimbursement x x x x x x 25% 25% 25% 25% 25% 25% = $75,000 = 87,500 = 100,000 = 62,500 = 75,000 = 100,000 $500,000 Resources: DCA Short Form Sample: http://rates.psc.gov/fms/dca A-21: http://www.whitehouse.gov/ omb/circulars_a021_2004 Ginger Baker Senior Manager (702) 994-2999 [email protected] Eileen Campbell Manager (435) 770-5225 [email protected]
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