1. Leading Excellence in Research Costing Practices
PRESENTATION FOR NATIONAL CONFERENCE ON COLLEGE COST ACCOUNTING Presenters: Arif “Mak” Karim, Director Janet Turner, National Specialist U.S. DEPARTMENT OF HEALTH & HUMAN SERVICES Program Support Center, Grants Finance & Administration Services
Leading Excellence in Research Costing Practices
General Conference: 11/2 – 11/4, 2016

2. COST ALLOCATION SERVICES (FORMERLY, DIVISION OF COST ALLOCATION)
U.S. DEPARTMENT OF HEALTH & HUMAN SERVICES
PROGRAM SUPPORT CENTER
FINANCIAL MANAGEMENT PORTFOLIO
GRANTS FINANCE AND ADMINISTRATION
Cost Allocation Services (CAS)

3. COST ALLOCATION SERVICES (FORMERLY, DIVISION OF COST ALLOCATION)
New York
Bethesda
Dallas
San Francisco

4. COST ALLOCATION SERVICES (FORMERLY, DIVISION OF COST ALLOCATION)
Director: Arif “Mak” Karim
(Dallas, Texas)
Deputy Director: Darryl Mayes
(Bethesda, Maryland)

5. COST ALLOCATION SERVICES (FORMERLY, DIVISION OF COST ALLOCATION)
CAS BRANCH CHIEFS BY REGION/OFFICE
New York San Francisco
Michael Stack (S/L) Naomi Tamashiro (S/L)
Louis Martillotti (C/U, NP &H) Patrick Smith (C/U, NP &H)
Louis
Dallas Bethesda
Matthew Dito (C/U, NP & H) Steven Zuraf (C/U, NP & H)
State, Local and Tribal Governments (S/L)
Colleges/Universities (C/U)
Non-Profits (NP)
Hospitals (H)

6. COST ALLOCATION SERVICES (FORMERLY, DIVISION OF COST ALLOCATION)
CAS NATIONAL SPECIALISTS
COLLEGES/UNIVERSITIES - New York Office
Michael Leonard
STATE, LOCAL & TRIBAL GOVERNMENTS – San Francisco Office
Janet Turner
PUBLIC ASSISTANCE COST ALLOCATION PLANS – Dallas Office
Terry Hill (Retiring 11/30/2016)
NOT-FOR-PROFIT ORGANIZATIONS & HOSPITALS
VACANT

7. COST ALLOCATION SERVICES (FORMERLY, DIVISION OF COST ALLOCATION)
CAS AS COGNIZANT AGENCY REVIEWS AND APPROVES
Facilities & Administration Cost Rate for
Institutions of Higher Education
State-Wide Central Services Cost Allocation Plans
Public Assistance Cost Allocation Plans
State & Local Government Departmental Rates
Hospital Patient Care Rates
Non-Profit Organizations
Audit Resolutions
Cost Allocation Standards Board’s Disclosure Statement (DS- 1&2)

8. COST ALLOCATION SERVICES (FORMERLY, DIVISION OF COST ALLOCATION)
PRESIDENTIAL TEAM IS VISITING HHS AS PART OF THE TRANSITION PROCESS
PSC/CAS - Provided Updates on:
GAO Report
Legal Issues Involving Appeals
Congressional Inquiries
Audit Issues
Organizational Structure

9. GAO RECOMMENDATIONS (4)
GAO REPORT
GAO RECOMMENDATIONS (4)
IMPROVE DESIGN OF INTERNAL CONTROLS TO PERIODICALLY REVIEW AND UPDATE POLICY AND REGULATORY CHANGES
STANDARDIZED DOCUMENTATION
SUPERVISORY AUDIT REVIEW STEPS
SIMPLIFIED METHOD BASE INFORMATION ON WEB
ABOVE WILL BE COMPLETED BY DATE 12/31/2016

10. COST ALLOCATION SERVICES EFLOW PROJECT – PAPER REDUCTION ACT
Mak Karim
Director, Cost Allocation Services
COST ALLOCATION SERVICES
EFLOW PROJECT – PAPER REDUCTION ACT

11. COST ALLOCATION SERVICES (FORMERLY, DIVISION OF COST ALLOCATION)
EFLOW PROCESS
CAS PROPOSAL SUBMISSION AND REVIEW PROCESS PAPERLESS. NON-FEDERAL ENTITIES MUST SUBMIT PROPOSAL ELECTRONICALLY
ENHANCEMENTS TO THE SYSTEM – WIP
PORTAL ACCESS – F&A PROPOSAL SUBMISSION DIRECTLY INTO EFLOW BY SPRING OF 2017
FOR PROFIT GROUP AT NIH/DFAS (DIVISION OF FINANCIAL ADVISORY SERVICES) WILL DEPLOY EFLOW BY 2017 (CAS MODEL)
CAS TO HOST FEDERAL RATE AGREEMENTS

12. COST ALLOCATION SERVICES (FORMERLY, DIVISION OF COST ALLOCATION)
OFFICE OF MANAGEMENT & BUDGET
DUE END OF NOVEMBER

13. ADMINISTRATIVE CONTRACTING OFFICER (ACO)
COST ALLOCATION STANDARDS BOARD (CASB – Disclosure Statement DS-2)
APPROVAL LETTER - CAVEAT
However, the CASB DS-2 Section requires disclosure of the Salary and Wage Cost Accumulation System.  In accordance with 45 CFR , Federal approval of the salary and wage cost accumulation system is not required.  Therefore, we express no opinion on the University’s salary and wage cost accumulation system. 
Approval of your DS-2 is subject to the following condition:  The information provided by the Institution of Higher Education is not later found to be materially incomplete or inaccurate by the Federal Government.

14. GASB – STATEMENT No. 68
During our review of your proposal, it was disclosed that the University’s actuarially determined pension contributions exceeded the Governmental Accounting Standards Board (GASB) Statement No. 68 calculated pension expense.  However, 2 CFR (g)(3) only allows pension plan costs determined in accordance with GAAP (i.e., GASB 68)
The Office of Management and Budget (OMB) is aware of the issue, and may publish proposed rule to delete 2 CFR (g)(3) soon
Since a final rule has not been issued, we reserve the right to make an adjustment to the billed pension costs to disallow the pension contributions in excess of the GASB 68 calculated pension expense.

15. De-Minimis rate - 2 CFR 200.414(f) / 45 CFR 5.414(f)
De-Minimis 10% Indirect Cost Rate
(10%of Modified Total Direct Costs)
New Grantee – Only for those Who Have Never Had a Federally Negotiated Indirect Cost Rate
Not available to State/Local Govt. Depts. receiving > $35 million Direct Federal awards
May be used indefinitely
No documentation required to support

16. De-Minimis rate - 2 CFR 200.414(f) / 45 CFR 75.414(f)
Pass-Thru Entities:
NOT PERMISSABLE (Pass-Thru Entities) – to force / entice a proposed subrecipient without a rate to take less than the 10% de minimis rate.
Pass-Thru Entities MAY, but are not required to negotiate a rate with a proposed subrecipient with no Direct Federal Funds who asks to do so
However, if a Pass-Thru Entity approved actual allowable indirect costs for a subrecipient prior to the Uniform Guidance, they are expected to continue doing so!

17. Indirect Cost Rate One-Time Extensions
2 CFR (g)/45 CFR (g) Any non-Federal entity that has a current federally negotiated indirect cost rate may apply for a one-time extension of the rates in that agreement for a period of up to four years
Requires review and approval by cognizant agency for indirect costs

18. Indirect Cost Rate One-Time Extensions
May not request a rate review until extension period ends
At end of 4-year extension, the non-Federal entity must re-apply to negotiate a rate
Subsequent one-time extensions (up to 4 years) are permitted IF a renegotiation is completed between each extension request

19. ANOTHER DAY AT THE OFFICE
NEGOTIATIONS
ANOTHER DAY AT THE OFFICE

20. NEGOTIATION PROCESS

21. Useful Websites & OMB Contact Information
Current version of Title 2 CFR Part 200 and
Title 45 CFR Part 75
Links include: 2 CFR 200 (link to ecfr.gov)
OMB Contact: Gilbert Tran (202)
CAS: rates.psc.gov