Insular Areas, State, and Local Governments
What's New with Indirect Cost Negotiation Services? | Information for Nonprofit Organizations | Information for Insular Areas, State, and Local Governments | Information for Indian Tribal Governments | FAQs
Welcome to Indirect Cost Services and our focus on insular areas, state, and local governments!
This information is intended to facilitate the completion and submission of your indirect cost rate proposal or Cost Allocation Plan. We have designed a series of checklists, forms, samples, and templates to assist you in meeting the ICP or CAP documentation requirements.
Additional support is provided with links to cost principle guidance and frequently asked questions.
Please be sure to include the completeness checklist and required certifications with your ICP or CAP.
- Insular Areas, State and Local Governments Indirect Cost Rate (ICR) Proposal Completeness Checklist
- Cost Allocation Plan CAP Completeness Checklist
For fiscal years prior to December 26, 2014 (subject to 2 CFR 225)
- Certification of Indirect Costs State
- Insular Areas, State and Local Governments Certificate of Cost Allocation Plan
For fiscal years that start after December 26, 2014 (subject to 2 CFR Part 200)
- Certificate of Indirect Costs for State & Local Governments and Indian Tribes
- Certificate of Cost Allocation Plan for Insular Areas, State & Local Governments
Guidelines and Related Links:
- 2 CFR 225- (OMB Circular A-87) Cost Principles for State, Local, and Indian Tribal Governments
- A Guide for State, Local and Indian Tribal Governments: Cost Principles and Procedures for Developing Cost Allocation Plans and Indirect Cost Rates for Agreements with the Federal Government. (U.S. Department of Health and Human Services Guide --ASMB C-10)
- HHS-DCA Best Practices Manual For Reviewing State and Local Governments State/Local-Wide Central Service Cost Allocation Plans and Indirect Cost Rate Proposals
- Catalog of Federal Domestic Assistance
How to locate the Code of Federal Regulations (CFR):
- After following this link to the Electronic Code Federal Regulations: http://www.ecfr.gov
- Under Browse, select "Title 2 – Grants and Agreements" then press "Go"
- Under Browse Parts, select "200-299" Office of Management and Budget Guidance
- Under CHAPTER II—OFFICE OF MANAGEMENT AND BUDGET GUIDANCE, select "200-299"
- Select Part 200 - UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS
Indirect Cost Services FAQs:
- Carryforward Template
(For use by Insular Areas, State and Local Governments to calculate carryforward amounts when using a fixed with carryforward rate.)
- PRDJ 3% Limitation Verification Schedule
(Template and instructions to analyze the three percent limitation on central services administrative costs chargeable against the U.S. Fish and Wildlife Service's programs.)
Insular Areas, State, and Local Governments FAQs:
1. Which federal agency is the cognizant agency for my organization?
The cognizant agency for negotiating indirect cost rates shall be the federal agency that provides the majority of the federal funding (per OMB guidance).
Interior Business Center's Indirect Cost Services is the federal cognizant agency designated by OMB to negotiate indirect cost rates for:
- All Indian tribal governments and their component units (component units are legally separate organizations for which the elected officials of the primary government are financially accountable)
- Insular area governments (such as Guam, America Samoa)
- Nonprofit, state, and local entities that receive a majority of their federal funding from the Department of the Interior
On January 6, 1986 Federal Register, OMB published a list of cognizant agency assignments for state and local governments. To date, this list has not been revised.
2. What is the difference between an indirect cost rate and a cost allocation plan?
An indirect cost rate is a device for determining, in a reasonable manner, the proportion of indirect costs each program should bear. It is the ratio (expressed as a percentage) of the indirect costs to a direct cost base. Indirect costs are grouped into a common pool and then distributed to individual federal awards by the use of the indirect cost rate. Once negotiated by Indirect Cost Services, an indirect cost rate will be accepted and used by all federal agencies unless prohibited by statute - so that an organization can use the negotiated rate for new programs/grants from all federal agencies.
In contrast, a cost allocation plan (CAP) is a document that explains an organization's methodology in identifying, accumulating, and allocating allowable costs to its all departments and agencies. Some federal agencies still require an approved indirect cost rate even though a CAP has already been approved.
3. Is there a standard format that we should follow to compile the indirect cost proposal or cost allocation plan?
Indirect Cost Services has created sample proposal formats, checklists, and templates to assist you in completing the ICP and CAP proposals. Please select the appropriate sample proposal for your type of organization (i.e., Insular Areas, State, and Local Governments). Although it is not required that you follow our ICP or CAP format, we encourage you to follow as much as possible because doing so will expedite our review process since our format will contain the information we needed to process the proposals. Even if you do not follow our format, please ensure all the items on our checklist is provided.
4. What is the 3% limitation applicable to SWCAP/CSCAP?
For state entities that receive federal aid apportionment through the Department of Interior, Fish and Wildlife Service's Wildlife Restoration Act (PR) and Sport Fish Restoration Act (DJ), there are restrictions placed on the expenditure of indirect costs in relation to these funds.
Specifically, 50 CFR Ch.1, Part 80.15 (d) requires that "administrative costs in the form of overhead or indirect costs for state central services [SWCAP/CSCAP] outside of the state fish and wildlife agency must be in accord with an approved cost allocation plan and shall not exceed three percentum (3%) of the annual apportionment."
Indirect Cost Services has created a sample 3% limitation verification schedule and working template for your convenience. If your entity receives PR/DJ funding, Indirect Cost Services requires a submission of the 3% limitation verification schedule and related support.
5. I've already included a copy of the SWCAP schedule in the proposal, why do I need to provide the entire signed SWCAP agreement?
We require the entire SWCAP agreement to ensure the SWCAP amount has been reviewed and approved by the Department of Health and Human Services. 2 CFR 225 Appendix E, Section D.1.d states that SWCAP must be based on the latest federally-approved plan.
6. The SWCAP/CSCAP for the year that we are finalizing has not been negotiated, what should we do?
Sometimes the proposed central service cost allocation plan for the period being negotiated has not been approved by the time the indirect cost rate proposal is submitted. In that case, the indirect cost proposal may be prepared with an amount for central services that is based on the latest federally approved central service cost allocation plan (See 2 CFR 225, Appendix E, Section D.1.d).
The difference between these central service amounts - and the amounts ultimately approved - will be compensated for by an adjustment in a subsequent period. Please contact Indirect Cost Services for an example demonstrating how the adjustment will be made.
7. Our state issued audited financial statements are comprehensive and extremely high leveled, I am not able to extract any information from the audit to support the figures I used in the proposal. What should I do?
In lieu of the comprehensive audited financial statements, you can submit a copy of the general ledger instead. However, we do not need the entire run, we just need the last page from the accounting system showing the total expenditure. The negotiator may request for more detail reports from the accounting system if deemed necessary during the desk review.
8. Why do I need to provide a copy of the SEFA schedule (Schedule of Expenditures of Federal Awards) every year?
We need the SEFA schedule to verify the majority federal funder to ensure we are the federal agency to negotiate your organization's indirect cost rate. If there has been a permanent shift in federal funding that DOI will no longer be your majority federal funder, you need to inform our office as quickly as possible so we can refer you to the correct federal agency to negotiate your indirect cost rate.