ALL AGENCIES, DEPARTMENTS, AND DISTRICTS GOVERNED BY THE BOARD OF SUPERVISORS
_________________________________ David E. Sundstrom, Auditor-Controller
County policy for charging the costs of County services to outside agencies, businesses, and individuals, and other County funds, is for full cost recovery whenever possible. This necessitates that departments'/agencies' billings include appropriate County and department/agency indirect costs.
The purpose of this procedure is to provide basic guidelines for calculating department billing rates and indirect costs. If any provisions of this procedure are in conflict with applicable state/federal regulations those other regulations govern.
Federal Office of Management and Budget (OMB) Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments, (revised 1995; amended 1997)
A-87 is the primary regulation for determining indirect costs chargeable to federal and state awards.
Federal Department of Health and Human Services (DHHS) publication ASMB C-10 Implementation Guide for OMB Circular A-87 (revised 1997; formerly OASC-10)
ASMB C-10 amplifies and comments on the provisions of A-87. It provides general guidelines for determining direct and indirect costs applicable to federal programs and for preparing and submitting cost allocation plans.
State Controller's Handbook of Cost Plan Procedures for California Counties
The Handbook supplements A-87 and ASMB C-10 and provides guidance that is specific to California counties.
Accounting Standards and Procedures Manual
The State Controller's Accounting Standards and Procedures for Counties provides generally accepted accounting principles and procedures.
State of California Government Code Section 51350
Authorizes counties to charge cities for costs incurred in providing services that are contracted or authorized by law.
State of California Government Code Sections 54985 et al.
Authorize counties to charge fees to recover the costs of providing services.
Board of Supervisors Resolution No. 68-566, dated May 28, 1968
Authorizes the Auditor-Controller to compute, or review and approve, all billing rates charged by County departments and districts, and requires inclusion of both departmental and general overhead factors when computing costs and determining charges for services.
Board of Supervisors Resolution No. 77-346, dated March 8, 1977
Clarifies the policies and procedures for including indirect costs in grant applications.
Board of Supervisors Resolution No. 77-1194, dated July 19, 1977
Established policy of charging General Fund overhead costs to specific districts and funds.
Established policy of charging General Fund overhead costs to special districts & County service areas governed by the Board of Supervisors.
Following are definitions of terms used in this procedure.
When allocating costs, calculating an indirect cost rate, or determining fees, costs are divided by an appropriate factor that is referred to as the base. Allocations and fees usually have bases related to the unit of work processed (e.g., one document), or the increment of service time (e.g., productive hour), or the use of an item (e.g., miles driven, square footage occupied, machine hours used). Indirect cost rates usually have a base of salaries or salaries and employee benefits (S&EB).
Billing rates comprise direct and indirect costs of providing a product or service divided by the unit of that product or service (e.g., service hour, completion of a specified service, unit of product provided).
Costs that can readily be identified with (i.e., tied to, traced to) specific functions, programs, jobs, or activities. Examples of direct costs include S&EB of program staff, expenditures incurred specifically to carry out a program, and charges through the Job Cost Accounting System to a billable work assignment.
Costs associated with, or attributable to, current services that will not be paid until a future period. If applicable, these costs should be determined and a portion of them included in current, indirect cost calculations. As an example, closure costs for County landfills must be estimated and included in current indirect costs. Other, possible future costs could be: extraordinary maintenance costs, allowances for defaults on collections, potential liability/damage claims, or estimated costs for statutory/regulatory changes. Future costs can be diverse; therefore, take time to consider what they might be and whether they should be built into current indirect cost calculations. The primary consideration is whether costs that will be paid in the future are attributable to current operations or service recipients.
Costs incurred for common or joint purposes that benefit most of a department's/agency's operations and that cannot be directly associated with particular operations without unreasonably excessive efforts. Indirect costs may comprise one or more of the following components: (1) indirect costs of the department/agency; (2) indirect costs of the department's/agency's divisions or other organizational units; and (3) County General support service costs as determined by the County Wide Cost Allocation Plan (CWCAP).
When indirect costs are recovered through an agreement between the County and another entity, or a state/federally funded program, they may be limited by the agreement or by what state/federal agencies allow. See specific agreements or program reimbursement guidelines.
County Wide Cost Allocation Plan (CWCAP)
CWCAP (also referred to as the "cost plan") is an annual allocation of the indirect costs of building and equipment depreciation and of County General Fund support services to those County departments, agencies, and funds that receive the benefits of those fixed assets and services. CWCAP allocates costs using bases (e.g., direct billings, hours paid, checks processed, expenditures) that correlate with the benefits/services received.
Annual CWCAP allocations are based on service departments'/agencies' actual costs from two years prior (e.g., FY 2002-03 CWCAP is based upon FY 2000-01 actual costs). Because support departments often direct bill other departments/agencies for services provided, CWCAP reduces total cost allocations for direct billed amounts.
Although CWCAP allocates costs to the departments/ agencies within the County General Fund, the costs are not charged to them; only costs allocated to funds outside the County General Fund are charged ("debt service" and "agency" fund types are not charged). CWCAP allocations of building and equipment depreciation costs are not charged to funds unless the assets were paid for by the County General Fund.
CWCAP costs allocated to a department/agency, whether charged or not, are indirect costs to that department/agency. Departments/agencies should include these costs when determining their fees and billing rates.
Auditor-Controller Cost Studies prepares CWCAP each fiscal year for the upcoming fiscal year. For information related to CWCAP contact staff in that unit.
Department-wide and Division/Program-level Indirect Costs
Departments have indirect costs (e.g., administration and support) which benefit their entire organization. Individual divisions/programs within departments may have their own indirect costs (e.g., managers and supervisors), which may need to be determined and recovered.
Often only department-wide indirect costs need to be determined. Sometimes division/program-level indirect costs must be determined if they support a program but cannot be recovered as direct costs of that program.
Indirect Cost Rate (Percentage)
An indirect cost rate refers to indirect costs divided by an appropriate base (typically salaries or S&EB).
Indirect Cost Rate Proposals (ICRPs)
ICRPs are a specific form of departmental indirect cost rate calculation. They are addressed by A-87, Attachment E and must conform to state/federal regulations, terminology, and preparation methodologies. An ICRP rate is stated as a percentage that represents the ratio of total department/ agency indirect costs and CWCAP costs to a base (e.g., salaries, S&EB). A department/agency can apply that percentage to base amounts (e.g., salaries) of functions, programs, or activities to determine its indirect costs.
For more information about ICRPs, see A-87, Attachment E, or contact Auditor-Controller Cost Studies.
The term overhead is not used elsewhere in this procedure. Although it is a commonly used term, it sometimes refers to an entity's indirect costs, and it sometimes refers only to indirect, fixed costs (e.g., facility costs).
This is a combination of the costs of employees' non-productive time and fringe benefits (e.g., insurance, retirement) that is typically calculated as a percentage of base pay and is applied to employees' hourly pay rates. It is often used as a factor in the Job Cost Accounting System to charge appropriate amounts of labor burden costs whenever employees charge direct hours to jobs. Inclusion of a labor burden factor helps recover costs of employees' non-productive time and fringe benefits.
Organizational Unit (Organizational Level)
As used in this procedure, the term organizational unit refers to the County Accounting & Personnel System (CAPS) term for organizational unit designations within a fund/agency.
Revenue (Credit) Offsets
These are revenues or credits that reduce/offset the costs of providing a product or service. These receipts, or reductions of expenditures, reduce or offset cost items allocable to billed programs/activities. Examples of such transactions include purchase discounts, rebates, allowances, recoveries, indemnities on losses, insurance refunds, gains on a sale of fixed assets, and adjustments resulting from overpayments or erroneous charges. To the extent that credits accruing to, or received by, a department/agency relate to allowable program/activity costs, a proportionate share of the credit must be utilized as a cost reduction to the program/activity. For state/federal awards this cost reduction is required by A-87.
Roll Forward (Carry Forward)
A-87 requires that CWCAP contain roll forward calculations for all departments (excluding the support departments being allocated). County departments with federally funded programs (e.g., SSA) must use these roll forward amounts. Other County departments generally do not use roll forward amounts, even though the amounts are shown for them. Roll forward amounts represent an adjustment of the costs used in CWCAP two fiscal years previous. The earlier year's CWCAP costs were estimates for that year. Two years later we have actual costs. The differences between the estimated cost allocations and the actual cost allocations are roll forward amounts.
Following are definitions of different units of employee time (hours). When calculating hourly fees and rates, an appropriate time base must be used.
An employee's total paid time includes a combination of productive (see 188.8.131.52) and non-productive time. Non-productive time is non-work time and includes:
paid time away from the job, of which the major types are: vacations, sick leave, paid holidays, compensatory time off, jury duty;
paid time at work not directly performing a department's/ agency's tasks/operations (e.g., training and break time).
Properly calculating total non-productive time provides the basis for calculating productive time and hourly rates based upon productive time.
Employees often include their break time in the time they charge to work assignments. If break time is not charged directly to work assignments, and if it is separately listed on employees' time sheets, then it should be included as a component of non-productive time.
Hours worked in excess of regular straight-time hours. Overtime hours should be billed at different rates than regular hours. Consequently, it may be necessary to determine incremental cost adjustments for overtime work. Overtime compensation usually entails higher hourly pay offset by lower benefit costs; these compensation differences can be used to calculate an adjustment to basic hourly billing rates.
Productive time is on-the-job work time. Productive time is usually calculated by deducting non-productive time (see 184.108.40.206) from total time. Productive time is used as a base when determining productive hourly rates.
CAPS report HR67A10 provides productive and non-productive hours and cost information. The report is calculated from payroll; therefore, it does not show departments'/agencies' internal non-productive time, such as break time and training time.
If actual productive hours cannot be determined in a cost effective manner, the State Controller generally allows (for state funded/mandated programs) the use of a default of 1,800 productive annual hours based upon a total of 2,080 annual hours.
Standard Times (Measured Clock Times to Perform Services)
These are standard times needed to perform tasks, and they are sometimes used to calculate fees for performing a task (e.g., processing a document). Under-recovery of costs may occur when using fees based upon standard times if the rates are calculated using bases of total hours (e.g., 2,080 hours/year) or productive hours. When developing billing rates using standard times, a position's costs should be spread over the hours charged to work assignments (see 220.127.116.11). Under-recovery may also occur if standard times are not designed to recover non-task times such as wait time (e.g., wait time between serving customers), filing, or responding to inquiries.
Time Charged to Work Assignments
Time charged to work assignments represents time that employees charge to their primary work assignments, whether billed or not, and generally excludes their indirect work such as record keeping, maintenance, filing, and training. It will usually be less than productive hours; consequently, it will result in higher hourly rates. If a significant portion of productive time is not charged to work assignments, then a base of time charged to work assignments may be more appropriate than productive time for recovering costs. This distinction is important when deciding on an appropriate base for a billing rate. See the example in Exhibit II attached to this Procedure, which emphasizes the differing results from different time bases.
Total hours, such as 2,080 hours/year may be an appropriate base for calculating a full year's S&EB costs. It may also be appropriate when billing a percentage of a position's costs. It is usually an inappropriate base for calculating an hourly billing rate.
Review Controlling Statutes, Agreements, and Regulations
Review statutes, agreements, and regulations that govern the specific billing rates or indirect costs. This procedure cites only general statutes and regulations; often, other rules apply (e.g., funding agency's claiming instructions, grant guidelines). If rates or fees are for a funded program, identify any claiming limitations, calculation methodologies, and unallowable costs specified by the agreement or claiming guidelines.
Determine the Purpose of Billing Rate or Indirect Cost
Before preparing a billing rate or an indirect cost amount or rate, clearly determine the intended purpose/use (e.g., bill other departments, include in a grant claim, charge public for costs of a service) and the type of result that will be needed (e.g., amount/hour, amount/product, percentage rate). To help clarify the purpose, consider the following:
What costs are to be recovered (i.e., costs of an entire organization or costs for particular services/personnel)?
Do some customer groups incur different costs that should be billed differently?
How will billings be done?
Will there be one or multiple billing rates/methodologies?
What product or service unit will be billed (e.g., one photocopied sheet or one service hour)?
What cost base will be used (e.g., salaries, S&EB, productive S&EB, assignment hours)? Calculations can be directed toward the desired unit of measure.
Does the department/agency want a single, combined indirect cost rate for all of its units? Regulations permit a single, overall rate if operations are similar in nature, and if units' individual indirect cost rates would not be materially different.
Are multiple rates needed because of diverse operations that have widely varying indirect costs among divisions, organizations, or programs? If so, departments/agencies may need to calculate indirect costs at the division or organization level.
If a department calculates multiple rates or fees it must treat costs consistently for the different calculations. The same costs cannot be indirect costs for one rate/fee and direct costs in another rate/fee calculation. For example Accounting Assistants cannot be 100 percent indirect costs when calculating one rate and direct costs when calculating another rate. However, a cost element (e.g., Accounting Assistants' S&EB) may be split into direct and indirect components, which are allocated differently.
Select an Appropriate Allocation Base
If a rate is being calculated, select an allocation base that corresponds with how the rate will be used. Depending on the need, rates may include all costs (i.e., both direct and indirect costs), or they may be limited to specific components. Fees will generally include all costs and use an allocation base that is the unit of product or hour of service that will be charged. When the rate is an indirect cost rate, the allocation base will generally be either salaries or S&EB.
Often studies are prepared before or during the period to which they will apply, and the costs will be either actual costs from a previous period or estimated costs (e.g., budgeted amounts) for the period of study.
Calculations of Billing Rates and of Indirect Costs
These steps are to aid in calculating billing rates and/or indirect costs/rates applicable to services and products. Many of the steps apply both to billing rates and to indirect costs. Indirect costs are just one component of billing rates. The primary components of most billing rates are the direct costs associated with the product or service.
Regardless of how costs are classified and distributed, account for all costs, including unallowable costs. Expenditures (individually and in total) must agree to supporting financial source documentation (e.g., CAPS accounting reports such as Expenditure Budget to Actual reports and Job Cost Accounting reports). Itemizing and grouping costs should usually be done to aid referencing back to original source documentation and to associate costs with a funding entity's required claiming categories. If necessary, obtain organization level expenditure data (e.g., level 01, 02, 03) from CAPS to identify costs for a particular function, program, or activity.
Identify Credits and Revenue Offsets
Identify any rebates, refunds, recoveries, credits, or carry-forward adjustments that were received or accrued. Deduct amounts that represent credits/offsets to costs.
Once all costs have been listed, sort them into categories of unallowable costs, allowable indirect costs, and allowable direct costs.
Determine Unallowable Costs
Review costs for allowability under applicable regulations. Allowable costs must be necessary and reasonable. Unallowable costs must be identified and excluded. Regulations cited in section 1.2, above, provide guidance on costs that are allowable, unallowable, or allowable under specified conditions.
Below is a partial list of the most common allowable/ unallowable expenses according to A-87, Attachment B. Even if unallowed by a federal program, some costs may be includable when determining rates or fees that will be charged to others (e.g., landfill fee, permit fee).
Materials and supplies
Maintenance and repair
Printing and reproduction
Training and education
Bad debts (cannot be charged to the federal government unless provided for in the applicable federal regulations)
If unallowable costs are base unit costs, they must receive an allocated share of indirect costs. For example, costs of issuing bonds are unallowable; nevertheless, a share of indirect costs must be allocated to staff working on bond issuance activities.
Costs Allowable Under Certain Circumstances (see *, below):
Some interest and other financial costs (see A-87)
Memberships, subscriptions, and professional activities
Meetings and conferences
* According to A-87, the above costs may be allowable provided: (1) benefits received are related to the function, program, or activity; (2) the cost is reasonable relative to the value of the service benefit received; and (3) the department/agency does not devote a substantial part of its activities to influencing legislation. Whenever allowability is in doubt, discuss with the funding agency and obtain specific advance approval.
Categorize Direct and Indirect Costs
Group department and County direct and indirect costs. Exclude items from indirect costs if they have been, or will be, claimed as direct costs. For example, some programs receive funding to reimburse the costs of fixed asset purchases; if so, they must ensure that corresponding portions of their fixed assets' depreciation are excluded from CWCAP costs.
Personnel Costs: Sort all positions into direct and indirect categories. Some positions may have portions of their time in both categories. An organization chart is usually helpful when determining whether positions are direct or indirect. Directors, assistant directors, division managers, administrative staff, secretaries, clerks, systems/computer support personnel, receptionists, analysts, accounting staff, and technicians should be considered when identifying indirect positions since most of these support more than one function.
Services and Supplies Costs: Examine expenditure line items and determine whether they benefit one program (direct) or multiple cost objectives (indirect). Costs such as telephone, office supplies, and office equipment maintenance are typically treated as indirect. Some costs may be direct with respect to one department, but indirect with respect to another; classification depends on the particular department/agency and the type of activity.
CWCAP Costs: The Auditor-Controller allocates CWCAP costs (see section 18.104.22.168) to most departments/agencies at the fund-agency level, not at individual organization levels. If an indirect cost rate is being calculated for the entire department/agency, include the entire CWCAP allocation to the agency (generally excluding roll forward). Use the CWCAP that is for the same year as the indirect cost rate.
Allocate Allowable Indirect Costs
Developing a single indirect cost rate for an entire department/agency is the easiest option and entails dividing all indirect costs by a single base. If usage of indirect support is reasonably equal among units, indirect costs may be uniformly allocated to all organizational units.
When some organizational units use significantly more or less resources than others, greater or lesser amounts of indirect costs should be allocated to them. Developing multiple indirect rates for a department/agency requires allocating indirect costs to the department's/agency's organizational units. Methods of allocation depend on how similar (or dissimilar) units' operations are and how they share indirect resources.
Single Rate for Entire Department
When a County department/agency has only one major function, program, or activity, or when all of its major functions, programs, or activities benefit from allowable indirect costs to approximately the same degree, a single rate for the entire department/agency may be prepared. Allowable indirect costs are divided by the selected cost base (e.g., salaries, S&EB).
Multiple Rates for Department's Functions
Departments/agencies that have several major functions, programs, or activities that benefit, in widely varying degrees, from its allowable indirect costs may have functional indirect cost rates that would be significantly different from one another. If that appears to be the case, cost rates will need to be determined for each major function. Group indirect costs into functional cost pools (e.g., general administration, divisional administration, building occupancy) that have similar characteristics. Then, allocate each cost pool among benefiting functions, programs, or activities by means of bases that best reflect the relative benefits received. When doing this, similar groups of programs may be combined.
Many cost factors associated with a function, program, or activity may be adaptable for use as allocation bases provided (1) they can readily be expressed in terms of dollars or other quantitative measures (e.g., total direct costs, direct salaries, staff hours applied, square feet used, hours of usage, number of documents processed, population served, etc.), and (2) they are common to the benefited functions. For other bases for cost distribution refer to ASMB C-10, Appendix 3.
It may also be necessary to allocate CWCAP among the department's/agency's individual organizations. If so, use a reasonable allocation base for each CWCAP line item (e.g., allocate building depreciation based upon square footage or employee counts; allocate equipment depreciation based upon AC42 depreciation details or equipment expenditures; allocate A-C Payroll costs based upon hours paid). If some organizations receive significantly more or less central support than other organizations, they should also receive relatively greater or lesser allocations of CWCAP. Re-allocations should distribute CWCAP costs in proportion to the benefits the organizations receive. For example, County Counsel provides outstationed attorney staff to John Wayne Airport and when calculating County Counsel hourly billing rates the building depreciation portion of County Counsel's CWCAP is re-allocated with none directly allocated to outstationed staff.
Calculate an Indirect Cost Rate
Compute an indirect cost rate by dividing total remaining indirect costs by the direct cost base selected for distribution of the indirect costs. In most cases, the direct base is either direct salaries or direct S&EB. However, other bases, such as total direct costs less capital expenditures, may be used when they can be demonstrated to be more equitable. See Exhibit I for a simplified example of a departmental indirect cost rate calculation.
Calculation of Billing Rate
A billing rate can be determined by combining direct and indirect costs and dividing them by the unit of service. See Exhibit II for a simplified example of a billing rate calculation.
Default Indirect Cost Rate
Some state/federal programs allow an indirect cost rate (encompassing both CWCAP and department indirect costs) of 10 percent instead of preparing an indirect cost rate study. This can save the time and cost of preparing a rate study; however, using a 10 percent indirect cost rate usually under-recovers indirect costs.
A-87, Attachment A, paragraph G allows a 10 percent default indirect cost rate for billing one County department's/agency's costs to another (see this A-87 section for details).
Updating Indirect Costs, Fees, and Rates
Indirect costs, fees, and rates should be reviewed periodically to determine whether they require updating. If updating is needed, the study may be entirely redone. Alternatively, it may be possible to adjust for inflationary changes or to update specific cost elements. Implementing fee changes will generally require Board of Supervisors approval.
Reviews of Indirect Costs
When a department/agency calculates its own indirect costs, it may, if desired, submit its calculations to Auditor-Controller Cost Studies for review. Even when a department/agency contracts with a consultant to prepare its rate study, Auditor-Controller Cost Studies is available to review the consultant's work.
Record Keeping Requirements for Specific Cost Elements
This procedure has not discussed record keeping requirements for specific costs elements, such as personnel costs. Documentation requirements are covered by A-87, department policies, and agreements.
Retention of Records
Documentation should be retained for a minimum of three years after the year to which the cost study applies. If applicable, departments/agencies should review their grantor agency's specific record retention requirements.
For additional information regarding CWCAP, departmental indirect costs/ rates, or ICRPs, contact the Auditor-Controller's Cost Studies.
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