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Preparing Indirect Cost Proposals and
Understanding OMB's Super Circular





The two most important things to master if you’re involved with federal grants and contracts are indirect cost concepts and the new OMB Super Circular. A thorough understanding will assure that your tribe or organization receives the maximum allowable contract support and that there will be no surprise disallowed costs during the life of your contract or grant.

This class was designed to give you the best of our two most popular programs — Indirect Cost Strategies and OMB Circulars. Our simple, practical approach to indirect costs will help you gain the skills needed to create a winning proposal. Careful case study analysis and hands-on experience will reveal strategies for managing successful tribal government programs.

In December 2013, the Office of Management and Budget (OMB) released its long-anticipated Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, popularly known as the "Super Circular." This final guidance supersedes and streamlines requirements from OMB Circulars A-21, A-87, A-110 and A-122 (which have been placed in OMB guidances); Circulars A-89, A-102 and A-133; and the guidance in Circular A-50 on Single Audit Act follow up. Make sure you're in the know about what these changes are, how they'll impact your tribe and what you need to do to make sure you're in compliance!

In this class, you'll get the most comprehensive, up-to-date information available on the revised guidelines for administering federal grants and contracts. You’ll learn about new recordkeeping requirements for employees, new limitations on council and board stipends and requirements regarding the preparation of indirect cost proposals. Learn how the latest Supreme Court decision impacts IDC recoveries and claims.

Don’t miss this great opportunity to learn the essentials for successfully managing your federal grants and contracts. Space is limited — so register early!

T O P I C S   I N C L U D E
OMB's Super Circular
  • Consolidation of 8 existing OMB Circulars into one document
  • Key reforms to regulations on:
    • Uniform grant administrative requirements
    • Cost principles
    • The Single Audit rules
    • Indirect Cost Proposals
    • Notice of Funding Opportunities
    • Major Program determination process
    • Percentage of coverage
    • Criteria for Low-Risk Auditee status
Understanding Indirect Costs
  • Introduction to indirect cost theory
  • Tribe’s right to define
  • Purpose and definition of indirect cost
  • Types of rates/agreements:
    • Provisional
    • Fixed/carry-forward
    • Lump sum
  • Typical direct and indirect costs
  • Choosing a base
  • Indirect cost recovery
  • Consistency rule
Indian Self-Determination and Educational Assistance Act
  • Application of the Act
  • Key excerpts
  • Indirect cost funding
  • Contract support
Multiple Indirect Cost Rates
  • Departmental indirect cost rates
  • Establishing indirect cost pools
  • Maximizing your department’s funds
  • Calculating the rates
  • Distribution methodology
  • Indirect cost template
Negotiating with the Cognizant Agency
  • Right to negotiate
  • Effective negotiating strategies
  • Appeals process
Contract Support Costs
  • Federal Register
  • IHS Circular 2001-05
  • Standards for review and approval of contract support costs in the IHS
Proposal Format
  • Sample indirect cost proposal for a tribal organization:
    • Introduction
    • Certification
    • Accounting system
    • Organizational chart
    • Rate computation
    • Proposed base and pool
  • Applying a format to your organization
Space Allocation Plans
  • Purpose of the plan
  • Capturing all costs
  • How to change common area
  • Costs that can be included
  • Including your mortgage payments
  • Sample plan
Indirect Cost Issues
  • Ramah-Navajo impact on indirect cost issues
  • Disallowed costs
  • Department of the Interior — National Business Center guidelines for proposals
  • Over-recovery issues
  • Calculating IHS-BIA shortfalls
  • Collecting actual under-recovery
Common Problems
  • Inconsistency
  • Capital items
  • Lease-backs from tribe
  • Tribal enterprises
  • Direct billing of indirect charges
Cost Principles for Taxes
  • Allowable and allocable costs
  • Unallowable charges
  • Allowable taxes to federal programs
  • Tribal and TERO taxes
  • Indian Self-Determination Act provisions:
    • Relating the new cost principle provisions of Section 106(k) to existing cost circulars
Interest and Insurance Costs
  • Charging interest on your own funds
  • Interest paid on capital projects
  • Interest costs on capital equipment and buildings
  • Allowability of general insurance costs
  • Not insuring government-owned property
  • Self-insurance funds
General Government Expenses
  • Salaries of tribal chairs
  • Cognizant agency approval requirements
  • Managing and operating programs
Disallowed Costs
  • Justifying questioned costs
  • Appeals process under P.L. 100-472
  • Recent Board decisions:
    • EPA Inspector General opinions
    • HHS Departmental Appeals Board decisions
Grants and Cooperative Agreements with State and Local Governments
  • Pre-award requirements
  • Post-award financial management
  • Monitoring and reporting requirements
  • Audit close-out and enforcement provisions
  • The Common Rule
Purchasing Standards
  • Micro purchase guidelines
    (< $3,000)
  • Small purchase guidelines
    ($3,000 - $150,000)
  • When prior approval is needed
  • Protest and bonding issues
Matching Requirements
  • Using other agencies and program income funds as match
  • Special provisions for Section 103 P.L. 93-638 grants
  • Value of in-kind services
  • Recent HHS Board decisions
Management Requirements
  • Property management:
    • Titles, equipment and real property
    • Disposal
  • Financial management:
    • Obtaining certification
    • Cash management
    • Returning interest earned
The Single Audit Act
  • OMB Super Circular
  • Audit follow-up
  • Failure to have a required audit
  • Recordkeeping
  • Report submission and release

Topics subject to change.

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