2017 07-26 Demystify the Government Contracting Challenges and Opportunities for Nonprofit Orgs

NON-PROFIT’S GOVERNMENT

CONTRACTING CHALLENGES, AND

HOW TO ADDRESS THEM

Helping Great Organizations Thrivewww.raffa.com P: 202.822.5000 F: 202.822.0669

PRESENTERS:

Jean Gilbert, CPA Raffa

Brett Martin, Raffa

Glenn Anstead, CPA Raffa

Mark Hoffman, CPA CPCM

JULY 26, 2017

Introductions and Overview

Who is in the room?• Your name and organization

• Size of organization

• Current accounting system

• What do you hope to take away from

today’s seminar?

Presenters • Jean Gilbert

• Glenn Anstead

• Brett Martin

• Mark Hoffman

RAFFA OVERVIEW

LARGE ACCOUNTING, PROFESSIONAL

SERVICES & TECHNOLOGY CONSULTING

FIRM

• Serve hundreds of clients in DC/MD/VA

• 240+ specialists on staff at all levels

• Support over 230 Financial System Clients

• Certified System Consultants, Certified Project

Management Professionals, Business Process

Consultants

32+ YEARS IN BUSINESS

17 PARTNERS, INCLUDING 11 WOMEN PARTNERS

WOMEN-OWNED FIRM

MULTI-CULTURAL WITH DIVERSITY AT ALL LEVELS

PRIMEGLOBAL ALLIANCE MEMBER

Raffa is nationally recognized with access to all the resources of the largest

international firms. We contribute to our clients’ abilities to achieve their

missions and deliver promises to the world.

WIDE RANGE OF SERVICES

• Technology Solutions

• ERP & Accounting Systems

• Software Development

• Managed IT Services

• Audit and Tax

• Managed Accounting

• HR Consulting

• Business Advisory

• Forensics and Litigation Support

• Employee Benefit Plans

• Search and Transition Services

NATIONALLY RECOGNIZED

• Top 100 Largest Accounting Firms

• Top 100 ERP VAR (Bob Scott & Accounting Today)

• Top 100 and Fastest Growing Value Added Reseller

NON-PROFIT GOV’T CONTRACTING

Agenda

• Welcome & Introductions

• Managed Accounting Services

• 10 Keys to Ensure a Successful Audit

• JAMIS Prime, the top cloud ERP for Government Contracting

• Overview - Uniform Guidance vs. FAR

• Cost Accounting & Indirect Rates

• Update on 10% de minimis

• Q & A

What type of government contracts do you do the

majority of the time?

Fixed Price

Time and Material

Cost Plus

All of the above roughly the same

We haven’t done contracts yet, just exploring

DISCUSSION #1

Part 1: Federal Grants

Managed Accounting Services

FEDERAL GRANTS ACCOUNTING

OUTSOURCING

UNIFORM GUIDANCE

• Consolidates regulations previously located in disparate places

• Remember A-110, A-120, A-122, A-123, A-133?

• Now, it is 2 CFR 200, with subparts

• Agency specific guidance

• US Department of Health and Human Services (45 CFR 75)

• National Science Foundation (Proposal and Award Policies and Procedures Guide)

• Environmental Protection Agency (2 CFR 1500)

• National Aeronautics and Space Administration (2 CFR 1800)

• National Endowment for the Arts (2 CFR 3255.1)


OUTSOURCING

COMPLIANCE REQUIREMENTS UNDER UNIFORM GUIDANCE

• Activities allowed or unallowed

• Allowable costs

• Cash management

• Eligibility

• Equipment and real property management

• Matching, level of effort and earmarking

• Period of performance

• Procurement suspension and debarment

• Program income

• Reporting

• Subrecipient monitoring

• Special tests


OUTSOURCING

WHERE DO I LOOK NOW IF I WANT TO COMPLY?*

*Does not include agency specific guidance

Compliance requirement Compliance source

Activities allowed or unallowed Grant document or contract

Allowable costs 2 CFR 200 Subpart E

Cash management 2 CFR 200 Subpart D

Eligibility 2 CFR Subpart C; Grant document or contract

Equipment and real property management 2 CFR 200 Subpart D

Matching, level of effort and earmarking 2 CFR 200 Subpart D

Period of performance Grant document or contract

Procurement suspension and debarment 2 CFR 200 Subpart D; 2 CFR Subpart C

Program income 2 CFR 200 Subpart D

Reporting 2 CFR 200 Subpart D

Subrecipient monitoring 2 CFR 200 Subpart D

Special tests Grant document or contract


OUTSOURCING

WHERE ARE THE MOST FINDINGS?

Compliance Requirement

% of Total

Findings

Allowable Costs 22%

Special Tests and Provisions 21%

Reporting 17%

Allowable Activities 13%

Cash Management 6%

Eligibility 5%

Equipment and Real Property Management 5%

Procurement and Suspension and Debarment 5%

Subrecipient Monitoring 4%

Period of Performance 3%

Matching, Level of Effort, Earmarking 2%

Program Income 1%

Source: 2015 Data Collection Forms Federal Audit Clearinghouse


OUTSOURCING

HOW CAN RAFFA HELP ME?

Compliance requirement Raffa services

Activities allowed or unallowed

We evaluate expenses and determine if the activity the

expense is paying for is an activity which is allowed by the

grant. It is extremely important that allowability of costs are

monitored internally.

Allowable costs

We track funds by line item and budget, we review the

invoice documentation to ensure it is an allowable cost.

We also review expenditures to ensure that they are being

captured in the period of performance, i.e. within th approved

award period..

Cash managementWe review your draws against your spend, and advise on

what you should draw

Eligibility

Eligibility requirements are specific to each contract. We

evaluate the eligibility of the recipients and subrecipients for

participation in the program and the amounts for which they

qualify.


OUTSOURCING

WHAT ELSE CAN RAFFA DO?


Equipment and real property

management

We set up fixed assets tracking to ensure that depreciation

charges for equipment purchased with grant dollars doesn't

get charged back.

Additionally, we review the agreement to ensure that the

equipment or real property is being properly accounted for

based on who has title to the equipment and that any assets

disposed off are disposed off in accordance with the terms of

the agreement.

Matching, level of effort and

earmarking

We track matching requirements based on the grant by

setting up an appropriate tracking mechanism in your

accounting system

Period of performanceWe track period requirements based on the grant document,

and carefully review cutoff dates for invoices

Procurement suspension and

debarment

We assist you writing policies, setting up a procurement

system, and procedures which will ensure that you are not

using vendors on the excluded parties list


OUTSOURCING

ANYTHING ELSE?


Program income

We ask in advance if you will be charging registrations or

subscription fees for anything that is produced by this

program. We carefully track any program income generated

for accurate reporting.

Reporting

We ensure that your monthly close is complete and that all

grant revenue and expenses are accurately reported so you

may report timely. We assist you in identifying reports

expected to be submitted and create a tickler file to ensure

that all reports are accurately and timely submitted.

Subrecipient monitoring

We will assist with ensuring that your policies and procedures

are in accordance with the regulations, in addition to working

with you to establish a risk monitoring plan for each

subrecipient based on the results of the risk assessment.

We help you to set up reports that subrecipients are required

to complete as well as reasonable deadlines; we advise you

if we see an issue with the subrecipient's report

Special tests

We read the grant document the gain an understanding of

what special tests the auditor may have in store for you, so

that you are not hit with a surprise finding

Part 2: 10 Keys for a

Successful DCAA Accounting

System Audit

10 KEYS FOR A SUCCESSFUL DCAA

ACCOUNTING SYSTEM AUDIT

1. CONDUCT PRELIMINARY MANAGEMENT REVIEWS/INTERNAL AUDITS

• Undertake management reviews or internal audits of the system to ensure compliance with the Contractor’s established policies, procedures, and accounting practices. DFARS 252.242-7006(c)(8)

• Utilize SF Form 1408 and DCAA Pre-award Accounting System Adequacy Checklist as guides

• Management should review company key policies e.g., timekeeping

• Internal audit team review DCAA Contract Audit Manual

2. ENSURE PROPER RECORDS RETENTION

• FAR Subpart 4.7 generally describes records retention requirements. Specific retention periods for the differing types of records are addressed as well as how to calculate the retention periods.

• Requires contractors to make available records, which includes books, documents, accounting procedures and practices, and other data, regardless of type and regardless of whether such items are in written form, in the form of computer data

• Necessary to satisfy contract negotiation, administration, and audit requirements of the contracting agencies and the Comptroller General



3. ESTABLISH INTERNAL AUDIT TEAM AND APPOINT INTERNAL LIAISON

• Management team to review policies and ensure corporate compliance

• Internal liaison to act as intermediary between DCAA and management team

• Internal audit team should have senior representative from finance/accounting, payroll/human resources, operations, legal and business development departments as well as a senior executive

• Internal liaison should have solid understanding of company operations and products/services, finance background and, ideally, experience with past DCAA audits

• Ensure that internal liaison is present at interviews of personnel

4. REQUIRE AN ENTRANCE CONFERENCE (CAM 4-302.1)

• Clarify the specific scope/parameters of the audit

• Ask auditor to identify approach to the audit

• Ask auditor to identify personnel he/she intends to interview

• Ask auditor to define length of intended field work



5. IDENTIFY AND COMMUNICATE WITH KEY EMPLOYEES

• Advise key managers and employees how to properly respond to audit requests and remind them to cooperate timely

• To the extent possible, have internal liaison schedule interviews during mutually convenient times with employees to mitigate disruption

• Inform key employees and managers of scope of audit and caution them to keep responses within scope

• Inform key employees and managers of internal liaison and that questions should be directed to internal liaison

6. BE RESPONSIVE

• DCAA Access to Your Employees (MRD PPS 730.4.A.9(July 2013))

• DCAA considers access to contractor employees a routine and established audit procedure that is necessary to satisfy the Generally Accepted Government Auditing Standards (GAGAS).

• “If during the course of any audit, the auditor considers access to employee observations or interviews to be essential to completing their audit, and the contractor fails to permit the auditor to interview those employees or observe them during the performance of their current duties, the auditor should follow the guidance in CAM Section 1-504.5, Resolution of Contractor Denials. If those efforts prove unsuccessful, the field audit office should continue to elevate the matter as an access to records issue, in accordance with DCAA Instruction 7640.17.”



7. MAINTAIN COMMUNICATIONS LOG

• Maintain a log of documents provided to DCAA and date provided

• Never provide originals

• Important for assessing what auditor relied upon to make findings and what auditor may have neglected to consider

8. KEEP AUDIT IN SCOPE

• Prevent audit creep and sure auditor stays within scope of audit agreed upon during preliminary conference

• If auditor refuses to stay in scope, request conference with supervisor

• Do not develop reports or analysis not otherwise maintained by company in ordinary course of business even if auditor demands



9. REQUEST THAT AUDITOR DISCUSS PRELIMINARY FINDINGS (CAM 4-303.1)

• The auditor should discuss preliminary audit findings (e.g., potential system deficiencies, potential FAR/CAS non-compliances, etc.) with the contractor to ensure conclusions are based on a complete understanding of all pertinent facts. MRDS 10-PAS-024(R) (DCAA “Rules of Engagement”)

• Contractor may make revisions after the auditor has discussed preliminary issues with the contractor.

• In those cases, the audit report MAY reflect the results of the audit of the original submission and include all questioned cost and/or deficiencies identified during the audit. The requestor/contracting officer should be notified that the audit report will reflect the FAO’s audit of the original submission, and the auditor will consider the contractor’s management approved revised submission the contractor’s concurrence with DCAA’s audit position. MRDS 10-PAS-024(R) (DCAA “Rules of Engagement”)

10. REQUIRE AN EXIT AND DRAFT REPORT (CAM 4-303.1)• “Upon completion of the field work, the auditor should hold the exit conference to discuss the audit

results and obtain the contractor’s views concerning the findings and conclusions.” MRDS 10-PAS-024(R) (DCAA “Rules of Engagement”)

• “For other than audits involving forecasted costs subject to negotiations, the auditor should provide the contractor a copy of the draft report, or at a minimum, the results of audit section of the draft report (including the opinion and any exhibits and notes, or statement of conditions and recommendations).” MRDS 10-PAS-024(R) (DCAA “Rules of Engagement”)

NON-PROFIT GOVERNMENT CONTRACTING

Let’s take a short 10-minute break…

Part 3: JAMIS Prime

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Proposal Estimating

Project Budgeting & Planning

Resource Management

Contract to Cash

Contract Management

Billing

Revenue Recognition

Accounts Receivable

Cash Receipts

Procure to Payment

Vendor Management

Procurement

Subcontract Management

Employee Expenses

Fixed Assets & Gov’t Property

Accounts Payable

Hire to Retire

Talent Acquisition

Employee Data Management

Time & Leave Management

Payroll

Benefits Management

Talent Management

Record to Report

Financial Architecture

Job Costing

Multi-Currency

Closing Process

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Reporting & Consolidation

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LET’S TAKE A TEST DRIVE…

Part 4: Overview

Uniform Guidance vs. FAR

UNIFORM GUIDANCE VS. FAR

1.1 Non-profits and FAR contracts

Some traditional “assistance” projects issued as FAR

contracts

Donors not paying full share of indirect costs on grants,

or are requiring cost-share

Non-profits seek to replenish fund balance with contract

profit

NON-PROFITS ARE CHASING AND WINNING CONTRACTS


1.2 Uniform guidance (2 CFR 200)

Applies to grants & cooperative agreements (COAGS)

Applies to “non-federal entity” (NFE)

Separate subsections for types of NFE:

• Non-profit organization

• Institute of higher education (IHE)

• State & local government

• Hospitals


1.2.1 Uniform Guidance at Agency Level

Agency implementation of 2 CFR 200 (e.g. USAID 2 CFR 700)

“Provisions” = agency requirements defined

May apply to applications and performance of award

Limited uniformity - each agency issues own provisions

• Standard provisions: special provisions, administrative

provisions, mandatory provisions (M), required as

applicable provisions (RAA), etc.

• “Non-standard” provisions unique to each award


1.2.2 Uniform Guidance (UG) Cost Accounting

Largely consistent across agencies

• Subpart A - definitions

• Subpart E - cost principles (basic cost accounting, UA

costs)

• Appendices, esp. Indirect cost identification and

assignment


1.3 Contracts under FAR

FAR applies to:

• Contracts awarded by most agencies

• Federally-funded contracts issued by state & local

governments (usually)

• Subcontracts under federally-funded contracts


1.3.1 FAR clauses

“Clause” = requirements stated in contract

Clauses apply to proposal and performance

FAR clauses = uniformity across all agencies

FAR supplement clauses = uniform across an agency

“Non-standard” clauses = unique to each contract


1.3.2 FAR procurement methods

FAR procurement basis:

FAR 12 commercial item acquisition

FAR 13 simplified acquisition

FAR 15 contracting by negotiation

(This session focuses on FAR 15)


1.3.3 Cost Accounting under FAR

Mostly consistent across agencies

Some changes in agency FAR supplements

• FAR 2 definitions

• FAR 31 cost principles

• Cost accounting standards (CAS) might apply


1.4 Similarities: Grants and Contracts

Usually Competitive Awards with defined evaluation criteria

Award based on technical and cost

RFA and “application” may look like RFP and “proposal”

Agency officials frequently overlap – Procurement, Audit, PM

Overlap in bidders and sub-awardees / subcontractors

Specialized accounting systems required for cost reimbursement, e.g. JAMIS Prime

Retroactive adjustment invoices may be required

Extensive audit exposure possible


1.6 COMPARISON OF AWARDS

Attribute Contract Grant/CoAg

Regulations applicable to award

(excluding cost principles)

FAR & Agency supplements

CAS possible

Uniform Guidance,

Agency Implementation

Cost principles applicable

NFE = Uniform Guidance and Agency supplement

Commercial entity = FAR 31.2 and Agency supplements

Contract types allowed Cost Plus,

Fixed Price,

Time & Materials

Cost Reimbursement

Fixed Amount Award (uncommon)

Profit allowed Yes, with limitations. No

Funding in advance? No Generally yes for qualified NFE

Indirect costs paid by Agency Yes Yes with NICRA, or 10% de minimis, or fixed indirect

rate. Possibly as “direct costs”. No for most non-US

NGOs.

Administrative, accounting and other

requirements

“Clauses” from FAR, FAR

supplement, and “non-standard”

clauses.

Award “provisions” unique to each Agency. May

incorporate UG.

Audit burden imposed Varies from low to very high.

Depends on contract type,

Agency, other factors.

CPA audit scope expanded at $750k/year total grant

funding.

Program audit possible.

Part 5: Cost Accounting & Indirect

Rates

Caution - this gets complicated!

COST ACCOUNTING & INDIRECT RATES

2.1 Uniform Guidance Cost Principles

Cost Principles by type organization

Appendix III – Education (IHE)

Appendix IV – Non-Profit Organizations

Appendix VII - State/Local Govt

Appendix IX - Hospitals, etc.

Appendix VIII – Organizations exempt from

Subpart E and Appendix IV


2.1.1 Non-Profit Cost Accounting – Appendix IV

1. Direct costs vs. indirect costs

2. Indirect costs = pooled and allocated to final cost

objectives

3. Unallowable costs identified and excluded from

claimed costs


2.2 Direct vs. Indirect Costs

UG approach roughly similar to FAR, but …

Some significant differences


2.2.1 UG Direct Costs (200.413)

“Directly assigned” to a final cost objective

May be prorated on an objective, documented basis

Criteria for “direct” affected by indirect cost allocation method (Appendix IV)

Joint costs may be direct (Appendix IV.A.4.(A) & (b))

Fringe costs on DL are “direct”, even if pooled and allocated

Direct must include: self-funded projects, member services, publications, lobbying/PR, conferences, investment fund management, etc. (200.413 (f))


2.2.2 UG Indirect Costs (200.414 and 200.413)

“Incurred for common or joint objectives, and cannot be

readily identified with a particular cost objective” (Appendix

IV.A.1.)

Any costs not directly assigned to final cost objective under

200.413 and Appendix IV.A.1

Items specifically listed as indirect:

• Administrative & Clerical Labor (200.413(c))

• General Administrative costs and General Expenses

(GA&GE), Appendix IV.B.3.B.(4)


2.2.3 UG Allocate Indirect Costs (Appendix IV)

Three “indirect cost allocation methods” prescribed for

non-profits (Appendix IV)

Allocation method drives indirect rate structure (pools

and bases)

• Step 1. Select the allocation method

• Step 2. Apply the method

• Step 3. Compute the rate(s)


2.2.4 UG Terminology & Concepts

Major function

Individual projects or activities

Unallowable costs that represent activities, E.G.. Fundraising

Broad cost groupings (i.e. Facilities, Admin)

Separate cost groupings (subset of a broad cost grouping)

Cost categories (level at which pooled costs are allocated)

Benefiting function

Segment (subset of major function, award, group of awards)


2.3.1 Simplified Allocation Method (Appendix IV.B.2)

Single major function, or multiple similar major functions

One indirect expense pool (includes facilities and administration)

Permitted allocation bases:

1. Total direct cost excluding sub-award over $25k, participant support, other distorting items (similar to but not same as MTDC)

2. Direct labor and fringes

3. Other equitable base

Compute single indirect % rate

If direct federal funding in year > $10M, must also compute as two % rates:

Facilities % Administration %


2.3.2.1 Multiple Allocation Base Method (Appendix IV.B.2)

More than one major function

Indirect costs benefit the major functions in varying degrees

Accumulate indirect cost into “cost groupings”

• Depreciation (subset of facilities)

• Interest (subset of facilities)

• Operations and maintenance (subset of facilities)

• GA&GE (administration, includes allocation from facilities cost groupings)


2.3.2.2 Multiple Allocation Base Method (Appendix

IV.B.2)

Allocate $ of each cost grouping to major functions using:

1. Direct assignment where possible

2. Allocation bases listed in appendix IV.B.3.C.

3. Other equitable allocation base, but …

GA&GE must be allocated to functions using MTDC


2.3.2.3 Multiple Allocation Base Method (Appendix

IV.B.2)

Accumulate $ allocated to each major function into single

pool for that major function

Compute single % rate for each major function using MTDC

and

Re-compute two broad category % rates for each major

function:

Facilities % Administration %


2.3.3 Direct allocation method (appendix IV.B.4)

All costs are direct except GA&GE

Joint costs (ie. facilities) are assigned as direct cost based on:

• Appropriate, reasonable allocation base, supported by

current data

• Some facilities costs assigned to GA&GE

GA&GE allocation follows simplified allocation method

Compute single % rate


2.3 Observations on UG Indirect Rates (Appendix IV)

No concept of “overhead”

No layered final indirect rates, i.e. G&A on overhead

GA&GE is not the same as G&A

Total cost input (TCI) is not acceptable base

No concept of “material & subcontract handling” or “value added cost input”

Does not use unique FAR treatment of B&P labor


2.4 Unallowable (UA) costs under UG

Allowability dependent on:

• Necessary and reasonable

• Conform to award provisions, POP, budget

• Conform to UG and agency cost principles

• Consistency treatment by NFE

• GAAP

• Not part of cost sharing or matching on other federal awards

• Adequately documented, auditable

May apply to direct and indirect costs, but differently


2.4.1 UG selected items of cost (200.420 – 200.475)

56 items covered

Some are expressly UA

Some conditionally allowable

May include cost accounting instructions

Different than FAR 31.205 selected costs!


2.4.2 UG treatment of Unallowable (UA) costs

UA activities are direct cost (200.413(e))

• Member services

• Lobbying, public relations, etc.

• Conferences

• Costs of maintaining special funds

• Group benefits of members, clients, etc.

UA direct costs stay in base for fringe, indirect (F&A) expense allocation

UA indirect costs excluded from pool


2.5 Contracts awarded to NFE under FAR 15

Cost accounting for FAR contract imposed through

“clauses”, so …

Which portions of FAR apply to NFE?


2.5.1 Contracts Awarded to NFE under FAR 15

Contract cost accounting clauses:

52.216-7 (cost reimbursement)

52.232-7 (T&M payments clauses)

Other clauses or certifications

• T&M proposal instructions

• TINA certification

• Incurred cost proposals certification

Contract clauses generally refer to FAR 31 contract cost principles and procedures


2.5.2 FAR 31 = cost principles (by type organization)

Far 31.2 Commercial Organizations

Far 31.3 Educational Institutions

Far 31.6 State and Local Governments

Far 31.7 Non-Profit Organizations, which …

(defers to 2 CFR 200 subpart E and Appendix IV)

See also FAR 31.109 Advance Agreements


Contract/Proposal is subject to FAR 31

(FAR payments clauses, other clauses, or

RFP instructions direct contractor to comply with FAR 31.)

FAR 31 directs contractor to applicable FAR 31 subsection for

cost accounting instructions and list of unallowable costs

Commercial contractor

FAR 31.2 accounting

methods and cost principles

Non-profit

FAR 31.7, linked to UG for cost accounting and cost principles

State, Local, Tribal Govt


Educational Institute



2.5.4 FAR 31.2 Cost Accounting compared to UG

Concepts are roughly similar, but not the same

Terminology is different

Specific instructions are different

Indirect rate structures are very different

Lists of UA costs are different


2.5.5 Typical Commercial Enterprise Indirect Cost

Structure under FAR:

• Fringe #1 - regular/fully benefited/US staff

• Fringe #2 - part time/limited benefits/non-us staff

• Overhead #1- contractor/US site

• Overhead #2 - client/government/separate division site

• Subcontract & material handling

• General and administrative (G&A)


3. The uniform guidance 10% de minimis

What is it?

Who is using it?

What issues are we seeing?


3.1 10% de minimis 200.414(f)

NFE may “elect” to use a fixed rate of 10%

NFE has never had a NICRA

May be used indefinitely

Must be 10%

10% applied to MTDC

Direct vs indirect cost rules still apply

Used consistently on all federal awards


3.2 Who is using 10% de minimis?

What kinds of firms are requesting?

Is it being granted? (GROUP DISCUSSION encouraged)

Examples:

• Prime awardees new to federal awards

• Small sub-awardees, if prime approves

Non-us NGO are being denied by some agencies


3.3 Cost recovery issues with the de minimis

10% for indirect costs too low, even with the “direct allocation

method”

NFE must still identify and classify indirect costs:

• GA&GE, at a minimum

• Facilities costs not “directly assigned” to awards or

activities

• Other joint costs not “directly assigned”

• New time reporting rules may send more labor costs to

GA&GE (indirect)


3.4 Audit Issues with the de minimis

Single audit requirement remains

Audit scope might include:

• Was NFE eligible to elect 10%?

• Is 10% applied to MTDC correctly?

• Direct vs. Indirect policy complies with UG?

• Direct vs. Indirect applied consistently?

Any over or under recovery is not auditable


3.4 de minimis and USAID

US NGO (prime or sub) may elect 10% de minimis or propose indirect rates

NICRA issued by USAID/W only to US prime awardees

Indirect costs not allowed for non-US NGO’s without NICRA, AND …

• Few non-US NGO’s are given NICRA by USAID Missions

• Only some non-us NGO primes have been allowed to use the 10%

• Prime may allow 10% for non-US NGO sub-awards


3.4 de minimis and HHS / CDC

Similar to USAID, but more harsh for non-US NGO’s

No indirect costs allowed for non-US NGO prime without

NICRA

No NICRA issued by CDC for non-US NGO

No 10% for non-US NGO prime awardee

10% for sub-awardees allowed?


3.5 de minimis case study

Take-home case study

• You are prime awardee, negotiating subaward

• Sub-awardee elects 10% de minimis, and ..

• Asks your help in refining their budget to match de

minimis rules

• For answers, contact Glenn or Mark, or attend our

follow-up online session

• Scheduled August 10, 2017 at 2pm ET

Acronym handout

Questions

&

Answers

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CONTACT INFORMATION

Glenn Anstead - Raffa, PC

[email protected] / 301-279-6503

Jean Gilbert, Raffa, PC


Brett Martin, Raffa, PC


Mark Hoffman, CPA CPCM


Jeremy Taro - Raffa, PC


mailto:[email protected]





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2017 07-26 Demystify the Government Contracting Challenges and Opportunities for Nonprofit Orgs

Government & Nonprofit

Transcript of 2017 07-26 Demystify the Government Contracting Challenges and Opportunities for Nonprofit Orgs