FFP Made Pursuant to Cooperative Agreements
January 28, 1977
TO:STATE AGENCIES ADMINISTERING CHILD SUPPORT ENFORCEMENT PLANS APPROVED UNDER TITLE IV-D OF THE SOCIAL SECURITY ACT AND OTHER INTERESTED INDIVIDUALS
SUBJECT:Documentation Required to Support Claims for Federal Financial Participation Made Pursuant to Cooperative Agreements
PURPOSE:To provide additional guidance on acceptable methods for documenting the cost of compensating individuals providing IV-D services pursuant to cooperative agreements where such costs are included in claims for Federal financial participation.
CONTENT:OCSE-AT-75-06, issued September 25, 1975, set forth guidelines for costing title IV-D services purchased from public agencies or obtained through cooperative agreements. This issuance stated that the procedure and practices found in 45 CFR Part 74, Appendix C would be used to identify the costs incurred under cooperative agreements that are eligible for Federal financial participation. Experience in administering the program under these requirements indicates a need to develop more definitive guidelines which specify the documentation needed to support claims for Federal participation in costs incurred as part of the IV-D program.
45 CFR 74, Appendix C, Part II, B.10.b. sets forth two major requirements that must be met when claiming FFP for costs of personnel.
1. Payrolls must be supported by time and attendance or equivalent records for all employees. This requirement is for the purpose of documenting total payroll costs, not, for the purposes of providing 100 percent identification of functions performed by individual employees. This requirement covers both direct and indirect costs.
2. When an individual performs activities chargeable to more than one grant program or cost objective, charges for personnel costs must be supported by appropriate time distribution records. The method used should produce an equitable distribution of time and effort.
The following methods are acceptable for documenting the costs for compensating individuals which are eligible for Federal financial participation under title IV-D.
1. If an individual performs only IV-D functions, and no other non-IV-D activities or functions, then 100 percent of the costs for compensating such individual is eligible for Federal financial participation, and no allocation of costs need be performed.
2. If an individual performs IV-D functions and additional functions which are in furtherance of a cost objective other than the IV-D program, then an acceptable allocation method must be employed to support an equitable distribution of costs based on time and effort. The following alternatives are considered acceptable methods for distributing and documenting costs attributable to the IV-D program.
a. Daily Time Records-- A daily record which indicates the total time and effort (specific cases handled, action taken, etc.) spent performing appropriate IV-D functions will be adequate. For the purposes of Federal financial participation under title IV-D, this record need not include time and effort spent in performing functions not related to the IV-D program.
b. Predetermined fixed rates for costs--A predetermined fixed rate for computing costs applicable to the IV-D program may be negotiated by the IV-D agency (and renegotiated no less often than annually) with court and law enforcement officials under cooperative agreements. This method may be used in those instances where the cost experience and other pertinent facts available are deemed sufficient to enable the contracting parties to reach an informed judgment (1) as to the probable level of costs related to the IV-D program during the period to be covered by the negotiated rate, and (2) that the amount allowable under the predetermined rate would not exceed actual costs.
c.Sampling-- Sampling techniques may be utilized in determining an equitable method for identifying and claiming costs. Such sampling techniques must be representative of the publication and produce equitable distribution of time and effort. The sampling technique must have prior approval of the State IV-D agency, and the State IV-D agency must maintain records of actual application and methods used in each application.
The following formula can be used to determine the number of person days in each quarter that must be randomly selected and sampled to produce an acceptable estimate of time allocable to IV-D.
75 x N
______ = n
75 + N
N = 65 (number of workdays per person in a quarter) x number of persons performing IV-D functions on a part-time basis.
n = sample size (number of days to be sampled)
Example 1. One person
75 x 65 4875 = 34.8 days = 35 randomly selected
= person days should be
75 + 65 140 sampled.
Example 2. Six people
N = 65 x 6 = 390
75 x 390 - 29,250 = 62.90 = 63 randomly selected ________ = ______ person days should be
75 + 390 465 sampled.
Example 3. Twelve people
N = 6 x 12 = 780
75 x 780 53,500 = 68.42 = 68 randomly selected person
= days should be sampled.
75 + 780 855
Example 4. Twenty-four people
N = 65 x 24 = 1,560
75 x 1,560 117,000 71.55 = 72 randomly selected person
= days should be sampled.
75 + 1,560 1,635
d.Other Methods with Advance Notice to Regional Office--A State may propose other methods for identifying IV-D costs or offer variations on any of the above provisions. However, under authority of Section 302.15(a)(2), the State shall report to the OCSE Regional Office intended procedures prior to the quarter in which such procedures will be used as a basis for claiming FFP in the costs of the IV-D program.
INQUIRIES TO : OCSE Regional Representatives
Office of Child Support Enforcement