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HomeMy WebLinkAboutReview of indirect cost plan 03-04 INDIRECT COST PLAN REVIEW 2003/2004 Presented to the Deschutes County Audit Committee by the Internal Audit Program David Givans, CPA – County Internal Auditor Report# 03/04 - 3 Dated February 17, 2004 Deschutes Count y, Oregon {THIS PAGE LEFT BLANK} Report# 03/04 - 3 (Dated February 17, 2004) To: Audit Co mmittee CC: Mike Daly, Tom DeWolf From: David Givans, Count y Internal Auditor Subject: Internal Audit Report on the INDIRECT COST PLAN REVIEW 2003/2004 (Report #03/04-3) Date: February 17, 2004 The enclosed audit reports provide informat ion concerning the review of the Indirect Cost Plan for 2003/2004. Informat ion contained in this reports is fro m interviews, observat ions and analyt ical work performed. Audit results have been discussed with the management personnel o f the various internal service funds as well as the County Administrator. Responses received fro m management have been included at the end of this report as well as comments by so me of the indirect subco mmittee. The assistance received fro m the indirect subco mmittee comprised Jeanine Faria – Finance, Tom Anderson- CDD, Greg Canfield – Mental Healt h, and James Ross – Sheriff in evaluating the observat ions and preparing this report was appreciated. The cooperation extended by management and staff o f the internal service programs was appreciated. Based on direct ion fro m the Audit Committee, a follow-up on the recommendat ions and management’s response will occur nine mo nths from the issuance of this report. Deschutes Count y, Oregon Internal Audit Program David Givans, CPA County Internal Auditor Deschutes County-Administration building 1130 NW Harriman Bend, OR 97701 Phone: 541-330-4674 Fax: 541-388-4752 davidg@co.deschutes.or.us Report# 03/04 - 3 (Dated February 17, 2004) {THIS PAGE LEFT BLANK} Report# 03/04 - 3 (Dated February 17, 2004) INDIRECT COST PLAN REVIEW 2003/2004 TABLE OF CONTENTS: EXECUTIVE SUMMARY 1. INTRODUCTION 1.1. BACKGROUND ……………………………………………………………………... 1 1.2. OBJECTIVES & SCOPE ………………………………........................................... 1-2 1.3. METHODOLOGY …………………………………………………………................ 2 2. INTERNAL SERVICE FUNDS - BACKGROUND 2.1. Overview …..……………………………………………………………………….. 3-4 2.2. a. - Informat ion Technology ………………………………………………………..… 5 2.3. b. - IT Reserve ………………………………………………………………………... 5 2.4. Building Services …….……………………………………………………………….. 6 2.5. Finance ………………………………………………………………………………... 6 2.6. Personnel …………………………………………………………………………….... 7 2.7. Legal ………………………………………………………………………………... 7-8 2.8. Administrative Services …………………………………………………………….… 8 3. INDIRECT COST PLAN REVIEW 3.1. General issues…….……………………………………………………………...… 8-12 3.2. Informat ion technology / IT reserve ……………………………………………... 12-14 3.3. Building services ………………………………………………………………….… 14 3.4. Finance …………………………………………………………………………... 14-16 3.5. Personnel …………………………………………………………………………..… 16 3.6. Legal ……………………………………………………………………………... 16-17 3.7. Implications to grant applicat ions ……………………………………………….. 18-19 4. ISSUES REQUIREING ADDITIONAL STUDY …………………………………… 19 5. RESPONSES AND COMMENTS 5.1. From internal service fund departments ....…………………………………......... 20-22 5.2. From Assessor ……...……………………………………………………………….. 22 5.3. From indirect subco mmittee participants ……………….……………………….. 22-24 APPENDICES Appendix I - Oregon county survey results A. Methodology ……………………………………………………………………….… 25 B. Observations - Allo cation methodology ….……………………………………..... 25-29 Appendix II – Oregon county survey data ………………………………………………….. 30-41 Report# 03/04 - 3 (Dated February 17, 2004) {THIS PAGE LEFT BLANK} Report# 03/04 - 3 (Dated February 17, 2004) i INDIRECT COST PLAN REVIEW 2003/2004 Report# 03/04-3 (Dated February 17, 2004) EXECUTIVE SUMMARY The Deschutes County’s Audit Co mmittee approved a review o f the methodologies for allocating County indirect charges. The purpose of the noted findings is to assist management and staff in assessing whether improvements can be made to the current allocat ion system. The report includes observations from surveying Oregon counties. Internal service funds reviewed include: · Informat ion Techno logy (IT) · IT Reserve · Building services · Finance · Personnel · Legal · Administrative Services The fo llowing highlights some of the findings presented to management for consideration in a summarized format. The findings and an excerpt of the associated recommendation include: INFORMATION TECHNOLOGY (IT) · The IT department does not have sufficient basis for adjustments to its allocations IT should remove these adjustments from its allocation computation. · Internal and external billing rates used by Information Technology are understated Information technology should recalculate its direct hourly charge rates. Total compensation should be divided by available charge hours (total hours available for work less anticipated overhead hours). In addition, the department should consider including in its billing rates the additional overhead incurred by the department including supervisory overhead, training, supplies and other departmental overhead. For outside service contracts, the department should consider using a fully costed hourly rate. FINANCE · Finance allocation base requires a review of each fund/department budget The County Finance Department should consider utilizing transactional allocation bases or use them as a tool to corroborate and adjust their current methodology and adjustments. Report# 03/04 - 3 (Dated February 17, 2004) ii · Finance does not allocate service fees to all funds/departments Finance should calculate costs to all funds and departments and allocate costs to those that can legally be charged. The general fund should probably incur the costs for those funds not charged. PERSONNEL · Some costs incurred by departments are expended by Personnel and allocated out as indirect costs The County should consider recording direct costs as expenditures to the operating department. These costs may be coordinated through the Personnel department. LEGAL · Legal costs allocated on out-dated time study Legal should update its time study to support its allocation to all funds/departments. Legal should consider allocating the overhead equitably among the users of their services based on time charges. · Legal has not been billing non-County entities for legal support Legal should track and bill all time spent with non-County entities. A fully costed billing rate should be used. The department should develop procedures for billing and collection so that this function can be performed in a timely manner. IMPLICATIONS TO GRANT APPLCIATIONS · Some grant applications do not include internal service fund costs Management should consider complying with the OMB Circular A-87 requirements for indirect cost plan certification. By doing so, the County may be able to recover reasonable indirect costs. GENERAL ISSUES · Board of County Commissioners exempt from all but one indirect cost Indirect costs should be allocated to the BOCC. Report# 03/04 - 3 (Dated February 17, 2004) iii · Indirect charges are not allocated to internal service funds Internal service departments should gather relevant statistics to calculate costs to other internal service funds. Internal service funds should consider these imputed costs when developing a fully costed hourly rate for third party contracts. Analysis indicates there is no significant benefit to allocating between internal service funds. · Allocation bases using budgeted amounts might not properly reflect activity Management should consider utilizing prior results of activity for allocation bases (i.e. from prior calendar year) if this will achieve better equity in assessing charges for the projected period. This might depend on the type of allocation base used. An even better approach is to use actual activity results and actual cost to subsequently adjust charges to funds/departments. · Efficiency and effectiveness of internal service fund services are not measured Activities of County internal service funds should be separated into clearly identifiable components. Internal service managers should clarify expectations and responsibilities with users. The County should consider implementing appropriate performance measures so quality and cost of services can be monitored. · Survey of Oregon counties identified some other indirect costs County management should consider allocating costs of the Board of County Commissioners and building usage to funds/departments. · User departments do not have input on internal service fund methods and allocations The County should consider forming a subcommittee of County Departments to review the indirect cost plan including internal service fund budgets and allocation methodology prior to allocation of charges to departments to gain a better understanding of internal service fund charges and underlying allocation methodology. · Some funds/departments do not receive allocations Internal service funds should calculate charges to all funds/departments. Finance should provide internal service fund managers with the anticipated fund/department descriptions to be used in the County budget. Report# 03/04 - 3 (Dated February 17, 2004) iv RESPONSE FROM MANAGEMENT Management generally concurred with the recommendat ions. Some management did not comment on the recommendat ions since it is st ill too early to determine how the County might respond and implement the recommendat ions. Report# 03/04 - 3 (Dated February 17, 2004) Page 1 1. INTRODUCTION 1.1 BACKGROUND Audit authorit y: The Deschutes County Audit Committee authorized the audit by its approval o f the County’s internal audit workplan for fiscal year 2003/2004. Purpose of the audit: The audit was prompted by continued concerns by County depart ments regarding the amount spent on internal services, the methodology for allocation, and the services received for those costs. This report also includes managements’ response to these recommendat ions. Definit ion o f internal service funds Internal service funds provide services to other departments within the same government, or to other governments, on a cost reimbursable basis. They operate like “businesses” within the government and must charge internal customers sufficient fees to recover the full cost of the service they provide. These services are billed using a specific rat ionale proportionate to the benefits received. Internal services are typically established in order to standardize and conso lidate the use of services in order to better account for and control the overall costs of government, Not only do internal services represent a significant usage of public resource, but they also impact direct services provided to cit izens. Usually internal services are accounted for in separate funds and emplo y business like accounting methods. Internal services often include activit ies such as finance, personnel, facilit ies and data processing. Brief history of Deschutes County’s internal service funds The use of internal service funds was started in Deschutes County in 1997. The first funds created were for informat ion techno logy (IT), building services and general support services (which included finance, legal and personnel). In 1998, the general support service fund was split into separate funds. The IT reserve (previously called the Citrix fund) was started in 2000. The latest of the internal service funds, administrative services, was started in 2003. The allocat ion methodology o f the various internal service funds has continued to evolve. The original documentation used for the 1997 service fund allo cat ions has not been updated to represent the current methodologies. 1.2 OBJECTIVES and SCOPE Audit objectives: The object ives of the audit were: 1) Review the internal service fund allocat ion methodologies to determine if they are fair and reasonable. a. Is the methodology sound and is it clearly documented and supported? b. How does the methodology co mpare to other counties in Oregon? 2) To evaluate compliance wit h Federal, State or Count y regulat ions and requirements. Report# 03/04 - 3 (Dated February 17, 2004) Page 2 Opportunities for increased efficiency and effect iveness were included in the recommendat ions when applicable. Scope: The audit was limit ed to reviewing the specified internal service funds for the most recently completed budget cycle (2003/2004). We limited our review to seven internal service funds –IT, IT reserve, building services, legal, personnel, finance and administrative services. Risk management and healt h insurance trust are beyond the scope of this review. 1.3 METHODOLOGY The review invo lved meet ing wit h internal service fund managers and obtaining and reviewing their charges and associated methodology. Relevant evidence was obtained through analysis, interviews and testing. This evaluat ion is, by nature, subject ive. Indirect cost plans should achieve the fo llowing object ives: 1. Propriet y of the methods used to allocate expenses, 2. Appropriateness of the bases used to allocate indirect costs (bases should link an internal service with the associated costs for providing the service), 3. Consistency in applying po licies and procedures, 4. Mathemat ical accuracy o f the computed amount of indirect costs allocated, 5. Reasonableness of indirect costs allocated, and 6. Compliance with applicable laws and regulat ions. Audit procedures included: · Reviewing budgets and account ing informat ion for the appropriateness of the allocated costs. · Reviewing the methodology and the allocation of costs. · Interviews with staff and management. · Surveying other Oregon counties to assess co mmo n practices in preparing indirect cost allocat ion plans and the allocat ion bases used. · Reviewing governmental and cost accounting publicat ions for best practices wit h indirect cost allocat ion plans. · Modeling analyses to ascertain fairness of direct allocat ion method over reciprocal allocat ion method. · Preparing a model o f an alternate method for allocation of the Finance depart ment. In addit ion, a subco mmittee was formed co mprising of three business managers from CDD, Mental Health, and Sheriff’s Office and the County Account ing Manager. The subco mmittee provided input and direct ion. The audit was conducted in accordance with Government Auditing Standards issued by the Comptroller General of the United States. A fo llo w-up review will be co mpleted in approximately nine mo nths. Report# 03/04 - 3 (Dated February 17, 2004) Page 3 2. INTERNAL SERVICE FUND BACKGROUND 2.1 Overview The fo llowing Deschutes County internal service funds were identified for review: · Informat ion Techno logy (IT) · IT Reserve · Building services · Finance · Personnel · Legal · Administrative Services Budget and staffing summary These internal service funds have a combined budget of $5.3 millio n for FY 2003/2004. Full time equivalent (FTE) emplo yees budgeted for these internal service funds is 56.81 for 03/04. Total internal service charges to departments have decreased 3.5% in the latest budget (03/04). The Finance depart ment indicates the decrease is related to reduced personnel costs and the removal o f utilit y costs from the internal service funds and directly charged. IT and building services represent the largest internal service fund charges to departments. Finance, personnel, legal and administrative services co mbined are less than the combined charges of IT and building services. Source: Deschutes County Budgets Analysis of inte rnal servic e fund c harge s - 200,000 400,000 600,000 800,000 1,000,000 1,200,000 1,400,000 1,600,000 1,800,000 2,000,000 IT / IT reserve Building services Finance Personnel Legal Administ rative services 02/03 03/04 Source: Deschutes County Budgets Composition of total internal service fund charges- 03/04 IT / IT reserve 33% Building services 26% Finance 15% Personnel 10% Legal 8% Administrative services 8% Report# 03/04 - 3 (Dated February 17, 2004) Page 4 The fo llowing ten funds receive 88% of the internal service fund charges. The County has 58 funds that are charged indirects. The types of internal service charges to each of these vary significant ly. The fo llowing chart indicates the charges incurred by these funds. Applicable laws and regulations Deschutes County has not created any laws regarding internal service funds. Oregon statute (ORS 294.470) provides that charges for services (fro m internal service funds) shall be co mputed to cover all costs for such services and the charges shall be periodically revised to eliminate any element of profit or loss. Federal regulat ions allow grant recipients to recover indirect costs from the federal grant funds received. This is also true for many state grants. In order for indirect cost plans to recover these costs they must fo llow certain standards. Most federal grants and so me state grants refer to standards under OMB Circular A-87 (issued by the Office of Management and Budget). Normally Deschutes County does not include indirect costs in its state and federal grant applicat ions choosing instead to absorb those costs as part of the match the County will bear to receive those grant monies. Source: Deschutes County Budget Top Te n Funds Re ce iving Inte rnal Se rvice Charge s (03/04) $- $200,000 $400,000 $600,000 $800,000 $1,000,000 $1,200,000 G e n e r a l F u n d D e s c h C o S h e r i f f 's O f f i c e C o m m u n i t y D e v e l o p m e n t M e n t a l H e a l t h R o a d C o m m u n i t y J u s t i c e -J u v H e a l t h D e p a r t m e n t A d u l t P a r o l e & P r o b a t i o n I n s u r a n c e S o l i d W a s t e 1 255 295 275 325 230 259 355 670 610 FUND# / De s cription I n t e r n a l s e r v i c e f u n d c h a r g e s Report# 03/04 - 3 (Dated February 17, 2004) Page 5 2.2 a. Information Technology The Informat ion Techno logy (IT) Department provides techno logical support services to most County depart ments. Services include: · Connectivit y to the Internet, County-wide e-mail, calendaring systems, and Microsoft Office available through a Citrix environment; · Network services and support - including securit y, backup and storage protocols and virus protection; and · Software and hardware integration for specific department applications. This includes programming for internally developed programs. IT develops charges based on three areas of service as fo llows: · Basic Internet access charged at a flat rate for each depart ment computer, · Actual t ime charges providing service to a department in the prior year, and · All other associated costs of the IT department not included in the above charges allocated by type and amount of computer hardware. 2.2 b. IT - Reserve The IT department also manages an IT reserve fund, which was init ially used to fund the purchase of the Citrix system. This reserve now funds other significant hardware and/or software purchases. Fund charges are based upon the number and type of computer hardware. Inte rnal Se rvice Charge s Budge t (in thousands ) - IT (* charges adj usted for inf lat ion, ** includes IT Reserv e) FY FTE Charges * 99/00 11.75 1,209$ 00/01 15.00 1,332$ 01/02 **15.87 1,956$ 02/03 **16.41 1,943$ 03/04 **16.41 1,772$ % change 40%47% Source: Deschutes County Budgets - by charges to specific funds * Utilizing CPI - 12 m onth index Source: IT Department internal service charge allocation C om posi ti on of IT C harge s Direct p ersonnel charges 38% Flat rate charge 11% Indirects 51% Report# 03/04 - 3 (Dated February 17, 2004) Page 6 2.3 Building Services The Building Services Department is responsible for repairs, custodial services, grounds keeping, HVAC, courier services, archiving, and telecommunicat ions. The methodology for allocating costs was changed significant ly for the 03/04 budget. Building services costs are divided into two pools - evening custodial and dayt ime maintenance. Administrative overhead is allocated to these pools based on budgeted personnel do llars of each pool. The costs of evening custodial pool are allo cated to departments based on square footage of buildings receiving custodial services mult iplied by the numbers of day’s service received. The costs of dayt ime maintenance are allocated on square footage of the buildings receiving dayt ime maintenance. Some departments, primarily Sheriff, who do not use dayt ime service, are not allocated a cost. 2.4 Finance The Finance Depart ment services to the County include: · Annual budget preparation · Financial planning · Accounts payable processing · Payro ll processing · Fixed asset data base management · Debt issuance coordinat ion · Transient room tax collect ion · Internal and external reporting Finance charges are allo cated based upon fund/department budgeted expenditures as modified. Modificat ions to budgeted expenditures include eliminat ion of unappropriated ending fund balance, transfers out, and other adjustments. Addit io nal adjust ments are made for debt service funds, which cannot legally be assessed charges, funds wit h significant pass-through funds, and reserve funds. Inte rnal Se rvice Charge s Budge t (in thousands ) - Building Se rvice s (* charges adjust ed for inflation) FY FTE Charges * 99/00 16.50 1,264$ 00/01 16.50 1,243$ 01/02 17.50 1,367$ 02/03 20.25 1,660$ 03/04 20.25 1,361$ % change 23%8% Source: Deschutes County Budgets - by charges to specific funds * Utilizing CPI - 12 m onth index Inte rnal Se rvice Charge s Budge t (in thous ands ) - Finance (* charges adj ust ed f or inflation) FY FTE Charges * 99/00 7.05 661$ 00/01 7.05 730$ 01/02 7.90 795$ 02/03 6.90 866$ 03/04 7.00 798$ % change -1%21% Source: Deschutes County Budgets - by charges to specific funds * Utilizing CPI - 12 m onth index Report# 03/04 - 3 (Dated February 17, 2004) Page 7 2.5 Personnel The Personnel Depart ment is responsible for administering the salaries and benefits for all County emplo yees. Services include: · Recruit ing, · Processing and orienting new hires, · Administering salary, co mpensation, leave programs, · Administering health, life and disabilit y insurance programs, · Administering PERS (Public Emplo yees Ret irement System), · Administering 457 deferred compensation programs, · Administering IRC Section 125 flexible spending programs, · Administering unemplo yment benefit program, · Negotiat ing, implement ing and maintaining four emplo yee unio n contracts · Maintaining Count y-wide emplo yee records and centralized personnel files, and · Providing training opportunit ies. Personnel charges are allocated based upon Departments’ budgeted number of Full Time Equivalent (FTE) emplo yees. 2.6 Legal Legal Counsel provides legal advice on municipal and civil matters to the Board of Count y Commissio ners (BOCC). They are also responsible for · Drafting and reviewing ordinances, reso lutions and orders of the BOCC, · Drafting and review of legal documents to which the Count y is a party, · Coordinat ion with bond counsel and outside financial consultants regarding issuance of bonds, · Advising property management on legal matters relat ing to the transfer of real property, · Overseeing any lit igation matters against the County or its emplo yees, · Maintaining the Count y Code book, and · Providing legal advice to the County Depart ments and Board of Count y Commissio ners. Legal charges are based on an est imate of services to be provided departments. Inte rnal Se rvice Charge s Budge t (in thous ands ) - Pe rs onne l (* charges adj ust ed f or inf lat ion) FY FTE Charges * 99/00 4 368$ 00/01 5 466$ 01/02 5 527$ 02/03 5 625$ 03/04 5 514$ % change 25%40% Source: Deschutes County Budgets - by charges to specific funds * Utilizing CPI - 12 m onth index Report# 03/04 - 3 (Dated February 17, 2004) Page 8 2.7 Administrative Services The Administrative Services Fund includes the Count y Administrator and staff that manage the fo llo wing funct ions: · Finance/tax · Budget · Internal audit program · Risk management · Building services · Personnel · Communicat ions and media services · Informat ion technology · Property management · Veterans services · Law library This internal service fund was established in 03/04. Administrative service charges are allocated based upon budgeted expenditures as modified (same modificat ions as for Finance). The department has 3.15 FTE budgeted. 3. INDIRECT COST PLAN REVIEW The indirect cost plan (the Plan) review for Deschutes County was supported by the Finance Department with the assistance of the other internal service fund departments. Internal service fund personnel were open and professio nal during interviews and provided a full disclosure of the business practices in place. The results of the review indicate most of the Plan methodologies are reasonable. Some issues should be reso lved for allocat ions to fairly reflect the relative benefits received by depart ments. The fo llowing are recommendat ions for improvement which, addit ionally, will allow recovery of indirect costs from Federal and State agencies. The review, by its nature, was focused on evaluating the methodologies currently used in the indirect cost plan. Inte rnal Se rvice Charge s Budge t (in thous ands ) - LEGAL (* charges adjusted f or inflation) FY FTE Charges * 99/00 5.00 472$ 00/01 5.00 462$ 01/02 5.00 495$ 02/03 5.00 494$ 03/04 5.00 435$ % change 0%-8% S o urce: Deschu tes Co u nty Bu d gets - by cha rg es to sp ecific fun d s * Utilizin g CPI - 1 2 m on th in d ex Report# 03/04 - 3 (Dated February 17, 2004) Page 9 3.1 General issues Indirect charges are not allocated to internal service funds Deschutes County internal service funds do not generally allocate costs to other internal service funds even though they receive services. The IT reserve fund is the only internal service fund allocat ing costs to other internal service funds. Many internal service funds provide (or receive) more services than they receive (or give) to other internal service funds. For example - Building services provides $62,000 more in services than it receives from other County internal service funds. Legal fails to track internal service departments’ usage of their services since they do not charge them. In addit ion to providing Count y Departments with services, internal service funds charge third party ent it ies for services. Excluding indirect costs may result s in less than full cost recovery by internal service funds. Best practices promulgated by the GFOA (Government Finance Officer’s Associat ion) indicate departments should co mpute their actual cost of providing services. Most of Oregon counties surveyed (60%) indicated they allocate indirect costs to internal service funds. An analysis was performed to see what, if any, difference in departmental charges occurs if internal service funds charge each other. Including these reciprocal charges between internal service funds did not yield substant ially different charges to departments, than the direct method. Internal service departments should gather relevant statistics to calculate costs to other internal service funds. Internal service funds should consider these imputed costs when developing a fully costed hourly rate for third party contracts. Analysis indicates there is no significant benefit to allocating between internal service funds. Board of County Commissioners exempt from all but one indirect cost Indirect costs, other than IT Reserve, are not allocated to the Board of Count y Commissio ners (BOCC). The indirect costs attributable to the BOCC are instead allocated to operating departments. Allocat ion of indirect costs to all funds/departments benefit ing from internal service fund efforts is considered to be a more fair allocat ion plan. Indirect charges of approximately $70,000 attributable to the BOCC have instead been allocated direct ly to operating depart ments. Indirect costs should be allocated to the BOCC. Allocation bases using budgeted amounts might not properly reflect activity The allocation bases used to allocate costs of County internal service funds are based on budget Report# 03/04 - 3 (Dated February 17, 2004) Page 10 amounts. Actual expenditures can differ significantly from budget. For allocat ion bases to be reasonable, they should: · Represent actual cost or effort expended · Be within management’s abilit y to control on a timely basis · Provide minimal distortion · Be consistent ly applied over time · Be consistent with variat ions in funding · Be not unduly co mplex - should be commensurate with materialit y o f charges · Be efficient as possible in terms of cost to develop Many o f Oregon counties surveyed had allo cat ion plans that utilized actual data fro m one or two years prior. One of the guides for cost allocat ion plans indicated that budgeted amounts might not be a reasonable base since it does not reflect actual act ivit y. Budgeted amounts differ fro m actual and departments do not benefit fro m efforts to reduce usage of internal services. Grant guidelines require the difference between actual cost and that projected to carryover and benefit the next period. When budgeted amounts used for allocat ion bases differs significant ly fro m actual, departments actual indirect costs will vary fro m budgeted indirect costs. In some cases, these differences might be immaterial and budgetary informat ion a fair representation for these allocat ions. Management should consider utilizing prior results of activity for allocation bases (i.e. from prior calendar year) if this will achieve better equity in assessing charges for the projected period. This might depend on the type of allocation base used. An even better approach is to use actual activity results and actual cost to subsequently adjust charges to funds/departments. Efficiency and effectiveness of internal service fund services are not measured Effect iveness or efficiency in providing services is not measured by the internal service funds. Some operating departments perceive themselves as captive customers who have litt le impact on decisio ns made by internal service funds. Departments may be able to ident ify services outside the County but are unable to effect ively co mpare by cost and amount of service. County internal service funds often focus on effect ive customer service rather than efficiency, often providing a level of service far in excess of comparable services from an outside source. Internal service depart ments should work with their customers to define and articulate their services. Users are not always sure of the services they are paying for and service providers do not always provide clear criteria as to what service are being provided. Typical outsourcing questions can be reso lved only if costs of services are identifiable and comparable to those provided outside the organizat ion. Services need to be defined so that effect ive measurement and management can occur. GFOA encourages all local governments to utilize performance measures as an integral part of the Report# 03/04 - 3 (Dated February 17, 2004) Page 11 budget process. Somet imes business decisio ns made for the County as a who le may not satisfy individual departments. To achieve a balance between the departments’ needs and those of the County internal service fund managers must promote good business practices. Activities of County internal service funds should be separated into clearly identifiable components. Internal service managers should clarify expectations and responsibilities with users. The County should consider implementing appropriate performance measures so quality and cost of services can be monitored. Quality can also be measured by comparison to industry standards and surveying department’s satisfaction with the quality of services. When costs and performance are consistently calculated, decision makers and citizens can determine the true cost of providing County services and achieving outcomes. Survey of Oregon counties identified some other indirect costs The Survey o f other Oregon counties indicated some addit ional indirect costs charges allocated to departments. Board of County Co mmissio ners - Most Oregon counties surveyed (73%) allocated out the costs of the BOCC. Some count ies do not allo cate out all of the costs of the office. The allocation base was most often on budgeted expenditures, FTE, board agenda items, or a combinat ion thereof. Building usage – Three of the five larger counties surveyed allocated out this cost. This charge is generally described as building depreciatio n or usage allowance. Allocat ion bases for building usage are generally on square footage and the associated charge based on depreciat ion or use charge. Depreciat ion of buildings is usually over a 50-year life and this is a reasonable method for purposes of federal grants under OMB Circular A-87. Amounts in excess of this depreciable rate are not recoverable fro m federal grants or those grants using similar rules. Best practices promulgated by the GFOA (Government Finance Officer’s Associat ion) indicate costs should include those costs that might be fully unfunded in the current period including depreciat ion or use allowance. Of the five larger Oregon Counties surveyed (60%) indicated they charged to departments some form of use or rent charge. Departments who charge fees to third parties and or obtain grants may be able to recover these indirect costs. County management should consider allocating costs of the BOCC and building usage to funds/departments. Report# 03/04 - 3 (Dated February 17, 2004) Page 12 User departments do not have input on internal service fund methods and allocations Departments receiving indirect allocat ions do not have a formal mechanism to provide input on the internal service fund budgets and methodology. Operating depart ments believe they have little input on indirect costs and often are unaware of the services they are receiving. The County should consider forming a subcommittee of County Departments to review the indirect cost plan including internal service fund budgets and allocation methodology prior to allocation of charges to departments to gain a better understanding of internal service fund charges and the underlying allocation methodology. Some funds/departments do not receive allocations Each of the internal service funds allocates to a different set of funds and departments partly because of the nature of their allocat ion bases. Some internal service funds allo cate to global areas (i.e. County Fair) and end up charging one fund (i.e. Fund 618-Fair and Expo Center) and don’t charge fund 619 (County Fair). This primarily occurs with allocat ions fro m IT and Legal. All funds and departments should be considered for allocat ion. Having all internal service funds calculate costs by specific fund and depart ment will provide for better allocat ion during budget preparation. The most complete set of departments/funds is used by Finance in its allocat ions. Wit hout a commo n set of funds and depart ments to calculate by, the allocat ion bases might not allocate to some funds/depart ments. Internal service funds should calculate charges to all funds/departments. Finance should provide internal service fund managers with the anticipated fund/department descriptions to be used in the County budget. 3.2 Information Technology (Internal service fund - 660) The IT department does not have sufficient basis for adjustments to its allocations The IT cost allocat ion model includes an adjust ment, that modifies the equipment units on which the indirect portion of IT charges are allocated. The adjust ment has had a significant impact on department charges. Five departments have received a material reduct ion in charges due to the adjust ment and include: · Sheriff’s office (including Jail), · Road, · Mental healt h, · Health, and · 911. Report# 03/04 - 3 (Dated February 17, 2004) Page 13 The allocation of IT charges is based on time and computer hardware and appears to be acceptable. Judgmental adjust ments should be quant ifiable and supportable. Analysis of the IT allocat ions indicates that after removing the adjustment, nearly $171,000 in allocat ions are shifted. Benefit (cost) to departments from indirect adjustment Sheriff Public Works Mental Health Health Jail 911 Law Library Property Management GIS Parole and Probation Veterans Children & Families Solid Waste Risk Juvenile Surveyor TAX County Fair Clerk Assessor DA CDD Justice Court (50,000)(40,000)(30,000)(20,000)(10,000)-10,000 20,000 30,000 40,000 50,000 Based on discussions with IT, the adjust ments were included to allow for departments who had experienced staff handling their IT matters or for departments who had IT staff do miciled in their departments. The extent of the adjust ments can not be object ively supported. IT recognized the impact of the adjust ment and over the last four years has been phasing out the adjust ments for some departments. IT believes these adjustments may distort the amount allocated to departments. IT should remove these adjustments from its allocation computation. Internal and external billing rates used by Information Technology are understated Calculated emplo yee charge rates include only emplo yee co mpensation and benefits. The average charge rate for IT staff t ime is $48 per hour. Salaries and benefit s are a significant portion of providing personnel services but the non- personnel service costs should not be ignored. The charge rate should recover all costs of the emplo yee (direct and indirect). Indirect costs include supervisio n, training, and other overhead. The calculat ion of charge rates should have a divisor representing the ant icipated chargeable hours to be worked by the emplo yee. An analysis was performed to re-calculate emplo yee charge rates. The re-calculation included supervisory overhead for the IT Director and $112,000 of budgeted overhead costs. The analysis took into account the chargeable hours available by staff member. The estimated average charge Report# 03/04 - 3 (Dated February 17, 2004) Page 14 rate increased to $59 per hour. The average increase was 23%. This shifted charges from indirect to direct time charges by $134,000. Information technology should recalculate its direct hourly charge rates. Total compensation should be divided by available charge hours (total hours available for work less anticipated overhead hours). In addition, the department should consider including in its billing rates the additional overhead incurred by the department including supervisory overhead, training, supplies and other departmental overhead. For outside service contracts, the department should consider using a fully costed hourly rate. Costing a service is not the same thing as pricing it. The pricing decision needs to weigh issues of equity and efficiency. (Costing Government Services: A guide for Decision Making). 3.3 Building services (Internal service fund - 620) {No specific recommendations} 3.4 Finance and Administrative Services (Internal service fund-630/625) Finance allocation base requires a review of each fund/department budget Finance’s allocat ion base is modified budgeted expenditures. The extent of modificat ion requires Finance to understand what the fund/department is do ing. Finance staff must review for changes in the way a fund/department operates and consider an adjustment and the extent of that adjustment. The Finance Depart ment allocat ions are based on budgeted expenditures modified for · transfers out, · unappropriated ending fund balance, · expenditures fro m debt service funds, · inter-county transact ions, and · other items. The “other item” adjustments are often judgmental and are applied to operational funds, reserve funds, construction funds, and internal service funds. These “other” adjustments amount to 33% of the init ial budgeted expenditures. Some of these adjust ments are to compensate for pass-through expenditures. Pass-through expenditures are expenditures not made by the Count y but contracted for. Source: Finance internal service charge allocations Modifications to expenditures - Finance allocation T ransfers out , ($19,977,070) 17% Ending fund balances, ($18,246,386) 16% Debt service, ($8,788,557) 8% Ot her it ems, ($67,899,243) 59% Report# 03/04 - 3 (Dated February 17, 2004) Page 15 Costing Government Services: A guide for Decision Making (GFOA) indicates an appropriate base for allocat ing an account ing funct ion is normally on transactions processed. For many of the Oregon counties surveyed, allocat ions were based on number of transactions. The most commo nly observed allocation bases included number of accounts payable transact ions, number of revenue items, and number of payro ll checks. Finance charges were re-figured to use more transactional type allocat ion bases. The draft model considered there to be four equal areas to Finance ident ified by direct staffing and were · accounts payable processing; · payro ll processing; · revenue co llect ion entry; · and budget and financial reporting. The respect ive account ing bases used were · number of accounts payable line items, · number of FTE, · number of revenue lines, and · modified expenditures (only adjusted for debt service, transfers and ending fund balance). The draft analysis used readily available transactional measures. The draft analysis indicated one particular department had been overcharged. Finance agreed this was a reasonable observat ion and could be adjusted for manually as an “other adjust ment” in their current methodology. This was a model calculat ion for purposes of discussio n. Addit ional discussio n on the bases, the weight ing of the bases, co llect ion of informat ion, and cost pools could yield improvements to this draft model. The County Finance Department should consider utilizing transactional allocation bases or use them as a tool to corroborate and adjust their current methodology and adjustments. Finance does not allocate service fees to all funds/departments A limited number of funds are exempt fro m Finance charges because it was believed this was in accordance with Oregon Revised Statute (ORS). However, no specific ORS exemption exists for the fo llowing funds · Business loans (Fund 105) · Communit y development block grant (Fund 110) · Grant projects (Fund 120) · Special transportation (Fund 150) · Taylor grazing (Fund 155) All departments and funds should be calculated charges based on their usage of services. Allocat ion of costs should be charged to those funds that can be legally assessed. Excluding the above noted funds fro m finance charges resulted in $30,000 of costs allocated to other funds/departments during fiscal year 2003/2004. Finance should calculate costs to all funds and departments and allocate costs to those that can legally be charged. The general fund should probably incur the costs for those funds not Report# 03/04 - 3 (Dated February 17, 2004) Page 16 charged. 3.5 Personnel (Internal service fund - 650) Some costs incurred by departments are expended by Personnel and allocated out as indirect costs During review of Personnel expenditures, it was determined that some of the expenditures are direct ly traceable to another fund/department. Expenditures ident ifiable by depart ment and therefore could be charged direct ly to those departments include: · Advert ising – Expended for all departments advertising open posit ions. · Recruit ment - Significant expenses to recruit director level and management positions. · Moving and relocation expenses for department personnel · Pre-emplo yment exams - Many relate to specific departments. The Sheriff in particular had Personnel incur above average costs testing performed for init ial applicants and emplo yee transfer. · Tuit ion reimbursement – Not many departments having Personnel fund these costs. Most Departments direct ly fund these costs. · Management consult ing - Included so me direct analysis o f job descript ion research for a specific depart ment and surveys for specific departments. · Legal - Legal costs for grievances for specific department. Some general unio n legal support that is appropriate. · Legal invest igat ions - Specific allegat ions in specific departments. Indirect costs should be limit ed to costs that can not be efficiently traced to a specific department. County management has indicated that many of these expenses are coordinated through the personnel depart ment as a way of making sure this funding is available countywide. The County should consider recording direct costs as expenditures to the operating department. These costs may be coordinated through the Personnel department. 3.6 Legal (Internal service fund - 640) Legal costs allocated on out-dated time study Legal’s allo cat ion is judgmentally based on 2000/2001 time study. The time study showed approximate percentages of time spent on work for the various direct service departments. Newer County funds subsequent ly established have not been allocated legal cost. Legal does not track time expended on general government or internal service fund matters. Legal has addit io nal overhead fro m non-work time (vacat ion, holidays, etc.). CDD, Road and Risk management funds seem to have absorbed the largest share of the overhead cost. Report# 03/04 - 3 (Dated February 17, 2004) Page 17 Charges based on est imated time should be supported by time record or estimates. Overhead time should be equitably spread among user departments. Allocat ion methodologies should be reasonable and calculate costs based on benefit s provided. Legal should update its time study to support its allocation to all funds/departments. Legal should consider allocating the overhead equitably among the users of their services based on time charges. Legal has not been billing non-County entities for legal support Legal has not been charging certain outside service districts (such as 911 county service district) for legal services provided. All direct services provided to outside agencies should be recovered through timely billing and collect ion. Failure to do so places an increased burden on County funds. A fully costed billing rate should be developed that considers chargeable hours and include appropriate overhead, supervisio n, and support staff costs as well as waived internal service fund charges. Legal does not have to do this frequent ly enough to have a standard procedure to track and perform this process. Legal should track and bill all time spent with non-County entities. A fully costed billing rate should be used. The department should develop procedures for billing and collection so this function can be performed in a timely manner. Legal incurs costs directly traceable to operating departments Some expenditures from Legal are directly traceable to a specific department. Such costs included outside attorney fees required due to an internal conflict of interest or due to a need for specialized legal expertise. Outside legal fees for the fiscal year 2002/2003included: · Grievance work specific to a specific depart ment. · Advice on personnel issues that could be charged to the Personnel Depart ment. · Lawsuit work that should be paid by Risk Management Indirect costs should be limit ed to costs that can not efficient ly be charged to the benefit ing department. Direct expenses of depart ments should be charged to those departments, not to the internal service fund. Outside legal fees in 2002/2003 were $10k. Most outside legal services are coordinated through legal counsel. Outside legal fees should be paid by the benefiting department. Report# 03/04 - 3 (Dated February 17, 2004) Page 18 3.7 Implications to grant applications Some grant applications do not include internal service fund costs The County currently prepares so me federal grant applicat ions, which do not include internal service fund charges in ant icipated costs. Most federal and state grants allow certain indirect costs. Federal grants generally require indirect costs be part of a certified indirect cost plan as provided for under Circular A-87 prepared by the Office of Management and Budget (OMB). The current County indirect cost plan does not meet the requirements of OMB Circular A-87. The County’s current plan for 03/04 is not documented, does not identify and remove potential unallowable costs, and is not certified by the Chief Financial Officer or higher position. Major requirements of OMB Circular A-87 include: · Documentation of allocat ion methodology · Removal o f unallowable costs · Certificat ion of the Plan by Count y Financial Officer · Carryforward of differences between actual costs and those charged Local governments of Deschutes County’s size are not generally required to submit their indirect cost plan unless requested by the cognizant agency for the federal government. County management overseeing these grant programs require a clear understanding o f the underlying cost of providing these programs. Count y grant applicat ions strive to recover as many costs as possible fro m these outside funding sources. However, as noted above, Deschutes Count does not currently meet the requirements ne4cessary to include indirect costs in its applicat ions. A majorit y of the Oregon counties surveyed prepared their indirect cost plans for compliance wit h OMB Circular A-87 and were, therefore, eligible to include indirect costs as a line item wit hin their federal grant applicat ions. Recent grant awards totaling $579,000 to the Juvenile Co mmunit y Just ice, District Attorney, Commissio n on Children and Families, and Sheriff’s Office did not include a share of indirects. Assuming a conservative indirect percentage of 3.4% (the percentage of indirect charges to County expenditures), the County may have recovered up to $20,000. Excluding indirect costs in the grant program budget can result in one of the fo llowing situat ions: 1. A department develops and submits a budget for a proposed project or program that accurately reflects the cost of each line item wit h the except ion of indirect costs. If a grant is then awarded, the department must absorb the associated indirect costs allocated within its exist ing budget, possibly creat ing shortages in other areas. 2. A department attempts to include generally accepted indirect costs, such as utilit ies or administration, in the proposed budget by categorizing them as direct charges. If the grantor agency determines that these charges are not valid the applicat ion could be disqualified, the rating affected, or the budget reduced accordingly. If a federal indirect cost rate is approved, a significant number of ongoing grants and programs might be able to recover addit ional indirects as they are renewed in future periods. Additionally, Report# 03/04 - 3 (Dated February 17, 2004) Page 19 new grants could include indirect costs as appropriate to ensure that the true program cost is accurately reflected. Management should consider complying with the OMB Circular A-87 requirements for indirect cost plan certification. By doing so, the County may be able to recover reasonable indirect costs. In addition, the County will have better management information as to the underlying costs for its programs and be better able to make decisions about those programs. 4. ISSUES REQUIRING ADDITIONAL STUDY The fo llowing item was outside the scope of this review but was encountered on review of rental charges. Rent and internal service fund charges might be double counted in grant application The application for the State of Oregon Assessment and Taxat ion grant included both rent and internal service fund charges as expenditures for the grant. The grant limits “indirect costs” to 5% of direct expenditures. The rent expense incurred by the associated departments are internal charges and do not reflect direct rent payments. The Count y receives a share of monies based on the proportion of the County’s applicat ion to other counties in Oregon. The instructions and discussio n with the Oregon Department of Revenue indicate that for rent to be includable as a direct expenditure it needs to be paid to an outside party. In addit ion, there is some confusio n over what “indirect costs” are and which ones should be included in direct expenditures. The instructions indicate that you are not to include indirect costs. These “indirect costs” are allowed for in a 5% addit ion at the end of the applicat ion. The applicat ion allows a higher indirect cost rate if supported by an indirect cost plan prepared in accordance with OMB Circular A-87. The County receives approximately 29% of the expenditures shown in the grant applicat ion. Expenditures could be overstated by as much as a couple hundred thousand dollars. Discussions with the Assessor indicated there has been significant confusio n in the State over the instructions for the grant and consistency wit h Oregon counties in preparing the applicat ion. Ongo ing efforts by the Assessor are being made to clarify these issues with the Department of Revenue but there are some grey areas that have not been resolved. The County should research this area since it appears the A&T grant application as submitted might be overstating expenses. Report# 03/04 - 3 (Dated February 17, 2004) Page 20 5. REPONSES AND COMMENTS 5.1 From Internal service fund departments Internal service fund management provided the fo llowing comments. The finance department declined to comment at this time. Information Technology Comments 3.1 General Issues Page 9 Building Services is referenced as a department that provides $62,000 more services than it receives fro m internal service departments. Might want to mention that I.T. provides in excess o f $60,000 as well. {Internal Audit Comment- IT does provide more net services than they receive. The analysis indicated some $35,000} pages 10 thru 11 Efficiency and effectiveness,– I agree with this would be nice to do, however, it will be very t ime consuming. Especially for work activit ies that do not have nationally available statist ics. Page 12 User departments and their input into the process,– I.T. provides monthly reports to department management indicat ion what work was done, who did the work, when the work was performed, and how long it took. In addit io n, I.T. started an I.T. advisory committee in September of 2003. These t ypes of issues have been or will be discussed at these meet ings. Page 12 Some funds/departments do not receive allocations,– I.T. allocates charges to the funds and departments it is aware of. If there are further divisio ns, we need to know. In addit ion, I.T. personnel who provide these services need to be aware of these divisio ns and have an easy way o f dist inguishing them. For example, if they are doing work for the County Fair, they will have difficult y ident ifying fund 618 or 619. 3.2 Information Technology - fund 660 (pages 12 thru 14) · Add Juvenile to list of departments · I agree the reductions should be eliminated. I.T. will do this as instructed. · I am not in agreement with so me of the changes recommended to determine hourly rates. o Allocat ing a portion of my costs to the others’ hourly rate. o Allocat ing so me of the M&S to everyone’s hourly rate. · I do agree with your suggest ion to change how the off-t ime portion of the hourly rate is computed (i.e. subtract the hours instead of adding). Report# 03/04 - 3 (Dated February 17, 2004) Page 21 Thanks for all your work, Dave Peterson Informat ion Techno logy Director Personnel Comments 3.5 Personnel I concur with your report. The only concern I have, and you and I discussed this, is that it would be hard for departments to budget for the "unknown". It is impossible to predict top management recruit ments, lawsuits, grievances, discriminat ion/harassment complaints, posit ion/salary reviews, etc. I do agree that the Sheriff's department should be paying for their own pre-emplo yment physicals and psycho logical exams. Starting this fiscal year, they are paying for the psycho logical exams but we are still paying for the physicals. No other department requires those types o f pre- emplo yment exams. Personnel should continue to pay for County-wide pre-emplo yment drug screening only. Certain departments have many more recruitments than other smaller departments. If we choose to charge those individual departments, it may impact their decision o f how often and where we advert ise. Last year was the first year $25,000 was budgeted for Tuit ion reimbursement. It is not commo n knowledge to the departments that those funds are available, and so far this year we have not spent anything in this line-item. It was the BOCC's decisio n to include this in the Personnel budget. It is my understanding this money was to be used for the occasional "Leadership" series for directors/managers and to assist those departments that have limited funds available for training. Thank you for the opportunit y to review your report. Debbie Legg, Personnel Services Manager Legal Comments 3.6 Legal Legal costs allocated on out-dated time study Concur – Legal Department should update the time study by keeping daily t ime records for attorneys. Allocat ion to departments on time charges might include so me adjust ments for other factors such as ant icipated use. Overhead will be allocated equitably. Legal has not been billing non-Count y ent it ies for legal support Report# 03/04 - 3 (Dated February 17, 2004) Page 22 Concur – Fees for services should be billed to non-County ent ities such as Count y service districts. Legal incurs costs direct ly traceable to operating departments Concur – Outside legal fees and other outside fees and costs should be paid by the benefit ing department even if County legal counsel coordinates the outside services. Mark Amberg County Counsel 5.2 From Assessor 4. Issues requiring additional study Grant application expenditures might be overstated Due to the inconsistencies in how counties are filing, unclear direct ion fro m the Oregon Department of Revenue (DOR), and lack of audit ing and oversight by the Depart ment of Revenue I am not sure a problem/issue exists in how Deschutes County is applying for this Grant. I would agree that the County should research this area and continue to ask the Department of Revenue for clear guidance that they administer state wide so any inconsistencies are addressed in ALL counties. As I went over with you, I have asked the DOR to clarify these types of quest ions in their Grant instructions both verbally in Assessor/DOR committee meet ings as well as through various written correspondence that I also shared with you. The DOR has indicated that based on this type of feedback they received that they have added language to the Grant application instructions for this upco ming year. These new applicat ions and instructions should be arriving shortly. It is my hope that they answer a number of these questions and when I receive them, I will be happy to forward you a copy and meet with you to discuss. Scot W. Langton Deschutes County Assessor 5.3 From indirect subcommittee members Board of County Commissioners and Internal Audit Committee Tom Anderson, Operations Manager – Community Development Department Comments-Indirect Cost Plan Review 2003/2004 Report# 03/04 - 3 (Dated February 17, 2004) Page 23 In general, Communit y Development supports both the undertaking of this report as well as its findings. As you know, CDD is a fee supported operation with an invo lved customer base, particularly the Central Oregon Builders Associat ion (COBA) and the Central Oregon Associat ion of Realtors (COAR). Since we must incorporate indirect charges into our fees, and since we work with our customers each year in the development of our budget from a cost and service level perspect ive, indirect charges are a key item of discussio n. In the past, it has been difficult for us to accurately co mmunicate the methodology behind the calculat ion of these costs. This report will be an excellent tool in acco mplishing that task. Further, with the implementation of the recommendat ions contained in the report, those costs will be considerably more fair and logical in just ifying the level o f cost to our customers. The fo llowing comments pertain to specific sections o f the report: Methodology We strongly support adherence to the object ives listed in the report as to what an Indirect Cost Plan is meant to achieve, particularly wit h regard to appropriateness, reasonableness and accuracy. We believe ourselves to be clients of internal service providing departments, and would expect similar object ives if the service was being provided by outside vendors. In addit ion, our expectation would be that we can influence the costs assigned to us by changes in our service demand. For example, if we reduced the number of computers in our department, called for building maintenance less frequent ly, or requested less service of the Legal Department, then our costs would be reduced, if not in the current year then at least in the fo llo wing year. We believe many of the specific recommendations on allocat ion methodology will further that goal. General Issues – Allocation bases using budgeted amounts might not properly reflect activity Related to the comments in the Methodology sect ion above, we believe that in order for cost allocat ions to be as accurate as possible and also truly reflect ive of services requested and delivered, that service output levels should be tracked and used as a means to allocate costs. Changes are recommended wit hin the report which moves the County in that direction. Our hope would be in future years that this objective could be furthered, including practices such as the Legal Depart ment charging hours much as a private legal firm would, Building Services charging time and materials for work orders, and the Finance Department implement ing an automated formula which uses system generated data such as vouchers, deposits, and payro ll to allocate charges based on client department usage. General Issues – Efficiency and effectiveness of internal service fund services are not measured We strongly concur in this finding, and would recommend taking it a step further. We believe it reasonable and appropriate that service providing departments should make a stronger effort in customer/client outreach and co mmunicat ion. This might take the form of periodic (quarterly/annual) meetings with service receiving departments to discuss qualit y o f service provisio n, assurance that services are addressing the specific needs o f client departments, and planning for future general needs and/or specific projects or events. Communit y Development has appreciated the opportunit y to serve on the review co mmittee for this study. We believe the work was extremely thorough and allowed for substant ial input from Report# 03/04 - 3 (Dated February 17, 2004) Page 24 both service providing and service receiving departments. We believe in the recommendations contained in the report and respectfully urge their full implementation. We will gladly provide further testimo ny should it be requested. -------------------------------------------------------------------------------------------------------------------------------------------- James F. Ross Deschutes County Sheriff's Office Business Manager Here are my comments regarding the Indirect Cost Plan Review. These comments represent my opinion only and not the views of the Sheriff or Undersheriff. 1. Indirect costs allo cat ions should be treated as contracts between the providing organizat ion and the receiving organizat ion. The process needs to be formalized. The organizat ions providing the indirect services need to provide documentation on what services will be provided and how they developed the $ amounts. The receiving organizat ions should have the opportunit y to decide what level of services they want fro m the indirect organizat ions. 2. Indirect should not be based on authorized FTE or budget $ amounts. I would reco mmend adjustments be made during the fiscal year for differences between actual FTE and authorized FTE's and $ actual and $ budgeted. 3. The Sheriff's Office would be opposed to eliminating the IT adjust ments. We have our own IT person (Larry Vierra) while other County Departments do not. 4. I'm opposed to allocat ing building/equipment depreciat ion costs. This would raise the operating expenses of the Sheriff's Office. We may want to consider "memo" accounts, which provide depreciat ion informat ion only. 5. We should "benchmark" the cost of Deschutes County indirect organizat ions wit h other Counties or private companies providing similar services. If Deschutes County indirect organizat ions are not cost compet it ive, the using organizat ions should be allowed to pursue outside vendors for these services. Report# 03/04 - 3 (Dated February 17, 2004) Page 25 APPENDIX I – OREGON COUNTY SURVEY RESULTS A. METHODOLOGY The Deschutes County Internal Audit Program surveyed Oregon Counties to assess differences and similarit ies in their indirect cost allocat ion plans. The survey focused on the internal service costs allocated by Deschutes County. In addit ion, compliance wit h OMB Circular A-87 in the development of indirect cost plans was noted. This Circular outlines requirements needed to allocate costs to federal grant programs. Most of the informat ion received fro m other Oregon Counties was for their 2003/2004 budgets, but some were for 2002/2003 budgets. Informat ion was requested of all Counties with a populat ion between 40,000 and 450,000. Two of the smaller counties did not respond to requests. The survey included five count ies larger than Deschutes and nine counties smaller than Deschutes. Oregon counties include: · Washington County · Clackamas Count y · Lane Count y · Marion Count y · Jackson Count y · Deschutes County · Linn Count y · Douglas County · Yamhill Count y · Benton County · Josephine Count y · Umat illa Count y · Klamath Count y · Coos County (no response) · Polk County (no response) · Lincoln Count y · Columbia Count y Informat ion provided by each of the Counties varied significant ly. A copy of the full cost allocat ion plan and schedules was requested. Only a few count ies provided such detailed informat ion. Some count ies provided only narrative informat ion on their plans. Some counties provided copies o f their underlying spreadsheets. Some fo llow-up was performed to clarify the data received. The informat ion gathered included: · Indirect cost pools and allo cat ion base(s) · Type of allo cation methodology (direct, step or reciprocal), · Use of proprietary so ftware to perform allo cat ion or use of Excel, · Whether the Plan co mplies with OMB Circular A-87 Several assumpt ions were required to assemble the informat ion in a format suitable for comparison. Not all count ies include the same services in each cost pool. Some counties utilized more than one allo cation base for a given service. Each of the allo cation bases was given equal weight in the survey results. B. OBSERVATIONS The survey o f Oregon Counties (the Survey) included input from 15 Oregon counties (includes Deschutes County). Data for each county was not always available for comparison to Deschutes County, therefore not all charts include all 15 counties. Charts are based upon detailed matrixes of the observat ions located under Appendix II. Report# 03/04 - 3 (Dated February 17, 2004) Page 26 INFORMATION TECHNOLOGY A majorit y of the Oregon counties surveyed use one or a number of allocation bases usually focused around direct charges and number of personal computers (PC’s). Four of the five larger counties surveyed used direct charges and/or PC’s to distribute IT charges. Deschutes County’s allocation bases are consistent with other Oregon counties in the survey. BUILDING SERVICES A majorit y of the Oregon counties surveyed use an allocat ion base of square footage. Deschutes County’s methodology is consistent with other Oregon counties surveyed in using square feet to charge out services. Deschutes County goes one-step further than most to weight service for nighttime custodial by number of days service is provided, since not all departments receive the same level of service. No other Oregon counties surveyed weighted their allocation by days of service. FINANCE A majorit y of the Oregon counties surveyed use one or a number of allocat ion bases usually focused on number of transact ional type items handled through Finance. A majorit y of the larger counties used number of accounts payable (A/P) transactions, number of paychecks and other factors. Smaller counties used actual expenditures more often. It is unclear fro m the informat ion received whether these other counties significant ly modify expenditures. Deschutes County’s allocation base is based on modified budgeted expenditures. One small county allocated finance solely on 03/04 budgeted personnel expenditures. Source: Survey of Oregon Counties (Appendix I) IT - Al l ocati on base s Dire ct c harg e s (us ua lly t ime ) 4 8 % F TE 8 % C o nnec t io ns 8 % Exp e nd it ure s 4 % Lo g ins 4 %C P U t ime 4 % # o f P C's 2 4 % S o urce: S urvey o f Oreg o n Cou nties (Ap pen d ix I) BUILDING S ERVICES - Allocation bas es Square fo ot age 65 % FT E 5 % T ime 5 % Exp end it ures 1 0% Dire c t C ha rge s 15 % Source: Survey of Oregon Counties (Appendix I) FINANCE - Allocation bas e s # o f A/P inv o ic e it e m s 19 % Expe ndit ure s 15% # o f re v e nue tra ns . 11% # o f pa yc he c ks 9% Tim e 9% F TE 7 % P e rs o nne l c o s ts 7% G/L line s 7% Oth e r fa c t o rs (<5%) 16% Report# 03/04 - 3 (Dated February 17, 2004) Page 27 PERSONNEL A majorit y of the Oregon counties surveyed allocated costs by FTE. Two of the larger counties separately allocate the costs for union and non-unio n emplo yees. Deschutes County’s allocation base is consistent with other Oregon counties surveyed. Union employee costs are not handled separately. LEGAL A majorit y of the Oregon counties surveyed use attorney time to allocate charges or they consider legal a direct charge. Three of the larger counties consider most legal costs as direct costs. Three of the larger counties allocated legal charges based on attorney t ime utilized. Deschutes County’s allocation is based on estimated usage of attorney time. This is consistent with other Oregon counties surveyed. Legal uses estimated time instead of actual time. ADMINISTRATIVE SERIVCES A majorit y of the Oregon counties surveyed use expenditures or FTE to allocate these charges. A majorit y of the larger counties used FTE and/or a combinat ion of other factors. Expenditures were used more often by smaller count ies. Deschutes County’s allocation base is based on modified budgeted expenditures. It is unclear from the information received whether these other counties use modified expenditures. Most of the smaller counties allocate on actual expenditures. Larger counties utilize other allocation bases such as FTE, budgeted expenditures, and agenda items or combination thereof. S ou rce: Su rvey o f Orego n Cou nties (App en dix I) PERS O NNEL - Al l oca ti o n bas e s # o f p ayro ll checks is s ued 7% FTE 6 0 % Exp end it ure s 13 % Pers o nnel co s t s 7% # o f emp lo yees 13 % S o u rce: S urvey o f Orego n Co un ties (App end ix I) LEGAL - Allocation bas es T ime 55 % Direct ch arges 17 % Exp end it ures 1 1 % FT E 11 % by files o pen ed 6 % S ou rce: Su rvey o f Orego n Co u nties (Ap p end ix I) ADMINIS TRATIVE S ERVICES - Al l ocation base s FT E 32 % Ot h er fact o rs (<6%) 2 6% Exp e nd it u r e s 4 2 % Report# 03/04 - 3 (Dated February 17, 2004) Page 28 OTHER INDIRECT COSTS ALLOCATED A number of Oregon counties surveyed allocate other indirect costs in their Plan. Commissioners’ Office - A majorit y of Oregon Counties surveyed allocate some portion of the cost of the Commissio ners’ Office based on a combinat ion of factors including expenditures, FTE and number of agenda items. Building usage - A number of Oregon counties surveyed (three of the five larger counties) assessed a building rental charge. This was allocated by square footage. Purchasing - Four of the five larger Oregon counties surveyed had a centralized purchasing funct ion and allocated such costs based on purchase orders. Deschutes County does not have a centralized purchasing funct ion so this is not relevant. Archives – Five counties had the cost of archives allocated in their Plans. Archive costs were allocated based on a number of factors including cubic feet stored or amount of time. Twenty- five percent of Deschutes County’s archivist is allo cated through the Building Services charge. Internal audit - Some of the larger Oregon counties have more internal audit staffing and, therefore, just ify a separate indirect charge for these services. As Deschutes County accounts for its internal auditor costs in its administrative services fund a separate allocation is not necessary. Equipment usage - Three of the five larger Oregon counties surveyed assessed an equipment charge. Usually this was to recover usage of internal service fund equipment based on a depreciable rate. As Deschutes County includes the expenditure in its annual charge, a separate charge is not necessary. ALLOCATION METHODOLOGY A majorit y of the Oregon counties surveyed use the step or reciprocal method, which allocates costs between internal service funds. The direct method does not allocate charges between internal service funds. Four of the five larger Oregon counties use a step or reciprocal method. Deschutes County uses the direct allocation method. Source: Survey of Oregon Counties (Appendix I) P e rc e nt a g e o f a llo c a tio n m e t ho do lo g y o bs e rv e d Direct 40%R e cip ro c al 60% Source: Survey of Oregon Counties (Appendix I) Other se le cte d i ndi rect costs 0 2 4 6 8 10 12 Equipment us age County auditor Ar chives P ur chas ing Building us age (r ent) Commis sioner 's Of f ice # of counties that allocated Report# 03/04 - 3 (Dated February 17, 2004) Page 29 OMB CIRCULAR A-87 A majorit y of the Oregon counties surveyed (and four of the five larger counties) indicate compliance with OMB Circular A-87 requirements. Local governments can recover indirect costs from federal and many state grant funds received if they co mply with OMB Circular A-87 requirements. The primary requirements include: · Documentation of allocat ion methodology · Removal o f unallowable costs · Certificat ion of the Plan by Count y Financial Officer · Carryforward of differences between actual costs and those charged Deschutes County does not currently meet all of the requirements of the Circular. The County presently does not include indirect costs on grants coming under this Circular. FUNDS/DEPARTMENTS RECEIVING INDIRECT COST ALLOCATIONS A majorit y of the larger Oregon counties surveyed calculate indirect costs to all departments. Those counties frequent ly do not allocate to some funds/depart ments. Funds not allocated to included debt service and construction funds. The general fund usually receives the cost for those funds not allocated to. S o u rce: S urvey o f Orego n Co un ties (App end ix I) P e rc e nt a g e o f c o untie s o bs e rv e d who pre pa re a n OMB -A 8 7 indire c t c o s t pla n No 31% Yes 69% Report# 03/04 - 3 (Dated February 17, 2004) Page 30 APPENDIX II – OREGON COUNTY SURVEY DATA The fo llowing data is the underlying data for the observat ions shown under Appendix I (B) Information Technology Cost Pool Allocation factors INFORMATION TECHNOLOGY County (by popln size)Allocation factors D i r e c t # o f P C 's F T E E x p e n d i t u r e s # o f C o n n e c t i o n s # o f L o g i n s C P U t i m e Washington System maintenance - by assigned logins Management - by assigned logins X Clackamas Projects - by time spent times internal rate Other services - by # of computers X X Lane Directly allocated X Marion Administration - by FTE by staff direct billings X X Jackson by direct charges by # of PC's X X Deschutes by time charges by # of PC's & printers X X Linn by direct time (87%) and by CPU time (17%)X X Douglas by expenditures X Yamhill by time spent times internal rate X Benton Programming-by planned time PC's - by # of PC's Network-by # of connections Depreciation - by # of connections Software maint - direct allocation X X X Josephine Direct charges - by 5 year avg. times fixed rate Infrastructure - by fixed dollar value times # PC's Base system - dollar value times # PC's X X Umatilla by direct charges X Klamath by time X Lincoln by % of personal and by service expenditures X X Columbia by direct charges by # of PC X X Count 12 6 2 2 1 1 1 FTE = Full Time Equivalent employee COMPARISON LIST Report# 03/04 - 3 (Dated February 17, 2004) Page 31 Building Maintenance Cost Pool Allocation factors BUILDING MAINTENANCE COMPARISON LIST County (by popln size)Allocation factors S q u a r e f o o t a g e D i r e c t c h a r g e s E x p e n d i t u r e s T i m e F T E Washington Bldg maintenance - by square footage served Janitorial - by square footage served Grounds maintenance - by square footage served Utilities - by square footage served X Clackamas Maintenance and Utilities - by square footage Projects - direct by time spent Repairs & maintenance - by time Administration-by budgeted utilities and other costs 95% to full service facilities X X X Lane by square footage X Marion Janitorial-by square footage Facility-by square footage X Jackson Direct charges by square footage X X Deschutes Day Maintenance - by square footage Night maintenance - by square footage Utilities - direct charges X X Linn by square footage X Douglas by expenditures X Yamhill by square footage X Benton Included with rent charge - by square footage X1 Josephine by square footage X Umatilla by square footage Mail under printing-% of total alloc. postal X Klamath by square footage X Lincoln by % of personal service expenditures X Columbia Gen Service - by FTE Maintenance & utilities - by square footage X X Count 13 3 2 1 1 FTE = Full Time Equivalent employee 1 - Most are charged as a direct cost and not included in indirect cost plan. Report# 03/04 - 3 (Dated February 17, 2004) Page 32 Finance Cost Pool Allocation factors FINANCE County (by popln size)Allocation factors # o f A /P i n v o i c e i t e m s E x p e n d i t u r e s # o f r e v e n u e t r a n s . # o f p a y c h e c k s T i m e F T E G /L l i n e s P e r s o n n e l c o s t s # o f p a y r o l l t r a n s a c t i o n s # o f b i l l i n g s # o f b u d g e t l i n e s # o f j o u r n a l e n t r i e s # o f F o r m 1 0 9 9 's # o f e m p l o y e e s Washington Accounts Payable - by invoice line items Payroll - by # of paychecks General - 80% by G/L lines and 20% by budget X X X X Clackamas Accounts Payable & Receivable - by # of transactions Payroll - by # of paychecks issued Grant accounting - by hours spent Budget - by # of budget lines Other accounting - by hours spent General government - not allocated X X X X X Lane Accounts Payable - by # of transactions (39%) Payroll-by # of checks (32%) Cash receipts - by # of transactions (13%) Investment- by estimated time (10%) Benefits- by FTE (6%)X X X X X Marion General - by FTE (w/temps) (10%) Accounts payable - by # of transactions (35%) Accounts receivable- by # of billings (20%) (35%) by material & services budget {no capital items}X X X X Jackson General - by # of A/P and payroll transactions Payroll - by # of payroll transactions X X Deschutes by modified budget expenditures X Linn Treasurer-by # of receipts Accounting-by # of employees X X Douglas by expenditures X Yamhill General - by modified expenditures Payroll-by # of payroll checks X X Benton Accounting- by # of A/P, journal entries, and Revenue transactions Payroll-by personnel costs X X X X Josephine by # of A/P and Payroll transactions X X Umatilla Accounts payable - by # of A/P transactions Receipts-by # of receipts Tax-by expenditures Bank reconciliations-by expenditures 1099's-by # of 1099's Government obligation bond-by direct time General ledger-by # of financial transactions tax notes-by expenditures X X X X X X Klamath by G/L, accounts payable, payroll, time and expenditures X X X X X Lincoln by personal service expenditures X Columbia by FTE X Count 9 7 5 4 4 3 3 3 2 1 1 1 1 1 FTE = Full Time Equivalent employee COMPARISON LIST Report# 03/04 - 3 (Dated February 17, 2004) Page 33 Personnel Cost Pool Allocation factors PERSONNEL County (by popln size)Allocation factors F T E # o f e m p l o y e e s P e r s o n n e l c o s t s E x p e n d i t u r e s # o f p a y r o l l c h e c k s i s s u e d Washington by FTE Unions - by FTE for union ee's X Clackamas by FTE X Lane by FTE Union - by FTE X Marion by FTE (adjusted for temps)X Jackson HR - by number of employee's X Deschutes by FTE X Linn by number of employee's X Douglas by expenditures X Yamhill by # of payroll checks issued X Benton by personnel costs X Josephine by FTE X Umatilla HR-by FTE X Klamath by FTE and expected new hires X Lincoln by personal service expenditures X Columbia by FTE X Count 9 2 2 1 1 FTE = Full Time Equivalent employee COMPARISON LIST Report# 03/04 - 3 (Dated February 17, 2004) Page 34 Legal Cost Pool Allocation factors LEGAL County (by popln size)Allocation factors T i m e D i r e c t c h a r g e s E x p e n d i t u r e s F T E b y f i l e s o p e n e d Washington by direct charges on time General funds balance - by time X X Clackamas Not allocated out - by direct charges X Lane by FTE (33%) by actual time (67%)X X Marion Not allocated out - by direct charges X Jackson by actual time X Deschutes by estimated time X Linn by estimated time X Douglas by expenditures X Yamhill by estimated time X Benton by actual time (p/y)X Josephine by files opened and FTE X X Umatilla by estimated time (in BOCC)X Klamath by time X Lincoln by personal service expenditures X Columbia by estimated time X Count 10 3 2 2 1 FTE = Full Time Equivalent employee COMPARISON LIST Report# 03/04 - 3 (Dated February 17, 2004) Page 35 Administrative Services Cost Pool Allocation factors ADMINISTRATIVE SERVICES County (by popln size)Allocation factors E x p e n d i t u r e s F T E s p e c i f i c d e p t . G r a n t d o l l a r s # o f a g e n d a i t e m s # o f A /P t r a n s a c t i o n s # o f e m p l o y e e s Washington Administration - by FTE Employee Relations - by FTE Budget analysis - by modified budget X X Clackamas Administration - 2/3 by FTE BOCC support-1/3 not allocated X Lane by Agenda items (45%) by Expenditures (29.5%) {10% lobbying} by Grant dollars administered (10%) by FTE (12.5%) to Economic development (3%)X X X X X Marion by FTE (w/temps)X Jackson by budgeted expenditures X Deschutes by modified budget expenditures X Linn by average # of employees by accounts payable transactions X X Yamhill by modified expenditures X Benton Departmental overhead-by internal service FTE X Josephine by modified budget expenditures (p/y)X Umatilla by FTE and expenditures X X Klamath by budget, resolutions, and transfers Lincoln by personal service expenditures X Count 8 6 1 1 1 1 1 FTE = Full Time Equivalent employee COMPARISON LIST Report# 03/04 - 3 (Dated February 17, 2004) Page 36 Other Indirect Cost Pools County (by popln size)C o m m i s s i o n e r s o f f i c e B u i l d i n g u s a g e (r e n t ) P u r c h a s i n g B u d g e t & p l a n n i n g C o u r i e r s e r v i c e s C o u n t y a u d i t o r C o m m u n i c a t i o n s A r c h i v e s E q u i p m e n t u s a g e C o p i e r &/o r p r i n t i n g s e r v i c e s P C r e p l a c e m e n t F i n a n c i a l s y s t e m R e a d y s t o r e s M o t o r p o o l R e t i r e m e n t r e s e r v e Washington X X X X X X X X Clackamas X X X X X X Lane X X X X X X X X X X X Marion X X X X Jackson X X X X X X Deschutes (iii)(v)(iv)(i)(ii) Linn X X Douglas X Yamhill X X X X Benton X (i)X Josephine X X Umatilla X X X X X X X X Klamath X X (i) Lincoln X X Columbia X X X Count 11 6 6 6 5 4 5 5 4 4 3 3 2 2 1 Note:This matrix was used to identify other areas of indirect costs allocation. Other indirect cost pools are broadly defined for purposes of comparison. Notes: i Included in administrative service fund ii System acquisition costs spread between personnel and finance iii No consistent payment of rents by departments/funds iv Included in building services fund. Mail costs directly charged on usage. v Included in finance Other indirect cost pools Report# 03/04 - 3 (Dated February 17, 2004) Page 37 BOCC Cost Pool Allocation factors BOCC (other indirect cost pool) County (by popln size)Allocation factors E x p e n d i t u r e s F T E # o f a g e n d a i t e m s S p e c i f i c d e p t T i m e P o r t i o n - N o t c h a r g e d Washington by FTE (35%) by agenda items (35%) by budget appropriations (30%)X X X Clackamas Lane by FTE (15%) by agenda items (30%) by expenditures (40%) to Road dept (10%) to Planning (5%)X X X X Marion by FTE (w/temps)(50%) by Expenditures (50%)X X Jackson by budgeted expenditures X Deschutes Linn Douglas by staffing expenditures only X Yamhill by modified expenditures X Benton Josephine by modified p/y budget X Umatilla Klamath by time not charged (33%)X X X Lincoln by personal service expend.X Columbia by FTE (35%)X Count 9 4 2 1 1 1 FTE = Full Time Equivalent employee COMPARISON LIST Report# 03/04 - 3 (Dated February 17, 2004) Page 38 Building Usage Cost Pool Allocation factors BUILDING USAGE (Rent)(Other indirect cost pool) (by popln size)Allocation factors Square footage Washington by square footage (2% of bldg cost)X Clackamas Lane by square footage (depreciation of 3.3% of total X Marion by square footage (debt service)X Jackson Deschutes No consistent charge for usage of facilities. Linn Douglas Yamhill by square footage X Benton by square footage (uniform rental rate plan)X Josephine Umatilla by square footage X Klamath Lincoln Columbia Count 6 COMPARISON LIST Report# 03/04 - 3 (Dated February 17, 2004) Page 39 Archives Cost Pool Allocation factors ARCHIVES (Other indirect cost pool) County (by popln size)Allocation factors # o f c u b i c f e e t s t o r e d S h a r e o f l a b o r # o f l b s . d e s t r o y e d # o f r e c o r d s P e r s o n a l s e r v i c e e x p e n d i t u r e s Washington Clackamas Admin cost - by share of labor Microfilm - by staff hours required Records storage-by cubic feet stored Destruction-by lbs destroyed Inform. Mgmt. -by share of clerical ee's X X X Lane by # of records X Marion Jackson by # of cubic feet of storage X Deschutes Linn Douglas Yamhill Benton Josephine Umatilla by % of estimated support X Klamath Lincoln by personal service expenditures X Columbia Count 2 2 1 1 1 COMPARISON LIST Report# 03/04 - 3 (Dated February 17, 2004) Page 40 Allocation Methodologies Type of allocation method from review of indirect plan materials* County (by popln size)D i r e c t S t e p R e c i p r o c a l Washington X1 Clackamas X Lane X1 Marion X Jackson X Deschutes X Linn X Douglas X Yamhill X Benton X Josephine X Umatilla X1 Klamath X Lincoln X Columbia X 1 - Proprietary software used for allocation (Maximus). Most other counties utilize a spreadsheet program. *Allocation methodologies - brief descriptions Direct - direct allocation to program depts. Step - sequence of inter-allocation between internal service depts. Reciprocal - explicit allocation in-between internal service depts. Allocation Methodology Report# 03/04 - 3 (Dated February 17, 2004) Page 41 Prepare indirect cost plan to comply with OMB A-87 ? County (by popln size)Y e s N o Washington X Clackamas X Lane X Marion X Jackson X Deschutes X Linn X Douglas Yamhill Benton X Josephine X Umatilla X Klamath X Lincoln X Columbia X Note:OMB-A87 indirect cost plans allow for indirect costs to be charged to federal grants OMB A-87 Plan? Report# 03/04 - 3 (Dated February 17, 2004) {THIS PAGE LEFT BLANK}