Negotiated Indirect Cost Rate Agreements: Opportunities Exist to Improve Processes and Data Management

Audit Report
Report Number
3-000-24-001-U

Why We Did This Audit 

  • We contracted with the independent certified public accounting firm of Williams, Adley & Company-DC LLP (Williams Adley) to conduct a performance audit of USAID’s management of negotiated indirect cost rate agreements. Indirect cost rates are used to reimburse contractors and grantees for costs incurred for a common purpose in carrying out foreign assistance programs, such as office space, utilities and salaries that are not directly tied to specific award.
  • Indirect costs carry risks for USAID because indirect cost rates and the basis for their allocation is sensitive information, and determining whether those costs are reasonable, allowable, and allocable can be difficult. We have received allegations of contractors and grantees charging indirect costs incorrectly and our past oversight has shown this to be in part due to unfamiliarity with requirements for indirect cost calculations. 
  • The overall audit objective was to determine the extent to which USAID applied best practices for managing the indirect costs charged by its award recipients to USAID awards from fiscal year 2016 to 2021. Specifically, Williams Adley examined the extent to which:
  1. USAID negotiated provisional and final indirect cost rates with contractors and grantees within necessary timeframes and in line with applicable cost principles.
  2. USAID ensured that the indirect costs charged by contractors and grantees to USAID awards were (1) based on the approved indirect cost rate and/or method; (2) calculated consistently across USAID awards whether as prime and/or sub-contractor or grantee; and (3) reasonable, allowable, and allocable.

What We Found

  • Williams Adley was not able to determine the extent to which USAID applied best practices for managing indirect costs charged to USAID awards from fiscal year 2016 to 2021 due to a limitation with USAID’s systems. This systems limitation precluded Williams Adley from obtaining a complete listing of contractors and grantees to complete required testing. 
  • However, during the course of the audit Williams Adley reported findings, including that:
  1. USAID’s systems could be improved to report and analyze the usage of indirect cost rates.
  2. USAID does not have a process to monitor prime implementers’ verification of sub- awardee indirect cost rates; and
  3. USAID does not have proper documentation to support indirect costs charged.

Why It Matters

  • Indirect costs are a legitimate cost of doing business only to the extent that they are reasonable, allowable, and allocable.
  • We are making six recommendations to ensure contractor and grantee indirect costs are negotiated and applied in compliance with government-wide and USAID requirements.
3-000-24-001-U.pdf1.28 MB

Recommendations

Recommendation
1

To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Develop and implement procedures to collect indirect cost data from implementers in a systematic manner that will allow it to comprehensively report and analyze the indirect costing methodology and rates for implementers. This information should include indirect cost rate agreement type (e.g., cognizant agency-negotiated indirect cost rate or de minimis agreements).

Questioned Cost
0
Funds for Better Use
0
Recommendation
2

To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Review the results of the prime implementer's sub-awardee monitoring specifically for indirect cost concerns during site visits or other reviews of the prime.

Questioned Cost
0
Funds for Better Use
0
Close Date
Recommendation
3

To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Develop written internal control policies, procedures, or guidance specific to USAID's Overhead, Special Cost, and Closeout Branch indirect cost processes to clarify minimal documentation retention rules during every phase of the indirect cost process, notably first time, subsequent, and final negotiations.

Questioned Cost
0
Funds for Better Use
0
Recommendation
4

To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Develop checklists to verify completion of for-profit organizations files similar to the checklist used for non-profit organizations.

Questioned Cost
0
Funds for Better Use
0
Recommendation
5

To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Develop a process to conduct periodic reviews of a sample of implementer files for missing documents or accuracy of indirect costs charged and report unsupported payments as improper payments.

Questioned Cost
0
Funds for Better Use
0
Close Date
Recommendation
6

To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Consider implementation of a centralized document control methodology and tracking mechanism to improve internal document control practices.

Questioned Cost
0
Funds for Better Use
0