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最后更新： 2014-08-20
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i’m writing to you regarding financial reporting and accounting of the “de minimis” indirect cost rate for the livelihoods for resilience activity. we realized recently that when an organization uses the usaid “de minimis” indirect cost rate, they are supposed to exclude “participant support costs” (as well as rent) from the direct base calculation, so that the indirect costs are applied to the “modified total direct costs”. in other words, the organization is allowed to pay for these costs with the project budget, but when calculating the direct costs on which the 10% indirect rate is applied, the participant support costs should be excluded from the calculation. (for example, if you have $10,000 in total direct costs, but $2,000 were used on participant support costs, your base for the 10% would be $8,000 rather than $10,000, and the total indirect would be $800 rather than $1,000.) participant support costs are defined in the regulations as follows: “participant support costs - means direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects. this does not include workshop expenses such as meals and accommodation paid for participants.” after many discussions with our compliance colleagues and care usa’s legal advisor, we have been instructed to consider “participant support costs” to include trainee per diem and transport allowances, including at the field level. meals and accommodations covered by kyeema aren’t considered participant support costs, but any per diem or travel allowances paid to project clients are. therefore, going forward, we will need kyeema’s financial reports to separate out participant support costs—trainee per diem and transport allowances—and exclude them from the direct cost base on which your indirect rate is calculated. this may be tough, but i believe we can make it work. in particular, mahlet can work with you to figure out where kyeema might be able to reclassify expenses from indirect to direct, so that your total recovery for those costs stays about the same. mahlet can work with you on next steps, but please let me know if you have any questions.
最后更新： 2020-12-22
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