UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                          WASHINGTON, D.C.  20460
                              FB I I  1993
                                       OSWER Directive #9202.1-09
MEMORANDUM
SUBJECT:  Guidance on Program
FROM:
                                                             omce OF
                                                           AOMHISTRATION
                                                           AM) RESOURCES
                                  ctivities Ur der ARCS
Richard Guimond
Assistant Surgeon GeneralMJSPH
Deputy Assistant Administrator
Office of Solid Waste a/io) Emergen
          'SallyanneJ^irper, Depu
           for Finance and Acquisition
          Response

ssistant Administrator
TO:
ARCS Contracting Officers and Project Officers
     I. BACKGROUND/PURPOSE

     In July 1991, Administrator Reilly established a task force of senior EPA
managers and analysts to address concerns regarding the Agency's Alternative
Remedial Contracting Strategy  (ARCS) contracts.  In the area  of program
management the task force made six specific recommendations.  This guidance
document addresses two of those recommendations:  1) division of program
management  costs  into administrative support costs  and technical cleanup
costs and 2) development of guidance on cost management activities.  The
guidance is to be  implemented  beginning  with ARCS  contract invoices
submir.ed for March, 1993.

     In order to  improve the  ability of the Government to track program
management costs, the task force directed that all costs currently characterized
as program management  costs be  segregated into  two functional areas.
administrative support costs and technical  cleanup costs. Section II of this
guidance addresses  this recommendation.

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     The task force also directed that the Agency develop guidance on cost
management activities that would assist the Regions in their efforts to control
program management costs.  Sections III through V address this recommenda-
tion.

     Finally, Section VI provides specific instructions which will implement the
recommendations.

     Whereas  this guidance  u.ovides  direction on segregating  program
management costs, it should  be noted  that during contract  negotiations
contractors were encouraged to maximize site-specific program management
wherever such costs could be legitimately associated with a single site. This
should continue to be encouraged.
      II. SEGREGATING PROGRAM MANAGEMENT COSTS

      Each ARCS contract provides for the delivery of architect/engineering
services for the remediation of hazardous waste sites.  The contracts provide
for two centers against which all costs will be reimbursed (excluding the Special
Subcontracting Pool for Construction).  The first cost center is designated as
remedial planning activities and consists of all site-specific contract costs, that
is, all cost directly associated with activities on specific hazardous waste sites
assigned to the ARCS contractor for  remediation.  The second cost center is
designated as program  management activities which  consist of all  non-site
specific contract costs. Typically, program  management costs support and
benefit the remedial sites on which a contractor is performing in the aggregate
but cannot be attributed to a specific site.

      Prooram Management, as define* in the ARCS contracts, "is teemed to
constitute those technical, management, administrative, clerical and secretarial
activities to be performed by the Program Management Office (PMO) and those
support functions to be performed by the corporate office which are allocable
to the PMO."

      Currently, program management costs are tracked and reported on the
basis of an aggregate amount.  In order to improve the tracking, reporting and
analysis  of these costs,  program  management  costs will henceforth  be
segregated into administrative and technical cleanup costs on all contract
invoices.  Invoices shall include two separate accounts with different activity

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codes for Administrative and technical cleanup costs.  Attachment II, Technical
and Administrative Costs  Tracked By  Activity Code,  provides  specific
instructions on the use of these codes.

      Program management activities are non-site-specific  in nature, that is,
they support more than one site " support general Contract activities. Program
n.anagement does not constitute any portion of the  LOt hours stipulated for
remedial planning  activities.

      To assist in improving the tracking and monitoring of these costs, the
following definitions have been developed to segregate the program manage-
ment costs into administrative and  technical cleanup cost categories.   The
ARCS  Contract Tracking (ACT) System will be modified  concurrently  with
implementation  of this  guidance to  reflect  the segregation  of  program
management into administrative and technical cleanup costs. Invoices and the
ACT system reports should reflect the same dollar amounts for administrative
and technical cleanup costs.
      A. Administrative Support Costs are non-site-specific costs necessary for
managing the overall contract regardless of the amount of specific site work.

      Administrative support activities are necessary to enable the contractor
to perform remedial site work as well as keeping  the Government informed of
overall contract activity.

      The following examples will assist in determining which activities fall into
the administrative support category. Because activities vary under each ARCS
contract, this is not a definitive list of all administrative support activities which
might be required.

                 Contract Mobilization (development of field equipment needs
                 and inventory control guidelines)

                 Personnel  Management

                 Preparation of Monthly Reports (Progress and Financial)
                  (The compilation of site specific progress and financial data
                   should be charged site-specifically)

                 Meetings concerning contract operations

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                Financial Accounting Activities

                Computer Support

                Invoicing/Voucher Preparation

                Updates to Management,  Health  and Safety and  Quality
                Assurance/Control Plans

                Routine Communication/Coordination between
                EPA/Contractor

                Audit Support

                Preparation of Contractor's Program Management Summary
                Evaluation  Reports (SER)

                Team Subcontractor Management Activities  (Pool subcon-
                tract management activities should be charged to remedial
                planning.)

                Labor Standards Compliance (Service Contract Act/
                Davis-Bacon Act)

                Maintenance of Corporate Conflict of Interest Plan
                and System Support

                Annual Contract Close-Out Activities

                Clerical Activity in Support of Administrative Functions

                Other Administrative Activities (library and other reference
                activities,  annual  allocation  reporting,  non-site-specific
                records retention activities, etc.)
     Staffing
      Each contractor proposed staffing positions necessary to perform program
management functions.   Specific staffing plans were negotiated  prior to
contract  award.  The final approved  staffing plans can  be  found m the
Confirmation of Negotiations in the pre-award contract file. These staffing

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positions are not part of the labor provided under the level of effort capacity of
the contract; they are a unique labor pool available to provide specific program
management functions.  Since each of the contractors' staffing plans contain
unique staff descriptions, the examples of staffing shown for administrative and
technical cleanup are used only to indicate staff activities and not specific titles;
they are not provided to indicate staffing patterns for any contract.  They are
sample categories  of disciplinary expertise  and  management  oversight
necessary for the contract operation. However, anv activities performed by thp
program management staff for  site specific activities should be charged to
remedial planning activities.

      Examples of staffing that  might be used to accomplish administrative
activities are:

            Program Manager           Reports Manager
            Accountant                 Subcontract Manager
            Contract Administrator      Secretary/Data  Entry Clerk
      B.  Technical  Cleanup Costa are non-site-specific costs for technical
      activities that cover multiple sites, and are related to the site-specific
      work conducted under the contract.

      Most  technical  cleanup activities  under program  management  are
performed as a result of requirements from multiple sites. These costs will vary
with the number of sites assigned under the contract.

      Examples  of  technical  cleanup activities  are provided to  assist in
determining which  activities to include in the technical cleanup category.
Again, this is not a  definitive catalogue of these activities.

                 Equipment/Warehouse  Management  (Including  cost  of
                 equipment maintenance, calibration and inventory)

                 Meetings concerning technical issues relevant to multiple
                 work assignments

                 Health and Safety

                 Quality Assurance/Quality Control

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                 Technical Guidance

                 Pollution Liability  Insurance (Site-specific  PLI  should be
                 invoiced as a site-specific cost)

                 Mobile Lab

                 Tiaining (Requites  PO and CO ap^.oval)

                 Limitation on Future Contracting

                 Preliminary Conflict  of Interest investigations for potential
                 work assignments

      The following are examples of staffing that might be used to accomplish
technical cleanup activities:

           Program Manager           QA Officer
           Contracts Manager          Equipment Manager
           Sample Coordinator         Analytical Coordinator
           Health and Safety Officer
           Clerical Support for these activities

      Health and safety, QA/QC and coordination of CLP/analytical services
should be charged to site specific activities when possible.

      C. Activities Containing Components of Both Administrative and
           Technical Cleanup Costs

      The following  activities may fall into both administrative and technical
categories. As a result the contractor should be advised that depending on the
nature of the activity, staff time and related costs should be classified under the
definitions for administrative and technical cleanup costs.

                 Subcontracting (e.g. Basic Ordering Agreements)

      Any subcontracting activities that are not site-specific will be classified
as an administrative support cost.

                 Standard Operating Procedures

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      Standard Operating Procedures (SOP) which deal with overall contract
administration will be classified as an  administrative support cost.   SOPs
developed  for multiple site work will  be classified as  a non-site-specific
technical cleanup cost.

      Equipment/Travel/Other Direct Costs (ODQ/Clerical  Support

      ODC, equipment, and travel pools for program management should be
allocated between administrative support and technical  cleanup areas for
purposes of tracking the costs.

      In implementing the segregation of program management costs, actual
equipment  costs will be classified as a technical cleanup  cost.  Labor costs
associated  with the justification and approval of equipment purchases will also
be classified as a technical cleanup cost. Travel and ODC costs can be either
administrative or technical cleanup costs and  should be monitored, analyzed
and reported  under each discrete element.

      Clerical support should be similarly segregated by cost into the specific
element supported, either administrative or technical cleanup.
      Site-Specific Program Management

      Program management costs, both administrative support and technical
cleanup, may be site-specific in nature. Site-specific program management is
also called project management when the activity is part of a site-specific work
plan.  Where such costs can be associated with a single site, they must be
included within the approved budget for the individual work assignment. Note
that during contract negotiations contractors wara ancoura^d to maximize site
apaeific program management wherever  such  coats could be legitimately
associated with a single site.
      III. CONTRACT COST INDICATORS

      Effective contract management depends on the availability of reliable
indicators of contractor performance.  This guidance establishes a number of
key indicators  which will be used by regional and headquarters management in
monitoring and analyzing ARCS contract costs.

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     The primary beneficiaries of this management data will be the managers
directly responsible for the administration and  oversight of ARCS contracts.
Trends can be spotted and cost comparisons can be made to other contracts.
Manual collection of data will be  required far less frequently.

     All of the information required can be gathered from the ARCS Contract
Tracking (ACT)  System.   Because critical  decisions will  be based on  the
information provided by these management indicators, regional personnel must
enter data in a timely, accurate, and comprehensive manner. Quarterly reports
will be utilized by headquarters and the Regions in reaching these decisions.

     The following indicators are included as examples which can be used to
improve the  analysis  of contract  costs.  These  indicators  and others  are
currently available from the ACT System. New indicators will be developed to
meet future needs for trend analyses of contractor performance.  Individual
regions may likewise develop additional cost indicators  to solve  specific
management problems in their own regions.

           Expenditures.  This indicator provides  basic information  on total
sums actually expended. The program management data will be displayed in
total and subdivided into administrative support and technical cleanup costs.

           Obligations.  This indicator will show amounts obligated by work
assignment and total program management obligations.  It will provide useful
information for fiscal planning purposes and should be compared to expendi-
tures to avoid excessive funding  (i.e. banking money).

           Administrative Support Costs vs  Total  Contract Cost,
           Technical Cleanup Costs vs Total Contract Costs,
           Program Management  Costs vs Total Contract  Cost.   These
indicators will display total costs associated with these elements as percentag-
es of total contract cost.  They will be calculated on  the  basis of actual
expenditures by  region,  and by contract. The objective will be to assess  the
relative efficiency  of program management.   To provide  consistency  in
analyses, pollution liability insurance costs and  equipment costs may be
segregated from other administrative and technical cleanup costs.

           Administrative Support Costs per LOE Hour Delivered,
           Technical Cleanup Costs per  LOE Hour Delivered,
           Program Management  Cost per LOE  Hour Delivered.   These
indicators will  measure the cost-effectiveness  of  program management

                                   8

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operations. They will provide individual contract rates which can be analyzed,
compared and contrasted.
      IV. COST EFFICIENCIES DURING WORK SLOWDOWN

      During periods of low contract activity, support costs should be carefully
monitored. Contracting officers and project officers should take the initiative to
assure that contractors  incur only absolutely essential costs.  Evaluation of
contractor performance under the award fee process during these  periods
should focus on the efficiency with which the contractor manages contract
support costs. To insure consistency among ARCS contracts, changes made
to required reports, deliverables or other contract activities should be coordinat-
ed with the Office of Acquisition Management (0AM) and HSCD.

      Congress has mandated  that the Agency achieve a national  target for
program management expenditures compared to total contract expenditures for
ARCS contracts.  In FY92, this target was 15%.  Future targets may be
adjusted by Congressional action.
     V. PROGRAM MANAGEMENT OPTIONS

     One of the  principal goals of ARCS  is to provide incentive to the
contractors to perform in an  outstanding manner.  To achieve this goal, in
addition to the  award  fee structure  of the contracts, EPA designed the
contracts to have a small base level-of-effort (LOE) with an extended option
structure. Contractors performing in a manner superior to other contractors in
a given region/zone would be rewarded with additional work and contractors
performing less well would receive correspondingly less work.

     To complement this option structure for increased quantity of LOE hours,
a corresponding option structure for program management was created. The
difference between the two is that remedial planning options are calculated in
numbers of LOE hours and program management options were calculated as
dollars estimated to support the delivery of the LOE hours.

     Contract  options  for both remedial planning activities and  program
management are exercised by the  contracting officer at the request of the

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project  officer.  Note that ARCS contract option structures  are variable
depending on the capacity of individual ARCS contracts.

     The relative dollar value negotiated for each type of option is based on an
estimated labor mix and an estimated annual delivery rate of LOE. Because the
actual labor mix and  annual delivery rate for each ARCS contract are unique,
the ratio between LOE options and program management options has changed
since the contracts were negotiated.  It is the responsibility of the contracting
officer and project officer to analyze these  changes to assure that adequate
program management support is provided while closely monitoring the overall
costs.
      VI. IMPLEMENTATION GUIDANCE

      Implementation of this guidance will require a change in the preparation
of supporting documentation utilized in  the award fee evaluation.   These
changes,  addressed in detail  below, should  be implemented in the next
evaluation period.  Implementation will  also require the standardization of
selected invoice and reporting requirements among all ARCS contracts. Revised
invoices should be submitted for costs incurred in March, 1993.
      A. Roles and Responsibilities

      Contractors are responsible for the accumulation and categorization of
program management contract expenditures into administrative and technical
cleanup costs and for the submission of this information in monthly invoices
through the use of the Contractor Invoice Supplemental' Report for Program
Management provided as Attachment I to this guidance. In addition, contractor
invoices should reflect the segregation of administrative and technical cleanup
costs through the use of the two separate activity codes provided in Attach-
ment II, Technical and Administrative Costs Tracked By Activity Code.

      Pro/met  Officers are responsible  for reviewing  and  approving  the
segregated costs as part of the invoice  review process and for the evaluation
of these separate activities as part of the award fee process. In addition. Project
Officers are responsible ensuring that the contractor invoices contain the proper
activity codes provided  in Attachment II and  that the Contractor  Invoice
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Supplemental Reports submitted reflect the same amounts for administrative
and technical cleanup services as are reflected in the invoice account coding.

      Contracting Officers are responsible for the contractual implementation
of this guidance, evaluation of these separate activities as part of the award fee
process as well as conducting informal reviews not less than semi-annually to
insure that the guidance is being implemented correctly and consistently under
all ARCS contracts.  A separate review will be conducted as part of the routine
Financial Management  Reviews conducted by OAM.
      B. Award Fee

      Program management is one of the two areas under which ARCS con-
tractors are evaluated.  Contracting officers prepare a Summary Evaluation
Report (SER) on contra-*or activity in the program management area. These
evaluations are incorpc  .ted in the final SER prepared by the project officers
to support overall recommendations to the Performance Evaluation Board (PEB).
The Fee Determination Official (FDO) determines the final amount of fee to be
awarded to contractors based upon the findings and recommendations of the
PEB.

      The segregation of program management costs into administrative and
technical cleanup costs will result in a change to the supporting documentation
provided.   Contracting   officers  and  projects  officers,  in preparing their
evaluations  of  contractor performance, should address administrative and
technical cleanup costs as discrete elements in determining overall contractor
performance  in providing program management activities.

      Because the relative value of administrative and technical cleanup costs
may vary  during each evaluation period,  no specific ratio between the two
elements can be developed.   The project officer,  in consultation  with  the
contracting officer,  will  need to determine the relationship between the two
elements  and  incorporate that determination  into  the SER on  program
management.

      Implementation of these changes to the award fee evaluation process will
not require a formal change to the award fee plan incorporated in the ARCS
contracts.  However, contracting officers and project officers will discuss the
changes in the program management evaluation  process with  their ARCS

                                  11

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contractors focusing on the need to improve the tracking and control of
program management costs.

      ARCS award fee plans contain general guidance on evaluating program
management activities.  The following are some additional areas to be consid-
ered when evaluating the contractor:

      In the area of administrative support:

                Scheduling, coordinating, and executing all individual work
                assignments within the region/zone.

                Predicting  resource requirements,  properly staffing  and
                training personnel.

                Development and  adherence  to the  management  plan,
                including the health  and  safety plan and quality assurance/
                quality control plans.

                Establishing and effectively utilizing the management infor-
                mation and cost/schedule monitoring systems and ongoing
                analysis for costs and  LOE utilization.

                Maintaining good communication channels with Regional EPA
                officials involved  in the Superfund program  as well  as
                responding to regional priorities in a cooperative environment.

                Efficient, cost effective management of team subcontractors
                and timely placement and efficient, cost effective manage-
                ment  of pool subcontractors  with emphasis  on realistic
                efforts in meeting the Small Business/Small Disadvantaged
                Business  Enterprises  (SB/SDBE)  goals specified  in  the
                contract.

                Timeliness  and  quality of monthly progress and financial
                reports.

                Timeliness and quality of invoices with particular  emphasis
                on the adequacy  and reasonableness  of invoice support
                documentation.
                                   12

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                Compliance with all contract terms and conditions.

     In the area of technical cleanup:

                Effective utilization of contract lab program (CLP) and non-
                CLP lab support where applicable in meeting the program
                commitment.

                Cost effective acquisition and utilization of equipment and
                adherence to a property control system.

                Timely implementation of corrective action plans affecting
                . multiple sites where applicable.

                Timely development and modification of health and safety
                plans.

                Management of corporate COI issues related to the limitation
                on future  contracting activity.

                Diligent efforts to secure non-site-specific PLI


     C. Invoicing and Reporting Requirements

     In order to effectively monitor costs incurred for both administrative
support and technical cleanup costs, an adjustment in the method by which a
contractor  invoices program management costs must be made.   The ARCS
contracts already require contractors to supply detailed cost element invoicing
in accordance with the contract clause entitled "Submission  of Invoices"
(EPAAR 1552.232-70).    The contractor is  required to provide cost detail
support on all major cost elements such as direct labor, travel, equipment and
subcontracts as well as any associated indirect costs.

     On January  13, 1992,  the Office of Administration and Resources
Management (OARM) issued  a memorandum signed by David O'Connor,
Director of PCMD, and Henry Longest, Director of OERR, addressing mandatory
invoice  tracking elements under ACT.   The memorandum  provided as  an
attachment a Contractor Invoice Supplemental Report for Program Management
indicating the minimum invoice data elements to be reported by the contractor.
This invoice supplement does not requi.c any additional information than is

                                  13

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already required by the contract and by FAR 52.232-25. As a result of the
segregation in program management however, this guidance provides revisions
to the invoice supplement contained in the January 13th memorandum. In as
much as this type of invoice reporting detail is already a contract requirement,
modifications to existing ARCS contracts will not be necessary.

      The  revised  Contractor Invoice  Supplemental Report for Program
Management is included as Attachment I  to  this guidance.  This revised
attachment requires the contractor  to  provide a summary level report of
program management by cost element. Beginning with the invoices submitted
for March, 1993, the ARCS contractors will be required to use this form when
invoicing their program management administrative and technical cleanup costs.
' In determining whether to report a program management cost as administrative
support or technical cleanup the  contractor must follow this guidance.

      Please  note  that the invoice for program management/administrative
support  costs  does not include the cost elements for  Pollution  Liability
Insurance (PLI), Equipment,  Lab Services and Mobile Lab Services as part of the
cost elements on the administrative program management invoice. The actual
cost of purchasing any PLI  (premiums), equipment, or lab/mobile lab services
as well as labor costs associated with the procurement  of these goods and
services will  be reported under technical cleanup costs.

      Requiring the ARCS contractors to utilize the Invoice Supplemental Report
will  facilitate the subsequent  input of this data into the  ACT  system and
promote standardization and national consistency.

      D. Other Implementation Guidance

      Attachment II, Technical and Administrative Costs  Tracked by Activity
Code, proves specific implementatic.. instructions regarding the use by ARCS
contractors of separate activity codes within account numbers in invoicing for
administrative and technical support under the  ARCS contracts.  The attach-
ment also provides a point of contact within the Superfund Accounting Branch
of the Financial Management Division to answer  questions regarding the proper
use of these new activity codes.

      A  Guide to Program Management Cost Allocations  is provided as
Attachment III to this memorandum. This will simplify the analysis of costs by
the CO and PO.
                                  14

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          ATTACHMENT I
CONTRACTOR INVOICE SUPPLEMENTAL REPORT
 SUMMARY PROGRAM MANAGEMENT INVOICE
1 of 3
1 INVOICE NUMBER:
INVOICE P*T-
PERIOO START DATE: 1
PERIOD END DA 'E: |
CATEGORY
PRIME LABOR COSTS
INDIRECT COSTS
G&A
OTHER DIRECT COSTS
POLLUTION LIABILITY
INSURANCE
TRAVEL
EQUIPMENT
LAB SERVICES
MOBILE LAB COSTS
TEAM SUBCONTRACTORS
OTHER SUBCONTRACTORS
BASE FEE
AWARD FEE
TOTAL » INVOICED
NOTES
BASE LABOR (STRAIGHT
SALARY WITHOUT FRINGE)
OTHER THAN G&A (INCLU-
DING FRINGE)

EXCLUDES TRAVEL, EQUIP-
MENT, LAB SVCS, & MOBILE
LABS
UNLOADED VALUE
DOES NOT INCLUDE RELO-
CATION (INCLUDED IN ODC
LINE)
UNLOADED VALUE
UNLOADED VALUE
UNLOADED VALUE
INCLUDES ALL FEES
CHARGED TO P9"ME
INCLUDES ALL FEES
CHARGED TO PRIME
INCLUDES FCCM
PRIME ONLY

VALUES















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CONTRACTOR INVOICE SUPPLEMENTAL REPORT
     PROGRAM MANAGEMENT INVOICE
        ADMINISTRATIVE SUPPORT
2 of 3
INVOICE NUMBER:
INVOICE DATE:
PERIOD START DATE:
PERIOD END DATE:
CATEGORY
PRIME LABOR COSTS
INDIRECT COSTS
G&A
OTHER DIRECT COSTS
TRAVEL
TEAM SUBCONTRACTORS
OTHER SUBCONTRACTORS
BASE FEE
AWARD FEE
TOTAL » INVOICED*
NOTES
BASE LABOR (STRAIGHT
SALARY WITHOUT FRINGE)
OTHER THAN G&A (INCLU-
DING FRINGE

EXCLUDES TRAVEL, EQUIP-
MENT, LAB SVCS, & MOBILE
LABS
DOES NOT INCLUDE RELO-
CATION (INCLUDED IN ODC
LINE)
INCLUDES ALL FEES
CHARGED TO PRIME
INCLUDES ALL FEES
CHARGED TO PRIME
INCLUDES FCCM
PRIME ONLY

* Total must aoree with total amount invoiced undar a£fiyjiy.£Qfla_
VALUES










a**

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CONTRACTOR INVOICE SUPPLEMENTAL REPORT
     PROGRAM MANAGEMENT INVOICE
       TECHNICAL CLEANUP COSTS
Page 3 of 3
INVOICE NUMBER:
INVOICE DATE:
PERIOD START DATE:
PERIOD END DATE:
CATEGORY
PRIME LABOR COSTS
INDIRECT COSTS
G&A
OTHER DIRECT COSTS
POLLUTION LIABILITY
INSURANCE
TRAVEL
EQUIPMENT
LAB SERVICES
MOBILE LAB COSTS
TEAM SUBCONTRACTORS
OTHER SUBCONTRACTORS
BASE FEE
AWARD FEE
TOTAL $ INVOICED*
NOTES
BASE LABOR (STRAIGHT
SALARY WITHOUT FRINGE)
OTHER THAN G&A (INCLU-
DING FRINGE)

EXCLUDES TRAVEL, EQUIP-
MENT, LAB SVCS, & MOBILE
LABS
UNLOADED VALUE
DOES NOT INCLUDE RELO-
CATION (INCLUDED IN ODC
LINE)
UNLOADED VALUE
UNLOADED VALUE
UNLOADED VALUE
INCLUDES ALL FEES
CHARGED TO PRIME
INCLUDES ALL FEES
CHARGED TO PRIME
INCLUDES FCCM
PRIME ONLY

VALUES














* Total must agree with total amount invoiced under activity code a.

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                                     "^^
                            KJ_
                                               TT
             TECHNICAL ft ADMINISTRATIVE COSTS TRACKED BY ACTIVITY CODE

               EPA will be able to track and report the technical and
           administrative contract expenses in its accounting systea through
           the usa of account limbers.  FMD haa designated activity coda "9"
           for adMinir*—*«-ive costs s» defined in tha guidance and activity
           coda "A" for technical cleoj.jp as defined in the guidance.
           Contractors should use these activity codes in the account codes
           on the invoice site distribution sheets.   Project Officers are
           responsible for ensuring that the correct codes are used.  Zf
           there are any questions about the account codes or activity
           codes, please contact the Chief, Superfund Accounting Branch, FMD
           at (202) 260-9268.
          USE ACTIVITY CODE "9" POR ADMINISTRATIVE COSTS PORTION OF PROGRAM
          MANAGEMENT
                NON-SITE
                ACCOUNT
                  FOR
                SUPPORT
            3    TFA   72    F  9  00
                                                          ACTMT>
                                                BITE/SPILL

                                                 DENT.
          USE ACTIVITY CODE "A" POR TECHNICAL COSTS PORTION OP PROGRAM
NON^TTE
6^fc^*j^%s^s^^ 1
3
TFA
72
F
A
00
           o

           o
TECHNICAL
 SUPPORT

8TH DIGIT
                          APPN.
                          YEAR
                              AUXKV
                                          CODE
t
TE/BPlU

BENT.
           REPRESENTS ACTIVITY CODE.
9TR AND 10 DIGIT REPRESENTS SITE NUMBER.  POR ADMINISTRATIVE
OR TECHNICAL CLEANUP, USE "00" SITE, UNLESS THE ACTIVITY CAN
BE TRACED TO A SITE SPECIFIC S8ID.

CONTACT THE SUPERFUND ACCOUNTING BRANCH IN FMD AT
(202) 260-9268.

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                                                                     ATTACHMENT III


                 GUIDE TO PROGRAM MANAGEMENT COST ALLOCATIONS
     The purpose of this guide is to assist th« Regional COs and POs in evaluating
the program management costs for segregation into administrative or technical
cate ories.

     Currently, program management costs are tracked and report   on the
basis of an aggregate amount.  Zn order to improve the tracking   eporting and
analysis of these costs, program management costs will be segre.  ed into
administrative and technical cleanup costs.

     To assist in improving the tracking and monitoring of these costs, the
following definitions have been developed to segregate the program manage-
ment costs into administrative and technical activitiee.  Examples cannot be
provided for every program management cost you may encounter, however, the following
may assist in your determination.

     A. Administrative Support Costs are non-site-specific costs necessary for
managing the overall contract regardless of the amount of specific site work.  The
following are examples of administrative support costsi

            Contract Mobilization (development of field equipment needs and
            inventory control guidelines)

            Personnel Management

            Preparation of Monthly Reports (Progress and Financial)
            (The compilation of site-specific progress and financial
            data should be charged site-specifically)

            Meetings (concerning contract operations)

            Financial Accounting Activities

            Invoicing/Voucher Preparation

            Computer Support

            Updates to Management, Health and Safety, and Quality Assurance/Control
            Plans

            Routine Communication/Coordination between EPA/Contractor

            Audit Support

            Preparation of Contractor's Program Management Summary Evaluation
            Reports (SER)

            Team Subcontractor Management Activitiee (Pool subcontract management
            activities should be charged to remedial planning.)

            Maintenance of Corporate Conflict of Interest Plan and System Support

            Labor Standarde Compliance (Service Contract Act/Davis Bacon Act)

            Annual Contract Close-Out Activities

            Clerical Activity in Support of Administrative Functions

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                                         -2-


            Other Administrative Activities (library and other reference activities,
            annual allocation reporting, non-site-specific records retention
            activities, etc.)

      .     staffing - Bach contractor proposed staffing positions necessary to
            perform program management functions.  Specific staffing plans were
            negotiated prior to contract award.  The final approved staffing plans
            can be found in the Confirmation of Negotiations in the pro-award
            contract file.  These staffing positions are not part of the labor
            provided under the level of effort capacity of the contract; they are a
            unique labor pool available to provide specific program managtaent
            functions.  Since each of the contractors' staffing plaaa contain unique
            staff descriptions, the examples of staffing shown for administrative
            and technical cleanup are used only to indicate staff activities and not
            specific titles; they are not provided to indicate staffing patterns for
            any contract.  They are sample categories of disciplinary expertise and
            management oversight necessary for the contract operation.  However, any
            activities performed by the program management etaff for site specific
            activities should be charged to remedial planning activities.

            Examples of staffing that might be used to accomplish administrative
            activities aret

            Program Manager          Reports Manager
            Accountant               Subcontract Manager
            Contract Administrator   Secretary/Data Entry Clerk

     B. Technical Cleanup Costs are non-site-specific costs for technical
activities that cover multiple sites, and are related to the site-specific work
conducted under the contract.

     Most technical cleanup costs under program management are incurred as
a result of requirements from multiple sites.  Thus the amount of these costs
will vary with the number of sites assigned under the contract.

     Examples of technical cleanup activities are provided to assist in
determining which activities to include in the technical support category.
Again, this is not a definitive catalogue of these activities.

            Equipment/Warehouse Management (Including cost of equipment maintenance,
            calibration and inventory)

                         irning technical issues relevant to multiple work


            Health and Safety

            Quality Assurance/Quality Control

            Technical Guidance

            Pollution Liability Insurance (Site-specific PLI should be invoiced
            as a site-specific cost)

            Mobile Lab

            Training (Requires PO and CO approval)

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                                         -3-


            Limitation on Future Contracting

            Preliminary Conflict of Interest investigations for potential work
            assignments

            The following are examples of staffing that might be uaed to accomplish
            technical support aetivitieas

            Program Manager              Sample Coordinator
            QA Officer                   Analytical Coordinator
            Contracts Manager            Health and Safety Officer
            Equipment Manager            Clerical Support for these activities

            Health and safety, QA/QC and coordination of CLP/analytical services
            should be charged to site-specific activitiee when possible.

      C.  Activities Containing Components of Both Administrative and
            Technical Cleanup Costs

      The following activitiea may fall into both administrative and technical
categories depending on the nature of the activity!

            Subcontracting (e.g. Basic Ordering Agreements) - Any subcontracting
            activities that are not site specific will be classified as an
            administrative support coat.

            Standard Operating Procedures (SOP) which deal with overall contract
            adminiatration will be classified as an administrative support cost.
            SOPs developed for multiple site work will be classified as a non-site
            specific technical cleanup cost.


      Equipment/Travel/Other Direct Costs (ODC)/Clerical Support

            ODC, equipment, and travel pools for program management ehould be
            allocated between administrative support and technical cleanup areas for
            purposes of tracking the costs.

            In implementing the segregation of program management coeta, actual
            equipment costs will be classified as a technical cleanup cost.  Labor
            coats associated with the juatification and approval of equipment
            purehaaes will also be classified as a technical cleanup cost.  Travel
            and ODC coats can be either administrative or technical cleanup costs
            and ahould be monitored, analyzed and reported under each discrete
            element.

            Clerical support should similarly be eegregated by coat into the
            apecific element supported, either adminiatrative or technical cleanup.

      Site-Specific Program Management - Program management costs, both
administrative support and technical cleanup, may be site-specific in nature.
Site-apecific program management is alao called project management when the activity
is part of a site-epecific work plan.  Where auch costs can be associated with a
single site, they muet be included within the approved budget for the individual
work assignment.  Note that during contract negotiations contractors were encouraged
to maximise aita-apecific program managamert wherever auch costs could legitimately
be aaaociated with a aingle site.

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                             Guide to Program Management Cost Allocations
Cost Category
Administrative Support
Technical Cleanup
Other
Direct Labor
o Hours to support
preparation of monthly
progress reports (e.g.,
assembling input from
field personnel)
o invoicing  (e.g.,
time spent in
accounting, compiling
billing activities)
o  personnel Management
o  attending contract-
wide meetings
o  managing team
subcontractors
o  Maintenance of
corporate conflict of
interest plan and
system
o  Updating and
maintaining contract-
wide management, QA/QC
and Health and Safety
Plans, other SOPs
o Equipment
maintenance/-
warehouse
management
o  Hours billed to
train technical
personnel
o Maintenance of
mobile labs
o Hours billed by
safety officer
(e.g, guidance on
OSHA regs to site
managers)
o Hours billed in
technical
consultation
regarding
interpretation of
Agency requirements
on QA/QC,
analytical methods,
etc.
o Diligent effort
in procuring pollu-
tion liability
insurance for
entire contract
 o Clerical hours may
be directly allocable
to either
administrative or
technical support
(e.g., updating nn
equipment list is
technical, typing
monthly progress
reports is
administrative)
o Hours related to
site-specific IF >
requirements, sampling
procedures, QA/QC
plans, safety issues
and subcontracting
should not be billed to
PM but rather to the
site.
o Diligent effort for
site-specific Pr +
indemnification request
should be billed site-
specifically and mot
                                                                    o  Preparation of site-
                                                                    specific progress
                                                                    reports should be
                                                                    billed site-
                                                                    specifically and
                                                                    information should be
                                                                    used in summary
                                                                    reports.	

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Cost Category
Administrative Support
Technical Cleanup
Other
Indirect Costs
o Contract specific
established rate (other
than GtA)	
o Contract specific
established rate
(other than GfcA)
General and
Administrative
o Contract specific
established rate
o Contract specific
established rate
Other Direct Costs
o computer tine
o office supplies
o courier service
o Mobile lab
utility costs when
lab is idle.
o general office
equipnent for sites
should be billed site-
specifically

o when mobile lab is in
use utility costs
should be charged site
specifically.	
Pollution Liability
Insurance
                         o cost of contract-
                         wide or multi-site
                         policy
                     o cost of site-specific
                     policies should be
                     billed site-
                     specifically
Travel
o Travel related to
general management of
entire contract
o Sending a
technical
specialist to a
conference (with
EPA permission)
o travel by specialist
to an individual site
should be billed site-
specifically

o travel to present
material on individual
site at a conference
(with EPA permission)

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Cost Category
Administrative Support
Technical Cleanup
Other
Equipment
o General office
equipment for personnel
o special equipment
for site operations
o individual equipment
pieces leased or
purchased due to a
unique site-specific
requirement should be
billed site-
specifically	
Lab Services
                         o Purchase of
                         standards/methods,
                         lab maintenance and
                         calibration with
                         contractor-
                         owned/managed lab
                     o contracts with
                     laboratories should be
                     billed site-
                     specifically
Mobile Lab Costs
                         o Utility costs,
                         maintenance etc.
                         associated with
                         labs
Team Subcontractors
o Fees, invoices and
management of team subs
o Team sub experts
consulted for
multi-site support
o Other costs related
directly to management
of a specific site
should be billed to the
individual site
Other Subcontractor
o Fees, invoices and
management of subs to
primes
o Sub experts
consulted for
multi-site support
o Other subs procured
to support site
specific activities
should be billed to
individual site.
Baee Fee
o Contract specific
established %
o Contract specific
established %
o calculated as %
across all categories
      Pee
o Fee earned on admin-
iatrative support work
o Fee earned on
technical work

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