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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 10 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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** ------- 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. ------- "^^ 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. ------- 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 ------- -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) ------- -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. ------- 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. ------- 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) ------- 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 ------- |