ML20059H317

Request for OMB Review & Supporting Statement Re Billing Instructions for NRC Cost Type Contracts

ML20059H317
Person / Time
Issue date:	09/06/1990
From:	Norry P NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
OMB-3150-0109, OMB-3150-109, NUDOCS 9009170106
Download: ML20059H317 (14)

Text

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.g tk '- OMB SUPPORTING STATEPENT FOR BILLING INSTRUCT 10tlS FOR NRC COST TYPE 'ONTRACTS Description of the Information. Collection The HRC Division of Contracts, in administering.its contracts to ensure 0 that contractor costs billed for payment are proper, provides Billing -Instructions for its contractors to fc110w in their preparation of invoices. These instructions stipulate the level of detail in which supporting cost data must be submitted for NRC review of costs billed. Included with the instructions is a voucher / invoice format sample for contractor's reference. Submittal of the NRC Forms 416 and 418A are no longer reouired. The contractor may submit a voucher / invoice in alternate formats provided all requirements of the billing instructions are addressed. A. JUSTIFICATION 1. Need for the Collection of Information. The cost information is needed to perform the necessary contract 6dministration required to assure that costs incurred are allowable'and allecable and that the amount requested is proper for payment. 2. Agency Use of Information. Vouchers and supporting documentation are reviewed by the Division of Accounting and Fina1ce, the Division of Contracts and Property Management and tie Project Officer. Taken together, the review insures that costs are billed per the contract rates and the costs incurred are commensurate with work performance. The instructions provide Contractors with a clear idea of the level of detail required to support their voucher T submissions. Receipt of properly prepared vouchers expedites the review process and permits prompt payment. 2. Reduction of Burden.Throuah Information Technoloay. There are no legal obstacles to reducing the burden associateo with this information collection assuming that sensitive inf ormation can be protected ' rom improper disclosure. NRC encourages its use. e, 4. Effort to Identify Duplication. The Billing Instructions for NRC-Cost Type Coni.racts and use of a sample voucher / invoice format for collection of information is unique to NRC. The Information Requirements Control Automated System (IRCAS) was searched and no duplication was found. f 8 h' j

Q [EE.. ) ,7 py<- 5. Effort to Use similar Information. Costs-incurred are unique to S the contract and the billing per15d for which payment is a - requested. Information in the cost detail is not otherwise .available. g 6. Effort to Reduce.Smali Dusiness Burden. The collection J represents the minimum information required for submission of a proper voucher and supporting detail required for review to assure that costs billed are proper for payment. The buroen cannot be reduced. 7. Consecuences of Less Frequent Collection.- Contractort are required to complete and submit invoices in an original and three copies once each month unless otherwise authorized by the Contracting Officer. The consequence of less frequent collection' would be withholding o? reimbursement to the contractor of costs incurred as the work progresses counter to the provisior.s of FAR but (except for small business concerns).aent be made upon request Clause 52.216-7, which requires that pa not more often than once every two weeks. 8. Circumstances Which Justify Variation From OMB Guioelines. The requirement is inconsistent with the guioeline in 5 7R T320.6(a). l The justification for more frequent submission is as set forth below; e ine voucher / invoice review procedure described below ensures that i payment is made to the contractor promptly upon receipt of e properly approved invoice or within 30 calendar days of the official agency receipt date, whichever is earlier. This procedure ensures compliarce w;th the requirements of the Prompt Payment Act. as amended. Due to shortened turnaround time caused by the Prompt Payment Act. there is not sufficient time required to xerox the voluminous number of vouchers / invoices. The agency-designated billing office has oeen changed from the Division of Accounting and Fin 6nce to the Division of Contract and Property Management (DCPN) for receipt of the original and three copies of the centractor request for payment L. (voucher / invoice). This change was made to recuce unnecessary 'q delay in the payment process. The payment process begins once DCPM ^ receives a proper invoice. DCPM forwards two copies to the project-officer for review and approval, who retains one copy and returns one copy to DCPM. DCPM holds the original voucher / invoice and one copy. Upon receipt of the project officer's signed copy, the original voucher / invoice and one signed copy is forwarded to the ? Division of Accounting and Finance (DAF) for final processing. L DCPM retains or.e copy as a suspense copy until DAF pays the voucher / invoice. 9. Consultations Outside the NRC. None. ~ l '. x. =

y w,;Ma. k l 3 4.- -l W g y i s 10.Coifidentialityof.Information. NRC provides to pledge of -conficentiality for this collection of inforr.ation. To the extent 'i .information is business confidential, procedures cre in place to

l protect the information from improper disclosure.

1' A1. Justification for Sensitive Ouestions. NorinC1;' sensitive j infor1 nation considered private or personal is t.ot required or 'l requested. This information is only required wl'en contracts are' l processed which involve sensitive material.- I

12. Estimated Annualized Cost to the Federal Governnwnt. The cost to the agency for these B1Tling Instructions was deGd from i

experience as to the approximate number of hourt contract specialists, program and paying office personnel expend in ensuring that contractors comply with the instructions. Full implemen ;stion of the Prompt Payment Act has necessitated ar increase in the number of hours required for proper voucher / invoice review, Contract Procram and paying office personnel expend an,averale of i 1 hour per response for a total cost of $184,368 (12 responses x .i 167 respondents x $92/hr).

13. Estimate of Burden. The annual contractor burden for the Billing Instructions for hRC cost type contracts is estimateri to be 1,002 hours. The burden estimate was derived from ex)erierce as to the approximate number of contractors affected by tie Billing

-Instructions for cost type contracts and the approximate number of hours eacn contractor would have to expend to comply with the NRC 1 requirements of the form (167 respondents y 12 responses per year x..5hrperresponse). j t

14. Reasons for Change in Purden. There is a change in the estiniated burden because of a different trethoo of calculation used as a basis for the previous Request for CM6 Review estimates. The previous.

submission included burden estimates for Grants, and Cooperative Agreernents which are covered under the clearance for the Standard Form 270, " Request for Advance of Reittursement." Burden estimates for Time and Materials contracts are covered under the clearance for the Standard For.n 1034, "Public Voucher for Purchases and l Services Other Than Perscnal."

15. Publication for Stetistical Use. Results will not be tabulated or publisheo.

I 'L B. COLLECTIONS OF INFORMATI0N EMPLOYING STATISTICAL METiiODS This collectica of informatrm does not employ statistical methods, i m

a 77 o r.3 w

f REVISED 8/89 I

BILLING INSTRUCTIONS FOR COST-REIMBURSEMENT TYPE CONTRACTS General: The contractor shall prepare vouchers / invoices for reimbursement of costs in the manner and format described h'erein. A sample f" voucher / invoice is provided for your reference. FAILURE TO SUBMIT VOUCHERS / INVOICES IN ACCORDANCE WITH THESE INSTRUCTIONS WILL RESULT IN REJECTION OF the VOUCHER / INVOICE AS IMPROPER. Number of Copies: An original and three copies, including supporting documentation shall be submitted. A copy of all supportiny documents m.st be attached to each copy of your voucher / invoice, Failure to submit all the. required copies will result in rejection of the voucher / invoice as improper. Desianated Aaeney Billina Office: Vouchers / invoices shall be submitted to the following address: U. S. Nuclear Regulatory Conission Division of-Contracts and Property Management Contract-Administration Branch, P-902 Washington, D.C. 20555 HAND DELIVERY OF VOUCHERS / INVOICES IS DISCOURAGED AND WIll NOT EXPEDITE PROCESSING BY NRC. However, should you choose to deliver vouchers / invoices by hand, including delivery by any express mail servit.ws or special . delivery services which use a courier or other person.to deliver the voucher / invoice in person to the NRC, such vouchers / invoices must be addressed to the above Designated Agency Billing Office and will only be accepted at the following location: U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Room Rockville, Maryland 20852 HAND-CARRIED SUBMISSIONS WIll NOT BE ACCEPTED AT OTHER THAN THE ABOVE ADDRESS. Note that the official receipt date for hand-delivered vouchers / invoices will be the date it is received by the official agency billing office in c the Division of Contracts and Property Management. Aaency Payment Office: Payment will continue to be made by the office designated in the contract in Block 13 of SF 26 or Block 25 of SF 33, whichever is applicable.

<, - M ;;;;r - 1 ff \\ [ 2 REVISED 8/89 j i Freauency: The contractor shall submit claims for reimbursement once each month, unless otherwise authorized by the Contracting Officer. l Form: Claims should be submitted in the format depicted on the attached i sample form entitled " Voucher for Purchases and Services Other than' Personal." The sample-form is provided for guidance only. The form is not ^, required for submission of a voucher / invoice. Alternate formats are permissible provided all requirements of the billing instructions are-l addressed. Additional copies of the form are available from the Contracting Officer. The instructions for preparation and itemization of the voucher / invoice.sre included with the sample form. Task Orderina Contracts: If the contractor bills for more than one task order under a voucher / invoice, detailed cost information for each

individual task order shall be. submitted, together with a cumulative i

- summary of all charges billed on the voucher / invoice. This includes all applicable cost einments discussed in paragraphs'(a) through (p) of the attached instructions, together with appropriate supporting it formattor. I Billina of Cost After Expiration of Contract: If costs are. incurred i during the contract period and claimed after the contract has expired,.the period during which these costs were incurred must be. cited. To be considered a proper expiration voucher / invoice, contractor shall clearly mark it " EXPIRATION VOUCHER" or " EXPIRATION INVOICE." ? Final vouchers / invoices shall be marked " FINAL VOUCHER" or " FINAL INVOICE." I Currency: Billings may be expressed in the currency normally used by the contractor in maintaining his accounting records; payments vill be made in that currency. However, the U. S. dollar equivalent for all vouchers / invoices paid under the contract may not exceed the total U. S. ' [ dollars authorized in the contract, i lupersession: These instructions supersede any p-evious billing instructions. I o 6 i

72Wi. ~ ,a am., f ( a 1 REVISED 8/89 Page 1 INSTRUCTIONS FOR PREPARING COST INFORMATION FOR NRC CONTRACTS i .i Preparation and Itemization of the Voucher / Invoice: -In order to constitute a proper invoice, the contractor shall furnish all the information set forth below. These notes are keyed to the entries.on the sample l voucher / invoice. t Official Agency Billing Office: Address the original.and 3 copies of.the voucher / invoice, together with supporting documentation attached to each copy to: U. S. Nuclear Regulatory Commission, Division of Contracts and Property Management, P-902, Washington, D. C. 20555. Vouchers / invoices delivered by hand, including delivery by an express. mail services or.special delivery services which use a courier or other person i to deliver the voucher / invoice in person to the NRC, should be addressed in accordance with the foregoing and delivered to: U. S. Nuclear Regulatory Commission,0ne White Flint North,11555 Rockville Pike, Rockville, Maryland 20852. Hand-delivered vouchers / invoices will not be accepted at i other then the above address. Note, however, that the official receipt date for hand-delivered vouchers / invoices will be the date it is received. i by the official agency billing office in the Division of Contracts and l 3 Property Management. Payee's name and address. Show the name of the contractor as it appears in the contract and its correct address. When an approved assignment has been made by the contractor, or a different payee or addressee has been designated, insert the name and address of the payee. Indhate the name and telephone number of the individual responsib.e.or answering any questions that the NRC may have regarding the invoice. (a) Contract Number. Insert the NRC contract number ] Task Order Number, if applicable. Insert the task order number. (b) Title of Project, l.ist the full title of the project being performed l under.the contract. j (c) Sequential voucher / invoice number. The appropriate sequential number of the voucher / invoice, beginning with 001 should be designated. r Contractors may also include individual internal accounting numbers, if desired, in addition to the 3-digit sequential number. (d) Project Officer's name as designated in the contract. (e) Date of voucher /inv> Ace. Insert the date the voucher / invoice is prepared. (f) Contract Amount. Insert the total estimated cost of the contract, exclusive of fixed-fee. Include this information as it applies to individual task orders as well.

w. T 9 l ,( = i 3 j 2 REVISED 8/89 s i +, (g) Fixed-Fee. Insert total fixed-fee. Include this information as it applies to individual task orders as well. 1 (h) Billing Period. Insert the beginning and ending dates (day, month, j year)'of.the period during which costs were incurred and for which reimbursement is claimed. j (1) Direct Costs. Insert the major cost elements: (1) Direct Labor. This consists of talaries and wages paid (or accrued) for direct performance of the contract itemized as. follows: i " Labor Labor Hrs. Hours Cumulative 1 Category. Negotiated Billed Rate Total Hou s Billed (2) Fringe Benefits. This represents fringe benefits a',plicable to direct labor and billed as a direct cost. %nere a rate:is.used, indicate the rate. Fringe benefits incl.,ded in direct labor or in other indirect cost pools should no'. be identified here, t (3) Direct Equipment. For educational institutions, list each item costing $500.00 or more and having a life expectancy of more than one year.- For contractors other than educational institutions, list each item costing $200.00 or more and having a life expectancy of more than one year. List only those items of equipment for which reimbursement is requested. A reference. 1 shall be made to the following (as applicable): (a). the item number for the specific piece of equipment listed in the property schedule of the contract; (b) the Contracting Officer's approval letter if the equipment is not covered by the property schedule; or (c) be preceded by an asterisk (*) if the equipment is below the approval level. Further i itemization of vouchers / invoices shall only be required for items having specific limitations set forth in the contract. + (4) Materials, Supplies, or Other Expendable Items. These are consumable materials, supplies, and equipment other than that described in (3) above. (5) Premium Pay. This is remuneration in excess of the basic -{ hourly rate. (Requires written approval of the Contracting Officer.) (6) Consultant's Fee. The supporting information must include the name, hourly or daily rate of the consultant, and reference t,he NRC. approval (if not specifically approved in the original contract). \\ - : ~*M j

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3 REVISED 8/89 (7) Travel. Domestic travel.is trave 1'within the United States, its m'

territories, possessions, and Canada; It.should be billed .y separately fros foreign travel. All costs associated with each trip must be shown in the following format: Date Traveler Destination Purpose Cost-From To From To (8) Subcontracts. Include separate detailed breakdown of all costs paid to approved subcontractors during the billing period. (9) Other. List all other direct costs by cost element and dollar amount separately. (j) Indirect Costs - Overhead. Cite' the formula (rate and base) in effect during the time the cost was= incurred and for which reimbursement is claimed. .(k) Fixed Fee. If the contract provides for a fixed fee, it must be claimed as provided for by the contract. Cite the formula or. method of computation..The contractor may bill for fixed fee only up to 85% of totai iv. U (1)' Amount Billed for Current Period. Insert the amount billed for the major cost elements, adjustments, and total amount for the period. (m) Cumulative Amount from Inception to Date of Current Billing. Insert the cumulative amunts billed for the major cost elements and adjusted amounts claimed during this contract. 1 (n) Total Amounts Claimad. Insert the total amounts claimed for the current and cumulative periods. (o) Adjustments. This includes cumulative amounts billed that have been suspended or disallowed. (p)' Grand Totals. i \\ l

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+ YOUCTERS FOR PURCHASES AND SERVICES OTHER THAN PERSONAL My SAMPLE VOUCHER i 1 y Official Acenev Billina Office (a) Contract Number U.S. Nuclear Regulatory Commission b Division of Contracts and Property . Task Order No. (if App licable) 7 ., Management. P-902 C. Washington, DC 20555 (b) Title of Project (h Paven't Name and Addrett x' n (c) Voucher Number - (d) Proje:t Officer Individual to Contact Regarding This. Voucher: (f) Contract Amount Name: Tel, No.: (g) Fixed Fee (h)' This voucher represents reimbursable costs from thru Amount Billed (1) Qpreent period (m) Inceotion to Date (i) Direct Costs (1) Qgg,c,tLator* (2) Fringe Benefits lf comouted as cercentsee (3) Capitalized Nonexpendable

Eeuioment *

(4 ', Materials. Supplies and Nonenoitalized Eouioment * ($) Premium Pav (6) Ro. nim!! ants * (7) Travel-Domestic ' Foreion * (8) Sybcontract * (9) Qther.. Costs.' Total Direct Costa s (j) INDIRECT COSTS f ~ -(A)~ Overhead % of 1 (indicate Base) Subtotal General & Administrative Expense (B) % of Cost Elements Nos. Total Costs (k) FIXED-FEE EARNED (Formula) (n)' Total Amount Claimed (o) Adjustments Outstanding Suspensions (p) ' Grand Totals '(REQUIRES SUPPORTING INFORMATION-SEE ATTACHED) t e \\

' "' m g ~ a u VOCERS FOR PURCHASES AND SEVICbS ODIER 'DIAN PR .c NRC-10-81-624 Official Agency Billing'Of t' ice: (a) Contract Number 7, Task Order No. (If Anp11 cable) 002 !!. S. Nuclear Regulatory Corm.ission Division of Contracts and Propertv (b) Title of Droject " Study _of Nuclear 3 Waste Concepts" Management, P-902 Washington, 0.C. 20555 003 Payee's Name and Addres; (c)-VoucherNumber ABC Corporation - The National Bant (d) Project Officer 100 Main Street or Anywhere, U.S.A. Anywhere, U.S.A. Assignee for ABC Corp. (e) Date of Voucher / Anywhere, U.S.A. ,(f) Contract Amount Indiv. dual to Contac(When Payments Assigned (9) Billing Period Regarding This voucher: Name:- Harry Murphy Tel. No.: Zld-Jd-bbb4 J 3/1/82 thru 3/30/82 This voucher represents reimbursable costs from ( h) Amount Billed (1) Current Period (m) Inception to Date_ 1 (L Ron ( i) Direct Costs 12,400 (1) : Of rect Labor

• l',200 je (2) fringe Denefits 910.b:,

6pn fif computed as peFc~eitece) (3) Capetalized reonexpencacic 5,000 8,000 touipment. 'l 6 (4) Raterials, Supplies anc 2,000 4,000 floncapitalized Couipment ' 150 _J 100 100 (5) Fremium Pav _ ~ 100 '/ 00 (6) Consultents

• 200 (7) Travel - Domestic
• a 200 forcion -

200 9,000 (8) Subcontract

• J,000 (9) Dther Costs -

+ (j) INDIRECT COSTS 10% of Total Direct _ Costs $13,600 $29,650 A) Overhead (Indicate Base) 527,200 $59,300 Subtotal Qeneral & Administrative Expense 3,264 6,450 B) 12 % of Cost Elements Nos.1-9. A $30,464 us J r,o Total Costs 1,523 3.400 { k) flXEO FEE EARNED (Formula) $69.150 $31,987 ( n) Total Amounts Claimed 1 1.700 (o) Adjustments 1,700 Outstanding Suspensions %7,450 $30.287 (p) Grand Totals ~

• (REQUIRES SUPPORTING inf 0RMAT!03. )

(SCE ATTACHE 0.)

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o SAMPLE l .h SUPPORTING INFORMATION i . /, l': i

1) Direct Labor - $2400 s

Labor Labor Hours Hours Cumulative. , Category Negotia ted Billed Rate Total' Hours Billed 1 Senior Engineer 1 2400 100 $14.00 $1400 975 ? ' Engir.<e r 1500 50 $10.00 $500 465 m- . Computer Analyst 700-100 $5.00 $500 ~ 320 INDT 1

3) Direct Equipment Spectrometer - General Electric (as appmved in Property Schedule) $5,000 4)' Materials, Supplies & Other Expendable items l

$1100.00 10 Radon Tubes 9 $110.00 = $900.00 6 Pairs Electrostatic Gloves,9 $150.00 = 52000.00

5) Premium Pay-Walter Murphy - 10 hours,@ 510.00 Per Hour = $100 (This was approved by NRC in letter dated 3/6/89.)

,6) Consul tr.nts ' Fee r ' Dr. Carney - 1 hour 9 $100 = $100 t

7) Travel

-Date-Traveler Destination Purpose Costs From g From H S 3/1/89 3/6/89 William King Chicago Wash., Meeting with $200 i Il DC Project Officer l b.^ -4h A e -~ -~n .sn.. ,.c ---.-,v,- ~-

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8) Subcontracts XYZ CORP.

(CPFF) - 80 h' urs 9 $20.00 per hour Direct Labor:- $1600.00 o = 0/H. 9 50% $800.00 = Travel - 2 Trips - Wash., DC 9 $200 .$400.00 = to Boston, MA Profit 9 75. $200.00 = < TOTAL: 53000.00 e (k) Fixed-Fee (Fomula) (5%)- $350,000 X 5% = $17.500 Total Fixed Fee for this Contract $27,200 X 5% = $1360 Fee Billed for this Period 1 (o) AJJustments .$1700.- Indicates amount withheld from voucher #001, now approved by Contracting i. Officer letter 3/10S9. I t 6 9

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