The current approved
indirect cost rate methodology allows for the full total expenditures of
regular purchased service contracts to be used in calculating and applying
indirect cost rates. Further, only the first $30,000 of expenditures of
purchased services deemed subawards are to be used in calculating and applying
indirect cost rates.
Therefore, each school
district, open-enrollment charter school, and educational service cooperative
must submit a list of all subawards to the ADE Federal Finance Unit each
year. ADE will exclude expenditures above $30,000 for each of these
identified items from its process when calculating the indirect cost rates for
the LEA. This list should match what the district excluded when
applying the 2020-21 indirect cost rate.
The difference between a
regular purchased service contract and a subaward is found in the level of
administrative work required by the LEA when executing the arrangement. A
subaward requires little to no administrative effort by the LEA. A
regular purchased service requires more administrative effort by the LEA.
An actual subaward would resemble an independent contractor arrangement, where
an outside vendor works autonomously to complete the tasks assigned them by the
agreement with the LEA. Additionally, to be a subaward, the contract
should involve specific program objectives, not an organization-wide support
function, and not provide an auxiliary service normally provided in-house.
ADE has assembled some
written guidance from USDE Indirect Cost Group and attached to this memo as
“Subaward Guidance” in an effort to assist LEAs in making this distinction
within their expenditure data. Also attached is a short list of
“Subaward/Non-Subaward Examples” that are being compiled as new instances are
reported. While these are basic guidelines, determining what
constitutes a subaward is subjective and will differ from district to district.
ADE Federal Finance is
now beginning work on 2022-2023 indirect cost rates. These rates will be
based on expenditures from fiscal year 2020-2021. The LEAs must provide
ADE Federal Finance with the subaward data contained in the 2020-21
expenditures for consideration in these rate calculations. The “Schedule
of Subcontracts/Subawards” form is available at https://dese.ade.arkansas.gov/Offices/fiscal-and-administrative-services/school-funding/indirect-cost
The form must be received from every school district, educational
cooperative, and open-enrollment charter school.
ADE Federal Finance will
provide as much assistance as possible to districts working to identify
subawards. If specific situations require case-by-case examination, the
LEA is encouraged to contact the unit directly.
Completing the form:
- Select name from dropdown list at the top of the form
- Confirm the fiscal year of expenditures being reported on the third line
- Fill in information required in the first six columns, one line for each individual purchased service contract determined to be a subaward with expenditures over $30,000 in the year
- If no subawards are active in the expenditure data for the year, check the box indicating the LEA has no subawards
Return to ADE Federal
Finance by December 17, 2021
Email excel form to: email@example.com or firstname.lastname@example.org