Key Points
WSDOT Internal Audit Office overview
The WSDOT Internal Audit Office provides a variety of services to management including audit, consulting, and investigations. Our audits focus on internal agency activities as well as agreements with external service providers, including consultants.
The WSDOT Internal Audit Office has developed this FAQ in an effort to provide the consultants that are working with WSDOT with resources to understand the WSDOT audit process.
In this FAQ, we are providing guidance and tools to assist the consulting firms in developing overhead rates, understand and prepare for an Overhead Audit or Desk Review, and to improve consistency in the documentation that is provided to the Internal Audit Office. The information provided should help firms to develop an understanding of the treatment of various overhead cost items, and assist with determining which costs are allowable and which are unallowable.
The information in this FAQ was provided as a response to several inquiries from Consulting Firms.
1. What is the difference between an Overhead Audit and an Overhead Desk Review?
Overhead Audit
The Internal Audit Office conducts agreement compliance audits, which may include an audit of the firm’s overhead schedule for the most recent fiscal year end. These audits are performed on site at the consulting firm’s place of business, and are performed in greater detail than overhead desk reviews. Amounts on the overhead schedule are traced to the consultant’s source documents to determine reasonableness, allowability, and allocability. At the conclusion of our fieldwork, the audited rate is issued with a cover letter. See example of
Audited Overhead Rate Letter (pdf, 16kb).
Overhead Desk Review
Overhead Desk Reviews are an independent and objective service that we provide to assist WSDOT Management in the negotiation process. With the cooperation of the consulting firm, Desk Reviews are intended to be a quick process to provide a high-level review of the proposed overhead rate.
A Desk Review of an overhead schedule is completed in the WSDOT Internal Audit Office, with no visit to the consulting firm. This is an interactive process based on information provided by the consulting firm. We rely on data and information provided by the consultant to determine allowability of overhead costs, and if the overhead costs appear to be reasonably stated. At the end of each Desk Review, we issue a letter with the reviewed overhead rate. The letter notes that the overhead rate is still subject to WSDOT audit. See example of
Reviewed Overhead Rate Letter (pdf, 14kb).
If your firm has an audited overhead rate from a CPA firm, a Federal agency, or from another State Agency please provide a copy of the entire report to our office for consideration during our Overhead Desk Review.
2. What Documents are Needed for a Desk Review?
When we perform a Desk Review of a firm’s overhead rate, we request the following documents from the firm to help us perform the review:
- Overhead Schedule in our Standard WSDOT Format
The firm’s overhead schedule should be provided to the Internal Audit Office by email, in an Excel-compatible attachment – please do not provide your schedule in pdf format.
The overhead schedule should be in the WSDOT Standard Format. See attached example of the WSDOT format (xlsx, 33kb). The accounts and their respective amounts on the overhead schedule are from the firm’s financial statements for the associated fiscal year (typically we look at the most recently completed fiscal year), and should also tie to the firm’s general ledger. The overhead schedule will include adjustments for all unallowable costs, and these adjustments should be referenced with appropriate footnote designations with the reason for the adjustment.
Note: For your firm’s overhead schedule, the account titles and dollar amounts will be different for each firm. Those are taken directly from your financial statements & general ledger summary reports. The attached sample overhead schedule is just an example of one firm’s schedule.
- Copy of Financial Statements
Financial Statements include the detailed Profit & Loss Statement (pdf, 24kb), and the detailed Balance Sheet (pdf, 104kb). If your financial statements have been reviewed or audited by a CPA firm, please provide a copy of the completed review or audit report.
- Cost Disclosure Questionnaire
Answers to the Cost Disclosure Questionnaire (CDQ) (pdf, 171kb) provide us with basic but essential information as we approach the Overhead Desk Review. We encourage the firms to complete the questions fully and return to the Internal Audit Office with your overhead schedule.
We have found this questionnaire to be a real time saver for the firm as well as for the Internal Audit Office in the Desk Review process. The firms are encouraged to reply to the Cost Disclosure Questionnaire as soon as possible during our Review and to call our audit staff with any questions or concerns.
3. What timeframe can I expect for completion of the desk review process?
Overhead Desk Review – Tracking & Workload Management
WSDOT Management contacts our office when an overhead rate is needed for an A/E firm. We then contact the firm, and request the firm’s last completed fiscal year’s overhead schedule and related documentation for a desk review. The firm is given up to two months to provide all the requested documentation needed to begin the desk review. We will do our best to contact firms by phone and/or email to obtain the information we need. However, if the requested documentation has not been provided to our office within this time frame, we will need to remove the firm from our overhead queue. We will send the firm a letter notifying them that their overhead has been removed from our queue. We will typically reinstate the firm at the bottom of the queue if an overhead rate is later needed, and if all of the required information is provided at that time. This process allows us to focus our efforts on consultants that do submit the documentation as requested. At any given time, we typically have a queue of firms going through our office for a desk review.
Only after all of the necessary documentation has been received will the desk review be assigned to Audit Staff. During the review process, we request that an employee who is knowledgeable about the overhead schedule components be available to answer follow up questions and provide additional documentation as needed.
Overhead desk reviews are a service that we provide to assist WSDOT management in the negotiation process, and audit staff have a budget and timeframe for each desk review. If a firm becomes unresponsive at any time during this process, we will contact the firm by email or by phone to discuss the delay. Unexplained delays will result in our office concluding the review without issuing an overhead rate for your firm. (Two weeks with no response from the firm is considered “unresponsive”, and will result in the conclusion of the process, unless previous arrangements have been made with the audit staff assigned to the reviews.)
We consider “good faith efforts” to maintain the forward movement of the process and communication by the firm with the assigned auditor, as being responsive, so this would not affect the firm’s status in our work queue.
4. What Resources Are Available To Help Prepare for an Overhead Audit or Desk Review?
The following resources are available to the firm to help with developing its overhead rate. These are meant to help communicate the rules, regulations, and policies used by WSDOT management to assist firms as they develop their overhead rates and document their supporting records:
5. What is the Resolution Process for a Desk Review?
If you have questions or comments in regard to your overhead desk review during the process, please phone the Auditor that is currently working with you on your schedule. If you have questions or comments after the desk review is completed – please contact Martha Roach. If you still have questions or comments after speaking with Martha, feel free to contact Jeri Sivertson or Steve McKerney. The contact information is provided on this website.
Another option available to you aside from WSDOT relying solely on the completed desk review of your overhead schedule, would be for your firm to obtain a CPA Audit of your overhead, according to guidelines in the 2010 edition of the AASHTO Audit Guide. Your firm would be responsible for the cost of this service. The Internal Audit Office would reserve the right to review and accept the CPA workpapers. We do encourage the CPA firms to contact the Internal Audit Office before they begin their work, in regard to their approach to the overhead audit.
6. Effective date of 2010 Edition of AASHTO Audit Guide
Updated May 2012 – National Compensation Matrix Available
The criteria in the 2010 AASHTO Audit Guide will apply to your overhead for FYE December 31, 2010 (and all subsequent years). Please review the guide and become familiar with the requirements.
Chapter 7 of the Guide includes a new requirement for all firms to provide a Compensation Analysis on an annual basis when submitting your overhead schedules to the Internal Audit Office. Chapter 7 of the Guide also includes clarifications for the rules regarding Bonus in 48 CFR 31.205-6 (f).
The National Compensation Matrix (NCM), as mentioned in Chapter 7, is currently available for use on the AASHTO website (as of May, 2012). http://audit.transportation.org/Pages/default.aspx
The NCM is an interactive tool that establishes compensation amounts presumed reasonable for certain executive positions. A/E firms now have a choice of using the NCM to prepare an alternative analysis of compensation, or they may prepare the Compensation Analysis using National Surveys, per the steps listed in Chapter 7.5-C, and we will review it.
If your firm chooses to use the NCM, please read the Instructions and the Q&A first. (also found on the same AASHTO link above.)
As a reminder, all overhead schedules and/or CPA Audits must be sent to the Internal Audit Office for our review on a yearly basis.
This information is important for WSDOT to apply the guidelines in the 2010 AASHTO Audit Guide.The Internal Audit Office is continuing updates to our policies & procedures. Please check this website regularly for more information.
7. Does everyone need to keep timesheets?
Yes, we require that all employees track all hours worked on a timesheet. This requirement includes exempt employees, owners, and principals. Hours worked by exempt employees in excess of the standard 40 hours in a week, or in excess of 2,080 hours in a year, must be tracked on timesheets. This includes hours worked by exempt employees, but not compensated (this is uncompensated overtime). Your uncompensated overtime hours must also be included in your overhead schedule.
The elements of a timesheet are:
- employee name
- dates applicable to timesheet
- a space for the employee & the supervisor to sign
- There should be sections to record any sick, vacation, holiday, or overtime hours.
- There should be a job description section to what the employee worked on – project coding, marketing coding, or admin hours.
- Having the employee’s work schedule recorded on the timesheet is helpful. (for example – Monday – Friday, 8 am to 5 pm)
If your firm uses an electronic timesheet process, there is a lot of helpful information in the 2010 edition of the AASHTO Audit Guide. (See Chapter 6 of the Guide. This Chapter discusses manual timesheets as well as electronic.)
The consultant must have procedures covering the consistent recording & accounting for all hours worked, whether paid or unpaid, to ensure the proper distribution of labor costs. See DCAA Audit Manual 5-910 and 6-410 for further information. The 2010 AASHTO Audit Guide, Chapter 6, has a lot of useful guidance related to Labor Charging. (The links to the DCAA Manual and AASHTO Audit Guide are provided above – see FAQ Question #3 – Available Resources.) Uncompensated/Overtime Worksheet (pdf, 31kb)
8. Consultant Certification of Indirect Costs
Background on New FHWA Order
The Federal Highways Administration (FHWA) has implemented a new policy – FHWA Order 4470.1A requiring consultants to provide a Certification of Final Indirect Costs for compliance with federal cost principles.
WSDOT has incorporated this Order into our procedures for A&E procurement, and for our audit/review of A&E overhead rates.
Requirements of the New FHWA Order
The FHWA Order requires consultants for engineering and design-related services certify that costs used to establish indirect cost rates are in accordance with the applicable cost principles contained in the Federal Acquisition Regulations (FAR) 48 CFR, part 31.
Prime and subconsultants are required to submit the Certification along with the consulting firm’s Overhead Schedule and related materials to the WSDOT Internal Audit Office for review, before the agreement can be executed and before services may begin. The Certification should be submitted when providing the annual Overhead Schedule for review or when submitting an Overhead Schedule to WSDOT for its first agreement. The Certification should also be provided for renewals or revisions of rates effective immediately.
The FHWA Order applies to:
- Indirect cost rate proposals by the prime consultant and any subconsultants to provide engineering and design-related services
- New Agreements with WSDOT to provide engineering and design-related services
- Requests to revise rates under existing agreements for engineering and design-related services
- All prime & sub agreements for engineering and design-related services that are funded in whole or in part with FAHP funds, and directly related to an ultimate highway construction project (as specified in 23 U.S.C. §112(a)).
Relevant Links and Contact Information
FHWA’s Order 4470.1A is available in its entirety at the following link. Please see the complete Order for responsibilities and consequences http://www.fhwa.dot.gov/legsregs/directives/orders/44701a.htm
The Certification of Final Indirect Cost form can be accessed here.
This new requirement is effective January 25, 2011.
Posted to the WSDOT Internal Audit FAQ site on January 25, 2011
If you have questions, please phone the WSDOT Internal Audit Office at 360-705-7003.
The Internal Office plans to issue future FAQ’s on related topics.
[1] Training and guidance from AASHTO & FHWA in regard to the applicability of this guide is as follows:
“Most of the information in the Uniform Audit & Accounting Guide provides additional clarification and guidance in regard to federal regulations and auditing standards that are already in place and effective. Therefore, those regulations and standards should already be followed. One item in the Guide that is new is the National Compensation Matrix (NCM). The NCM is a recommendation from the Audit Guide Task Force to the Federal Highway Administration and, as such, it does not currently exist.”