| MICC-FSH-19-0002 Q&As - Ft Riley ACUB - XX Mar 2019 | | |
| QUESTIONS (Submitted by 27 Feb 2019) | Army Answers |
| Questions | Ft Riley ACUB | |
| General Questions | |
| 1 | Page 8 : NR/Land Management Plan preparation: In order to secure matching funds with USDA NRCS ACEP, the land trust is required to develop a land management plan in order to complete a conservation easement. Are the associated land trust staff and travel expenses an allowable expense? | NR/Land Management expenses, including labor and travel, will not be authorized for reimbursement for the Fort Riley ACUB project as the Army does not need any regulatory relief due to natural resources on the installation. Exceptions to policy can be requested from HQ IMCOM-G4 on a case-by-case basis. |
| 2 | Page 9: Labor / Staff Hours - Items marked with an asterisk (*) are only authorized if they are included as part of the entity's indirect rate (i.e., the costs are equitably allocated to all related activities, including Federal awards): What does this mean? What is required for an entity to set up an indirect rate? Are there limits to an indirect rate? | This means to not charge certain types of labor as direct costs, but if these types of costs are paid from money received by applying the indirect rate, that is permissable. Indirect costs are those incurred for a commmon or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefittted, without effort disproportionate to the results achieved. For example, salaries of administrative and clerical staff, executive officers, and accounting. An indirect rate is negotiated with the Army Grants Officer. The partner will calculate the rate in accordance with Appendix IV (non-profit) or Appendix VII (state/local government) of 2 CFR 200. A partner may elect to charge a de minimis rate of 10% of modified total direct costs (MTDC) in lieu of calculating a rate. MTDC means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (2 CFR 200.68). See also 2 CFR 200.414. |
| 3 | Page 9: Endowment for Stewardship/Land Management: In order to cover the perpetual costs of monitoring a conservation easement and educating successor landowners, is a contribution to our land trust's stewardship fund/endowment an allowable expense? If the land trust calculates these monitoring and educational expenses using evidence-based projected expenses for these actions along with reasonable returns on investment, will this evidence be acceptable to justify this payment? Are there any limitations to this stewardship/land management expense? To get USDA NRCS ACEP matching funds, land management plans may be required. Can the projected perpetual costs for working with successor land owners on land management plans be calculated in the contributions to the Endowment for Stewardship/Land Management? | Yes, a contribution to the stewardship fund is an authorized expense to cover monitoring (see answer to question 4 below). This category of the AACG is specific to an endowment for actual land management (e.g. prescribed burning, thinning, planting, invasive species control, etc.). The Fort Riley ACUB project does not involve regulatory relief related to natural resources, therefore there is no need for the Army to pay for land management. As such, it will not be an expense authorized for reimbursement. If land management plans are only required by USDA, the funding will need to come from non-military sources. |
| 4 | Page 9: Monitoring (one-time fee): What is the difference between this and the above Endowment for Stewardship/Land Management? In order to cover the perpetual costs of monitoring a conservation easement and educating successor landowners, is a contribution to our land trust's stewardship fund an allowable expense? If the land trust calculates these monitoring and educational expenses using evidence-based projected costs for these monitoring/education actions along with reasonable returns on investment, will this evidence be acceptable to justify this payment? Are the 5% of the property interest acquisition cost or 20,000, whichever is less, negotiable? If the land trust provides evidence that this is inadequate to cover perpetual costs, can the land trust make an appeal for a higher payment? | The land management endowment is specifically for land management, as described above. A one time fee for monitoring can be invoiced at the time of closing. How the money is managed by the partner is up to them as long as it goes towards monitoring. If they have a "stewardship fund" established, the partner can add the monitoring fee to that. Yes, the land trust can make an appeal for higher payments with sufficient evidence-based justification that the 5% or $20k is insufficient. Each request will be evaluated by HQ IMCOM-G4. |
| Page 9: Labor - ACUB Program reporting: These report are a required task for a land trust. Are these expenses not an allowable expense? | Correct, labor for reporting is not authorized for reimbursement. This is a partnership and the partner is expected to contribute to project costs. The indirect rate helps cover a portion of labor costs associated with reporting/accounting/etc. |
| 5 | Page 9: Labor - Invoicing/Accounting: Accounting is a required task for a land trust. Are these expenses not an allowable expense? | Correct, labor for accounting is not authorized for reimbursement. This is a partnership and the partner is expected to contribute to project costs. The indirect rate helps cover a portion of labor costs associated with reporting/accounting/etc. |
| 6 | Page 9: Labor - Fringe Benefits: What are fringe benefits? Is salary an allowable expense? Are FICA expenses related to salary an allowable expense? | Fringe benefits are allowances and services provided by employers to their employees as compensation in addition to regular salaries and wages. Fringe benefits include, but are not limited to, the costs of leave (vacation, family-related, sick or military), employee insurance, pensions, and unemployment benefit plans (See 2 CFR 200.431). Cost of labor specific to executing the ACUB program project tasks are reimbursable (e.g. contacting landowners, negotiating with landowners, contracting and reviewing due diligence, meeting with the installation). |
| 7 | Page 9: Indirect Costs: Facilities: Is a reasonable prorated overhead charge for office rental an allowable expense? | No. Facilities rental is not authorized for reimbursement. |
| 8 | Page 9: Indirect Costs: Administration: Is a reasonable prorated overhead charge for support staff and administration an allowable expense? | Not as a direct charge. The indirect rate helps cover a portion of labor costs associated with administrative/support staff. |
| 9 | Page 10: Audit Services: Purchasing conservation easements often requires a "single audit"? A single audit is based upon a contractual fee for service. How does this relate to an entity's indirect rate? Can the single audit fee based upon the service fee be an allowable expense? | The cost of audits is not currently allowed, but is under consideration in an update to the AACG. |
| 10 | Page 10: Travel: If a land trust needs to conduct multiple visits to a prospective conservation easement to meet with the landowner, surveyor, environmental assessor, complete a baseline documentation report, and meet with the closing agent; will the land trust have to submit individual ground travel requests for each travel visit and then wait for a written pre-approval to make the necessary travel to conduct the required due diligence for a conservation easement? | No, the partner does not need to submit individual ground travel requests associated with normal ACUB operations (e.g. meeting with landowners, closing agents, installation, etc). Only overnight travel trips (not commonly required/approved) require written pre-approval from the installation. Meals, vehicle rental, and parking are not authorized for normal ACUB operations. If seeking reimbursement for privately owned vehicle mileage for normal ACUB operations, installation approval is required, but does not have to be on a per trip basis (e.g. it could be an agreed upon maximum monthly allowance). |
| 11 | Page 10: Mapping and/or GIS Products: Is an subscription service for ArcGIS an allowable expense? Are printing expenses for maps and baseline reports an allowable expense? | Yes. |
| 12 | Page 11: Outreach (includes individual landowner contacts, public meetings to promote the ACUB program or promote a successful project.): A land trust will need to make outreach communications to identify prospective landowners who are interested in a conservation easement. Are the communications, meetings, travel, and staff time for this outreach an allowable expense? | Yes, labor associated with communication with landowners, installation POCs, and other ACUB stakeholders while executing the ACUB program is authorized for reimbursement. Labor associated with other types of public outreach, e.g. county fairs, town halls, etc. is not authorized for reimbursement. |
| 13 | Page 11: Postage Shipping: Will a land trust be required to get prior approval for every postal mailing/shipping to a landowner, closing agent, appraiser, surveyor, environmental assessor, and installation? What is the process to acquire prior approval? | This is approved by the installation, but does not have to be on an each and every basis. Email requests and approvals suffice. |
| 14 | Page 11: Publication/Printing: Will a land trust be required to get prior approval for each printing of communications, easement documents, etc? What is the process to acquire prior approval? | This is approved by the installation, but does not necessarily have to be on an each and every basis. Email requests and approvals suffice. |
| 15 | Can an applicant talk to a representative with questions about allowable expenses and the process to get approval for expenses? | No, direct communication between applicants and technical review committee is not allowed as it could create an unfair advantage. |
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