Attachments 2-10.pdf

Contract No. RECORD OF

GOVERNMENT PROPERTY REPORT

Inventory Performance

Date -----------------------

Contractor ID # / Tag #

Description/ Manufacturer

Model/ Serial

*Acquisition Date

Date Received

*Acquisition Cost

*Acquisition Doc. # Location

*Superfund (Yes/No)

Disposition Date

Reason for Disposition

A89010 Computer/Dell Optiplex GX 280 6/6/2006 NY 18 Yes

A90230 Computer/Dell Optiplex GX 280 01/28/2009 NY 18 Yes

C07597 Computer/Dell Optiplex GX 620 09/29/2009 NY 18 Yes

C07596 Computer/Dell Optiplex GX 620 09/29/2009 NY 18 Yes

C07621 Computer/Dell Optiplex GX 620 09/30/2009 NY 18 Yes

S36660 Computer/Dell Optiplex GX 620 09/30/2009 NY 18 Yes

S36636 Computer/Dell Optiplex GX 620 09/30/2009 NY 18 Yes

C07537 Computer/Dell Optiplex GX 620 09/30/2009 NY 18 Yes

C07700 Computer/Dell Optiplex GX 620 09/30/2009 NY 18 Yes

C07513 Computer/Dell Optiplex GX 620 10/01/2009 NY 19 Yes

S23037 Computer/Dell Optiplex GX 620 10/02/2009 NY 18 Yes

C07514 Computer/Dell Optiplex GX 620 10/02/2009 NY 18 Yes

S36663 Computer/Dell Optiplex GX 620 10/6/2009 NY 18 Yes

S36688 Computer/Dell Optiplex GX 620 10/15/2009 NY 19 Yes

C07512 Computer/Dell Optiplex GX 620 10/27/2009 NY 18 Yes

C07531 Computer/Dell Optiplex GX 620 11/03/2009 NY 18 Yes

C07697 Computer/Dell Optiplex GX 620 04/29/2010 NY 18 Yes

S23202 Computer/Dell Optiplex GX 620 11/12/2010 NY 18 Yes

Contractor ID # / Tag #

Description/ Manufacturer Model/ Serial #

*Acquisition Date

Date Received

*Acquisition Cost

*Acquisition Doc. # Location

*Superfund (Yes/No)

Disposition Date

Reason for Disposition

A89020 Scanner/Fujitsu fi-4220C 6/6/2006 NY 18 Yes

None Map Cabinet/Mayline unknown 6/6/2006 $1,600.00 NY 18 Yes

None 2 Map Cabinets/Planhold unknown 6/6/2006 $1,000.00 NY 18 Yes

None Label printer/Dymo Label Writer 310 6/6/2006 NY 18 Yes

None Film Cabinet/JB Engineer. unknown 6/6/2006 $1,276.00 NY 18 Yes

None Film Cabinet/Fenco unknown 6/6/2006 $1,000.00 NY 18 Yes

None 4 two-tier carts unknown 6/6/2006 $700.00 NY 18 Yes

A55834 Printer/Hewlett Packard Laserjet 4250n 6/6/2006 NY 18 Yes

A01849 Printer/Hewlett Packard Laserjet 8000 6/6/2006 $2,000.00 NY 18 Yes

A30997 CD copier/Alera 1:3 Copy Tower 40 6/6/2006 NY 18 Yes

S37262 Scanner/HP Officejet Pro L7780 All in one 11/14/07 NY 18 Yes

942628 Microfiche reader/Canon Microprinter 90 11/28/07 NY 18 Yes

S37288 Printer/Hewlett Packard Laserjet 4250 01/18/08 NY 19 Yes

S37278 Printer/Hewlett Packard Laserjet 4250 1/29/2008 NY 18 Yes

A89690 Scanner/Fujitsu fi-5900C. 1/8/2009 NY 18 Yes

Contractor ID # / Tag # Description/ Manufacturer Model/ Serial #

*Acquisition Date

Date Received

*Acquisition Cost

*Acquisition Doc. # Location

*Superfund (Yes/No)

Disposition Date Reason for Disposition

None Copy Machine/Xerox Copycentre C75 unknown $17,517 Edison 205 Yes None None 986498 Fax Machine/Panasonic Panafax UF-755e 5/7/2001 $1,950 Edison 205 Yes None None None Microfiche Reader/Canon Microprinter 90 5/7/2001 $4,188 Edison 205 Yes None None 836639 Microfiche cabinet unknown 5/7/2001 $1,296 Edison 205 Yes None None 690033 Bookcase unknown 5/7/2001 $400 Edison 205 Yes None None 690027 Bookcase unknown 5/7/2001 $400 Edison 205 Yes None None 690063 Bookcase unknown 5/7/2001 $400 Edison 205 Yes None None S37320 Printer/Hewlett-Packard HP 4250 unknown unknown Edison 205 Yes None None S29671 Computer/Dell Optiplex GX620 8/4/2008 unknown Edison 205 Yes None None S29669 Computer/Dell Optiplex GX620 8/4/2008 unknown Edison 205 Yes None None S29670 Computer/Dell Optiplex GX620 8/4/2008 unknown Edison 205 Yes None None A89040 Scanner/Fujitsu M4099D VRS II 1/8/2009 unknown Edison 205 Yes None None A90037 Computer/Dell Optiplex GX 280 12/15/08 unknown Edison 205 Yes None None A90016 Computer/Dell Optiplex GX 280 02/18/09 unknown Edison 205 Yes None None S29659 Computer/Dell Optiplex GX620 05/19/09 unknown Edison 205 Yes None None S29653 Computer/Dell Optiplex GX620 01/29/10 unknown Edison 205 Yes None None

ATTACHMENT 3

INVOICE PREPARATION INSTRUCTIONS

SF 1034

The information which a contractor is required to submit in its Standard Form 1034 is set forth as follows:

(1) U.S. Department, Bureau, or establishment and locat ion - insert the names and address of the servicing finance office unless the contract specifically provides otherwise.

(2) Date Voucher Prepared - insert date on which the public voucher is prepared and submitted.

(3) Contract/Delivery Order Number and Date - insert the number and date of the contract and delivery order, if applicable, under which reimbursement is claimed.

(4) Requisition Number and Date - leave blank.

(5) Voucher Number - insert the appropriate serial number of the voucher. A separate series of consecutive numbers, beginning with Number 1, shall be used by the contractor for each new contract. When an original voucher was submitted, but not paid in full because of suspended costs, resubmission vouchers should be submitted in a separate invoice showing the original voucher number and designated with the letter "R" as the last character of the number. If there is more than one resubmission, use the appropriate suffix (R2, R3, etc.)

(6) Schedule Number; Paid By; Date Invoice Received - leave blank.

(7) Discount Terms - enter terms of discount, if applicable.

(8) Payee's Account Number - this space may be used by the contractor to record the account or job number(s) assigned to the contract or may be left blank.

(9) Payee's Name and Address - show the name of the contractor exactly as it appears in the contract and its correct address, except when an assignment has been made by the contractor, or the right to receive payment has been restricted, as in the case of an advance account. When the right to receive payment is restricted, the type of information to be shown in this space shall be furnished by the Contracting Officer.

(10) Shipped From; To; Weight Government B/L Number - insert for supply contracts.

(11) Date of Delivery or Service - show the month, day and year, beginning and ending dates of incurrence of costs claimed for reimbursement. Adjustments to costs for prior periods should identify the period applicable to their incurrence, e.g., revised provisional or final indirect cost rates, award fee, etc.

(12) Articles and Services - insert the following: "For detail, see Standard Form 1035 total amount claimed transferred from Page of Standard Form 1035." Type "COST REIMBURSABLE-PROVISIONAL PAYMENT" or "INDEFINITE QUANTITY/INDEFINITE DELIVERY-PROVISIONAL PAYMENT" on the Interim public vouchers. Type "COST REIMBURSABLE-COMPLETION VOUCHER" or "INDEFINITE QUANTITY/INDEFINITE DELIVERY-COMPLETION VOUCHER" on the Completion public voucher. Type "COST

REIMBURSABLE-FINAL VOUCHER" or "INDEFINITE QUANTITY/INDEFINITE DELIVERY-FINAL VOUCHER" on the Final public voucher. Type the following certification, signed by an authorized official, on the face of the Standard Form 1034.

"I certify that all payments requested are for appropriate purposes and in accordance with the agreements set forth in the contract."

(Name of Official) (Title)

(13) Quantity; Unit Price - insert for supply contracts.

(14) Amount - insert the amount claimed for the period indicated in (11) above.

INVOICE PREPARATION INSTRUCTIONS

SF 1035

The information which a contractor is required to submit in its Standard Form 1035 is set forth as

(1) U.S. Department, Bureau, or Establishment - insert the name and address of the servicing finance office.

(2) Voucher Number - insert the voucher number as shown on the Standard Form 1034.

(3) Schedule Number - leave blank.

(4) Sheet Number - insert the sheet number if more than one sheet is used in numerical sequence. Use as many sheets as necessary to show the information required.

(5) Number and Date of Order - insert payee's name and address as in the Standard Form

1034.

(6) Articles or Services - insert the contract number as in the Standard Form 1034.

(7) Amount - insert the latest estimated cost, fee (fixed, base, or award, as applicable), total contract value, and amount and type of fee payable (as applicable).

(8) A summary of claimed current and cumulative costs a nd fee by major cost element. Include the rate(s) at which indirect costs are claimed and indicate the base of each by identifying the line of costs to which each is applied. The rates invoiced should be as specified in the contract or by a rate agreement negotiated by EPA's Cost Policy and Rate Negotiation Branch.

(9) The fee shall be determined in accordance with instructions appearing in the contract.

NOTE: Amounts claimed on vouchers must be based on records maintained by the contractor to show by major cost element the amounts claimed for reimbursement for each applicable contract. The records must be maintained based on the contractor's fiscal year and should include reconciliations of any differences between the costs incurred per books and amounts claimed for reimbursement. A memorandum record reconciling the total indirect cost(s) claimed should also be maintained.

SUPPORTING SCHEDULES FOR COST REIMBURSEMENT CONTRAC TS

The following backup information is required as an attachment to the invoice as shown by category of cost:

Direct Labor - identify the number of hours (by contractor labor category and total) and the total direct labor dollars billed for the period in the invoice.

Indirect Cost Rates - identify by cost center, the indirect cost rate, the period, and the cost base to which it is applied.

Subcontracts - identify the major cost elements for each subcontract.

Other Direct Costs - when the cost for an individual cost (e.g., photocopying, material and supplies, telephone usage) exceeds $1,000 per the invoice period, provide a detailed explanation for that cost category.

Contractor Acquired Equipment (if authorized by the contract) - identify by item the quantities, unit prices, and total dollars billed.

Contractor Acquired Software (if authorized by the contract) - identify by item the quantities, unit prices, and total dollars billed.

Travel - when travel costs exceed $2,000 per invoice period, identify by trip, the number of travelers, the duration of travel, the point of origin, destination, purpose of trip, transportation by unit price, per diem rates on daily basis and total dollars billed. Detailed reporting is not required for local travel.

The manner of breakdown, e.g., work assignment/delivery order basis with/without separate program management, contract period will be specified in the contract instructions.

NOTE: For other than small business concerns, amounts claimed for purchased material and subcontracted items should be based on the cash disbursed by the contractor. These costs cannot be billed to the Government until paid for by the contractor. Any of these costs billed to the Government prior to being paid in cash, in addition to their associated indirect costs, will be considered improper charges and will be suspended until evidence of cash payment is provided. Similarly, any costs requiring advance consent by the Contracting Officer will be considered improper and will be suspended, if claimed prior to receipt of Contracting Officer consent. Include the total cost claimed for the current and cumulative-to-date periods. After the total amount claimed, provide summary dollar amounts of cumulative costs: (1) suspended as of the date of the invoice; and (2) disallowed on the contract as of the date of the invoice. The amount under (2) shall include costs originally suspended and later disallowed. Also include an explanation of the changes in cumulative costs suspended or disallowed by addressing each adjustment in terms of: voucher number, date, dollar amount, source, and reason for the adjustment. Disallowed costs should be identified in unallowable accounts in the contractor's accounting system.

SUPPORTING SCHEDULES FOR FIXED-RATE CONTRACTS

The following backup information is required as an attachment to the invoice as shown by category of cost:

Direct Labor - identify by labor category the number of hours, fixed hourly rate, and the total dollars billed for the period of the invoice.

Subcontracts - identify the major cost elements for each subcontract.

Other Direct Costs - when the cost for an individual cost (e.g., photocopying, material and supplies, telephone usage) exceeds $1,000 per the invoice period, provide a detailed explanation for that cost category.

Indirect Cost Rates - identify by cost center, the indirect cost rate, the period, and the cost base to which it is applied.

Contractor Acquired Equipment - identify by item the quantities, unit prices, and total dollars billed.

Contractor Acquired Software - identify by item the quantities, unit prices, and total dollars billed.

Travel - when travel costs exceed $2,000 per invoice period, identify by trip, the number of travelers, the duration of travel, the point of origin, destination, purpose of trip, transportation by unit price, per diem rates on daily basis and total dollars billed. Detailed reporting is not required for local travel.

The manner of breakdown, e.g., work assignment/delivery order basis with/without separate program management, contract period will be specified in the contract instructions.

NOTE: For other than small business concerns, amounts claimed for purchased material and subcontracted items should be based on the cash disbursed by the contractor. These costs cannot be billed to the Government until paid for by the contractor. Any of these costs billed to the Government prior to being paid in cash, in addition to their associated indirect costs, will be considered improper charges and will be suspended until evidence of cash payment is provided. Similarly, any costs requiring advance consent by the Contracting Officer will be considered improper and will be suspended, if claimed prior to receipt of Contracting Officer consent. Include the total cost claimed for the current and cumulative-to-date periods. After the total amount claimed, provide summary dollar amounts of cumulative costs: (1) suspended as of the date of the invoice; and (2) disallowed on the contract as of the date of the invoice.

The amount under (2) shall include costs originally suspended and later disallowed. Also include an explanation of the changes in cumulative costs suspended or disallowed by addressing each adjustment in terms of: voucher number, date, dollar amount, source, and reason for the adjustment. Disallowed costs should be identified in unallowable accounts in the contractor's accounting system.

RESUBMISSIONS

When an original voucher was submitted, but not paid in full because of suspended costs and after receipt of a letter of removal of suspension, resubmissions of any previously claimed amounts which were suspended should be submitted in a separate invoice showing the original voucher number and designated with the letter "R" with the copy of the removal of suspension notice. The amounts should be shown under the appropriate cost category and include all appropriate supplemental schedules. NOTE: All disallowances must be identified as such in the accounting system through journal entries.

Voucher resubmittals may also occur as a result of: (1) a new indirect cost rate agreement; or

(2) adjustments to previously billed direct cost rates due to audit resolution. Such claims should be submitted in a separate invoice or request for contractor financing payment number. They should include supplemental schedules showing the previously adjusted amounts by contract period. If the resubmission is based on a new rate agreement, a copy of the agreement should be attached. Costs must be identified by delivery order or work assignment where appropriate.

If the contract is Superfund-related, voucher resubmittals shall also identify the amount claimed against each Superfund site and non-site-specific activity.

COMPLETION VOUCHERS

Submit a completion voucher when all performance provisions of the contract are physically complete, when the final report (if required) is accepted, and when all direct costs have been incurred and booked. Indirect costs may be claimed at the provisional rates, if final rates are not yet available. Contractors must identify these vouchers by typing "Completion Voucher" next to the voucher number. For contracts separately invoiced by delivery order, provide a schedule showing total costs claimed by delivery order and in total for the contract.

In addition to the completion voucher, the contractor must submit an original and two copies of EPA Form 1900-10, Contractor's Cumulative Claim and Reconciliation showing the total cumulative costs claimed under the contract.

The information which a contractor is required to submit in its EPA Form 1900-10 is set forth as

(1) Contractor's Name and Address - show the name of the contractor exactly as it appears in the contract and its correct address, except when an assignment has been made by the contractor, or the right to receive payment has been restricted, as in the case of an advance account. When the right to receive payment is restricted, the type of information to be shown in this space shall be furnished by the Contracting Officer.

(2) Contract Number - insert the number of the contract under which reimbursement is claimed.

(3) First voucher number and completion voucher number.

(4) Total amount of cost claimed for each cost element category through the completion voucher.

(5) Total Fee awarded.

(6) Amount of indirect costs calculated using negotiated final indirect cost rate(s) and/or provisional rate(s) as specified in the contract, if final rate(s) are not yet negotiated for any fiscal period.

(7) Fiscal year.

(8) Indirect cost center.

(9) Appropriate basis for allocation.

(10) Negotiated final indirect cost rate(s) or provisional indirect cost rate(s).

(11) Signature.

(12) Official title.

(13) Date.

FINAL VOUCHER AND CLOSING DOCUMENTS

After completion of the final audit and all suspensions and/or audit exceptions have been resolved as to the final allowable costs and fee, including establishment of final indirect cost rate(s) for all periods the contractor shall prepare a final voucher including any adjustments to vouchered costs necessitated by the final settlement of the contract price. Contractors must identify these vouchers by typing "Final Voucher" next to the voucher number. For contracts separately invoiced by delivery order, provide a schedule showing final total costs claimed by delivery order and in total for the contract. The contractor shall also provide an original and two copies of an updated EPA Form 1900-10, Contractors Cumulative Claim and Reconciliation, showing the total negotiated, cumulative costs for the contract. Indirect costs shall be included at the final negotiated rates.

In addition to the final voucher, the contractor must submit an original and two copies of the Contractor's Release; Assignee's Release, if applicable; the Contractor's Assignment of Refunds, Rebates, Credits and other Amounts; the Assignee's Assignment of Refunds, Rebates, Credits and other Amounts, if applicable; and the Contractor's Affidavit of Waiver of Lien, when required by the contract.

ATTACHMENT 4

SITE SPECIFIC INVOICING REQUIREMENTS

September 25, 1995 (9:10am)

This is not considered to be contradictory or in pl ace of other contract clauses. Changes to the required format of the s/s attachment may be necessary to assist the Environmental Protection Ag ency's cost recovery efforts. The EPA will notify the contractor of any format changes as they become necessary.

The Contractor shall provide an invoice/voucher tha t identifies the costs incurred at each site and/or operable-unit wi th an EPA site/spill identifier (SSID). These invoices may be for: Curr ent expenses, reclaim for suspended costs, indirect cost adjustments, or audi t adjustments.

Invoices/vouchers for reclaiming suspended costs sh all be submitted on a separate voucher. The voucher number shall be the original claim voucher number when suspensions are made. The letter AR@ must be added to the end of the voucher number; i.e. 123R1, (if it requires more than one reclaim , invoices are to be numbered:123R2, 123R3 etc.). All indirect cost adjustments due to EPA approved indirect rate adjus tments must be submitted to EPA on a separate invoice (claim or credit as th e adjusted rate requires). The invoice number should end with lett er AZ@, i.e. 117Z.

Likewise, adjustments due to audit reports and a co ntracting officer letter referring to the subject audit report/s, must be su bmitted to EPA on a separate invoice (claim or credit as the audit repo rt requires). The invoice number should end with the letter AX@, i.e. 146X. For example:

Voucher purpose

Original voucher

Reclaim suspended costs

Indirect cost rate adjustment

Audit adjustments

Voucher number

123R1, 123R2

117Z

146X

Invoices shall also include the following informati on:

1. A cost element summary that summarizes all the co sts invoiced for the billing period by cost element such as labor, t ravel, equipment, other direct, subcontractor and overhead or indirect cost s, as identified elsewhere in the contract.

2. A site specific detail attachment (S/S Attachment) to the invoice.

All invoiced costs are separated into the following categories:

- Sites with an EPA SSID, e.g. "01X3," one line p er site should be used; [ See description at item 2 page 3 ].

- All other sites without an EPA SSID, e.g. "ZZ," one line per site should be used;

- Superfund non-site-specific costs for the whole contract and project support costs incurred on each multi-si te work assignment, one line per work assignment;

- Non-Superfund costs, as applicable, one line it em.

The required format of the invoice s/s attachment i s provided in

Exhibit I. The sum of the detailed costs on the s/ s attachment must equal the total amount invoiced as shown on the cost elem ent summary. Contractors responsible for contracts that involve work assignm ents may submit a separate page for each work assignment [applying th e same format] if so directed by the EPA project officer. The contracto r shall use the invoice s/s attachment to record current monthly charges, indirect rate/a udit adjustments, and adjustments for previously invoice d costs.

Contractors shall submit the invoices/vouchers in c ompliance with the contract ASubmission of Invoices Clause. @ to the Research Triangle Park- Financial Management Center (RTP-FMC).

At fiscal year-end, contractors shall also allocate their non-site-specific costs through the annual allocation proces s as described in Clause ____ within the Contract.

Questions regarding site specific invoicing require ments should be directed to the Chief, Contract Payment Section, RTP-FMC at (919)541-2304. Questions regarding Annual Allocation should be directed to t he Chief, Superfund Accounting Branch, Financial Management Division at (202)260-9268.

EXPLANATION OF EXHIBIT I

SITE SPECIFIC DETAIL ATTACHMENT

The contractor shall report the total invoiced cost s on the invoice s/s attachment broken down by the five categories o f site/non-site charges:

Sites with an EPA SSID; all other sites without an EPA SSID; Superfund non-site costs; non-Superfund costs, and previous invoice site corrections. For each site/non-site charge incurred during the billi ng period, the contractor shall provide the following information:

Column No. Column Title

1 (Optional) Technical Direction Document (TDDs) or Work Assignment Number (WA) - The full WA number is provided by the applicable EPA contract manager, i.e. the Work Assi gnment Manager. If the contractor is providing a separate page for each WA, the WA number may be placed in the upper l eft corner.

Otherwise the work assignment or TDD numbers must b e placed in this column.

2 Region/SSID- This four-digit code, i.e. 01X3 or A1X3, consists of:

a. The first digit will always be a A0" ZERO. Unless the region exceeds the use of two-digit sites; then the first digit will be an alpha, i.e. AA@, AB@.. Thus the SSID will be A1X3;

b. The second digit is the regional identifier, i.e. one (1) for

Region I, two (2)for Region II etc. and zero (0) fo r Region X,

c. The third and fourth digits, representing the site s, are the last two digits of the four- digit SSID (see 2.a).

Example, if Region I sites did not exceed two digits, the Region/SSID will be 01X3; however, if Region I sites exceeded the two digits, the Region/SSID will be A1X3.

3 Action Code - Starting with FY96 funding, a two-digit action code must be used to represent different remedial, removal, and enforcement actions as provided by the Project Offi cer, via the work assignment (WA) or the technical direction doc ument (TDD).

However, for FY95 funding and before, the one-digit activity code may be used.

(Note- For FY 1995 and prior, it was called >activity= code; from FY 1996 and forward, it will be called >action= code).

4 Operable Unit - If an EPA SSID has been separated into operable units or sub-sites for cost recovery purposes and h ave not been assigned their own SSID, the costs should be includ ed on the invoice by operable unit name and any numeric desig nation of two digits. The operable unit number must be provided by the EPA contract manager, i.e. Work Assignment Manager, Pro ject Officer...etc. These operable unit costs should be subtotaled by the "parent" SSID for internal tracking purposes by EPA.

5 Site Name or Non-site Description - The name of the site, up to

28 characters. When the site name exceeds 28 characters, use the first 28.

NOTE: For non-site-specific activities, use this column t o briefly describe the non-site activity.

6 Action Sequence Number - The three-digit code used to represent the activities performed as given by ACERCLIS III.@ This number will be provided by the WAM/Project Officer as he/s he acquires it from ACERCLIS III@ . This three-digit code is provided via the work assignment (WA) or the technical direction document (TDD).

The Action Sequence Number will be available sometime during FY 1996.

7 IFMS line Reference - Column shall be left blank. The IFMS line reference will be inserted by an EPA invoice A pproving Official (PO). This three-digit line reference is found on the Invoice Approval Form (2550- 19T) .

8 Invoice Number/Legend - For corrections, insert the invoice number referencing the original charge for which t he correction is being made. An invoice legend must be included at the bottom of the attachment, or on a separate encl osure to the S/S Attachment. The invoice legend shall describe the reason for the correction as it relates to a previously in voiced and paid amount. If more than one correction is made, explanation must be given for each by referencing the invoice n umber. The net amount for all corrections in column nine(9) mu st always be zero "00."

9 Current/Adjustment Amount - The amount to be charged or credited to the SSID, Operable Unit, pre-SSID, or non-site-s pecific account. If there are operable units within a site , list the cost of each Operable Unit and provide a subtotal f or each SSID.

SSID's must be sorted by region and site within eac h region.

10 Cumulative Charge - Show the cumulative charge for each Operable

Unit, SSID or Pre-SSID.

Incurred and claimed charges should be listed and s ubtotaled on the S/S Attachment by row sequential order.

Row Row Title

1 Previous invoice site corrections; This is not for reclaiming previously suspended costs, nor intended for any indirect cost or audit adjustments. Only corrections or adjustments of site costs charged to previous invoices shall be listed in Row 1.

The subtotal for all corrections or adjustments in this row should equal zero. Every line item correction or adjustment must reference an original invoice number where the charge first appeared and a reason for the adjustment.

2 Sites W/SSID; Costs for sites with an EPA SSID. The SSID is provided by the EPA contract manager, i.e. WAM, TDD or Project Officer (PO).

3 Sites W/O SSID; Costs associated with Superfund site-specific work where no SSID has been established AZZ@ accounts. Once the SSID is established, all AZZ@ costs associated with that site should be reclassified (adjusted from the AZZ@ to the appropriate site within 30 days of establishing the SSID). Thu s, the contractor must, immediately, submit a letter to th e Project Officer (PO) with an S/S Attachment. Only section one (1)-- Previous Invoice Site Correction-- must be completed.

Consequently, the PO approves the reclassification letter and sends it to RTP-Financial Management Center for cos t redistribution.

4 Non-site Superfund; Superfund non-site-specific costs, along with base and award fees, as described below.

Contract-wide Program Management - Technical and Administrative;

For those contracts requiring separate identificati on of technical and administrative program management such as ARCS.

The respective amounts should be delineated in com pliance with instructions provided either by the contract or WA. The requirement for separation of program management is defined in "Administrative Guidance under ARCS" and is availab le from the Superfund Regional Management Branch, Superfund/RCRA Procurement Operations Division, Office of Acquisition Management (OAM) at

(202) 260-9158.

For contractors not subject to the technical/admini strative differentiation requirements, contract -wide progra m management should be listed under "Contract-wide Program Manag ement- Administrative."

Work Assignment Project Support; this line(s) shall include non-site-specific project support and management incurr ed with individual multi-site work assignments. The contra ctor should note that these costs should also be allocated to t he sites under each respective work assignment as part of th e annual allocation process. For further Guidance on annual allocation, contact the Superfund Accounting Branch (SAB) at (202) 260-9268.

Other Non-Site-specific Activities; If the contractors engage in activities apart from program management as describ ed above, which cannot be related to specific sites, each of these activities must be described under the column six (Site Name/Non-site description). The purpose of breaking out non-site activities from pr ogram support is to assist the contractor and EPA in preparing the Annu al Allocation report at the end of the year. All non-site activi ties must be determined to be either site-support or program-wid e for cost recovery through the Annual Allocation process. Please not e that, like Contract-wide non-site activities, these are also a llocated to sites through the Annual Allocation process. See the Ann ual allocation contract clause and guidance for further details or contact the Chief, Superfund Accounting Branch at (202)260-9268.

Base and Award Fees; Base and Award Fees which are not site-specific should be listed in this Superfund Non-site Section .

5 Non-superfund; All non-Superfund costs invoiced should be reported on the s/s attachment by appropriation suc h as Oil, RCRA...etc. These costs must be sorted by TDD/WA w ithin each appropriation; as directed by the project officer.

6 Total Invoice Amount; This amount is the total of the costs listed in column 9, "Current/Adjustment Amount", i. e., the total charges for this billing period. This must equal t he total amount on the invoice cost element summary. There should be no total for the cumulative charge column.

NOTES TO SITE ATTACHMENT:

- Provide one line per site or activity, sorted alpha/numerically and by Region.

- Page Formatting:

Upper Left Corner - Contract Number, Delivery Order Number (if applicable), Invoice Number, and Work Assignmen t (optional).

Upper Right Corner - Contractor Name and Invoice Period of Performance.

Bottom Left Corner - Invoice Legend for previous invoice adjustments. This information may be provided as a n enclosure to the s/s attachment if it could not be provided on the bottom left corner.

Bottom Right Corner - Page number for the attachments, i.e. Page 1 of 7, 2 of 7, ...etc.

ATTACHMENT 5

MINIMUM STANDARDS FOR EPA CONTRACTORS'

CONFLICT OF INTEREST PLANS

1. PURPOSE

The Environmental Protection Agency (EPA) has identified a need to avoid, neutralize, or mitigate actual and potential contractor conflicts of interest (COI). In order to avoid, neutralize, or mitigate conflicts, contractors are required to have a COI plan for identifying and reporting actual and potential COI. The purpose of this document is to set forth the minimum standards for a contractor's COI plan.

2. COI PLAN

The contractor's COI Plan is a document which describes the procedures a company uses to identify and report COI. Generally, a contractor's corporate COI plan will describe how a company, in its entirety, addresses conflicts, and will not be contract or program specific. The plan may also describe the options a company will consider proposing to avoid, neutralize, or mitigate a COI whenever a conflict is identified. The plan will be evaluated and approved* by the applicable EPA Contracting Officer (CO) if the COI Plan meets the EPA's minimum requirements for detecting and reporting conflicts of interest. Contractors' COI Plans should be identified by a version number and date, as appropriate. In addition, when applicable, please also identify the version number and date of any previously submitted COI Plans to the Agency, to whom (name, title, and phone number) the COI Plan was submitted, what the solicitation(s)/contract(s) numbers were, and if and when the COI Plan was approved.

* COs may accept another CO’s prior approval of the same version of a contractor’s COI Plan when appropriate. COs however, are not required to accept another CO’s decision if the CO performs his/her own independent evaluation.

3. MINIMUM STANDARDS FOR CONTRACTORS' COI PLANS

A. Corporate Structure

The COI Plan shall describe any parent relationship and list all affiliates, subsidiaries, and sister companies, etc. Generally, this need not exceed three corporate tiers, unless a relationship exists beyond three tiers that would potentially create a conflict. In such a case, relationships beyond three tiers should also be included in the COI Plan.

Contractors should report changes in its' corporate structure to the Agency throughout contract performance.

Contractors are invited to include under this section, a company profile. The profile should discuss all pertinent information relevant to COI including a summary of a contractor's primary and/or environmental business functions and activities. This background information will potentially be very useful to contracting officers and the Agency when evaluating whether or not a contractor has a COI.

B. Searching and Identifying COI

The COI Plan shall include a requirement describing when a COI search must be performed by company personnel and clearly identify the procedures to be followed.

The searching requirement shall encompass all work related to all clients for whom work was performed over the past three years, all current work, all sites (if applicable), and any future work reflected in marketing proposals. Contractors must search their records over the past 36 months from time of receipt of the work from EPA. However, EPA encourages contractors to search back as far as a company's records cover.

C. Data Base

The COI Plan shall require a data base that includes all necessary information for a contractor to review its past work (at a minimum over the past 36 months), work in progress, and work the company may be pursuing under any marketing proposals. This requirement does not establish any particular type or kind of retrieval system, however, the data base shall contain, at a minimum, the following information and capabilities:

(1) A list of the company's past and public clients;

(2) A description of the type(s) of work that was performed and any other pertinent information;

(3) A list of the past sites (when applicable) a contractor has worked on;

(4) A list of site name(s) (when applicable) related to any work performed;

and

(5) The ability to search and retrieve the information in the data base.

If applicable, the COI Plan shall include provisions for supplemental searches of a parents, affiliates, subsidiaries, or sister company’s records. The COI Plan shall also describe any cross-checks used by the company when searching COI issues.

D. Personal Certification

At a minimum, the COI Plan shall require ALL employees of the company performing work under an EPA Superfund and/or Non-Superfund contract, including work on a site, work relating to a site, or work pertaining to a CERCLA/RCRA action or work that may endanger a CERCLA enforcement action, to sign a personal certification. It should be noted however, that it is the preference of the Agency that ALL employees of the company be required to sign such a certification rather than only those employees working under an EPA contract. The certification shall require at a minimum, that the individual agrees to report to the proper company authority any personal COI the individual may have on any work that may result in an actual or potential COI. The certification shall also state the individual has read and understands the company's COI Plan and procedures. The employee certifications shall be retained by the company.

E. Work Assignment (WA), Technical Direction Document (TDD), or Task Order (TO) Notification and Certification

The COI Plan shall describe the process the company requires for notifying the Agency prior to beginning work, and for submission of its' WA/TDD/TO certification within 20 days of receipt of the work from EPA.

NOTE: WA/TDD/TO certifications are NOT required if the contract contains an annual certification requirement. Nevertheless, the contractor's COI Plan should address the procedures to be followed for WA/TDD/TO certifications.

F. Annual Certification

The COI Plan shall describe the process the company requires for submission of its annual certification.

NOTE: Annual certification is NOT required if the contract contains a WA/TDD/DO certification requirement. Nevertheless, the contractor's COI Plan should address the procedures to be followed for annual certifications.

G. Notification and Documentation

The COI Plan shall clearly delineate who is the responsible official for making COI determinations within the company. Generally, this would be someone at a middle to upper level of management. The responsible official shall be free of any personal conflicts for the purpose of making COI determinations, e.g., a program manager who receives bonuses based on the total amount of sales may not be free of conflicts.

The plan shall clearly identify the process that is required when notifying the EPA of any actual or potential COI and the actions that the company has taken or will take to avoid, neutralize or mitigate the conflict. In addition, a contractor shall document all COI searches related to EPA work, whether or NOT an actual or potential COI has been identified.

H. Training

The COI Plan shall require all employees of the company to receive basic COI training, and that each employee receive COI awareness training, at least, on an annual basis.

The company's COI Plan shall be available for all employees to review. Annual awareness training shall include, at a minimum, a review of the certification language and any changes that may have occurred in the company's COI Plan. In addition, companies are encouraged to routinely disseminate to their employees current COI information.

I. Subcontractor's COI Plans

The COI Plan shall describe the process and mechanism by which the company will monitor its subcontractors to ensure all subcontractors are complying with the COI provisions in their contracts. It is important that subcontractors identify and report COI as well as submit Limitation of Future Contracting (LOFC) requests for approval.

8/4/2004

INSTRUCTIONS FOR

PERFORMING

THE ANNUAL ALLOCATION

OF NON-SITE-SPECIFIC COSTS

Program Costing Staff Office of Financial Management

TABLE OF CONTENTS

INSTRUCTIONS FOR THE ANNUAL ALLOCATION

OF NON-SITE-SPECIFIC COSTS

SECTION I - INTRODUCTION

OVERVIEW

DEFINITIONS OF TERMS

GENERAL REQUIREMENTS

SECTION II - ANNUAL ALLOCATION OF NON-SITE COSTS

ANNUAL ALLOCATION PROCESS

Step 1 - Reconciliation of Amount Paid

Step 2 - Identification of Site-Specific Costs

Step 3 - Identification of Non-Site Costs

Step 4 - Program Management Costs

Step 5 - Start-Up Costs

Step 6 - Equipment

Step 7 - Non-Site Activities

Step 8 - Non-Superfund Costs

Step 9 - Summary of Amounts

Step 10 - Allocation of Program Management Costs

Step 11 - Allocation of Start-up Costs

Step 12 - Allocation of Capital Equipment Costs

Step 13 - Allocation of Site-Support Costs

Step 14 - Completion of Master Allocation Schedule

SECTION I

INTRODUCTION

OVERVIEW

Two appropriations: CERCLA as amended by SARA (Superfund program) and OPA (Oil Pollution Act) authorize the U.S. Government to recover all response costs associated with cleaning up hazardous waste sites and oil spills. A large portion of EPA's response costs consists of payments to response action contractors. In order for these costs to be adequately supported in cost recovery litigation against the potentially responsible party, a defendable, logical and supportable accounting methodology must be in place that can assign costs to specific sites.

The site-specific portion of the contract costs are accounted for by EPA on a site-specific basis. However, contractors' non-site-specific costs are accounted for in a general account and must be allocated to the sites in order to be recovered. This guidance provides a logical and equitable methodology for the distribution of these non-site-specific costs to the total of all sites with and without Superfund site spill identifier numbers (SSIDs) or OPA incident specific site I.D.s and program-wide non-site activities. This effort is called Annual Allocation. The resulting allocation will yield ratios between the total site specific portion for the superfund and oil sites. This ratio will be applied to all Superfund and OPA sites through the EPA cost recovery process. Completion of Annual Allocation reports by the response action contractors will result in the inclusion of all appropriate costs in the cost recovery effort.

This document has been prepared by the Program Costing Staff (PCS) of the Office of Financial Management. It provides instructions to contractors on how to perform the annual allocation. EPA recognizes that each contract may feature unique situations which may not necessarily be addressed in these instructions. In such cases, the contractor should contact PCS for guidance.

DEFINITIONS OF TERMS

Capital Equipment - EPA purchased equipment with a unit cost of $5,000.00 or more and with a useful life greater than l year.

Direct Site Costs - costs which are attributable to a specific site.

End of Contract costs - costs incurred to shut down a contract - usually occur at the end of the contract. End of contract costs may include such items as equipment removal costs and maintenance.

Program management - contract specific costs and fees incurred for the management of the specific EPA contract as a whole. May be split or wholly funded through the Superfund, OPA or other appropriation.

Non-site activities - costs incurred for activities not charged to specific sites. Examples include training of state personnel, calibrating EPA-owned equipment, and participating in general meetings and/or conferences. Non-site activities are broken down into two broad categories: program-wide and site-support. (See definitions below.)

Pre-SSID costs - costs incurred in connection with particular Superfund locations at which a Site/Spill Identifier (SSID) or OPA identifier has not been assigned. Also known as Sites without SSIDs or 'ZZ' costs. The “ZZ”site identifier is found in the second two digits of the site project field (positions 29 and 30) of the 41 digit EPA accounting code.

Program-wide non-site activities - usually identified with a “00" site identifier. Costs incurred for activities which support the overall Superfund or OPA program. The costs are global in nature and purpose and are not eligible for distribution to sites. Examples of program-wide activities include databases developed for use by the Superfund program, training given by the contractor for EPA employees, training to first responders, training of state personnel, and attendance at conferences held to discuss general Superfund or OPA issues.

Project Management - Program management type oversight costs for one or a number of sites within a multi-site work assignment. Multi-site project management costs should be allocated proportionately to the sites charged under the work assignment using a separate column and a backup schedule supporting the allocation of each work assignment (Schedule E). Such costs should be charged to the “00" site account at time of invoicing - if assigned to the “ZZ” account, they should be reassigned to the “00" account at the time of invoicing..

Site-support non-site activities - Usually identified with a “00" site identifier. Costs incurred for those activities other than program management and fees which relate to, support, and/or benefit the sites worked on by the contractor in the aggregate, but which cannot be accounted for readily on a site-specific basis. Examples include training for contractor employees working on sites, equipment maintenance, calibrating EPA-owned equipment, tracking and inventory, and a conference or meeting held to discuss issues related to sites the contractor worked on.

SSID - Site/Spill Site Identifier (Superfund term) or Incident Specific Site (OPA term) - specific two character alpha-numeric designation for each Superfund or OPA site within a region. The SSID or incident-specific number is in the site project field (positions 27-30) of the IFMS 41 digit accounting code. (Note that for Oil sites prior to FY98, the site ID was in the Org code field (pos.

11-17). Attached to the Annual Allocation Instructions is the Accounting code structure and Oil Pollution Accounting Structure memo. This number is used to track all costs incurred on the site.

Start-up Costs - also called mobilization costs-- cost of efforts and activities incurred early in the contract term whose benefits extend for the entire contract period. Examples may include recruitment and relocation of staff, preparation of the contract work plan, establishment of a quality assurance program and certain equipment purchases.

"00" costs - synonymous with "non-site-specific" costs. These are costs which are attributable to more than one site or the program. Examples include program management and fees, equipment, start-up costs, end-of-contract costs and all non-site activities. The "00" represents the second two digits in the site project field (positions 29-30) of the EPA 41 digit account number.

GENERAL REQUIREMENTS

The Annual Allocation process results in the contractor allocating all program management costs; fixed, base and award fees; and some non-site activity costs to sites and activities the contractor worked on during the fiscal year. The contractor submits an allocation report, along with supporting attachments, to the Program Costing Staff (PCS) of the Office of Financial Management (OFM). The amount included in the annual allocation report is the sum of the invoices paid for work performed during the Federal fiscal year, i.e., October 1 - September 30. Indirect and other rate adjustments for prior years paid in this fiscal year should also be submitted with explanation of this fact. If these prior year costs are deemed material by PCS, the annual allocation report methodology would be modified to recover these costs only to the benefitting sites.

The Contractor shall provide PCS within 120 days after the end of the fiscal year the total amount of each invoice paid for the annual allocation period, separating Superfund, OPA and other non-Superfund costs. PCS will reconcile this payment history against the Agency’s contract payment system and a letter confirming the total amount paid for the annual allocation period will be sent to the contractor. The contractor should provide an allocation report within 60 days after the letter confirming the invoice amounts are provided to the contractor. The format the contractor may elect to combine all costs for all prior years not already submitted separately on one allocation report. Otherwise, each fiscal year's costs should be allocated separately.

When the contract performance period ends at other than the end of the FY, the contractor shall provide the invoice listing 120 days after submission of the last invoice following contract expiration.

Draft and Final Reports

The contractor shall submit the draft reports to PCS 60 days after receipt of notification of the total amount paid. PCS has created a lotus spreadsheet for use by the contractor for the preparation of this report. PCS will review the drafts, notify the contractor in writing of any necessary corrections and request submission of a final report. Two copies of the final report are due to PCS 30 days after revision is requested by EPA. The contractor shall provide, as part of the final report, a signed statement certifying that the final report data accurately reflects the costs distributed to the total site amount and is supported by the contractor's accounting records.

Additionally, the contractor shall submit a Master Allocation report on a computer disk or electronically through EMAIL in a Lotus format. [PCS has a lotus format available for use by the contractor with all formulas.]

The annual allocation report submission includes the following:

Required Reports:

- Listing of all invoices paid during the Federal fiscal year (with invoice numbers and amounts) broken out between Superfund, OPA and other non- Superfund appropriations

- Master Allocation Schedule (Attachment A)

- Statement of Allocation Methodology

- Certification of Contractor's report - (final report only)

Required, if applicable:

- Schedule of Start-up Costs (Attachment B)

- Schedule of Capital Equipment Depreciation (Attachment C)

- Schedule of Non-Site Activities (Attachment D)

-Schedule of Work…