1. PURPOSE: To provide guidance concerning the charging of indirect costs under the Senior Community Service Employment Program (SCSEP).

2. REFERENCES: SCSEP regulations at 20 CFR Part 641; OW Bulletins 97-26 and 00-12; and Office of Management and Budget (OMB) Circulars A-122, A-87 and A-21.

3. BACKGROUND: There has been some confusion concerning whether SCSEP sponsors must charge all indirect costs to the Administration cost category, or whether those indirect costs associated with Other Enrollee Cost (OEC) activities may be charged to the OEC cost category. Older Worker Bulletin 00-12 and the planning instruction bulletins from previous years included the instruction that "All indirect costs must be attributed to the column headed "Administration." However, Section 641.404(c) of the regulations governing the SCSEP states that:

"Other enrollee costs (OEC) shall include, but not be limited to the direct and indirect costs of providing:

(1) Recruitment and selection of eligible enrollees as provided in §641.304 and §641.305;

(2) Orientation of enrollees and host agencies as provided in §641.308;

(3) Assessment of enrollees for participation in community service assignments and evaluation of enrollees for continued participation or transition to unsubsidized employment as provided in §641.309;

(4) Development of appropriate community service assignments as provided in §641.310;

(5) Supportive services for enrollees, including transportation, as provided in §641.312;

(6) Training for enrollees, including tuition; and

(7) Development of unsubsidized employment opportunities for enrollees as provided in §641.314."

This bulletin is intended to clarify the conflicting guidance contained in the above referenced documents.

4. POLICY: SCSEP grantees should apply the indirect cost rate to the base from which it was derived as stated in the organization's negotiated indirect cost rate agreement.

The guidelines set forth in Older Worker Bulletin 97-26, which deals with SCSEP cost classification, and related Older Worker Bulletins; the SCSEP implementing legislation and regulations; and the grant document should be used as references in determining how to distribute any direct or indirect costs between Administration and the program categories. It is not the case that all indirect costs must necessarily be charged to the Administration cost category.

5. INQUIRIES: Questions should be directed to your Federal representative at (202)

219-5904 or to the Director, Office of Cost Determination at (202) 219-8391.

     
TDNO:MErickson/MJ/9-12-00/Rm.N4644/219-5904