BRIEF

Policy Summary

This policy provides guidance on the Lawrence Berkeley National Laboratory (Berkeley Lab) Office of National & Homeland Security (ONHS) expenses, which represents technical and programmatic oversight of the Laboratory's funded projects from the Department of Energy National Nuclear Security Administration (DOE NNSA), Department of Defense (DoD), Department of Homeland Security (DHS), and the intelligence agencies, as well as other national and homeland security related projects.

Who Should Read This Policy

Any Berkeley Lab employee responsible for the financial management of ONHS projects

To Read the Full Policy, Go To:

The POLICY tab on this wiki page

Contact Information

Indirect Budget Manager, Office of the Chief Financial Officer

POLICY

A. Purpose

This policy provides guidance to ensure that the costs for Lawrence Berkeley National Laboratory's (Berkeley Lab's) Office of National & Homeland Security (ONHS) technical programmatic management oversight are accumulated in homogeneous indirect cost pools and allocated in a reasonable proportion to the beneficial or causal relationship of the costs to final cost objectives.

B. Persons Affected

Any Berkeley Lab employee who works with the financial management of ONHS

C. Exceptions

None

D. Policy Statement

1. General

The ONHS charge, which represents costs of the ONHS' technical programmatic oversight of Berkeley Lab’s National and Homeland Security research and development, will be:

1. 1. Appropriately budgeted and accounted for on a consistent basis.
   2. Accumulated in a separate OHNS cost pool.
   3. Allocated in a practical and equitable manner in reasonable proportion to the beneficial or causal relationship of the costs to final cost objectives.

For the purposes of this policy, OHNS research and development projects are defined by the presence of one or more of the following activities:

1. 1. Weapons of mass destruction, including but not limited to, chemical, biological, or nuclear weapons research or production.
   2. Technologies intended to analyze, detect, or mitigate threats (nuclear/radiological, biological, chemical, unexploded ordnance, mines and mine detection, and the like).
   3. Homeland security, proliferation detection, counterterrorism, or intelligence-related work from any source of funding and from any sponsor.
   4. The project is funded directly from the sponsor or as a flow through by any part of DOE NNSA, DoD, or DHS, or any of the intelligence agencies (i.e., Berkeley Lab is receiving a subcontract, but the ultimate sponsor is one of the cited parts of the U.S. government).
2. Cost Pool
   1. Elements of cost include labor, payroll burden, materials and supplies, travel, service center charges, and facilities use associated with the ONHS technical programmatic oversight. In addition, applicable burdens include related organization, travel, and procurement burdens.     
   2. Cost elements may include other operating expenses associated with the above functions.
   3. The OHNS pool shall not include research and development (R&D) activities.
   4. The cost pool should not include costs that are unallowable, or not in compliance with Berkeley Lab's prime contract, Federal Acquisition Regulations (FAR), and/or Cost Accounting Standards (CAS).
   5. Capital equipment cannot be purchased with OHNS funds. 
3. Distribution Base

The OHNS cost pool for a cost-accounting period is allocated to final cost objectives of that cost-accounting period by means of a total cost input base. All exclusions are detailed in the Lab’s annual Cost Accounting Standards (CAS) Disclosure Statement. 

      4. Rate Execution and Monitoring 

1. 1. OHNS expenses are allocated to final cost objectives using pre-established OHNS rates. The rates are based on forecasted costs for the applicable fiscal year.
   2. The pre-established rate is monitored throughout the fiscal year. If a material variance is anticipated, the pre-established rate will be revised to ensure the variance      is reallocated to the original cost objectives in the proportion it was originally recovered. Revised rates are retroactive to the beginning of the fiscal year.
   3. ONHS sets the criteria for determining whether the project is subject to the ONHS rate and includes all DOE and non-DOE sponsors of National and Homeland      Security work approved by DOE. The principal investigator (PI) is responsible for providing accurate information about the scope of work to assist in determining when this rate is applicable.
   4. Establishment of the OHNS burden, as well as established rates, forecasts, and revisions of predetermined rates for the applicable cost accounting period(s) are prepared by appropriate Area staff and coordinated and executed through the Office of the Chief Financial Officer (OCFO) Budget Office.

      5. Title

ONHS sets the criteria for determining whether the project is subject to the ONHS rate and includes all DOE and non-DOE sponsors of national and Homeland Security work approved by DOE. The principal investigator (PI) is responsible for providing accurate information about the scope of work to assist in determining when this rate is applicable. Below is a Rate Application Process flowchart for determining OHNS application.

E. Roles and Responsibilities

Managers, supervisors, and employees must adhere to the provisions of this policy.

*In the context of this policy, financial stakeholders may include area/division business managers or other area/division operations staff to whom area/division management has given accountability for financial matters. This may also include Office of the Chief Financial Officer (OCFO) staff matrixed to the area/division.

F. Definitions/Acronyms

G. Recordkeeping Requirements

None

H. Implementing Documents

None

I. Contact Information

Indirect Budget Manager, Office of the Chief Financial Officer

J. Revision History

DOCUMENT INFORMATION

Source Requirements Documents

• Cost Accounting Standard 401, Consistency in Estimating, Accumulating and Reporting Costs
• Cost Accounting Standard 402, Consistency in Allocating Costs Incurred for the Same Purpose
• Cost Accounting Standard 418, Allocation of Direct and Indirect Costs
• Cost Accounting Standards Board (CASB) Disclosure Statement, Lawrence Berkeley National Laboratory