Alternatives for the Accounting Treatment of Fringe Benefits
(Editor’s Note. The firm utilizing only full time employees who are paid generous fringe benefits are becoming the exception rather than the rule. The tough competitive environment of the government market are requiring increasing usage of mixed employment/contract relationships where, for example, temporary and/or offsite employees receiving lower fringe benefits, requiring lower facility and support costs, etc provide opportunities to offer the government lower prices based on lower indirect costs. Our consulting work helping organizations change their direct and indirect rate structure leads us to the unmistakable conclusion that each firm is different and requires a carefully designed approach. We have found the following article in the August CP&A Report by Darrell Oyer, a long time Government contracts consultant and principle of the Darrell J. Oyer & Company, intriguing for illustrating some alternative approaches.)
Fringe benefits costs as a percentage of direct labor has increased substantially in the last ten years. New employment arrangements altering the composition of the workforce has also caused potential variations in indirect cost rates. A brief review of FAR and CAS allocation rules precede a discussion of alternative treatment of fringe benefit costs.
Definition of Fringe Benefits
Fringe benefits are allowances and services provided by a contractor to its employees as compensation in addition to regular wages and salaries. They generally include costs of paid absences for vacations, sick leave, holidays and military leave, employee insurance and supplemental unemployment benefit tax. The US Chamber of Commerce adds (1) legally required payments such as employee FICA taxes (2) retirement and savings plan payments, profit sharing, stock bonuses, Employee Stock Option Plans and defined-benefit and defined contribution pension plans (3) life insurance and death benefit payments (4) medical and medically related payments (5) paid rest periods and (6) miscellaneous benefits such as discount on company products and services, education expense, child care and employee meals.
FAR 31.205-6(m) makes the costs of fringe benefits generally allowable to the extent they are reasonable, required by law, employee-employer agreements or are established policy of the contractor. Costs of several types of fringe benefits are subject to separate, detailed allowability criteria (e.g. employee rebate and discount (unallowable), hours and incentive compensation (allowable subject to specified purpose and documentation), pension plans (allowable if computed according to CAS 412 and 413)).
FAR 31.201-4 provides general guidance to cost allocations: "a cost is allocable if it is assignable or chargeable to one or more cost objectives on the basis of relative benefits received or other equitable relationship". Since it is difficult to identify fringe benefit costs to a specific contract the allocation criterion is whether a fringe expense benefits both the contract and other work and can be distributed to them in reasonable proportion to the benefits received. FAR 31.203 refines guidelines on allocating indirect costs by stipulating "homogeneous pools" of costs that can be allocated to separate contracts on a similar base should be accumulated while excessive cost grouping may be avoided if substantially similar results are achieved.
The allocation rules provide a wide range of choices for pooling and allocating fringe benefits. The guidance indicates contractors should consider whether the cost pool or pools are homogeneous. If fringe benefits vary substantially between full time and say, less than full time or field personnel, separate fringe pools might be necessary to achieve homogeneous grouping. FAR 31.203(b), on the other hand, stresses it is not necessary to proliferate pools to achieve perfect cost allocation.
A direct labor dollar base is the usual choice for allocating fringe benefit costs and certainly the preferred choice of government auditors. A different allocation base (e.g. labor hours) may be justified when some fringe benefit costs vary by number of employees (e.g. fixed medical cost) or salary level (e.g. pension). Two separate pools with different bases are usually frowned upon for providing excess complexity with little added benefit.
Cost Pool Alternatives
When a company has primarily full time employees there are various methods of pooling fringe benefits that can yield very different rates and pose various levels of complexity. Fringe benefit costs are usually included as (1) on of many cost elements in various overhead and/or G&A pools or (2) in various separate fringe benefit pools.
Inclusion in the Indirect Cost Pool. Frequently, fringe benefit costs are accumulated with other indirect costs in an appropriate pool such as manufacturing overhead, engineering overhead or general and administrative (G&A). The fringe benefits for both direct and indirect labor are usually included.
The primary benefit of this approach is its simplicity. Lumping all indirect costs including fringe benefits into one or two pools is quite easy. There are two major disadvantages to this approach: (1) fringe benefit costs are not easily identifiable and hence easily monitored and controlled and (2) a higher indirect cost rate results in contrast to including fringe benefits and or other indirect costs in separate pools. For example, an indirect rate of 138% may be viewed more unfavorably than a 100% overhead rate and a 38% fringe benefit rate. As an added incentive, an even lower overhead rate can be made to appear if "direct labor costs" are defined as direct labor dollars plus applied fringe benefit costs.
Allocation of Separate Fringe Cost Pool. A contractor may decide to establish a separate fringe benefit pool to focus management attention of this important cost, to lower indirect cost rates or achieve more precision in its cost allocation methods. Once this decision is made, the contractor must then decide which costs are included in the fringe benefit pool and which costs are in the base.
The discussion below assumes two categories of labor: direct employees who work both direct and indirect functions and indirect employees who work only indirect functions.
Total Fringe Benefits (for direct and indirect labor) with a Direct Labor Base of Direct Employees. If all fringe benefits are in the pool and divided by only direct labor, this approach will yield a high fringe benefits rate because the numerator (total benefits for all employees) is divided by a lower denominator (direct labor only).
Fringe Benefits Costs for Direct Labor Only with a Direct Labor Base of Direct Employees. The lower numerator (fringe benefits for only direct labor) divided over the direct labor base will tend to lower the fringe benefit rate. One problem of this approach is how to handle the fringe benefits of direct labor employees when they perform indirect rate functions (e.g. attending training, idle time).
Fringe Benefits Costs for Direct Labor Only with a Direct Labor Plus Indirect Labor of Direct Employees. Calculate separate fringe benefit rates for direct and indirect employees. When direct employees work directly their fringe benefits are in effect charged to the job worked while when charging indirect, their fringe benefits are charged to an overhead pool like the indirect employees. The advantage of greater precision and a lower fringe benefit is offset against more detailed recordkeeping.
Allocation Through Intermediate Cost Pool. Combine all fringe benefits for all employees in one intermediate cost pool and allocate them on a base of total labor dollars of both direct and indirect employees. Fringe benefit costs are then, in turn, charged either to cost objectives for direct labor or other indirect cost pools. This results in a lower fringe benefit rate and is easy to use but can cause some cost distortion if some employees receive significantly greater salaries and greater fringe benefits (e.g. executives). The distortion can be minimized if fringe benefit rates are similar for all employees or the dollar differences are minimal.
Multiple Fringe Benefit Cost Pools By Employee Category
The increased use of less than full-time employees has created a need for more sophisticated accounting. The use of these employees has created real cost savings (e.g. lower fringe benefits, less support, reductions in idle time disguised as other activities) and contractors need to translate these savings into lower indirect rates for pricing purposes. Full time employees may receive all fringe benefits such as health insurance, vacation, and statutory payroll taxes, part time employees may receive limited fringe benefits such as vacation and statutory payroll taxes while temporary employees may receive only statutory taxes.
One solution for accounting for these varied fringe benefits is to account for them in layers or tiers. As the Table 1 below indicates, the first fringe benefits pool or tier consists of statutory fringe benefits that all employees receive. The second fringe benefit tier could consist of those benefits available to part time and full time employees while the third tier consists of those benefits received only by full time employees. Table 2 illustrates the resulting fringe benefit rate for each class of employee. Contractors can bid temporary employees at 6.93%, part-time employees at 19.43% and full time employees at the full fringe benefit rate of 37.75%.
Multiple fringe benefit pools can also be useful if benefits vary for any reason between different organizational units or facilities. For example, an organization with multistate locations where state employment taxes or different union agreements may require establishing multiple fringe benefit cost pools.
(Editor’s Note. Contractors fully covered by CAS should be aware that changes to their methods or techniques of allocating fringe benefits will likely be considered a change to an accounting practice requiring altering the disclosure statement and possibly triggering the need for a cost impact proposal and negotiating a price adjustments on CAS covered contracts. On the other hand, we have seen instances of a different treatment of fringe benefits by new categories of employees considered as an adoption of a new accounting practice, averting the claim of a change to an old practice. This discussion is beyond the scope of this article and competent CAS experts should be consulted.)
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