State Operations Manual (Pub. 100-07), Ch. 4 § 4611
Line Item Justifications for SA Direct and Indirect Costs
4611 - Line Item Justifications for SA Direct and Indirect Costs
(Rev. 96, Issued, 12-13-13, Effective: 12-13-13, Implementation: 12-13-13)
In making the entries for items under non-personal services (Other Direct Costs, lines 5
through 14, of Form CMS-435), the SA is required to justify the amounts approved by
providing the rationale developed for each line item separately, using base period data
and format as described in §4605. Specific guides and criteria are listed below.
A. Retirement Contributions and Fringe Benefits
The SA enters the estimated total of the employer’s share of social security taxes, State
retirement system(s) contributions and other fringe benefits. Also, the SA indicates the
percentage used to determine the level of funding for Retirement and Fringe Benefits.
B. Travel
The SA includes the estimated travel costs of its personnel, including, where appropriate,
per diem or subsistence in lieu of per diem, applicable to the State survey program. The
SA derives estimated costs based on provisions of State law, regulation and
administrative procedures applicable to travel of State employees. The SA indicates in
the budget estimate expected number, type and extent of trips, and purpose. For out-of-
state travel, the SA indicates the number of trips, the purpose, and basis for charges to the
State survey program. The SA includes the basis for charges for all out-of-State travel
other than to meetings called by CMS.
C. Communications
In the budget estimate, the SA breaks out e-mail, telephone, telegraph, postage, and other
communications separately.
D. Supplies
In the budget estimate, the SA breaks out all major items of supplies, i.e., any supplies
comprising 20 percent or more of the total cost of supplies.
E. Office Space
1 - Agency In Identifiable Space
Analysis of base period expenditures and the budget estimate must contain these
elements for each location: total rental costs, number of square feet of space, cost per
square foot, and services included in rental. The SA identifies office space that is
State-owned.
2 - Office Space - Agency In Shared Space
SA analysis of base period expenditures and the budget estimate must contain these
elements:
• Total cost of space to the agency;
• Basis of proration;
• Office locations of SA staff; and
• Estimate of square feet allocated to the State survey program. The SA
identifies State-owned space.
3 - Office Maintenance
In the budget estimate, the SA breaks out the major items of expense, e.g., light, heat,
janitorial service, office equipment repair. If office maintenance, in whole or in part,
is included in the SA rental contract, the SA notes this fact and the amount need not
be separated.
F. Equipment
The SA enters costs of equipment to support specific personnel positions such as desks,
chairs, typewriters, computers and computer-related equipment, file cabinets, tables, and
other machines (fax machines, photocopiers, etc.) that are necessary for program
operational, administrative and management needs. In addition to line item justification,
the SA documents the budget estimate through use of Form CMS-1466 (Exhibit 54) for
both LTC and non-LTC requirements. (See §4614.)
G. Training
The budget estimate should provide for the cost of training SA personnel. The SA
includes the cost of travel and per diem associated with training sessions.
H. Consultants
The SA provides the estimated cost of consultants who are not State employees, but who
are used on a part-time, temporary, or fee-for-service basis.
I. Subcontracts
The SA provides the estimated cost of subcontracts when part of its responsibilities are
assigned to another State or local public agency. Subcontract costs attributable to State
survey activities (e.g., State Fire Marshal) are allowable and payable at the FFP rate
established for surveyors, i.e., 100 percent Federal payment for Medicare and 75
percent/25 percent FFP for Medicaid, with the exception of ICF/IID. The Federal
matching rate for ICF/IID is 75 percent of FFP for salary, fringe benefits, travel and
training. All other costs are matched at 50 percent FFP.
J. Miscellaneous
The SA provides the estimated cost of other items, which have not been reported in any
of the preceding classifications. Also, the SA enters as a separate line item anticipated
cost associated with the NAR and NATCEP, line 14A. (See §4543.)
K.. Total Direct Costs
Calculated sum total cost of all line items outlined here and in §4612.
L. Indirect Costs
The SA provides the rate negotiated and approved by the Director, Division of Cost
Allocation and Liaison, DHHS, for use during the budget FY together with the line item
base, against which it is applied.
Expenditures included in this category must not be duplicated under direct costs.
M. Total Budget Request
Calculated total of all direct and indirect costs.