How to Develop Indirect Rates Under the New Super Circular Part 1 Webinar Rubino & Company, Chartered May 8, 2014
• • Update / Impact of Super Circular Click to edit Master text styles • Definitions Direct Cost Allocations – Secondoflevel
• Definition Indirect Cost o Thirdof level – Fourth • Negotiation & level Administration of Indirect Rates » Fifth level
• Types of Allocation Bases • Simple, Multiple, Direct Allocation Methods • Special Rates • Problem of Double-Charging • Statement of Functional Expense for Indirect Rate Development
• • To provide participants with styles both conceptual Click to edit Master text and hands-on tools for developing indirect – Second level rates for not-for-profits that receive federal o Third level rates. – Fourth level • The session will cover different types of » Fifth level indirect rates: fringe, occupancy, and general and administrative. • To provide participants with the new options available under the Super Circular given the fact of the administrative recovery restrictions under Ryan White programs.
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Paul H. Calabrese
o Third&level Rubino Company, CPAs & Consultants – Fourth level Senior Manager » Fifth level
Tel: 301-214-4137 pcalabrese@rubino.com www.linkedin.com/in/pcalabrese https://twitter.com/Paulcompliance
All slides copyright 2014, Rubino & Company, Chartered
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• Federal agencies implement by 12/26/2014 o Third level • Subpart F Audit Requirements become applicable – Fourth level with audits of fiscal years beginning on or after » Fifth level 12/26/2014 or effectively 1/1/15 end 12/31/15 • Administrative (pre/post award) requirements and cost principles apply on new awards or additional / incremental funding on or after 12/26/14 • Existing awards before 12/26/14 follow existing terms and conditions which are covered by the prior OMB Circulars A-110, A-122, A-133
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• Non-Federal entities wishing to implement entityo Third level wide system changes to comply with the “uniform – Fourth level guidance”» (Super Circular) on or after 12/26/2014 Fifth level will not be penalized by Federal agencies, in that they may still have older agreements covered by the prior OMB Circulars. • FAQ Q III-5: Words in the uniform guidance: “Must” is a requirement. “Should” is a best practice or recommended approaches, COFAR wanted to bring to attention of non-Fed entities
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• Responsible for administering Federal funds o Third level consistent with terms and conditions, program – Fourth level objectives of award » Fifth level • Accounting practices must be: – Consistent with cost principles – Support accumulation of cost – Adequate documentation to substantiate costs charged to Federal awards – Cost principles are used as a guide to price fixed price contracts / subcontracts
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• Requirement to account to the Federal government – Second level for actual costs incurred 200.401(a)(5) reverse logic o Third level where principles do not apply • May
– Fourth level not earn keep » Fifthorlevel
any profit 200.400 (g)
• The Non-Federal Entity (NFE) must promptly refund any balances of unobligated cash that the Federal awarding agency or pass-through entity paid in advance or paid and that is not authorized to be retained by the non-Federal entity for use in other projects. 200.343(d)
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• The obligation of the Non-Federal Entity (NFE) to – Second leveldue as a result of later refunds, return any funds o Third level corrections, or other transactions including final Fourthrate leveladjustments. 200.344 (a)(2) indirect– cost » Fifth level rate: per 200.414(f) free lunch? • The 10% de minimis Never received a negotiated indirect rate Charge on a modified total direct cost base May use indefinitely until negotiate an indirect rate Direct and indirect costs charged consistently but not as both causing double-charging – Use consistently on all Federal awards – – – –
• Click to edit Master text styles – Second level • Cannot spend more than 10% of Federal funds on administrative expenses in a grant year for Ryan White o Third level – Fourth level • 10% de minimis rate per 200.414(f) » Fifth negotiated level • NFE has existing indirect rate: – One-time extension of current indirect rate – For a period of up to 4 years – If granted, cannot request a rate review until extension period ends – At end of 4 year period, must re-apply to negotiate a new rate
• Click to edit Master text styles Second level Direct– cost allocation principle 200.405(d) level two or more direct programs 1. If o Third cost benefits – Fourth level 2. In proportions that can be determined without undue Fifth level effort or » cost 3. Costs should be allocated to projects – If 1 and 2 cannot determine proportions based on interrelation of work involved, then allocated on benefited projects on a reasonable documented basis. – Purchase of equipment or capital assets for a specific award are assignable to that award only regardless of use on other projects or no longer needed as acquired.
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Direct charging of admin staff wages may be o Third level appropriate when all items are met: 200.413(c) •
– Fourth level Administrative services » Fifth level
are necessary to a project
• Individuals involved can be specifically identified to a project, such as time reports • Administrative wages are included in the budget or prior written approval from agency • Such costs are not recovered as indirect cost
• Click to edit Master text styles – Second level • Unallowable activities and donated services receive allocation of indirect costs 200.405(b) o Third level – Fourth levelto a Federal award may not be • Costs allocable level fund deficiencies to avoid charged » toFifth cover restrictions in the regulations 200.405(c) • Limitation on allowable costs 200.408 o
If maximum amount allowable under a limitation is less than total amount determined, the delta is not recoverable and cannot be charged to another award.
• Click to edit Master text styles – Second made level for costs determined to be • Payments o Third levelmust be refunded including unallowable – Fourth level interest to Federal government 200.410 » Fifth level
– Unallowable by Federal awarding agency – Cognizant agency for indirect cost – Pass-through entity – Either direct or indirect unallowable cost
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• Adjustments of previously negotiated indirect cost rates – Second level containing unallowable costs 200.411 o Third level • Negotiated indirect cost rates later found to have costs: – Fourth level 1. Unallowable specified by Federal statutes, regulations or » Fifth level
terms and conditions of a Federal award 2. Unallowable as not allocable to Federal award(s)
o Must be adjusted for a refund o Adjustments are used to correct established negotiated rates o Will not re-open for rate negotiation o Applied to all types of rates: fixed, final, predeter, prov.
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• Adjustments of previously negotiated indirect – Second level costo Third rateslevel containing unallowable costs 200.411 – Fourth level – For projected rates of a future year, the costs are » Fifth level removed from cost pools and rates appropriated adjusted downward – For historical rates of a past period, the unallowable costs will be computed by fiscal year and a cash refund including interest – For current year rates, either a rate adjustment or refund per cognizant agency
• Click to edit Master text styles – Second levelof previously negotiated • Adjustments o Third level indirect cost rates containing – Fourth level unallowable costs 200.411 » Fifth level o
For multiple years, the proportional amount of unallowable costs in the base year will be extrapolated to the out-year rates
• Click to edit Master text styles – Second level expenditures 200.415(a) • Assure proper o
o Third level Certifying project budgets, annual and final fiscal – Fourth level reports or vouchers requesting payments
Fifth level “By signing this» report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may be subject to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise”.
• Click to edit Master text styles • Certification of indirect rates 200.415(b) – Second level o
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Ano Third Indirect Cost Rate Proposal (ICRP) must have level a Certificate of Indirect Costs signed at a level – Fourth level » Fifth level not lower than VP or CFO Cost are not unallowable and not inallocable If an ICRP does not include a certification – –
The agency can unilaterally disallow all indirect costs The agency can unilaterally establish their own rate based on historical cost or other such data, to ensure that unallowable costs won’t be reimbursed.
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To summarize...
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• • Account incurred cost Click tofor edit Master text styles • – Documentation Second level such as time reports which supports the incurrence and allocation of cost o Third level
• Identify– unallowable cost Fourth level » Fifth level remain in allocation base, • Unallowable items receive a share of indirect cost • Unallowable items, items not entitled to retain, profit/excess funds must be returned to agency • Unallowable expenses determined later will be returned and rates adjusted downward
• Click to edit Master text styles • What is direct remains direct, same for indirect,
Secondcharging,e.g. level no– double 10% de minimis o Third level • Consistent allocation to avoid double-charging – Fourth level • Direct costs more » Fifth levellatitude: proration of cost or admin salaries identified/supported • Statutory limitations, limits the recovery in an award, even though the rate is determined higher - 10% limitation on Ryan White administrative cost
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Cost Accounting Definitions o Third level
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Segregate cost Master for each government • • Click to edit text stylesgrant • – Distinguish direct and indirect cost Second between level o Third level • Consistent cost allocation of indirect cost •
– Fourth level Identify unallowable, non-recoverable cost
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Assign cost to the appropriate accounting period
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Sufficient accounting controls to ensure compliance with government grant regulations
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Capable of performance measurement, such as provisional vs. actuals for indirect burden rates
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Facilitate the development of indirect cost rates
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• • Direct Cost costs specifically Click toare edit Master textidentified styles or traceable to – a Second Federal award, level project or activity 200.413(a) • Examples: o Thirddirect level labor and related fringe benefit cost, direct material, – Fourth level supplies, consultants, sub-awards, » Fifth level travel 200.413(b) & Appendix IV B.3.b.(4)2nd¶ • Direct charging of salaries of administrative personnel 200.413(c) [slide 13] • Direct proration of cost between 2 or more activities without undue effort 200.405(d) • Unallowable direct cost remain in base 200.413(e)
• • Click to edit text for styles Develop costMaster estimates grant – Second level proposals used in the SF 424a o Third level • Manage within cost measurement and – Fourth level performance requirements » Fifth level • Full Cost Recovery – Difficult to achieve – Certain grants restrict administrative cost – Certain NEA vehicles exclude indirect – State and local units of gov’t limit rates
• • Click to editon Master text Costs styles Limitation Indirect
– – Second Award – level specific rate (predetermined) o Third level
– Limitation on indirect cost recovery, i.e. if – Fourth level » Fifthdid levelnot provide an indirect rate awardee percentage in 6j of the SF 424-a, the awardee is barred from claiming and recovering indirect cost for this grant
• Click Indirect ratesMaster synonymous with: to edit text styles – Burdens – Second level o Third level – Loading – Fourth level – “Overhead” » Fifth level • Types – Fringe – G&A (Indirect, Management & General from IRS Form 990) – F&A: Facilities & Administrative rates
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Indirect Cost are costs not directly identified with a • single Clickfinal tocost edit Master text styles objective (grant), but rather relates to
two or more final cost objectives, or a service center, – Second level like occupancy o Third leveldepartment. Indirect – costs cannot be economically traced to each Fourth level grant so they must be placed in a cost pool to be » Fifth level allocated on a causal-beneficial basis to the final cost objective or grant. In developing a cost pool special care that costs can first be identified direct to a program, no doublecharging Appendix IV B.3.b.(4) 2nd¶ (paragraph) Typical indirect expenses are: office supplies, postage, local telephone, periodicals, memberships per Appendix IV B.3.b.(4) 2nd¶
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Indirect o Third levelRate Negotiation and Administration – Fourth level » Fifth level
• Click to edit Master text styles • OMB Circular A-122, Attachment A, § C – Second level and 2 CFR 200.414(b) o Third level – Fourth level » Fifth level
• Due to diverse characteristics and accounting practices of nonprofits, it is not possible to specify the types of cost which may be classified as indirect in all situations.
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• OMB Circular A-122, Attachment A, § A.6 – Second level • Under any award, the allocation and o Third level reasonableness – Fourth level of certain expenses may be difficult to determine » Fifth level • Purpose is to avoid subsequent disallowance or dispute • Seek a written agreement with cognizant awarding agency in advance of incurrence of cost • Examples provided such as pre-award costs
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OMB Circular A-122, Attachment A, § D.1.e – Second level Appendix IV B.1.e to 2 CFR 200 o Third level Period– for allocating and accumulating Fourth level incurred » indirect Fifth level cost to grants – Base period equals the org’s fiscal year – Grants cross over two fiscal years o Two different indirect rates
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• Negotiation and Approval of Indirect Rates – Second level pero Third OMB level Circular A-122, Attachment A, § E
– Agency with largest dollar value = cognizant – Fourth level agency» Appendix Fifth level IV C.2 – Indirect rate proposal submitted 90 days after new award to an organization App. IV C.2.b – May not happen if you have program restrictions, o HRSA Part B, CFDA 93.914 limits adm. to 10%
– Issues when agency is not proactive in the negotiation and settlement of indirect rates
• Click Negotiation to edit and Master Approval text styles of Indirect Rates – Second level o Third level – Existing org’s submit new rate proposals – Fourth level within 6 months after the end of their fiscal » Fifth level year Appendix IV C.2.c – Predetermined rate is based on estimate of costs to be incurred for the current or future fiscal year. The predetermined rate is not subject to adjustment. Appendix IV C.2.d
• • Fixed are similar to preClick(ceiling) to editrates Master text styles determined rates except: App. IV C.2.e – Second level – The difference between the estimated and o Third level actual costslevel of the period are carried – Fourth Fifth level forward» as an adjustment to the subsequent period’s indirect rate computation • Final rate Appendix IV C.1.d & C.2.f – Based on actual cost for period – Once negotiated, not subject to adjustment
Click to edit Master text IV styles • • “Provisional” Rate Appendix C.1.e & C.2.f Second indirect level cost rate pending final rate – – Temporary o Third level – Used for funding, interim billing or cost reporting – Fourth level • The results of any negotiation is distributed to » Fifth level other participating agencies Appendix IV C.2.g • Negotiating rates must be accepted by ALL Federal awarding agencies 200.414 (c)(1) • Many clients complain they cannot find the office for negotiating indirect rate
– Look at conditions clauses attached to grant
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Basic Indirect Rate Mechanics
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– Fourth level » Fifth level
• Click to edit Master text styles – Second level fringe cost includes • For example, o Third level pension, insurance and – Fourthmedical level » Fifth level payroll taxes for direct personnel, working on multiple programs, that cannot be economically assigned to each of those grants.
Click Master textreside stylesin a cost • • Each ofto theedit fringe expenses – Second level pool to be allocated on a causal-beneficial basiso Third to thelevel final cost objective or grant. – Fourth levelis the numerator and total • Fringe expenses » Fifth level labor dollars is the denominator to develop a % via a fraction. • Total labor has a functional relationship with fringe expense where total labor is the independent variable and fringe is the dependent variable.
Fringe & Base Example: • ClickPool to edit Master text styles Indirect Cost Pool: – Fringe Second level
$1,500 Pension o Third level 1,500 Medical Insurance – Fourth level 500 Payroll Tax » Fifth level $3,500 Total Fringe $2,000 Direct Labor (D/L) Grant A 8,000 D/L Grant B $10,000 Total Grant D/L* (Allocation Base) $3,500/$10,000 = 35% Fringe Indirect Burden Rate *Missing indirect labor applied to G&A.
Example: • Fringe Click Application to edit Master text styles
Grant A: – Second level $2,000 D/L o Third level 700 Fringe ($2,000 D/L x 35% fringe rate) – Fourth level 1,400 Other Direct Costs (ODCs) » Fifth level $4,100 Total cost for Grant A-final cost objective Grant B: $8,000 D/L 2,800 Fringe ($8,000 D/L x 35% fringe rate) 9,600 ODC $20,400 Total cost for Grant B-final cost objective
• General administrative costs Click to fund edit =Master text styles – director’s office – Executive Second level
– Finance, HR, IT, Purchasing, Facility Mgmt. o Third level – Office Space, Utilities, Audits, Insurance – Fourth level – Value =» $150,000 Fifth level (A)
• Programs, Value = $1,000,000 (B) – $900,000 in non-federal: programs, fundraising, membership, promotion, P/R – $100,000 federal grant
• Fractional relationship between general fund (M&G) and Programs = 15%
Distribution of Indirect Cost Pool Using 15% Indirect Rate
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$135,000 , 90%
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$15,000 , 10%
Federal Award of $100,000
• • Click to edit Master text styles Total Cost of Grant – Second level • $100,000 direct costs
o Third levelapplied indirect (15% x $100,000) • $15,000 – Fourth level • $115,000 = total » Fifth level
value of grant
• Total Cost Definition – The sum of direct and indirect costs allocable to an award less credits, refunds, rebates; and excluding unallowable costs. – OMB Circular A-122, Attachment A, A.1 and 200.402
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Analysis of Indirect Expenses
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– Fourth level » Fifth level
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• Indirect Rate Loading Factor: – Second level – Fringe o Third (1.35) level x G&A (1.25) = 1.6875
– Fourth level – For every D/L $1.00 spent, there will be an » Fifth level additional cost of 69¢ in burden cost.
1. 15% is to lower for Master IRS 990 • Click edit 2. 40% higher recovery?
text styles
– Second level
• Which is better 1 or 2? It o Third level depends.
– Fourth level • Rates are a function of base » Fifth level
• Foundations place limits on rates
• Under Federal rules you get all of your cost pool • Evaluate your indirect rate based on a comparison between 2 FYs
• Click to edit Master text styles Fringe Pool Example: – Second level o Third level
FY 2013– Fourth levelFY 2014 » Fifth level $1,500 15% $1,500 1,500 15% 2,500 500 5% 500 $3,500 35% $4,500 $10,000
$7,500
Account 20% Pension 33% Medical 7% Payroll 60% Fringe Pool Total Labor Base
• • OMB Circular A-122, Attch A, D.2.a. App. IV B.2 Click to edit Master text styles • Single purpose entity, small or large nonprofit with – Second level smallo Third amount of awards level – Fourth level indirect less credits from direct • Separate allowable » Fifth level cost
• Divide indirect by direct cost base (w/unallowable $) • Facility cost is combined with administrative pool • Facility cost supports direct and indirect personnel • Amount of federal awards is small
• Click Indirect to edit cost Master classified text into styles two broad activities: A-122, Attachment A, § C.3 – Second level o Third level and Appendix IV B.3.b – Fourth level – Facilities: buildings, equipment and capital » Fifth level investments, maintenance and operation expenses and interest
– Administration: general administration, director’s office, accounting, HR, library expenses and other types of expenditures not mentioned under “facility”
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• If an organization has more than $10 Million Secondfunding level of direct costs in a fiscal in– federal o Third level year, a breakout of indirect cost into two – Fourth level components: facility and administration, » Fifth level having indirect cost rates. • OMB Circular A-122, Attachment A, § C.3.e and 200.414 (a) last sentence of ¶, Appendix IV B.2.e
• General Administrative MTDC Base App. IV Click to &edit Master text styles B.2.c – Second level – Allocate on Modified Total Direct Cost (MTDC) o Third level – Direct labor, applied fringe, non-labor direct – Fourth level – Exclusions from MTDC base shown on next slide » Fifth level
• G&A Salaries and Fringe Base – Direct labor and applied fringe only Appendix IV B.2.c
• G&A Salary Base (per HHS indirect template) – Only direct labor • Results of special cost studies must not be used to determine and allocate indirect cost to Federal awards per Appendix IV B.3.c (last sentence of paragraph)
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• Salaries and wages (direct labor) – Second level • Fringe benefits o Third level on direct labor • Materials andlevel supplies, services & travel – Fourth Fifthsubcontracts level Sub-grants » and up to the first $25,000 of each sub-grant or subcontract, regardless of period covered by sub-grant
• Amounts excluded from MTDC: – Sub-grants/subcontracts > $25,000 – Equipment, capital expenditures (rent removed) – Participant support cost must be excluded
• • OMB Attachment ClickCircular to edit A-122, Master text stylesA, § B.3 and 200.413(e) – Second level • Cost of Certain Activities – Direct Cost o Third level Functions Remain in MTDC base though – Fourth level unallowable, must be treated as direct costs » Fifth level to determine ind. rates – Fundraising (not mentioned in super circular) – Membership – Promotion, lobbying, & public relations
• Bid & Proposal allowable per 45 CFR 74.27 – B&P is not fund raising – Proposal Costs new cost principle 200.460
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Allocate occupancy direct
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– Fourth level » Fifth level
• Click to edit Master text styles Rent example of allocability: level directly for a separate office 1. – Second Rent charged o Third level devoted to one grant 2.
– Fourth level Rent (G&A) applied » Fifth level
via square footage (SF) to various departments/programs based on SF or some other basis (next slide)
3. Allocating rent for executive director or director of finance, no direct relationship to grant or direct activities
• Click to edit Master text styles Rent example of allocability: levelapplied to various 2. – Second Rent (G&A) o Third level departments/programs based on SF or – Fourth level payroll dollars » Fifth level
a. If site devoted to grant is 1,000/10,000 SF for 10% of total rental cost ($5,000 = $500) b. If $5,000 in total rent is allocated via D/L dollars over $20,000/$80,000 = 25% for this program/ grant (total rent = $1,250), i.e. Direct Allocation Method Appendix IV B.4
• • Click to edit Master text styles Joint costs – depreciation, rental cost, repair
Second level telephone, and the like &– maintenance, o Third level (utility, property insurance, etc) – Fourth level • Prorate on a base that accurately measures » Fifth level benefits provided to each direct award and indirect departments Appendix IV B.3.c(1)(c) & (d) – Direct and indirect FTE positions – Hours worked direct and indirect – Direct and indirect labor dollars
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• Square footage for direct and G&A areas is – Second level difficult to measure and keep up to date o Third level
• In order to use – Fourth levelthe Direct Allocation Method, make sure thelevel grant budget has a line item » Fifth for joint costs or occupancy • Set up a separate department to track and allocate joint costs to direct and indirect cost objectives • OMB Circular A-122, Attachment A, § D.4.
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Multiple Cost Pools – Second level o Third level Step Allocations & Overhead – Fourth level » Fifth level
• Click to edit Master text styles – Second level • Indirect costs benefit major functions in o Thirddegrees level varying •
– Fourth level Indirect costs accumulated » Fifth level
into separate
cost groupings
• Constitute a pool of expenses that are of like character as they relate to base • Allocated to functions by means of a base which best measures relative benefits
• Click to edit Master text styles – Second level o Third level – Fourth level » Fifth level
• Click to edit Master text styles – Second level • Costs assigned to direct programs + adm dept’s o Third level to all dept’s including G&A • Fringe allocated •
– Fourth level Occupancy allocated » Fifth level
to all dept’s including G&A
• Program Administration (PA) can be allocated – PA is not G&A – PA cannot be recovered under OMB
• Special allocation of studio 50010 • G&A allocated to 10000 through 60000
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• Grouping (PA) administrative costs by – Second level department under a functional grouping o Third level – Department Head or VP – Fourth level
» Fifth level – Receptionist or other admin personnel
– PA supports the programs under 10000 series …
• Governmental group w/ multiple grants – Burden is necessary to recover admin $
• Can you recover local overhead? NO
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Special Rates & Double-Charging
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– Fourth level » Fifth level
• Click to edit Master text styles • A– single rate for all functions may not take Second level intoo Third account level factors that may impact a particular segment of work – Fourth level » Fifth level • Factors might include: – Site location: geographic or government site – Level of administrative support required – Level of facility or other resources used
• Click to edit Master text styles – Second level • Bifurcated G&A to avoid doubleo Third level
charging – Fourth level » Fifth level – Same administrative rate % for segments – Some segments have different facility cost due to different geographic locations – Some segments have no facility cost since the effort is performed at a government site
• Click to edit Master text styles – Second level • • • • • • •
level Majoro Third problem to get first NICRA approved – Fourth It is essential thatlevel each item of » Fifth Cost incurred for level the same purpose Be treated consistently in like circumstances Either as a direct or indirect (F&A) cost In order to avoid double-charging on Federal Awards. 200.414(f) 10% de minimis rate must be charged consistently as direct or indirect, but not be doublecharged or inconsistently charged AS BOTH
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• • Click to edit Master Administrative is 10%text andstyles Facility: Rent – Second cost is 5%level o Third level • 5% facility cost recap: (facility/ rent – Fourth level cost) » Fifth level – 1% facility cost for indirect personnel – 1% facility cost charged as direct-purpose rent to some grants as a direct cost – 3% facility cost for direct-purpose rent that could not be recovered direct
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Indirect Rate Agency Models
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– Fourth level » Fifth level
• Click to edit Master text styles • U.S. Department of Labor – Second level
o Third level • Indirect Cost Rate Determination – Fourth level Guide: » Fifth level
http://www.dol.gov/oasam/boc/dcd/npcomm-guide.htm
• DHHS ICRP Template: https://rates.psc.gov/fms/dca/np_exall2.html
Statement of – Second level Functional Expense o Third level used in Templates
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• • Click to edit Master text styles Service and Not For Profit (NFP)
– Second level – Non-Profit org’s – OMB Circular A-122 and o Third level Appendix IV – Fourth level » Fifth level
– Dept. of Labor & DHHS models
• Outside forces on NFPs – IRS 990 SFE – (FASB 117) ASC 958 SFE
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Permission to use from client
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HHS Indirect SOFE Template
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– Fourth level » Fifth level
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Any Questions? • Click to edit Master text styles – Second level o Third level – Fourth level » Fifth level
• Click to edit Master text styles materials – The Second level contained herein or discussed o Third levelin the seminar or shown in FourthPowerpoint level the– MS slides, are for » Fifth level illustrative and academic purposes only and should not be considered appropriate for your organization without careful adaptation by experts in the appropriate field of endeavor.