United States Department of Agriculture 

Animal and Plant Health Inspection Service 

Wildlife Services Directive 

WS 2.215 

9/23/2019

FINANCIAL MANAGEMENT OF REIMBURSABLE AGREEMENTS AND 

CARRYOVER ACCOUNTS 

1. PURPOSE 

The purpose of this Directive is to provide specific guidance for the standardization and 

consistent financial management of reimbursable agreements and carryover accounts 

across Wildlife Services (WS) work units. This Directive does not alter policy regarding 

Congressional appropriations. 

2. REPLACEMENT HIGHLIGHTS 

This Directive replaces WS Directive 2.215 dated August 23, 2013. 

3. AUTHORITY 

a. 7 U.S.C. 8351 to 8353, and 16 U.S.C. 667, authorizes officers, agents, and employees 

of the United States Department of Agriculture (USDA), Animal and Plant Health 

Inspection Service (APHIS), Wildlife Services to conduct a program of wildlife 

services and to enter into agreements with states, local jurisdictions, individuals, and 

public and private agencies, organizations, and institutions for the purpose of 

conducting such services.

b. 26 U.S.C. 6402 (d), Internal Revenue Code. Authority to make credits or refunds, 

(d) Collection of debts owed to federal agencies 

c. 31 U.S.C. 3720A, Money and Finance. Reduction of tax refund by amount of debt 

d. 15 U.S.C. 3710a et seq., Federal Technology Transfer Act. Cooperative research and 

development agreements 

e. 31 U.S.C. 1535, Economy Act. Agency agreements 

f. 16 U.S.C. 670a-670o, Sikes Act. (a) Cooperative plan for conservation and 

rehabilitation, (b) Migratory game birds; hunting permits, (c-1) Cooperative and 

interagency agreements for land management on installations, (d) Liability for funds; 

accounting to Comptroller General, (e) Applicability to other laws; national forest 

lands, (f) Appropriations and expenditures, (g) Wildlife, fish, and game conservation 

and rehabilitation programs, (h) Comprehensive plans for conservation and 
Wildlife Services Directive 2.215 2

 

rehabilitation programs, (i) Public land management area stamps for hunting, 

trapping, and fishing on public lands subject to programs, (j) Enforcement provisions, 

(k) Definitions, (l) Stamp requirements not applicable to Forest Service and Bureau of 

Land Management lands; authorized fees, (m) Indian rights; State or Federal 

jurisdiction regulating Indian rights, (o) Authorization of appropriations 

4. POLICY 

WS will recover all costs incurred while performing work funded by reimbursable 

agreements. WS will adhere to the described computational methods for fiscal 

management of reimbursable agreements and carryover accounts. 

Financial agreements must be consistent with WS and the cooperators’ internal policies, 

regulations and procedures. Agreements will be consistent with state and local laws and 

regulations in accordance with WS Directive 2.210. 

5. BACKGROUND 

WS accomplishes its mission by utilizing the following funding arrangements: 

a. Appropriations from Congress (not impacted, altered, or augmented by this 

Directive). 

b. Funds provided by cooperators. These funding agreements can be divided into two 

major categories: 

(1.) Federal (e.g., Interagency Agreements) 

(2.) Non-federal (e.g., Cooperative Service Agreements, Cooperative Research and 

Development Agreements, Material Transfer and Research Agreements, and 

Over the Counter Service Agreements) 

c. Combinations of Congressional appropriations and cooperator funds (commonly 

known as Cost-Share programs). 

6. DEFINITIONS 

a. Actual Cost: The cost of a particular cooperatively funded project, established by WS 

work units that is based upon the full cost of rendering the service (the sum of WSestablished direct, indirect, pooled job, and flat rate [as applicable] costs).

b. Allowable Cost: A cost, as recorded on the WS agreement’s Financial Plan, which

meets the criteria for authorized expenditures. Generally, it is a cost that WS intends 

to collect and is necessary for the project objectives.
Wildlife Services Directive 2.215 3

 

c. Carryover: Those funds collected by WS as no-year indirect, pooled job and flat rate 

costs which remain available until expended for purposes authorized by law. 

d. Cooperative Research and Development Agreement (CRADA): An agreement, made 

pursuant to 15 U.S.C. 3710a, between a federal laboratory and a non-federal party to 

perform collaborative research and development in any area that is consistent with the 

federal laboratory's mission.

e. Cooperative Service Agreement (CSA): A reimbursable agreement in which a nonfederal entity requests, and WS agrees, to provide technical or operational assistance, 

goods, or services on an annual or greater timeframe (generally from one to five 

years). These reimbursable agreements are identified by individual financial accounts 

in the USDA accounting system on a full cost recovery basis. Both pooled job costs 

and indirect costs are assessed unless formally waived through the waiver process as 

outlined in this directive and in Enclosure 2. 

f. Cooperator: Any government, public or private agency, organization, institution, 

corporation, individual, or other entity with which WS programs enter into a 

reimbursable agreement. 

g. Cost-Share: A formalized arrangement through which Congressional appropriations 

are used in conjunction with other funding sources toward a common goal. 

Cooperators, both federal and non-federal, can participate in cost-shares with WS. 

Cost-share arrangements outline the roles of each participant and the intent of each 

funding agreement that complements or directly aligns with Congressional 

appropriations. Each participant is responsible for the payment of all costs pertaining 

to its portion of the cost-share. 

h. Direct Cost: Any item of expense which can be specifically identified and computed, 

as is directly associated with a product, service, activity, or project. 

i. Financial Plan: A categorized summary of WS costs to perform a program or project. 

j. Flat Rate: An hourly rate applied to an agreement that allows WS to recover and 

retain funds to pay for large maintenance, repair, and replacement costs that may be 

incurred outside of the period of performance of any particular agreement. 

k. Indirect Cost (Overhead): Any item of expense incurred for a common objective that 

is not readily identifiable with a particular project or program but necessary to the 

general administration and conduct of cooperatively funded program activities.

l. Interagency Agreement: A reimbursable agreement made in accordance with the 

Economy Act, 31 USC 1535, in which WS is requested, and agrees, to provide 

technical or operational assistance, goods or services for another federal entity 

(generally from one to five years). These reimbursable agreements are identified by 

individual financial accounts in the USDA accounting system. 
Wildlife Services Directive 2.215 4

 

m. Material Transfer and Research Agreement (MTRA): An agreement between a 

federal laboratory and a non-federal party to perform collaborative research and 

development in any area that is consistent with the Federal laboratory's mission. The 

MTRA outlines the conditions and rights of transfer of material, may involve transfer 

of funds to WS, and is used primarily for proof of concept. A MTRA may lead to 

more extensive research that would be conducted under a CRADA. 

n. Over the Counter Service Agreements (OTCS): Agreements, previously known as 

Cooperative Service Field Agreements (CSFA), in which WS is requested to provide 

technical or operational assistance, goods, or services on a short-term basis (less than 

one year) with a financial value no greater than $7,500. Payment is due at the time of 

service and no USDA accounting system bill is sent to cooperators. These agreements 

are implemented through a consolidated financial account in the USDA accounting 

system that references the WS work unit responsible for performing the related work 

or providing the requested product. Individual accounts are not required. Due to the 

short term nature of these agreements, pooled job costs are always waived without the 

need for a waiver request. Indirect costs are always assessed. 

o. Pooled Job Cost: Any item of expense that may be directly identified with a project or 

program, but is not readily identified with a single agreement, and is distributed 

across identifiable projects or programs to which it pertains. These costs are assessed 

on Cooperative Service Agreements, Interagency Agreements, CRADAs, and 

MTRAs because of the long-term time frame of the agreement and the associated 

expenses that accumulate over this time frame. 

p. Projects: Products, work tasks, or similar activities resulting in an output(s) or an 

accomplishment(s). 

q. Reimbursable Closeout Figures: The sum of all reimbursable expenses that occurred 

October 1st through September 30th of the just ended FY, as recorded in the USDA 

accounting system.

r. Reasonable Cost: A cost, as recorded on the WS Agreement’s Financial Plan, which

does not exceed an amount that a prudent person, under the circumstances prevailing 

at the time the decision is made, would incur. 

s. Reimbursable Agreement: An agreement through which WS is reimbursed for the 

cost of technical and operational assistance, goods, or services provided to a 

cooperator. This includes cost-share programs in which a cooperator reimburses WS 

for their portion of assistance provided. Cooperative Service Agreements, CRADAs, 

Interagency Agreements, MTRA and OTCS agreements are types of reimbursable 

agreements. 

t. Work Breakdown Structure (WBS)/Funded Program Element: A unique project code 

assigned to reimbursable agreements to properly track and account for expenses. 

This is a piece of master data that is utilized in the USDA accounting system. 
Wildlife Services Directive 2.215 5

 

7. IMPLEMENTATION 

REIMBURSABLE AGREEMENTS 

WS and its personnel will adhere to federal, USDA, APHIS, and WS policy when 

projecting costs, charging expenses, billing, collecting, and monitoring all reimbursable 

agreements under this Directive. 

a. Projecting Cost: WS work units project and assign costs to projects by expense type. 

Costs must be associated with individual projects, to the extent feasible. Direct cost 

estimates will be determined by the office responsible for performance under the 

agreement and indirect, pooled job and flat rate costs will be applied as appropriate to 

create the actual cost of the agreement. 

b. Financial Plan Creation: Each Agreement’s Financial Plan will be created as a result 

of the actual cost projection and shall reflect as much detail as necessary to support 

the resources required to provide the goods and services. Expense categories within 

financial plans shall also be in alignment with invoice categories to ensure timely 

payment of invoices and reduce confusion and questions from cooperators. 

c. Reimbursable Agreement Creation: Agreements will include a Financial Plan that 

provides for direct costs, and the application of indirect, pooled job, and flat rate (if 

applicable) costs. See Enclosure 1. If indirect and/or pooled job costs are waived, the 

agreement should include the executed waiver. 

WS will use the most recent language provided in the APHIS Agreements 

Management Manual and WS reimbursable agreement templates. Appropriate contact 

information will be included with the agreement. Interagency agreements shall be 

used with cooperating federal agencies. 

d. Waiver Requests: Indirect and pooled job costs rates must be included in 

reimbursable agreements unless waived by the WS Regional or NWRC Directors, 

with the concurrence of the WS Deputy Administrator. Waivers can be requested for 

each of the specific indirect cost items (i.e., WS 11% or APHIS 5.15%) or the pooled 

job cost (i.e., WS 11%). If waivers are granted, the entire specific cost item is waived. 

There is no variability within these cost items. 

Waivers will be requested and considered on a case-by-case basis. Directors are to 

consider the relevant factors (e.g. state laws, insignificant need, etc.) and their overall 

knowledge of the WS work unit for which they are responsible. A cooperator’s lack 

of complete funding of an agreement is not a relevant factor to consider for waiver 

requests of either the APHIS or WS indirect costs. The request form for waiver of WS 

indirect and pooled job costs is contained in Enclosure 2. 
Wildlife Services Directive 2.215 6

 

e. Billings & Collections: Applicable costs (direct, indirect, pooled and flat rate) will be 

appropriately charged to the Agreement’s account(s), and billed as stipulated in the 

Agreement. All financial transactions will be recorded in the official topic-specific 

system (e.g. webTA, Access Online, WEX, etc.) which feed into the larger USDA 

accounting system. Costs will be reviewed to determine that they are allowable, 

reasonable and consistent with the Reimbursable Agreement’s Financial Plan. Any 

expenses that are determined to be inappropriately charged to the Agreement will be 

removed and redirected to other appropriate agreements or appropriations. When 

cooperators demonstrate a history of late or non-payment, WS state offices will 

identify those cooperators and may require subsequent agreements with this 

cooperator to be paid in advance. 

f. Surplus Collections: Collected funds remaining at the expiration of a reimbursable 

agreement (expenses that occurred within the period of performance, have disbursed 

and been billed for) will be handled in one of the following ways: 

(1.) Where a subsequent agreement is executed between WS and the cooperator, and 

there is no break between periods of performance, the “excess” funds may be 

credited to the cooperator’s account and will function as an available balance 

pursuant to the work considered under the new agreement; or 

(2.) Remaining funds may be credited to other debts owned by the same cooperator 

for other projects or financial agreements. These debts may be to APHIS or 

other Federal Agencies due to the treasury offset process, in accordance with 26 

U.S.C. 6402 (d) (collection of debts owed to federal agencies), 31 U.S.C. 3720A 

(reduction of tax refund by amount of debts), and other applicable laws; or 

(3.) Any funds collected in advance and remaining in a cooperator’s account after an 

agreement has expired will be considered “excess” and returned to the 

cooperator within sixty (60) days of the final billing of the agreement. 

FINANCIAL MANAGEMENT AND MONITORING

a. Status of Funds (SOF): Every month, WS program offices will review the status of 

funds (SOFs), including open and recently expired agreements to make 

determinations on next financial steps. The SOFs and any identified challenges for 

agreements will be reported to the Operational Support Staff (OSS) upon request of 

OSS or the WS Deputy Administrator, or as deemed necessary by the WS executive 

who oversees the funds. 

b. Accountability and Oversight: The OSS Director will ensure that OSS staff conduct a 

summary level review of the SOFs for all WS programs on a monthly basis, and will 

provide the review results to the Deputy Administrator and Regional Directors. OSS 

will notify the appropriate Regional or National Office of any concerns and will 

provide a reasonable timeframe for resolving them.
Wildlife Services Directive 2.215 7

 

c. Indirect/Pooled Job Cost Category and Rate Review: Regional and National Program 

Offices will conduct periodic reviews of the sufficiency of published indirect/pooled 

job cost categories and rates and will provide recommended changes to the OSS 

Director. Reviews will be conducted upon request by the Deputy Administrator or 

the Director of OSS, and reviews may be conducted at any time the Regional and 

National Program Offices determine a review is warranted. The Deputy 

Administrator considers and approves/disapproves proposed changes to indirect or 

pooled job categories or rates, or changes to the flat rate. 

d. Annual Indirect Costs: WS work units will closely monitor one-year indirect and 

pooled job funds collected from Interagency Agreements. Those funds will be 

accounted for separately and are not considered carryover funds because they are 

appropriated by Congress.

CARRYOVER ACCOUNTS AND CARRYOVER BALANCES

“Carryover” balances represent those funds that are collected by WS as no-year indirect, 

pooled job, and flat rate costs which remain available until expended for purposes 

authorized by law. Carryover balances are found only in carryover accounts which 

include the IDCT, POOL, and FE.FR accounts for each work unit. 

Unexpended available funds intended for future direct costs associated with multi-year 

agreements are not considered when calculating carryover balance limits. In addition, 

funds within the OTCS accounts are not considered when calculating carryover balance 

limits. The OTCS account is coded as a no-year account in order for the accounting 

system to process correctly across fiscal years. This account is a consolidated financial 

account for payments from small, short-term agreements (less than one year) to be 

entered into and expended against. As a result, this account has high turnover and will 

never contain funds collected more than 24 months prior. This high turnover rate prevents 

OTCS from being considered a carryover account or being included in the carryover 

balance limits. There may a balance in this account at the end of a fiscal year, however 

funds are expected to be spent on specific OTCS agreements or returned to cooperators. 

a. Need for Carryover Balances: Requests for WS assistance vary over time. Factors 

such as federal, state and local cooperator appropriation timelines, work seasonality, 

commodity prices, weather conditions, and disease prevalence affect variability in 

work. Carryover balances allow WS to manage wide fluctuations in its workload and 

continue providing critical services at the state and national levels. Mitigating 

performance risk requires having resources available to maintain organizational 

capacity during periods between peak demands. It is cost prohibitive and logistically 

impossible to release and reacquire the personnel, facilities, and equipment partially 

funded with carryover without WS mission degradation. Carryover balances provide 

relief from unforeseeable program expenses such as property damage, litigation, and 

accidents. 
Wildlife Services Directive 2.215 8

 

b. General Operating and Personnel Costs: Carryover balances may be used to pay for 

any general operating costs, including payment of accumulated balances for 

compensatory time, earned credit hours, annual leave, and sick leave, as well as 

buyouts/voluntary separation incentives, and severance pay. Specifically, it is 

permissible to use carryover balances to pay for the aforementioned benefits 

accumulated by both temporary and full-time employees. 

c. Upper and Lower Limits: To ensure carryover balances are not unbounded, 

percentages of total fiscal year reimbursable expenses are used to calculate upper and 

lower limits for carryover balances. Carryover limits are unique to each state or 

NWRC program. These limits are set based upon the most recently ended fiscal year 

reimbursable closeout figures. The targeted carryover range should be between 20 

and 25 percent of the closeout figures. 

Exception: In programs that manage agency-owned aircraft, the upper limit may be 

higher than 25 percent due to the need for additional resources to maintain these 

assets and prepare for known and expensive maintenance requirements and parts 

replacement. 

d. Accountability and Oversight: Regional and National Offices will conduct a review 

of their respective State and Field Station carryover balances annually and shall 

inform the Deputy Administrator of the results of these reviews. These offices will 

provide guidance whenever carryover balances fall outside of the carryover account 

limits. 

8. SCOPE 

This Directive is applicable to all WS programs. 

9. REFERENCES 

WS Directive 2.210, Compliance with federal, state, and local laws and regulations 

10. ENCLOSURES 

Enclosure 1: Table and guidance related to Direct, Indirect, and Pooled Job Costs 

Enclosure 2: Sample WS Indirect/Pooled Job Cost Waiver Request 

Janet L. Bucknall 

Deputy Administrator 
Wildlife Services Directive 2.215 Enclosure 1 

Table of Direct, Indirect, and Pooled Job Costs 

Categories

Direct Indirect* 

(16.15%)

Pooled Job 

(11%)

YES NO YES NO YES NO

Personnel Compensation

Accrued Annual, Compensatory and Sick Leave X X X

Awards X X X

Buyouts and Voluntary Separation Incentives X X X

Salary and Benefits X X X

Severance Pay and Lump Sum Leave Payout X X X

All Other Expenses

Accidents (Tort) X X X

Agency Costs* X X X

Equipment & Associated Maintenance – Project X X X

Equipment & Associated Maintenance – General X X X

Information Technology/Software – Project Related X X X

Information Technology/Software - General X X X

NEPA X X X 

Relocations – Project Related X X X

Relocations – General X X X

Rent/Lease – Project Related X X X

Rent/Lease – General X X X

Security Systems – Project Related X X X

Security Systems – General X X X

Services – Project Related X X X

Services – General X X X

Supplies – Project Related X X X

Supplies – General X X X

Telecommunications – Project Related X X X

Telecommunications - General X X X

Training – Project Related X X X

Training – General X X X

Travel – Project Related X X X

Travel – General X X X

Travel (Volunteer) X X X

Utilities – Project Related X X X

Utilities – General X X X

Vehicle Purchase – Project Related X X X

Vehicle Purchase - General X X X

Vehicle Usage – Project Related X X X

Vehicle Usage – General X X X

*Agency indirect costs calculated at a rate of 5.15% of direct costs – includes services such as financial 

management, human resources, purchasing, and other agency level services provided to Agency program 

projects. Not available to WS.
Wildlife Services Directive 2.215 Enclosure 1 

Personnel Compensation 

Accrued Annual, Compensatory, and Sick Leave: 

Direct Cost – Accrued leave of staff working directly on the project. 

Indirect Cost – Accrued leave of administrative staff that conduct work on behalf of the entire 

work group. 

Pooled Job Cost – Accrued leave of field staff working directly on more than one related 

project, pooled to spread costs across many projects.

Buyouts and Voluntary Separation Incentive Program (VSIP): 

Indirect Cost – Buyouts and VSIP costs of administrative staff working on behalf of the entire 

work group. 

Pooled Job Cost – Buyouts and VSIP costs of field staff working directly on more than one 

project, pooled to spread costs across many projects.

Salary, Benefits, and Awards: 

Direct Cost – Compensation and awards for field staff working directly and for time worked 

exclusively on the project.

Indirect Cost – Compensation and awards for administrative or field staff working on behalf of 

the entire work group (example, state director or budget analyst). 

Pooled Job Cost – Compensation and awards for administrative or field staff working directly 

on more than one project (example, district supervisor).

Severance Pay and Lump Sum Leave Payout: 

Direct Cost – Severance pay/lump sum leave payouts of staff working directly on the project. 

Indirect Cost – Severance pay/lump sum leave payouts of administrative or field staff that 

conduct work on behalf of the entire work group. 

Pooled Job Cost – Severance pay/lump sum leave payouts of field staff working directly on 

more than one project, pooled to spread costs across many projects. 

All Other Expenses 

Accidents (Tort): 

Direct Cost – Tort claim costs related to a specific project. 

Indirect Cost – Tort claim costs not related to a specific project or projects but are tied to work 

supporting the entire work group.

Pooled Job Cost – Tort claim costs related to project work but not tied to any specific project, 

pooled to spread costs across many projects. 

All Other General Expenses: 

Indirect Cost – General expenses that benefit the entire work group which are not specific to a 

specific project or project work. This includes general expenses for equipment and associated 

maintenance, information technology/software, NEPA, relocations, rent/leases, security systems, 

services, supplies, telecommunications, training, travel, utilities, vehicle purchases, and vehicle 

usage. 
Wildlife Services Directive 2.215 Enclosure 1 

All Other Project Related Expenses: 

Direct Cost – Project specific expenses which are incurred specifically for a particular project 

and are easily identified. This includes equipment and associated maintenance, information 

technology/software, NEPA, relocations, rent/leases, security systems, services, supplies, 

telecommunications, training, travel, utilities, vehicle purchases and vehicle usage. 

Pooled Job Cost – Expenses which are incurred for project work but not associated with a 

specific project, pooled to spread costs across many projects. This includes equipment and 

associated maintenance, information technology/software, relocations, NEPA, rent/leases, 

security systems, services, supplies, telecommunications, training, travel, volunteer travel, 

utilities, vehicle purchases and vehicle usage. 
Wildlife Services Directive 2.215 Enclosure 2 

WS Indirect/Pooled Job Cost Waiver Request Form 

Agreement Number: 

Cooperator: 

Agreement Amount: 

Indirect Costs Waived (16.15%) 

WS Portion of Indirect Costs Waived (11%): $____________ 

Project has insignificant indirect costs (e.g., direct costs are on-hand supplies)

Required by statute or policy (specify the statute or policy)

________________________________________________________________________ 

Indirect Costs are cost-shared by WS (where the cost share is identified and 

documented within the supporting financial plan)

Department, Agency, Program strategic priority (provide additional information)

________________________________________________________________________

________________________________________________________________________ 

 Other: 

________________________________________________________________________ 

________________________________________________________________________ 

APHIS Portion of Indirect Costs Waived* (5.15%): $____________ 

*Requires APHIS Administrator approval 

Project has insignificant indirect costs (e.g., direct costs are on-hand supplies)

Required by statute or policy (specify the statute or policy)

________________________________________________________________________ 

Indirect Costs are cost-shared by WS (where the cost share is identified and 

documented within the supporting financial plan)

Department, Agency, Program strategic priority (provide additional information)

________________________________________________________________________ 

________________________________________________________________________ 

 Other: 

________________________________________________________________________

________________________________________________________________________ 
Wildlife Services Directive 2.215 Enclosure 2 

WS Indirect/Pooled Job Cost Waiver Request Form 

Pooled Job Costs Waived (11%)

Program Pooled Job Costs Waived (11%): $____________ 

Program does not involve Pooled Job Costs (e.g., small project, all costs are directly 

charged)

Required by statute or policy (specify the statute or policy)

________________________________________________________________________ 

Pooled Job Costs are cost-shared by WS (where the cost share is identified and 

documented within the supporting financial plan)

Department, Agency, Program strategic priority (provide additional information)

________________________________________________________________________

________________________________________________________________________ 

Other:

________________________________________________________________________ 

________________________________________________________________________ 

 

Regional Director/NWRC Director Date 

Concurrence: 

 

Wildlife Services, Deputy Administrator Date