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Consultant Audit Materials

The following sections describe ODOT's requirements for annual cost submissions by A/E Consultants. Additionally, a set of compliance tools are provided to assist A/E Consultants in the preparation of overhead schedules and related financial documents to comply with Part 31 of the Federal Acquisition Regulation (FAR).


 Overhead Submittal Requirements:


On an annual basis, all Consultants that perform any of the "covered work types" must submit current cost information for review by the ODOT Office of External Audits. All Consultants must complete the AASHTO Internal Control Questionnaire for Consulting Engineers (ICQ), available below in the Templates and Tools section. All the required documents listed on the ICQ also must be submitted, and ODOT will accept only the current version of the ICQ. Older versions of the ICQ are obsolete and will not be accepted.

Annual Cost CertificationIn compliance with FHWA Directive 4470.1A, all companies must certify that proposed indirect cost rates were prepared in compliance with applicable Federal regulations. Accordingly, the Consultant Cost Certification document, available below in the Templates and Tools section, is mandatory.  


Submittal Package: A complete package consists of:
(1) the AASHTO ICQ and all the attachments listed on ICQ page B-1; 
(2) documentation sufficient to establish the reasonableness and allowability of executive compensation (see Sample NCM Compliance Worksheet in the Templates and Tools section); and
(3) the Consultant Cost Certification document.  
Note: ODOT has discontinued use of the Supplemental Accounting System Questionnaire (SASQ). 
Covered Work Types: In compliance with 23 U.S.C. 112(b)(2)(B), all companies must submit indirect cost schedules if they perform any of the following types of work: program management, construction management, feasibility studies, preliminary engineering, design, engineering, surveying, mapping, or architectural related services. ODOT does not require CPA-audited indirect cost schedules; however, if a CPA has performed such an audit, it must be included in the submittal package.  

Submittal Method: The required documents must be submitted electronically via email to (Note: Please do not send the documents via "cc" to any other ODOT email addresses.) The documents should be submitted in Microsoft Excel, Microsoft Word, or Adobe PDF format when possible. Please submit all indirect cost schedules in Excel format, if possible. This will greatly facilitate and expedite the review process. Documents submitted in hard copy format or via fax will NOT be accepted.

Confirmation Message: After submitting the indirect cost materials, you should receive an email confirming ODOT's receipt of the submittal package. If you do not receive this email within 24 hours after you submit the package, please verify the email address, and resubmit, if necessary. Note: You will not receive a return receipt or "read" receipt.

Individual email messages must be smaller than  25 MB , including attachments. When submitting your company’s indirect cost package -

1. The Firm name and year of the indirect cost rate schedule must appear in the 
    subject line.
2. The body of the email must include a listing of all attached files.
3. Multiple emails from the same company should be identified accordingly; for
    example, “Sample Consulting Firm, Year 2011 cost submittal, 1 of 3.”


A/E Safe Harbor Rate

The Ohio Department of Transportation (ODOT) is participating in a pilot program that allows for the use of a “Safe Harbor” indirect cost rate of 110 percent to be used by qualifying engineering consulting firms. The fundamental purpose of the Safe Harbor Indirect Cost Rate is to allow time for small engineering consulting firms, new engineering consulting firms, and engineering consulting firms that may not have previous experience with Federally-funded contracts, to become compliant with Federal and State laws and Part 31 of the Federal Acquisition Regulation. For more details, please see the Pathway to Compliance document below in the Templates and Tools section.  

Due Date: Documents must be submitted and updated annually, no later than six months after the close of the Consultant’s fiscal year. Accordingly, the documents are due by July 1 for calendar-year companies.  

Request for Extension: ODOT will grant an extension to the due date for any company that has made a timely submittal to its cognizant audit agency and is awaiting issuance of a cognizant letter of concurrence. Requests for extension must be in writing, on company letterhead, and submitted electronically via email to

Mileage Reimbursement: For direct billings on ODOT contracts, all A/E Consultants are limited to the mileage rate specified by the Ohio Office of Budget and Management (OBM). See the following site for details -

Mileage Logs: A/E Consultants must track mileage on all company-owned vehicles, so that vehicle costs are allocated consistently to direct and indirect cost categories. All direct vehicle costs, and costs associated with commuting and other unallowable activities (as discussed in 48 CFR 31) must be eliminated from the indirect cost rate used for billings on ODOT contracts. Please see the "Vehicle Cost Template" available below in the Templates and Tools section. 

Please direct all questions regarding cost submissions to:

Update: 6/6/2016 (AASHTO Audit Guide – 2016 Edition)
The 2016 Edition of the Uniform Audit and Accounting Guide for Audits of Architectural and Engineering (A/E) Consulting Firms (AASHTO Audit Guide or Guide) is now available for purchase at: The document is a digital download, in PDF format, and is $13/copy.
The AASHTO Audit Guide is a primer in the design of financial and project-management systems that comply with Part 31 of the Federal Acquisition Regulation and related laws and regulations that apply to A/E firms and transportation projects. The Guide also is a collection of recommended best practices that A/E firms and their auditors are expected to apply when designing and operating financial systems that record costs and allocate costs to projects and other cost objectives and/or auditing such systems and projects.
Along with most State Transportation Agencies, The Ohio Department of Transportation has adopted the AASHTO Audit Guide as official policy. Accordingly, A/E firms and their auditors are required to comply with the cost recording processes, allocation procedures, and other recommendations presented in the Guide.

Update: 7/16/2012 - Limited Contracting Status Eliminated:

After reviewing clarifications to the Federal rules concerning indirect cost rates and audits, ODOT reevaluated its Cost Accounting System prequalification categories and determined that the “Limited” category does not comply with Federal requirements. Federal rules require that contracting agencies provide assurance that any indirect cost rate considered for acceptance and use in its contracts has been developed in accordance with the FAR cost principles, as specified in 23 U.S.C. 112(b)(2)(B), 23 CFR 172.7(a), and 48 CFR 31. The requirements for the Limited Cost Accounting category do not meet these requirements.

Update: 5/8/2012:
The National Compensation Matrix (NCM) was released on 5/8/2012; accordingly, the Ohio Compensation Matrix (from former Circular 2) is no longer in effect. To determine the allowability and reasonableness of executive compensation for submissions based on actual costs incurred in years 2011 and thereafter, Engineering Consultants may either:
(a) prepare a compensation analysis in accordance with procedures set forth in Section 7.5 of the AASHTO Uniform Audit & Accounting Guide (2010 Edition), or
(b) use the NCM (please review the NCM Instructions and Q&A for further details).
Note: The NCM is available in the Templates and Tools section (below) or may be downloaded from at the AASHTO website:


Update: 3/2/2012 

The ODOT Contract Audit Circulars are no longer in effect and have been removed from this site. For guidance in designing and maintaining a compliant accounting system and the development of a compliant indirect cost schedule, please refer to the latest version of the AASHTO Audit Guide.



 Templates and Tools:

AASHTO GUIDE Chapter 5 Overhead Schedule - Example 1.xls
AASHTO GUIDE Chapter 5 Overhead Schedule with Fieldrate - Example 2.xls
Cost of Money Template.xls
Related-Party Rent - Cost of Ownership Template.xls
Vehicle Cost Template.xls
Sample NCM Compliance Worksheet.xlsm
AASHTO Audit Guide (2012 Edition).pdf
2013_National_Compensation_Matrix(FINAL 2-1-2013).xls
Pathway to Compliance.docx
2014 National Compensation Matrix (FINAL 2-18-14).xls
2015_National_Compensation_Matrix(FINAL 2-13-2015).xls
2016 NCM (to be used with 2015 data).xls
Appd B-ICQ (05-01-2012FINAL-updated to reference 2016 Guide-12-7-15).doc
Summary of Major Changes to AASHTO Audit Guide (2016 versus 2012 Editions).pdf
2017 National Compensation Matrix  (Final 2-1-17) (1).xlsx
Cost of Ownership Template.xls
Consultant Cost Certification (rev. 7-06-18).doc
2019_National_Compensation_Matrix (use for audits of FYE 2018 cost data).xlsx
2019 NCM LINKS (instructions, position descriptions and compliance template).docx
2020_National_Compensation_Matrix_RC1 (use for audits of FYE 2019 cost data).xlsx
2018-National-Compensation-Matrix (use for audits of FYE 2017 cost data).xlsx

 Reference Links:





Weighted Average Overhead For Net Fee


DCAA Contract Audit Manual (CAM)


Cost of Money Rates 


The 2019 average Prompt Payment Act Interest Rate for use in FCCM computations is 3.125% for companies with a fiscal year ending December 31, 2019. (This is the correct rate to use for FCCM rates for actual costs incurred in calendar year 2019.)
Note: Companies with other than a calendar year-end fiscal year must prorate FCCM using the applicable Prompt Payment rates available at the Cost of Money Rates link shown above.


State of Ohio Travel Policy (Ohio Administrative Code Rule 126-1-02, as amended)