Manpower and Training Costs · 1 of 3
Who pays for the people on a case
In short
- Case related manpower has two funding sources, and a matrix decides which.
- Military salaries may not be charged to a capacity building case.
- Charges must be traceable to a position or an employee number.
1. Two sources, and only two
On a case the government has to say which pocket each person is paid from, and the answer is binary. "Manpower for FMS case-related programs is funded from one of two sources: the FMS Administrative Surcharge or FMS case lines" (SAMM C9.4.2.5).
The split is between indirect cost recovered through the surcharge and direct cost priced as a visible line. Neither is free to the buyer, since purchasers pay the surcharge too. What it decides is whether a cost shows as a line item or vanishes into an overhead rate, a mechanism covered in what goes into the price.
Capacity building cases funded under Title 10 have three sources: program support costs, performing activity costs, and case lines (SAMM C9.4.2.5). That extra bucket is easy to miss when carrying the sales model across to building partner capacity work.
2. The matrix that decides which
Which function falls where is settled by a published matrix, not by judgment. Functions in the administrative column are indirect costs funded by the surcharge and must not be priced as direct costs. Functions in the case, non standard and frequency columns are direct costs the purchaser pays as line items (SAMM C9.4.2.1).
Departing from the matrix is not a local decision. "Requests to deviate from the funding sources shown on this table or requests for clarification regarding this table must be coordinated with the DSCA" (SAMM C9.4.2.1) financial policy division. The parallel rule for capacity building cases sends requests to the same place: "Requests for funding clarification regarding this table and possible funding alternatives or exemptions must be coordinated with the DSCA (OBO/FPRE/FP)" (SAMM C9.4.2.2).
3. Program management, then and now
Where a case needs American staff to manage the program, the drafting agency decides under the same matrix (SAMM C9.4.2.3). How that cost appears on the document depends on a date in 2006.
For cases accepted after 1 August 2006, program management goes on ordinary services lines, described so the buyer knows what is bought. "The tailored line item description note for each of these line items must include details describing exactly what services will be provided and the length of time they will be performed" (SAMM C9.4.2.3.1).
Before that date the cost sat on a dedicated line of its own. "PMLs were identified on LOA documents using Generic Code R6B" (SAMM C9.4.2.3.2), and on older cases still, "Generic Code L8A was used on older cases to identify Case Management Lines" (SAMM C9.4.2.3.2).
4. The lines frozen in 2006
Those old lines were not deleted. Neither code may be added to a case now. Existing lines run until the case closes, provided the activity stays inside the scope the line had on 1 August 2006 (SAMM C9.4.2.3.2).
Adjustment runs in one direction only. Changes may be made by amendment while they stay within the current scope, and "no adjustments will be made to increase the scope of these line items" (SAMM C9.4.2.3.2). Where more is needed, "Any additional scope required may be added as new line items in accordance with Section C9.4.2.3.1" (SAMM C9.4.2.3.2). The old line cannot be grown; a new one beside it can.
One feature of the old lines survives. "The FMS Administrative Surcharge is not applied to PMLs" (SAMM C9.4.2.3.2). Because the line sits outside the surcharge, the document has to add it separately, and "The total of these two values is the block (8) value of the document" (SAMM C9.4.2.3.2).
5. The sheet behind the numbers
Manpower is not simply priced, it is reported. "For FMS cases, manpower requirements listed on LOAs are generated and validated through the Manpower Travel Data Sheets (MTDS) in the Defense Security Assistance Management System (DSAMS)" (SAMM C9.4.2.4). It captures military, civilian and contracted manpower, travel and personnel support costs in one standard format (SAMM C9.4.2.4).
Capacity building cases are exempt because the scrutiny came earlier. "The MTDS is not required for Title 10 and Title 22 BPC cases because the costs for these types of activities are researched, validated and reported to DSCA and Congress before BPC LOA development begins" (SAMM C9.4.2.4). They carry a harder rule of their own: "Do not charge military salaries to BPC cases" (SAMM C9.4.2.4). Those costs go elsewhere, since "Direct military labor costs are charged to applicable military personnel appropriations" (SAMM C9.4.2.4).
The sheet also does a job its name does not suggest. Reporting the data helps ensure that government and contracted personnel working overseas on case funded activity are covered by a status of forces agreement or equivalent (SAMM C9.4.2.4). A person left off it may lack that protection.
6. What counts as a manpower error
The reviewing agency checks the numbers rather than accepting them. "DSCA assesses costs contained in the MTDS or planning documents for reasonableness and fairness and verifies consistency with the LOA" (SAMM C9.4.2.4.1). Failure has a stated consequence: "DSCA will return LOAs with manpower errors to the originating IA" (SAMM C9.4.2.4.1.1). Costs judged unfair, an incomplete sheet, or pay well off federal rates are the examples given.
The salary test is arithmetical. Base salary divided by work years gives the average work year cost, where "One WY is equivalent to 2087 personnel hours per year" (SAMM C9.4.2.4.1.1.1). The result is checked against published federal pay tables, and a ceiling applies: "Non-executive federal employees are subjected to a salary limit equivalent to the pay cap for political officials, or Level IV of the Executive Schedule pay rate" (SAMM C9.4.2.4.1.1.1). Exceeding it is possible but must be justified by citing the specific legal authority in case remarks.
Travel has its own trigger. "Any line in which the average daily travel costs which exceeds $1K per day, per person, and per trip must include specific details in the case notes which supports these costs" (SAMM C9.4.2.4.1.1.2), with the grammar as published.
7. What is exempt, and what must be traceable
Eleven categories sit outside the reporting requirement, and the pattern is manpower already buried in a price. Examples are labor inside a unit cost through the working capital fund, training inside a tuition rate, and embedded engineering support (SAMM C9.4.2.4.4). Where the working capital fund provides services alone rather than material, the exemption falls away.
Amendments reset the picture rather than adjusting it. Revised lines "must reflect the total manpower, travel (to include identifying CONUS and In-Country), and personnel support costs, not the differences between the previous and revised amounts" (SAMM C9.4.2.4.3).
Behind all of it sits an audit requirement, and the standard is individual. "Personnel charges must be identifiable by position number, employee identification number, or other traceable means" (SAMM C9.4.2.6).
8. What a supplier can take from this
Government labor on a case is not a soft cost. It is either recovered through the surcharge or priced as a visible line, and the matrix rather than the program office decides which. A buyer asking why a management line exists has a published answer.
For contracted support the traceability rule is the one to design around. Charges must be attributable to a position or an individual, which shapes how time is recorded long before an auditor asks. On an older case the frozen scope matters too: work that has grown beyond a line written in 2006 belongs on a new line.
Key terms
| FMS administrative surcharge | The indirect recovery that funds one of the two manpower sources. |
|---|---|
| Manpower travel data sheet | The standard format in which case funded manpower, travel and support costs are reported. |
| Program management line | A pre-2006 line carrying management cost, frozen in scope and outside the surcharge. |
| Work year | 2087 personnel hours, the divisor used to test whether a salary figure is reasonable. |
Every statement above links to the document behind it. The full source list for this piece is on the sources page.
This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.
How Sentfore supports this
Programs are delivered by people, and who pays for them is settled long before anyone deploys. Sentfore works at the delivery end of defense programs in difficult environments, providing secure movement, protective security, facilities and life support. Requirements can be sent through the contact page.