Administrative and Clerical Salaries

Definition:  Administrative and Clerical Salaries (§200.413(c)) – Administrative and clerical personnel who provide non-technical support services that benefit departmental, institute, center, or school activities. The services of these individuals could include: clerical support, financial management, procurement of materials and services, budget and planning, and personnel management.

When is it applicable to charge Administrative and Clerical Salaries to sponsored projects?  The salaries of administrative and clerical personnel are normally treated as an indirect cost unless they meet the definition of “unlike purpose and circumstance” and are integral to the project. As stipulated in the Uniform Guidance, direct charging of administrative salaries is allowable when all of the following four conditions are met:

  1. Administrative or clerical services are integral to a project or activity;
    • The requirement that the cost be “integral” means the services are essential, vital, or fundamental to the scope of work.
  2. Individuals involved must be specifically identified with the project activity;
  3. Such costs are explicitly included in the budget or have the prior written approval of the awarding sponsor.
    • If a sponsor requires a detailed budget justification at the proposal stage, then the inclusion of any administrative or clerical salaries must be justified by explaining how they are estimated and integral (essential, vital, or fundamental) to the scope of work.
    • If a sponsor does not require a detailed budget justification at the proposal stage, then ORA will obtain sponsor specific acknowledgment and approval for any administrative and clerical salaries before allowance of such expenses.
  4. The costs are not also recovered as indirect costs.

Administrative and Clerical Salaries must be approved by ORA prior to inclusion in a proposed budget.

Applicability:  This guidance applies to both federally funded and non-federally funded awards.  Administrative and clerical salaries are included in the university’s F&A rate calculation.  The F&A rates apply to both federally and non-federally funded awards.  Charging non-integral administrative and clerical salaries to a project creates a scenario where the sponsor is paying for the administrative activity twice, directly and indirectly, which is unallowable.

Examples of when administrative and clerical support on a sponsored project may be allowable?

  • Large, complex programs such as Program Projects, environmental research centers, engineering research centers, and other grants and contracts that entail assembling and managing teams of investigators from a number of institutions.
  • Projects which involve extensive data accumulation, analysis and entry, surveying, tabulation, cataloging, searching literature, and reporting (such as epidemiological studies, clinical trials, and retrospective clinical records studies).
  • Projects that require extensive travel and meeting arrangements for large numbers of participants, such as conferences and seminars.
  • Projects whose principal focus is the preparation and production of manuals and large reports, books and monographs (excluding routine progress and technical reports).
  • Projects that are geographically inaccessible to normal departmental administrative services, such as research vessels, radio astronomy projects, and other research field sites that are remote from campus.
  • Individual projects requiring significant amounts of project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications.

Examples of when administrative and clerical support on a sponsored project are not allowable?

  • You cannot charge sponsored agreements for those types of costs that are routine, such as costs for budget monitoring, recordkeeping, purchasing, personnel actions, etc. You can only charge those types of administrative costs that are specific to the project scope.
  • Assigning a “departmental tax” to projects for clerical/administrative costs is prohibited (APL VIII-C Direct Charging of Expenses – page 2)

Frequently Asked Questions on Direct Charging of Administrative and Clerical Salaries

  1. When is it appropriate to directly charge a Sponsored Agreement for administrative and clerical support?

You may charge a Sponsored Agreement for administrative and clerical support where a project requires extensive administrative or clerical assistance, such as working with large amounts of data or producing large reports or books. The support required must be integral to the award and such expenses must also be specifically identified with and benefit the project and be listed in the approved proposal budget. You cannot charge sponsored agreements for those types of costs that are routine, such as costs for budget monitoring, recordkeeping, purchasing, personnel actions, etc. You can only charge those types of administrative costs that are specific to the project scope.

  1. A project no longer needs to be identified as “major;” however, the administrative salary expense needs to be integral or essential to the project in order to be directly charged. It must also be included in the approved proposal budget and justification. Most of the other requirements for direct charging salary are the same as with major projects.

If I know that the project is administratively intense and will need administrative and clerical support, what should I do?

When writing your proposal, include a budget justification for categories of administrative costs, tailored to the sponsor requirements and the specific project. Explain the function of the position or cost as it directly relates to and benefits the project. Be sure to include project specific details to highlight the activities that make the administrative support integral to the sponsored project.

 Example: Clerical/Administrative support is requested for the project to <<summarize why the clerical/administrative support is needed>>.  This clerical/administrative support will entail <<outline the roles or responsibilities within the proposed activity>>.  The <<clerical/administrative support title>> will provide X% time and effort for a total of $X,XXX. This work is above and beyond usual duties assigned by the <<clerical/administrative position title>>.  We are requesting agency approval for a X% <<clerical administrative position title>> as a directly-charged administrative cost in accordance with 2 CFR 200.413.

  1. If we can’t charge administrative assistance to this grant, can we provide, for example, 10 hours a week of a clerical person’s time as UMS cost-share?

No. You can only provide administrative assistance as cost-share if that assistance is integral to the sponsored project. The same requirement to be “integral” to the project must be met that would permit charging such assistance as a direct cost to the sponsor.

     4. Must these costs be approved by the Federal awarding agency?

Yes, the Federal agency must approve the direct charging of administrative and clerical salaries. Costs must either be explicitly included in the approved budget or have prior written approval of the agency.

PIs and departments are strongly encouraged to include these costs in the budget at the time of proposal. In some cases, including NIH, an agency may waive the requirement to obtain prior approval to re-budget for such costs. If agency approval has been waived, then the Director or Associate Director of the Office of Research Administration must make a determination as to the need for direct charging of the salaries. 

  1. What if I am submitting a proposal to a non-federal sponsor? What should I include in my proposal?

The guidance for non-Federal sponsors is similar, but it may be more flexible. It is important to be familiar with the program guidelines, as well as terms and conditions. Assuming that sponsor terms and conditions do not restrict the direct charging of administrative and clerical salaries, you may wish to include such costs in budget justification.

If there are questions, please contact the Office of Research Administration for advice. 

  1. What is the difference between programmatic activities and administrative/clerical activities on a grant?

Programmatic activities are those activities that can be directly charged to a project without needing to provide additional justification or obtain prior approval. Administrative or clerical activities need to meet the four conditions outlined in 200.413(c) in order to be directly charged to a project, including being explicitly included in the budget or having prior approval of the Federal awarding agency. Examples of activities that fall into each category are included in the table below.

Programmatic Activities (direct costs, no prior approval needed)

 

 Administrative or Clerical Activities (normally indirect costs, unless prior approval obtained)

 
  • Activities contributing and directly related to work under an agreement, such as:
  • delivering special lectures about specific aspects of the ongoing activity,
  • writing reports and articles,
  • developing and maintaining protocols (human, animals, etc.),
  • managing substances/chemicals,
  • managing and securing project-specific data,
  • coordinating research subjects,
  • participating in appropriate seminars,
  • consulting with colleagues and graduate students, and
  • attending meetings and conferences

 

 If the four conditions are met, activities that support the project that may be allowable as direct charges might include:

  • travel and meeting arrangements
  • travel reimbursements
  • purchasing activities
  • financial tracking and management
  • data processing
  • payroll
  • human resources