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:
- 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.
- Individuals involved must be specifically identified with the project activity;
- 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.
- The costs are not also recovered as indirect costs.
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
Administrative and Clerical Salaries must be approved by ORA prior to inclusion in a proposed budget.
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