Direct charging of administrative and clerical salaries to federally sponsored projects is appropriate if all of the following conditions are met:
- Administrative and clerical services are necessary, essential, or fundamental to the project;
- Administrative and clerical staff’s effort can be identifiable for a specific project; and
- Such costs are included in the budget justification or must have prior approval from the Federal sponsor.
In addition, care should be exercised to confirm that these administrative salaries are not included in F&A.
The following describes examples where the project may require significant level of administrative and clerical salaries which could be justified as direct costs in the proposal:
- Projects with significant number of subawards that would involve substantial monitoring and complex management requirements
- Projects that require coordinating meeting and travel for a large number of participants
The activities described below are not considered administrative and clerical and may be charged to a project without obtaining prior approval, provided that they are directly related to work under the Federal award and meet all the standard costing requirements:
- Costs related to protocol development and maintenance
- Managing substance/chemicals
- Managing and securing specific project data
- Coordination of research subjects that are a part of the project activities
Excerpts from UG
§200.413 Direct costs
(c) The salaries of administrative and clerical staff should normally be treated as F&A costs.
Direct charging of these costs may be appropriate only if all of the following conditions are met:
(1) Administrative or clerical services are integral to a project or activity;
(2) Individuals involved can be specifically identified with the project or activity;
(3) Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
(4) The costs are not also recovered as indirect costs.
§200.430 Compensation – personal services
(h) Institutions of higher education (IHEs).
(1) Certain conditions require special consideration and possible limitations in determining allowable personnel compensation costs under Federal awards. Among such conditions are the following:
(i) Allowable activities. Charges to Federal awards may include reasonable amounts for 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.