Administrative and clerical salaries can be charged directly to a federal sponsor when the effort is integral to the project.
UCSF Summary (click to expand)
Generally, administrative and clerical salaries should be treated as facilities and administrative costs on federally sponsored projects; however, when certain criteria are met, they may be allowed as a direct cost.
The Uniform Guidance eliminates the major project or activity exceptions from A-21 for the direct charging of administrative and clerical salaries and has replaced it with the following criteria, all of which must be met:
- Administrative or clerical services are integral to a project or activity
- Individuals involved can be specifically identified with the project or activity
- Such costs are explicitly included in the budget or have the prior written approval of the federal awarding agency*
If all of these requirements are met, then administrative/clerical expenses may be included in the proposal budget justification that ties the administrative effort to the projects aims. It must also confirm that the costs are not recovered as indirect costs. Although the NIH has waived its right to pre-approve these expenses, we require the justification for auditing purposes.
Application at UCSF (click to expand)
The Uniform Guidance is effective for federally sponsored agreements and new funding increments incorporating the Uniform Guidance awarded on or after December 26, 2014. Federal awards received before December 26, 2014 must continue to follow the requirements in OMB A-21.
All federal proposals with anticipated start dates after December 26, 2014 must use the concept of integral when proposing administrative or clerical salaries.
Federal awards received before December 26, 2014 must continue to follow the requirements in OMB A-21.
UCSF has determined that integral means:
• Personnel costs must be essential, vital, or fundamental to the performance of the award or activity as documented in the award proposal or scope amendment.
• Generally administrative and clerical support as individual annual effort must not be less than 10% per year as documented in their effort report.
NIH modular grants or similar grant instruments do not require line-item budgets. (Note: Rebudgeting authority may be used to charge administrative expenses not included in the approved budget if specific rebudgeting authority for clerical and administrative expenses is allowed by award and sponsor rebudgeting guidelines. See, for example, NIH administrative requirements.)
Sample Budget Justification
"The PI has included effort for administrative salary that is integral to the project, and not for general support of the academic activities of the faculty or department. Effort charged to this project can be specifically identified to the project."
Describe how the administrative role is integral, i.e., essential, vital or fundamental, to the project.....
Affected UCSF Policies
Cost Accounting Standards (CAS) Guidelines: Charging Practices for Sponsored Projects - Section IV. Guidelines for Direct-Charging Administrative Costs to Federal Projects
Agency Specific Guidelines (click to expand)
• National Science Foundation - Grant Proposal Guide
Chapter II.C.2.g.(i)(b), Administrative and Clerical Salaries & Wages Policy
• National Institutes of Health - Grants Policy Statement
Part II, Section 184.108.40.206 Direct charging Salaries of Administrative and Clerical Staff