Policy: VIII.A.6x2 (inactive)
Issued: September 20, 1996
Owner: Assistant Vice President for Research Administration in the Office of Sponsored Programs
Latest Revision: January 28, 2004
CHARGING OF ADMINISTRATIVE AND CLERICAL SALARIES
This policy describes how administrative and clerical salaries should be charged.
2.0 Policy [Top]
Section f.6.b. of Office of Management and Budget (OMB) Circular A-21, "Cost Principles for Educational Institutions," states the following regarding the charging of administrative/clerical salaries as direct cost:
"The salaries of administrative and clerical staff should normally be treated as indirect cost. Direct charging of these costs may be appropriate where a major project or activity explicitly budgets for administrative or clerical services and individuals involved can be specifically identified with the project or activity."
OMB, with assistance from Health and Human Services (HHS), has issued the following interpretation guidelines:
"This provision is intended to establish the principle that administrative and clerical staff salaries should usually be treated as indirect costs but that direct charging of these costs may be appropriate where the nature of the work performed under a particular project requires an extensive amount of administrative or clerical support which is significantly greater than the routine level of such services provided by academic departments. The costs would need to meet the general criteria for direct charging in section D.1 i.e... 'be identified specifically with a particular sponsored project'...relatively easily with a high degree of accuracy. The special circumstances requiring direct charging of the services would need to be justified to the satisfaction of the awarding agency in the grant application contract proposal."
The following examples illustrate circumstances where direct charging of administrative or clerical staff salaries may be appropriate:
- Large, complex programs. Such as General Clinical Research Centers. Primate Centers, Program Projects, environmental research centers, engineering research centers and other grants and contracts that entail assembling and managing teams 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 making 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 seagoing research vessels and radio astronomy projects, and other research field sites that are remote from campus.
- Individual projects requiring project -specific database management.
These examples are not exhaustive, nor are they intended to imply that direct charging of administrative and clerical salaries would always be appropriate for the situations illustrated in the examples. Where direct charges for administrative and clerical salaries are made, care must be exercised to assure that costs incurred for the same purpose in like circumstances are consistently treated as direct cost for all activities. This should be accomplished through a 'Direct Charge Equivalent' or other mechanism that assigns costs directly to the appropriate activity."
The above guidelines should be followed for all future proposals. It is recommended that the need for clerical/administrative support be fully justified in the budget summary/explanation section of the proposal. Please note that these guidelines do not allow the routine charging of administrative/clerical salaries for general departmental functions.
Procedure 8-14, "Budgeting Direct Costs of Sponsored Programs,"
Office of Sponsored Programs Cost Accounting Standard Guidelines
3.0 Definitions [Top]
4.0 References [Top]
5.0 Approvals and Revisions [Top]
Previous version in effect from 9/20/96 to 1/28/04 available in policy archive.