Policy Section: Office of Research and Project Administration & Sponsored Research Accounting Policy Number and Title: Charging of Administrative or Clerical Salaries and General Expenses to Federal Sponsored Projects and Programs Applicable To: Sponsored Projects and Programs Effective Date: March 2, 2010 POLICY STATEMENT Under federal regulations and sponsor requirements, departmental types of expenses including but not limited to administrative or clerical salaries, office supplies, postage, local telephone costs, photocopy costs, network charges, cell phones, etc. should normally be treated as a Facilities and Administrative (F&A 1 ) cost and recovered through the F&A cost rate (also known as indirect cost rate). In exceptional circumstances where the nature of the work performed requires extensive departmental support, administrative or clerical salaries may be treated as a direct charge. However, administrative or clerical salaries and other general administrative costs must directly benefit and be easily identified with the particular sponsored project or program. This policy is issued to define the appropriate charging of administrative or clerical salaries and other departmental expenses consistent with the Office of Management and Budget (OMB) Circular A-21. EFFECTIVE DATE This policy is effective for all federally funded (including federal prime subawards received by the University through another entity) sponsored projects and programs. 1. Facilities and Administrative (F&A) costs are also known as overhead or indirect costs. This policy will use the term F&A costs. Page 1 of 7
APPLICATION OF THIS POLICY This policy applies to all federally funded (including federal prime subawards received by the University through another entity) sponsored projects and programs. It should be understood by Principal Investigators (PIs), Grant Managers, Department Managers, Department Chairs, Deans, Dean for Research, Sponsored Research Accounting (SRA) and the Office of Research and Project Administration (ORPA). COSTS INCLUDED IN FACILITIES AND ADMINISTRATIVE COST RATE Administrative or clerical salaries and other expenses that fall within the routine services normally provided by academic departments are treated as F&A costs. As a general rule, such routine services cover the general business of the department as a whole and may include some limited support to faculty to enable them to conduct their teaching and scholarly activities. General business functions include activities such as: basic financial management and accounting; purchasing; human resource management; facilities management; administrative or clerical support for course instruction; and secretarial and administrative support for professional correspondence, preparation of grant applications, etc. DIRECT CHARGING ADMINISTRATIVE OR CLERICAL SALARIES AND OTHER DEPARTMENTAL EPENSES The direct charging of administrative or clerical salaries 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 the academic department. Page 2 of 7
On July 13, 1994, OMB issued an interpretation of Circular A-21, Section F.6.b that states:...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, and 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 or contract proposal. Additionally, OMB Circular A-21 Exhibit C provides examples of circumstances where the direct charging of salaries of administrative or clerical staff may be appropriate. They are as follows: 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 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 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 research vessels, radio astronomy projects, and other research field sites that are remote from campus. Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications. Page 3 of 7
These examples are not exhaustive nor are they intended to imply that direct charging of administrative or clerical salaries would always be appropriate for the situations illustrated in the examples. Additional examples might also include computer science studies of large database management, computational biology studies, and astronomical surveys. The examples above are illustrative of the criteria that are applied to the treatment of items such as office supplies, postage, local telephone costs, photocopying, network charges, cell phones, etc. Direct charging of such expenses may be justifiable when the expenses are related specifically to the technical substance of a project or there is an unusually high level of expense because of the nature of the activity. Federal regulations require that costs incurred for the same purpose in like circumstances must be treated consistently as either direct or F&A cost. PIs and department administrators must exercise caution in applying the guidelines contained in this policy. Page 4 of 7
ROLES AND RESPONSIBILITIES PI & Dept Administrator Dean / Chair/ Director ORPA SRA Determines appropriateness of administrative or clerical salaries and other departmental expenses in the proposal budget Prepares appropriate justification for administrative or clerical salaries and other departmental expenses and the associated proposal budget Approves the proposal and associated proposal budget Verifies justification for administrative or clerical salaries and other departmental expenses meets OMB A-21 criteria Submits approved proposal, budget, and budget justification to sponsor Establishes a Project /Grant and award budget in Coeus and Peoplesoft Financials Guides expense requests through proper University channels to ensure adherence to OMB A-21 criteria Reviews administrative or clerical salaries and other departmental expenditures for allowability and maintains supporting documentation Verifies appropriateness of administrative or clerical salaries and other departmental expenditures Prepares and submits invoices and financial reports to sponsors as required Page 5 of 7
APPENDI A: NORMAL DIRECT AND NORMAL F&A COSTS This matrix indicates when a particular cost is normally charged directly to a sponsored project or as an F&A cost. This listing of costs is not all inclusive but provides examples of those most commonly associated with sponsored projects and programs. Normal Direct Cost Compensation & Employee Benefits Faculty, technicians, research associates and assistants, including graduate research assistants and other students performing scientific or technical work, post doctoral associates and other technical and programmatic personnel necessary to meet the goals of the project. Travel & Meals That which is required to carry out the objectives of the sponsored project or program including travel to research sites; does not include food & drink during a lab meeting. Supplies Laboratory and scientific supplies, including laboratory notebooks, glassware, chemicals, field supplies, compressed gases and liquids, radioactive material, software, animals. Parts and supplies related to scientific and technical equipment. Books & Subscriptions Books and subscriptions not available in University or departmental library. External & Internal Copying Copying of progress reports. Animals & Hazardous Materials Hazardous materials, animal purchases, animal per diems. Normal F&A Cost Compensation & Employee Benefits Administrative or clerical positions such as administrative assistants, accountants, office personnel, purchasing agents, executive assistants, and other administrators. Travel & Meals That which is related to administrative activities, food & drink during a lab meeting, entertainment (unallowable in the F&A rate as well), alcoholic beverages (unallowable in the F&A rate as well). Supplies Office supplies, custodial supplies, parts and supplies associated with repair and maintenance of general purpose equipment and facilities, paper, forms, stationery, pads, pens, pencils, markers, printer and fax paper toner, and ink cartridges. Books & Subscriptions Books and subscriptions available in University or departmental library and general purpose books and reference materials. External & Internal Copying Copying of new grant proposals, purchasing documentation, and timesheets, library copy cards. Animals & Hazardous Materials Radioactive and chemical waste Page 6 of 7
Communications Documented long distance calls (agenda, time, participants). Printing, Publications & Illustration Charges Reprints of manuscripts supported by award, scientific illustrative work and research subject recruitment. Postage & Mailing Express service for time-sensitive samples. Professional Services Lecture fee (not on research awards and depending upon training award) and consultant services. Equipment Scientific equipment (and maintenance contract). Other Human subject payments and subrecipient costs. Communications Local calls, telephone equipment purchases and installation/repair, cell phones and use, pagers, network charges (unless dedicated lines are required for large data transmissions with collaborators). Printing, Publications & Illustration Charges Printing of proposals, advertising (dependent upon award). Postage & Mailing Express service of proposals and progress reports, local postage costs (depending upon award), international postage, bulk mail services (depending upon award) and University mail services. Professional Services Accounting services, legal, or audit services (unless specified in award). Equipment General purpose equipment such as a desktop computer or laptop (unless used specifically and exclusively for scientific purposes). Other Dues and memberships, parking fines (unallowable in the F&A rate as well), taxes-non-payroll. Page 7 of 7