Charging Administrative and Clerical Costs to Federally Sponsored Projects
Policy Date: October 2016 Revision: 3 Last Review: February 2019
On December 26, 2014, the Office of Management and Budget (OMB) enacted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly called, "Uniform Guidance") to provide the foundation for grants management. In the Uniform Guidance, clarification is provided with regard to when the direct charging of administrative and clerical staff salaries may be appropriate.
When Administrative and Clerical Costs May Be Appropriate
Per the Uniform Guidance, § 200.413 Direct costs (c), administrative and clerical salaries are typically considered an indirect cost and should be treated as such. However, under certain circumstances it may be appropriate to direct charge administrative and clerical salaries costs. Per 200.413 Direct Costs (c), direct charging of clerical and administrative staff salaries "may be appropriate only if all of the following conditions are 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; and
- The costs are not also recovered as indirect costs."
Requesting to Direct Charge Clerical and Administrative Costs
If clerical and administrative salaries are anticipated on a sponsored project, it is crucial that these costs be included in the budget and, further, that the budget justification include the rationale to support the direct charging of such costs. It is important to note that sponsor approval for direct charging clerical and administrative salaries is not automatic. If a proposal is awarded with clerical and administrative salaries included as direct costs in the budget, Sponsored Projects infers this to be sponsor pre-approval for the direct charging of clerical and administrative costs. If sponsor pre-approval for direct charging clerical and administrative salaries is not obtained through the proposal submission process, then sponsor approval to direct charge clerical and administrative salaries to the active sponsored project must be obtained prior to the charging on any such costs.