Administrative and Clerical Expenses
Federal regulations state that administrative and clerical salaries should normally be charged as facilities and administrative costs rather than direct costs, but these costs are allowable if specifically approved by the funding agency. Therefore, for all federal proposals any administrative or clerical salaries should be clearly identified in the budget and adequate justification should be attached. Prior to proposal submission, projects should be approved as a “Major Project” in order to include these costs in the project budget. Following are examples from federal guidelines of the types of projects which may justify direct charging of administrative and clerical staff:
- Large complex programs that entail assembling and managing teams of investigators from a number of institutions;
- Projects which involve extensive data accumulation and entry, surveying, tabulation, cataloging, 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 (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 that are remote from the 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.
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. For instance, the examples would be appropriate when the costs of such activities are incurred in unlike circumstances, i.e., the actual activities charged direct are not the same as the actual activities normally included in the institution's facilities and administrative (F&A) cost pools or, if the same, the indirect activity costs are immaterial in amount. It would be inappropriate to charge the cost of such activities directly to specific sponsored agreements if, in similar circumstances, the costs of performing the same type of activity for other sponsored agreements were included as allocable costs in the institution's F&A cost pools. Application of negotiated predetermined F&A cost rates may also be inappropriate if such activity costs charged directly were not provided for in the allocation base that was used to determine the predetermined F&A cost rates.