Justifying and Documenting Administrative Expenses
As a recipient of Federal funds, UCI is required to propose, account for, and report costs in a consistent manner and in accordance with federal regulations and University policies. OMB Circular A-21 requires that administrative expenses shall normally be treated as Facilities and Administrative (F&A) costs.
- UCI Research Policy - Budgeting and Charging Administrative Expenses to Sponsored Projects defines certain terms, including the following, which are restated below for the convenience of the reader:
- Administrative expenses include salaries and related benefits of those employees who perform administrative/clerical (non-technical) activities, and other non-salary administrative expenses incurred to support a project. Lists of the most common, routine administrative/clerical activities and non-salary administrative expenses are available on the following pages: Administrative/Clerical Salaries and Non-Salary Administrative Expenses.
- Special Circumstance exists when a project requires an extensive amount of administrative/clerical personnel support, or non-salary administrative expenses that are significantly greater than the routine level of support that is provided to every UCI sponsored project.
- Major Project, as defined in OMB Circular A-21 and used in this policy, is a project that requires an extensive amount of administrative/clerical personnel support, which is significantly greater than the routine level of such services provided by academic departments.
- Unlike Circumstance exists when the scope of the project requires non-salary administrative expenses that are significantly greater than the routine level of support provided to every UCI sponsored project.
Justifying Administrative Expenses
A. Administrative/Clerical Salaries
The following criteria must be met before administrative and/or clerical salaries are charged to a federal project:
- It is necessary to incur the cost to perform the project's scope of work; and
- The cost must be identifiable to the project with a high degree of accuracy; and
- The proposal resulting in the award describes, in the budget justification, the project activities that satisfy the federal definition of Major Project and the budget explicitly includes administrative and clerical salaries (i.e., the individuals and/or positions providing administrative or clerical support must be specifically identified with the project activities); or
- The sponsor's prior approval of rebudgeting is obtained, provided that the prior approval request submitted to, and approved by, the sponsor explicitly includes administrative and clerical salaries (i.e., the individuals and/or positions providing administrative or clerical support must be specifically identified with the project activities); or
- The terms and conditions of the award transfers certain rebudgeting authority to UCI, provided that any such rebudgeting is approved at the appropriate level within UCI, that the delegated rebudgeting authority is not restricted in such a way as to prohibit the direct charging of administrative or clerical salaries, and that the project activities that satisfy the definition of Major Project are documented in the administering unit's award file; or
- The award received by UCI was made in response to a modular grant application, provided that the award terms do not prohibit the direct charging of administrative or clerical salaries and that the project activities that satisfy the definition of Major Project are documented in the administering unit's award file.
B. Non-Salary Administrative Expenses
The following criteria must be met before non-salary administrative expenses are charged to a federal project:
- It is necessary to incur the cost to perform the project's scope of work; and
- The cost must be identifiable to the project with a high degree of accuracy; and
- The proposal resulting in the award describes, in the budget justification, the project activities that satisfy the definition of Unlike Circumstance and the budget explicitly includes non-salary administrative expenses (i.e., such expenses are specifically identified with project activities); or
- The sponsor's prior approval of rebudgeting is obtained, provided that the prior approval request submitted to, and approved by, the sponsor explicitly includes non-salary administrative costs (i.e., such expenses are specifically identified with the project activities); or
- The terms and conditions of the award transfers certain rebudgeting authority to UCI, provided that any such rebudgeting is approved at the appropriate level within UCI, that the delegated rebudgeting authority is not restricted in such a way as to prohibit the direct charging of non-salary administrative expenses, and that the project activities that satisfy the definition of Unlike Circumstances are documented in the administering unit's award file; or
- The award received by UCI was made in response to a modular grant application, provided that the award terms do not prohibit the direct charging of non-salary administrative costs and that the project activities that satisfy the definition of Unlike Circumstance are documented in the administering unit's award file.
Documenting Administrative Expenses
Administering units are responsible for maintaining and retaining (in accordance with the UCI Records Retention Schedule) all documentation that explains and justifies a determination that Major Projects and/or Unlike Circumstance pertained to a specific cost or group of costs charged to a sponsored agreement.
A. Administrative/Clerical Salaries
When direct charging administrative/clerical salaries, the following documentation is required:
- Proposal Budget -- as described above in Section A of Justifying Administrative Expenses.
- Administrative Approval (AA) Form -- check the Major Project box indicating that an administrative/clerical salary expense is included in the proposal budget. The signature of the Principal Investigator, Chair or Director, and Dean or Vice Chancellor serve to certify this determination.
- Administering Unit Award File -- if administrative salaries are not included in the sponsor-approved budget, but are charged to a sponsored project (e.g., after post-award rebudgeting), the administering unit's award file must include a description of, and justification for, the specific administrative salaries. In addition, the award file must include the Principal Investigator's approval of such costs.
- Personnel Activity Reports (PARs) -- all effort of administrative/clerical staff direct charged to a federal sponsored project must be reported and certified by the appropriate official.
- Time sheet -- for staff employees (if required), a monthly time sheet should be prepared and signed by the employee and supervisor.
B. Non-Salary Administrative Expenses
When direct charging non-salary administrative expenses, the following documentation is required:
- Budget Proposal -- as described above in Section B of Justifying Administrative Expenses.
- Administrative Approval (AA) Form -- check the Unlike Circumstance box indicating that a non-salary administrative expense is included in the proposal budget. The signature of the Principal Investigator, Chair or Director, and Dean or Vice Chancellor serve to certify this determination.
- Administering Unit Award File -- if a non-salary administrative expense was not included in the sponsor-approved budget, but is charged to a sponsored agreement (e.g., after post-award rebudgeting), the administering unit award file must include a description of, and justification for the specific non-salary administrative expense. In addition, the award file must include the Principal Investigator's approval of such costs.
The daily monitoring of expenditures and budget control is exercised in the administering unit of an award by the Principal Investigator (PI) and with the assistance of departmental staff. The terms and conditions applicable to the award will be listed in the Award issued by the sponsoring agency and summarized on the Award Synopsis distributed by Sponsored Projects.
Review of Proposed Budget Change
When it becomes apparent that a change in budget allocations may become necessary, departmental staff and the PI should review the terms and conditions of an award to determine if prior approval of the change is required by the sponsoring agency. In addition, PIs should take under consideration the established cost principles contained in the Uniform Guidance (2 CFR 200) and UCI's Cost Accounting Standards Board Disclosure Statement (DS-2). If the proposed change would violate these established cost principles, the change should not be made.
In general, resources referenced for terms and conditions of federal awards will include the sponsor’s notice of award, policy documents issued by the sponsor, Uniform Guidance (2 CFR 200), and if appropriate, the Research Terms and Conditions (RTC), including any agency-specific RTC terms and conditions.
Some common policy documents issued by federal sponsors include:
- NASA Grant and Cooperative Agreement Handbook
- National Institutes of Health (NIH) Grants Policy Statement
- National Science Foundation (NSF)
Please note that the above list is not all inclusive and a specific award should be reviewed to determine the applicable terms and conditions. Also note that federal contracts generally do not reference a specific document, and the clauses within the contract itself govern the award.
For non-federal awards, most likely only the sponsor’s notice of award and policy documents issued by the sponsor will apply.
Requesting Prior Approval
When a change in project budget requires prior approval from the sponsoring agency, a request should be drafted seeking prior approval from the sponsor before a change has been made. This request should include:
- the cost categories affected,
- the proposed change in budgetary allocations, and
- the technical/scientific justification requiring such changes.
Requests are drafted by the PI, with a concurrence endorsement by an authorized official within Sponsored Projects prior to submission to the sponsor.
If approval for the change in budget is granted, Sponsored Projects records the approval within the office of record award file, and then informs the campus community of such approval. This notification is completed by use of our electronic award synopsis distribution process, and notification is sent to not only the Principal Investigator, but their departmental staff, dean’s office (if applicable), and the Contracts and Grants Accounting office, as well.
When a change in budget is made under the authority of the Principal Investigator granted by the terms and conditions of an award, the planned change in approved budget should be documented in the departmental award file. This documentation should include a description of and justification for the expense. In addition, the award file must include the PI's approval of such costs.
Audits and Site Visits
A sponsored project awarded and accepted by the University may contain a provision which permits the sponsor, or the sponsor’s representative, to access our facilities for the purpose of auditing the performance of that particular award. Should the sponsor request to perform a post-award audit, Sponsored Projects and Internal Audit should be contacted to coordinate the audit.
Annual Financial Audits
Annual financial audits for the University of California are conducted on a consolidated basis including all campus locations. The audited financial statements are included in the University's Annual Financial Reports.
A-133 Audit Reports
A sponsored project funded with federal monies may contain a provision requesting a copy of the University’s annual audit report, in accordance with the requirement of OMB Circular A-133. As with the financial audits, the A-133 audits are conducted on a consolidated basis including all campus locations. The University’s fiscal year ends June 30, and the A-133 audit report is issued by the end of March in the following year. A copy of the A-133 audit is submitted to the University’s cognizant federal agency for A-133, the U.S. Department of Health and Human Services, and also to the Federal Audit Clearinghouse operated by the Bureau of the Census. The latest available audit information can be found at https://www.ucop.edu/financial-accounting/financial-reports/a-133-audit-reports.html. Further information from A-133 audits is accessible through the Federal Audit Clearinghouse website, searching by organization name “UNIVERSITY OF CALIFORNIA”.
Clinical Trial Site Visits
See Clinical Trials for detailed information about site visits and audits in Sponsor-Initiated and PI-Initiated clinical trials.
Fulfilling and Documenting Cost Sharing
As a recipient of Federal funds, UCI is required to account for and report cost sharing in a manner consistent, and in accordance, with federal regulations.
If UCI accepts in response to a proposal that offered a cost sharing commitment, or if an award contains a cost sharing requirement, UCI is legally bound to cost share. Failure to fulfill the cost sharing commitment may result in the sponsor reducing available project funds and an increase in the project costs charged to departmental funds. Therefore, it is important to understand UCI Research Policy - Cost Sharing on Sponsored Projects, which defines cost sharing and describes when cost sharing is appropriate and permitted.
Please note that these guidelines do not supersede UCI Research Policy - Cost Sharing on Sponsored Projects.
UCI Research Policy - Cost Sharing on Sponsored Projects defines certain terms, including the following, which are restated below for the convenience of the reader:
- Cost sharing is any portion of the total costs of a project or program not borne by the sponsor. Cost sharing typically takes the form of in-kind resources (e.g., contributed project personnel effort) or cash.
- Cost sharing commitment means any cost sharing that is offered and quantified anywhere in a proposal.
- Cost sharing contribution means the use or expenditure of any in-kind resource or cash to fulfill a cost sharing commitment in the course of performing the scope of work under and extramural award.
- Third party cost sharing means cost sharing commitments or contributions made by an organization other than UCI or the sponsor.
Fulfilling Cost Sharing Commitments
UCI assumes certain obligations when it accepts an award involving a cost sharing commitment, including the obligation to certify and report to the sponsor the aggregate dollar value of cost sharing contributions. In fulfilling cost sharing commitments, principal investigators, department administrators, chairs, directors, deans and vice chancellors must exercise care to ensure that costs identified and tracked as cost sharing contributions meet the following eligibility criteria:
- the costs must be able to be documented and verified based on UCI's records;
- the costs must not be included as a cost sharing commitment related to any other project or program (i.e., the same costs may not be proposed as cost sharing for two or more projects);
- the costs may not be committed, or contributed, from another extramural award, except where specifically authorized by Federal statute or the sponsor (i.e., costs incurred under a NIH grant may not be proposed or accounted for as a cost sharing contribution under a NSF grant or any other federal or non-federal grant);
- the costs must be necessary and directly related to the project objectives;
- the costs must be incurred during the same performance period as the award supporting the project;
- the costs must be allowable and allocable under federal cost principles (OMB Circular A-21) and the terms of the sponsored agreement; and
- the costs must be identified in the approved budget or award (either directly or incorporated by reference) when required by the sponsor.
Principal investigators should notify the Office of Research Administration as soon as they reasonably know that the cost sharing commitment for a particular project may not, or will not, be fulfilled. This is includes those situations when a principal investigator transfers to another institution during the performance period of a project, as the sponsor may hold UCI responsible for fulfilling all or a proportionate share of any cost sharing commitment associated with the project.
Documenting Cost Sharing
Cost sharing contributions and third-party contributions are subject to audit and unit business offices and/or principal investigators may be requested to provide auditors with supporting documentation and records to justify the cost sharing contributions tracked in the UCI Cost Sharing Tracking System and ultimately reported to sponsors. Cost sharing records and supporting documents, such as paid invoices, travel vouchers and receipts should be retained in accordance with the University Records Management Disposition Schedules. In addition, effort contributed by project personnel should be recorded and certified on a Personnel Activity Report. If third-party contributions (other than cost sharing provided by subrecipients under UCI's prime awards) will be used to fulfill a cost sharing commitment, source documents supporting the dollar amount of third party cost sharing should also be retained.
Certifying and Reporting Cost Sharing
The principal investigator of a project must certify all cost sharing contributions related to a project by reviewing and signing the Cost Sharing Contribution Report, which is generated through the UCI Cost Sharing Tracking System. When the principal investigator certifies the report, he/she is assuring UCI and the sponsor that:
- the costs recorded on the report are true and accurate;
- the costs were contributed to the identified project during the reporting period; and
- the costs have not been, and will not be, used as cost sharing contributions on any other projects or for any other periods relating to the identified project.
Any total fund overdraft of an award (or overdraft of a cost category, in certain circumstances) represents cost sharing and may be used to meet any required cost sharing for that award. The over expended amount must be transferred to an unrestricted funding source and identified as cost sharing on the cost transfer if the overdraft will be used to fulfill a cost sharing commitment. If the overdraft amount is not being used to meet the cost sharing commitment, it does not need to be tracked or reported as cost sharing.
Any over expended amount that was charged to an award in error does not represent cost sharing and must be transferred to the appropriate account/fund.
NIH Policy Enhancing Public Access to Publications
Investigators preparing manuscripts for publications supported by funding from the National Institutes of Health (NIH) or applications to the National Institutes of Health—where previously funded NIH research is cited—must comply with two new requirements.
Requirement to Post Publications to PubMed Central
For all NIH-funded research, investigators are required to submit or have submitted for them to the National Library of Medicine’s PubMed Central an electronic version of their final, peer-reviewed manuscripts within 12 months of publication, along with all graphics and supplemental materials that are associated with the article.
- Only publications arising, in whole or in part, from funds provided by NIH and that are accepted for publication on or after April 7, 2008, require posting. This requirement applies to NIH grants and cooperative agreements active in Fiscal Year 2008 (October 1, 2007- September 30, 2008) or beyond, and to all NIH contracts awarded after April 7, 2008. Thus, a manuscript partially supported by an NIH grant that ended December 31, 2007, must be posted to PubMed Central if accepted for publication on or after April 7, 2008. You may submit articles that precede the implementation period if you so desire and have appropriate copyright permission.
- Publications already registered with PubMed, still require the principal investigator to submit the manuscript to PubMed Central.
- Investigators are responsible for ensuring that any publishing or copyright agreements concerning submitted articles fully comply with this policy. In order to provide advance notice to publishers regarding the NIH obligation, investigator/authors should submit a copy of the letter dated March 6, 2008, from UC Executive Director William T. Tucker at the time manuscripts are submitted to the publisher for consideration, or with any publication agreement signed by a UC investigator.
- Many publishers have agreed to automatically submit articles to PubMed Central on behalf of the authors; however, investigators should verify that their published article is submitted to PubMed Central to comply with this law. A list of cooperating publishers can be found at https://publicaccess.nih.gov/submit_process_journals.htm.
- For journals that deposit manuscript files, an author still must provide the associated award information, and review and approve the article in the NIH Manuscript Submission (NIHMS) system. NIHMS will notify the author via email when these actions are needed.
- If a publisher is not on the above list of cooperating organizations:
- Check the journal website. Some journals, such as Cell and Neuron, have information related to their compliance with the NIH requirement on their websites. Others may require a request from the author to post to PubMed Central.
- Contact the UCI Libraries NIH Group (firstname.lastname@example.org) for assistance. The Libraries have assigned staff to answer general questions about this new policy and help with copyright and publishing agreements.
- Submit the article to PubMed Central. You must use the NIH Manuscript Submission (NIHMS) system to submit an article.
- Deposit the manuscript files (e.g., Microsoft Word document and figures) into the NIHMS.
- Indicate the NIH award(s) to which the article is related.
- After the NIHMS converts the deposited files to a standard PubMed Central format, NIHMS will email the author to review the PMC formatted article and approve its release.
- For more information, visit the NIHMS website.
- Visit the Online NIHMS tutorials.
- Remember, NIH will reimburse publication costs, including author fees, for grants and contracts on three conditions: (1) such costs incurred are actual, allowable, and reasonable to advance the objectives of the award; (2) costs are charged consistently regardless of the source of support; and (3) all other applicable rules on allowability of costs are met. Other FAQs are available at https://publicaccess.nih.gov/FAQ.htm.
Requirement to Add Reference Numbers to Citations in NIH Proposals
Beginning May 25, 2008, investigators submitting an NIH application, proposal or progress report must include the PubMed Central or NIH Manuscript Submission reference number when citing articles that have arisen from their previous NIH funded research. This includes applications submitted to the NIH for the May 25, 2008 due date and beyond. PubMed Central references are added to the end of the standard citation in this format: “PMCID: 243493.”
Who to Contact
Direct questions to the UCI Libraries NIH group (email@example.com) or to your Contracts and Grants officers. The UCI Libraries website has more information on how to upload documents and work with your publishers to include appropriate copyright language in your agreement.
NIH Public Access Policy Presentation
Foreign Travel on Federal Awards
Federal regulations govern the use of federal funds (grants, contracts, cooperative agreements) and the selection of air carriers for foreign travel. Foreign flag air carriers may not be used solely on the basis of costs.
Fly America Act
The Act applies to federal awards and with a few exceptions requires the use of U.S. flag air carriers, i.e., an air carrier that is certified under 49 U.S.C. 41102, or service under a code share agreement with a foreign air carrier when the ticket or e-ticket identifies the U.S. flag air carrier’s designator code and flight number.
- If a U.S. carrier offers nonstop or direct service (no aircraft change) between the U.S. and your foreign destination, you must use a U.S. flag air carrier unless such use would extend travel time by 24 hours or more.
- If a U.S. carrier does not offer nonstop or direct service (no aircraft change) between the U.S. and your foreign destination, you must use a U.S. flag air carrier on every portion of the route unless the use of the foreign carrier would:
- increase the number of aircraft changes outside of the U.S. by two or more; or
- extend your travel time by at least six hours or more; or
- require a connecting time of four hours or more at an overseas interchange point.
- If a U.S. carrier does not offer service on a particular leg of your travel route, a foreign air carrier may be used, but only to or from the nearest interchange point to connect with U.S. flag air carrier service.
- Use of a foreign carrier is also acceptable when determined to be a matter of necessity:
- A U.S. flag carrier involuntarily reroutes travel on a foreign air carrier;
- medical reasons;
- to avoid unreasonable risk to traveler’s safety; or
- a seat on U.S. air carrier in authorized class of service is unavailable, and a seat on the foreign air carrier in authorized class of service is available.
Open Skies Agreement
The U.S. General Services Administration has issued a limited exception to the Fly America Act for transportation under an Open Skies air transportation agreement between the U.S. and the government of a foreign country. These agreements give foreign airlines the right to transport passengers and cargo on flights funded by the U.S. Government. Otherwise, the Fly America rules apply.
Note: This exception has been implemented only by the National Science Foundation for its award recipients. It is anticipated that other agencies may adopt Open Skies in the future. If so, this webpage will be updated.
Grant and contract recipients are allowed to use foreign carriers if an Open Skies Agreement exists, but a City-Pair agreement does not. Follow these steps:
1. An Open Skies Agreement exists between the U.S. and the foreign country. To determine if an Open Skies Agreement exists, review the General Services Administration’s (GSA) Travel website. Currently, agreements exist with the European Union, Australia, and Switzerland.
- If an Open Skies Agreements exists, go to step 2.2.
2. A City Pair agreement does not exist for the departure and arrival cities. To determine a City-Pair arrangement, review the City Pair Program (CPP) website.
- If a City Pair agreement is listed, you may not charge costs for a foreign air carrier to a federal award, unless an exception is designated under the Fly America Act.
- If a City Pair agreement is not listed, you may charge the fare on a foreign carrier to a federal award.
Training Grant Information
- At UCI, training grants receive a new fund number every year.
- Using UCI’s Kuali Financial System (KFS), at least two expense accounts are established for each training grant:
- Accounts starting with 44 are used for trainee travel and training related expenses
- Accounts starting with 78 are used for pre-doc stipends, and tuition and fees
- Four accounts should be linked to the fund if the prior year has an unliquidated balance. If there is no unliquidated balance from prior year, two accounts are sufficient.
- Per the Notice of Award (NOA), “Carryover of an unobligated balance into the next budget period requires Grants Management Officer prior approval.”
- An Annual Federal Financial Report (FFR) is required for all training grants.
- No-cost time extensions are granted to allow continuation of trainees currently appointed. A new trainee may not be appointed during this period.
- The F&A rate for NIH Training Grants is 8% of Modified Total Direct Cost (MTDC), and at UCI the base code “E” is assigned to the expense account. Student tuitions and fees are excluded from MTDC. UCI’s indirect costs rates can be found on our F&A cost rates page
- Make sure to include the entire tuition amount on your applications, not the percentage to be paid by the sponsor, in order to avoid a double-reduction in award amount.
Questions? Contact Julia Yang firstname.lastname@example.org or Alice Han (email@example.com).