Standard TreatmentIn accordance with OMB Circular A-21, UCI Research Policy on Budgeting and Charging Administrative Expenses to Sponsored Projects, and UCI Guidelines for Direct Charging Sponsored Projects, administrative/clerical salaries are considered F&A costs and should not be budgeted in proposals or charged to extramural awards (sponsored projects).
The following list (which is not all inclusive) represents the most common, routine administrative/clerical activities:
- General Departmental Administration
- Contracts and Grants Administration
- Personnel Functions
- Accounting and Budgeting Functions
- Travel Planning
- Newsletter/ Brochure Preparation
- Processing and Tracking Purchase Orders
- Maintaining General Departmental Databases
- Proposal Budget Preparation
- Payroll/Human Resources
- Financial Monitoring
- Reconciling Accounts/Ledgers
- Correspondence/Report Preparation
- Space Management
- Equipment Inventory
- Regulatory Committee Requirements (Human Subject Oversight, IRB Preparation, etc.)
Administrative/Clerical salaries may be treated (budgeted and/or charged) as a direct cost if special circumstances exist that would necessitate or require an extensive amount of administrative/clerical personnel expenses significantly greater than the routine level of support that is provided to every UCI sponsored project.
To treat an administrative/clerical salary as a direct cost, the following conditions must be met:the sponsored project must satisfy the Major Project criteria; and
- the administrative/clerical activities of the individuals whose salary and related benefits comprise such expenses can be specifically identified (i.e., with a high degree of accuracy) with the sponsored project; and
- the administering unit must maintain documentation that explains and supports items 1 and 2 above.
Major Project, as defined in OMB Circular A-21 and used by UCI in its costing policies and procedures, 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.
The following examples of federal Major Projects are illustrative of circumstances where direct charging of administrative and clerical support is appropriate:
- 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 (e.g., field projects).
- Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars.
- 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 whose principal focus is the preparation and production of manuals and large reports, books, or monographs (excluding routine progress and technical reports).
- Projects requiring the management of large databases; individualized graphics or manuscript preparation; projects involving multiple human or animal protocols; or projects involving coordination of, and communication between, multiple investigators at various locations.
- Since training grants are for a different purpose than a traditional research project, these project budgets may include costs that are normally treated as F&A costs. Training grants permit a budget for an “institutional allowance” which authorizes direct charging of appropriate expenses normally treated as facilities and administrative costs if they are reasonable, specifically identified with the project, and budgeted in the award.
The following examples are illustrative of circumstances where direct charging of administrative or clerical salaries to non-federal projects may be appropriate if the costs are budgeted and approved by the awarding agency:
- For-profit (Industrial/Commercial) sponsors: Projects performed for these organizations are proposed and awarded to be performed, at least in part, for the benefit of the sponsor. Total costs are the concern of the sponsor, not whether the costs are direct or facilities and administrative.
- Non-profit sponsors: Generally the purpose of private foundation funding is to supplement federal research support. Typically, non-profit sponsors do not support the facilities and administrative activities of the research project as indicated by their practice of funding facilities and administrative costs at a rate less than the institution’s full F&A cost rate.
- State sponsored agreements: State agreements that have defined the types of costs that are direct or facilities and administrative would constitute a different circumstance than costs incurred under federal agreements. UCI must comply with State agency regulations and statutory requirements. Consequently, costs normally treated as facilities and administrative costs could be treated as direct if they are reasonable, specifically identified with the sponsored agreement, and included in the award budget.
- Competitive and complex procurement (e.g., equipment, services, fabrication)
- Conducting a telephone survey
- Coordinating and managing a high number of consultant contracts/subcontracts
- Coordinating extensive travel and meeting arrangements
- Extensive data entry
- Extensive research accumulation
- Extensive interviewing (e.g., human subjects, data collection)
- Managing projects with multiple sites
- Planning and organizing large conferences
- Preparing manuscripts/publications beyond the routine
- Extensive administrative activities in support of related projects (see OMB Circular A-21 (C.4.d. (3))
The above examples are neither exhaustive nor are they intended to imply that direct charging of these expenses would always be appropriate.
When justifying administrative/clerical salaries in proposal budgets (or before charging such expenses to a sponsored project), it is helpful to address the following issues:
- Are the administrative support needs of this project significantly greater than the routine level of administrative support provided for all projects? If so, why? Also, describe how the administrative support activities of the administrative/clerical personnel working on the project are necessary for the successful performance of the project.
- If a job title or payroll classification implies that an individual's work is administrative in nature, but the person will be engaged in non-administrative work on a sponsored project, describe the non-administrative work to be assigned to the individual, as well as how such work is necessary for technical performance of the project.
- Can the proposed administrative/clerical support costs be easily and accurately allocated to the project? How will this be done? For example, an administrator working full-time for a project can be allocated easily and accurately to the project. However, if that person works on multiple projects, it may be difficult to accurately document the relative benefit of the administrator's salary (effort) to any specific project. The more projects a person works on, the more difficult it is to accurately and easily document the relative benefit to each project.