Direct charging of these costs may be appropriate if all four of the following conditions are met:

(1) Administrative or clerical services are integral to a project or activity;

(2) Individuals involved can be specifically identified with the project or activity;

(3) Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and

(4) The costs are not also recovered as indirect costs. (See FAQ #8)

Federal regulations require the PI to explicitly include direct costs for administrative and clerical salaries in the proposal budget and budget justification. The PI must explain why the salaries are integral or fundamental to the project or activity. The administrative or clerical staff member must be allocated at least 20% time or roughly eight hours per week to the project. The budget justification should include an explanation of the work to be done for the project and an explicit request (shown in bold). An example is provided below:

This is a collaborative project involving over 200 individuals from 30 institutions in 10 countries. The project involves coordination of funding from U.S. Federal government agencies, along with funding from agencies in other partner countries. Our institution will oversee seven subawards to other U.S. institutions, perform data storage and analysis, coordinate annual collaborator meetings, and manage overall project operations. We are requesting agency approval for a [list % time appointment] [list position title] as a directly-charged administrative cost in accordance with 2 CFR 200.413.

Yes, the Federal agency must approve the direct charging of administrative and clerical salaries. Costs must either be explicitly included in the approved budget or have prior written approval of the agency.

PIs and departments are strongly encouraged to include these costs in the budget at the time of proposal. In some cases, including NIH, an agency may waive the requirement to obtain prior approval to re-budget for such costs. If agency approval has been waived, then the Dean's or Director's office must make a determination as to the need for direct charging of the salaries.

The guidance for non-Federal sponsors is similar, but it may be more flexible. It is important to be familiar with the program guidelines, as well as terms and conditions. Assuming that sponsor terms and conditions do not restrict the direct charging of administrative and clerical salaries, you may wish to include such costs in budget justification. An example is provided below:

This project requires management of twelve separate subawards to other U.S. and non-U.S. institutions. Our university will oversee all subawards, perform data storage and analysis, coordinate annual collaborator meetings, and manage overall project operations. We are requesting sponsor approval for a [list % time appointment] [list position title] as a directly-charged administrative cost.

If there are questions, please contact your dean's or director's office for advice.

Programmatic activities are those activities that can be directly charged to a project without needing to provide additional justification or obtain prior approval. Administrative or clerical activities need to meet the four conditions outlined in 200.413(c) in order to be directly charged to a project, including being explicitly included in the budget or having prior approval of the Federal awarding agency. Examples of activities that fall into each category are included in the table below.

Please see the list below for some examples of project activities where administrative and clerical salaries might be considered integral and allocable to the project. Even for these very reasonable examples, the costs associated with the salary must be included in the approved budget or have prior written approval from the awarding agency:

a. 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.

b. 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).

c. Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars.

d. Projects whose principal focus is the preparation and production of manuals and large reports, books and monographs (excluding routine progress and technical reports).

e. 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.

f. Individual projects requiring significant amounts of project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications.

The examples above should be helpful in determining some of the costs that might necessitate administrative and clerical salaries as direct costs.

Although Modular Grant Application guidelines do not require a detailed categorical budget, NIH requires that a modular budget must still include a Personnel Justification within the Budget Justification section. If the PI/department seeks to direct charge administrative and clerical salaries, the personnel justification should explicitly include:

• The name(s) of such personnel (or indicate that a position is "to be appointed");
• The number of person months devoted to the project (at minimum, equivalent to 20% time or roughtly eight hours per week); and
• The individual's role/responsibilities on the project and why the services provided are integral to the project or activity.

It must be clear to NIH that the individual will be performing administrative/clerical duties. The personnel justification should include a statement such as, "In accordance with 2 CFR 200.413 and 45 CFR 75.413, we are including [list name, position title] for [list person months] as a directly-charged administrative cost."

The Office of Research and Sponsored Programs is responsible for preparation of the University's Facilities & Administrative cost rate proposal. As such, RSP is responsible for ensuring that any direct charged administrative and clerical salaries are also not recovered as indirect costs. RSP follows the federally-mandated formula that excludes these salaries from being recovered as indirect costs.

While it is possible to charge 100% of an administrative or clerical staff person's salary to a single sponsored project, the practice is not encouraged. Similar to 100% research faculty, charging 100% of an administrative/clerical staff person's salary to a single sponsored project raises the question of whether or not the individual is involved in activities (e.g., university governance, committee work, or proposal development) that should be funded by sources other than the sponsored project.

Splitting the administrative/clerical salary charges across more than one sponsored project may cast doubt upon whether the salary would be more appropriately categorized as an F&A expense.

An assignment taking less than 20% time would not strongly support that an individual is integral and specifically identifiable with a project or activity.

Yes. Any salaries charged to sponsored projects must be certified to ensure that they are reasonable in relation to the work performed.

Contact your Dean or Director's office for guidance.

a. If a need for administrative or clerical support arises after the project has been funded, rebudgeting for those costs will require prior approval of the awarding agency before an appointment to the grant is made. The request should include:

• An explanation as to why the salaries are integral or fundamental to the project or activity;
• Identification of the proposed amount of time (a minimum of 20% time or roughly eight hours per week) that the individual will spend on the project; and
• An explicit request to charge administrative/clerical costs (shown in bold in the example).

Here is an example of a request that might be approved by the funding agency:

A need has been identified for administrative and clerical support for this project. The survey responses have been much greater in number than anticipated, and the need to accumulate, analyze, and tabulate data has increased commensurate with our responses. We would like to allocate time for a staff person within our department to support these activities. We are requesting agency approval for a [list % time appointment] [list position title] as a directly-charged administrative cost in accordance with 2 CFR 200.413.

The request should be routed to the Dean's or Director's office, who will review and forward to RSP. RSP will submit the request to the Grants Official at the Federal awarding agency.

b. If the PI/department is seeking additional funds – beyond the awarded amount – from the agency for administrative and clerical salaries, then a supplemental request should be routed in WISPER.

In either case, an approval from the agency must be received in order to charge the administrative and clerical salaries directly to the project.

NIH has waived the requirement to obtain prior approval to re-budget for administrative and clerical salaries, unless additional funds are being requested or the incurrence of such costs constitutes a change in scope. While NIH has waived the requirement to approve administrative and clerical salaries, the institution has assumed the responsibility to approve such costs. There are three possible scenarios:

1. Additional funds are being requested to pay for administrative/clerical salaries: A supplemental request should be routed in WISPER. The request should include the same information as described in FAQ #7. An approval from the agency must be received in order to charge the administrative and clerical salaries directly to the project.
2. Incurrence of administrative/clerical salary costs constitutes a change in scope, but no additional funds are being requested: A prior approval request should be submitted to NIH. The request should include the same information as described in FAQ #7, as well as address how the scope of the project is changing and why it is changing. An approval from the agency must be received in order to charge the administrative and clerical salaries directly to the project.
3. Funds are available to re-budget to pay for administrative/clerical salaries, and incurrence of such costs does not constitute a change in scope: You should submit your request to the Dean’s or Director’s office for review prior to making any expenditures in this category. The request should include the same information as described in FAQ #7. If the Dean’s or Director’s office approves your request, they will send a copy of the approval to the RSP accountant.

If you receive a cost transfer where a PI/department is trying to direct charge administrative and clerical salaries, it should be verified that the direct charging of such salaries has been approved by the Federal awarding agency or the Dean's or Director's office. The transfer should not proceed until prior written approval from the Federal awarding agency or the Dean's or Director's office has been confirmed.