Direct Charging of Administrative and Clerical Salaries to Federal Awards
The following guidelines address salaries and fringe benefits of administrative and clerical staff and are based on the Uniform Guidance, 2 CFR §200.413.
The salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs. It may be appropriate to charge these as direct costs to the award if they meet ALL of these conditions:
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. The costs are not also recovered as indirect costs.
The principal investigator is responsible for justifying administrative expenses in a proposal or budget modification. The word "integral" is generally interpreted as activities that are necessary or fundamental to the project. administrative and clerical salary expenses should be reviewed routinely throughout the life of the award. If the charges no longer meet all of the conditions, they must be removed from the federal award and charged elsewhere.
Also see: Allowable Costs
Non-Federal Sponsors
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. Sponsor terms and conditions may restrict the direct charging of administrative and clerical salaries. All other sponsor-required stipulations apply (rebudgeting, prior approval, etc.). If there are questions, please contact SPA for advice.
Responsibility for Compliance
PIs and their department administrators are responsible for ensuring that costs assigned to federal projects are appropriate. Restricted cost categories and other inappropriate charges can be readily detected in audits, and resulting disallowances must be reimbursed to the federal government from the funds of the responsible unit.