UG-Administrative and Clerical Salaries and Conferences

ADMINISTRATIVE AND CLERICAL SALARIES

Administrative and clerical salaries can be charged as a direct charge to a federal sponsor when the effort is integral to the project.

Updated: 9/1/2015

Administrative and clerical salaries should typically be treated as facilities and administrative costs on federally sponsored projects; however, when certain criteria are met, they may be allowed as a direct cost.

The Uniform Guidance eliminates the major project criteria from A-122 for the direct charging of administrative and clerical salaries and now requires an administrative salary to meet the criteria of integral.

Direct charging of costs administrative and clerical salaries to federally sponsored projects is appropriate only if ALL of the following conditions are met:

  1. administrative or clerical services are integral to a project or activity (the requirement that the cost is “integral” means the services are essential, vital, or fundamental to the 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 (a detailed budget justification must be included in the proposal);
  4. the costs are not also recovered as indirect costs

Non-federally Sponsored Projects

Direct charging of administrative or clerical salaries to a non-federally sponsored project may be allowed if the services benefit the sponsored project.  Follow the sponsor’s specific requirements for direct charging of administrative costs.

The Uniform Guidance is effective for federally sponsored agreements and new funding increments incorporating the Uniform Guidance awarded on or after December 26, 2014.

Uniform Guidance Section:  200.413

Federal awards received before December 26, 2014 must continue to follow the requirements in OMB A-122.

NIH Implementation

NIH modular grants or similar grant instruments do not require line-item budgets. (Note: Re-budgeting authority may be used to charge administrative expenses not included in the approved budget if specific re-budgeting authority for clerical and administrative expenses is allowed by award and sponsor re-budgeting guidelines). (See, for example, NIH administrative requirements).

 

CONFERENCES                                                                                                                                    Updated: 9/1/2015     

The language from the proposed item of costs for External Meetings and Conferences has been clarified to better articulate the limits on the types of gatherings for which these costs are allowable. In addition, the language clarifies that the costs of identifying, but not providing, locally available dependent care options for attendees are allowable. The result is that non-Federal entities have clear limits around conference spending which should limit these costs appropriately.  (see Charging for Administrative and Clerical Salaries above)

You must propose administrative salaries that are integral to the project for effort related to the cost of identifying locally available dependent-care resources. Include detail in the budget justification about the benefit to the project. If you did not propose administrative salaries for the identification of locally dependent-care resources, prior approval is required by the sponsor prior to charging.

Uniform Guidance Section: 200.432

FAQs for Administrative Salaries and Conferences:

How does the integral definition change our current policy?  A project no longer needs to be identified as “major;” however, the administrative salary expense needs to be integral or essential to the project in order to be direct charged. It must also be included in the proposal budget and justification. Most of the other requirements for direct charging salary are the same as with major projects.

What should be included in a budget justification for charging administrative/clerical salaries?  A description of administrator’s salary that is being proposed and what makes it integral to the sponsored project. This should include:
• a description of the administrator’s role
• how the administrator’s effort relates to and benefits the project
• the level of effort expressed as a percentage FTE or person months per sponsor instructions
• the time period(s) in which the person will be working
• any other information that will aid the sponsor in evaluating and funding the proposed salary.

NOTE: Although NIH modular grants or similar grant instruments do not require line-item justifications, the personnel, including administrative salaries, do need to be described in a modular budget’s justification.

Does the “integral” criteria apply to non-federal sponsored projects?  Most non-federal sponsors do not require the administrative activity to be integral.   However, some non-federal sponsors may include such a requirement or the sponsor may incorporate OMB Uniform Guidance requirements.  Check the terms and conditions of the  award to determine if your non-federal projects have adopted the Uniform Guidance or the “integral” requirement.

Is there a minimum threshold for charging administrative and clerical salaries in order for it to be considered integral?  No, but you must consider that there is a continuum in terms of the amount of effort devoted and charged to the sponsored project. The lower the percentage effort proposed, the more difficult it may be to document and justify the integral nature of the activity.

What are some types of proposals at MBL that might have administrative salary charges that would be considered integral?  Some examples include: any grant mechanism that provides for an administrative core, such as NSF Research Centers, NIH program project grants, NIH Center grants.  Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars.  Projects that require monitoring and management of multiple subawards and/or foreign subawards.

If my project was classified as “major,” and additional funding is received on or after December 26, 2014, what should I do?  It will need to follow the definition of “integral” under the Uniform Guidance.  If it previously met the major project criteria, it will most likely meet the “integral” requirement.

I am proposing a conference grant and I don’t believe the resources provided by the MBL will be sufficient. Can I budget for an administrator to expand on these resources?  Yes.  Uniform Guidance allows for administrative salaries that are integral to the project and for the cost of identifying (but not providing) local dependent-care resources.