Administrative and clerical
salaries
BACKGROUND, BEST PRACTICES, AND
THE FUTURE OF DIRECT CHARGING
ADMINISTRATIVE/CLERICAL SALARIES
TO GRANTS
MRAM
MARCH 2014
FISCAL COMPLIANCE
CORNER
Breakdown of Facilities & Administrative rate
Incurred for common or joint objectives and cannot be identified readily and
specifically with a particular sponsored project:
Facilities* includes:
• Operation/maintenance of buildings
• Building Interest (cost of interest)
Administrative* includes:
• General administration
• College/School administration
• OSP/GCA (research administration)
*Based on OMB Circular A-21
Management Accounting and Analysis (MAA) website contains detailed information on the cost pools
Administrative portion is 26%
 Established by Congress in 1991.
 No change since that time despite efforts by Universities
and COGR requesting this be re-visited.
 Administrative costs associated with sponsored projects
are charged to the project by virtue of sponsor paying the
F&A rate associated with the project.
 Direct charging administrative or clerical costs is
generally disallowed for this reason. No doublecharging!
Are there exceptions?
 No bright line exceptions, just general guidance via OMB
interpretation issued in 1994:
...direct charging of these costs may be appropriate where the nature
of the work performed under a particular project requires an
extensive amount of administrative or clerical support
which is significantly greater than the routine level of such
services provided by academic departments. The costs would need to
meet the general criteria for direct charging in section D.1. -- i.e., be
identified specifically with a particular sponsored project
relatively easily with a high degree of accuracy, and the special
circumstances requiring direct charging of the services would need to
be justified to the satisfaction of the awarding agency in the
grant application or contract proposal. {italics, bold added}.
Proposal stage: Key steps
 CONSISTENT TREATMENT within your unit: Compare activity to
be undertaken by individual with other grants with similar activity or
other grants the individual is on doing same type of work.
 CLEAR and THOROUGH JUSTIFICATION: Explain the activity
of the individual and why this project has “unlike”circumstances
warranting the direct charging of the salary cost.
 RESPOND to OSP Review Comments: OSP has a “bird’s eye” view of
grants at the University and is looking to ensure consistent treatment of
costs in budget proposals across the University.
 Know DEPT RESPONSIBILITY/RISK: Despite your best efforts to
justify and OSP approval of the proposal, the sponsor/auditor may see
it differently! See POST-AWARD key steps.
REMEMBER: OSP approval does not guarantee acceptability of costs as a direct cost!
When is it guaranteed the costs would be
allowable?
1)
Sponsor EXPLICITLY approves the line item cost in the
award terms and conditions (this rarely happens).
1)
University requests and receives direct sponsor approval to
add/charge such a cost to a budget. If post-award, this
would come through as a concurrence request.
Merely receiving an award in response to a proposal
that includes admin/clerical costs as a direct line item
with justification, is NOT explicit sponsor approval.
Spend at your risk and document, document,
document (see Post-Award key steps)
Key Post-Award Steps
 Identify the individuals/positions involved.
 Document activity directly related to achieving the
objectives of the sponsored program.
 GCCRs processed and signed by the PI per university
policy.
If costs are questioned . . .
Have available:
 Proposal with justification
 Documentation in department file
 Be prepared to explain individual’s activity and why
unlike/unusual
 Be prepared to explain why individual’s activity on
THIS grant is different than on another grant, if such
individual’s time is NOT directly charged on another
grant.
Specific findings from recent years (at other
Universities)
 Auditor’s findings included unallowable salary for
administrative and clerical type work such as
cleaning glassware, ordering supplies, and
supervising data collections.

The auditors determined that neither the nature of the work
performed on the projects nor any other circumstances
justified any unusual degree of administrative support or
showed that the employees were necessary for the
performance of the awards.
 Disagreement over what constitutes a Major project
or program.
Uniform Administrative Requirements
(“OmniCircular”)
 New provision:
(d) The salaries of administrative and clerical
staff should normally be treated as indirect
(F&A) costs. Direct charging of these costs
may be appropriate where all of the
following conditions are met:
Uniform Administrative Requirements
(“OmniCircular”)
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) such costs are explicitly included in the budget;
and
 (4) the costs are not also recovered as indirect
costs.
Uniform Administrative Requirements
(“OmniCircular”)
 Applies to new funding received after Dec 26, 2014
 Current regulations will continue to apply to existing




funding.
The new language dropped the reference to “Major
Project or Activity” and the examples in Exhibit C.
Appears to provide some additional flexibility for
direct charging.
Not sure what specific sponsors or auditors will do.
Cautiously optimistic
Resources
 OMB Circular A-21
 GIM 23: (Includes list of job codes considered administrative/clerical
as determined by UW Management Accounting and Analysis, MAA)
 OSP: osp@uw.edu
 GCA: gcahelp@uw.edu
 FAQs and additional process information:
http://www.washington.edu/research/guide/news.php?entry=795