Cost Restrictions on Federally Supported Projects
Direct charging of administrative, secretarial or clerical salaries on federal funds is appropriate only where all of the following conditions are met:
- an extensive amount of administrative or clerical work is required to carry out the project, and
- the administrative or clerical personnel are specifically listed and justified in the budget proposal, and
- the individuals have responsibilities specifically related to the project and the effort devoted to the project is documented, and
- the sponsoring agency accepts the cost as part of the project’s direct cost budget
Clarification: Account monitoring, meeting arrangements, or typing general correspondence or reports on behalf of a grant/contract would be considered the normal services to be provided by the University and treated as an indirect cost; consequently they would NOT be allowed as a direct cost. However, when administrative/clerical services involve extensive data collection literature/ library searches, analysis, surveying or similar services required for accomplishing the programmatic objectives of the grant/contract, such services may be direct charged. Also, if a grant/contract requires an extraordinary amount of normal services such as large, complex programs, admin./clerical services may be direct charged. Other examples are projects that require travel arrangements for large numbers of participants, such as conferences and meetings; projects whose principal focus is the preparation and production of manuals. Large reports, books and monographs (EXCLUDING routine progress and technical reports); projects that are geographically inaccessible to normal departmental administrative services; projects requiring project-specific database management or project- specific regulatory protocols.
Review these sample secretarial justifications to get a flavor of allowability.
Charging for administrative/clerical costs on federally funded projects is not normally allowable on Federal funds but if the criteria listed above is met, the position can be budgeted, but only at 25% effort or greater and justification must be provided in the proposal itself. If budgeting for less than 25%, a policy waiver request must be submitted to and approved by the Mike Malone Vice Chancellor for Research and Engagement.
Proposals containing secretarial expenses, whether temporary or permanent, require adequate justification. Federal regulations permit the direct charging of administrative and clerical costs only when 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.
This type of expense may be appropriate as a direct charge to a grant/contract only when it clearly benefits/supports programmatic objectives. Examples would include research notebooks and computer paper used during the technical course of a project . Items such as pencils. paper clips, memo pads and post-its are normally considered an indirect cost and therefore not allowable as a direct charge. Reasonable judgment should be exercised when charging office supplies directly to a grant/contract because they are likely to be highly scrutinized during sponsor proposal review or during an audit.
The direct charging of postage to an award for purposes such as the shipment of materials, mailing of research surveys to human subjects and submitting deliverables is appropriate if reasonable care is taken to assure that such costs are for the sole purpose of the grant/contract and can be specifically identified and justified as such. Routine correspondence is considered to be an indirect cost and not an allowable direct charge.
Toll calls are allowable if they are allocable to the project. However, local calls (including service) should not be included as a direct expense unless documented and justified to the project, i.e. that the nature and size of the project is such that the line is crucial for the successful execution of the project. Normally this will mean that the service is 100% dedicated to the project and no other use will be made of that line.
Review these sample administrative cost justifications for a flavor of allowability.
For further details on administrative cost restrictions, see Policy on Administrative Costs.