Administrative and Clerical Salaries (“admin salaries”) on Federal Awards are expenses for non-technical supporting services that generally benefit departmental, institute, or center activities or objectives, including functions such as clerical support, financial management, procurement of materials and services, budget and planning, and personnel management.
Generally, administrative and clerical salaries should 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 or activity exceptions from A-21 for the direct charging of administrative and clerical salaries and has replaced it with the following criteria, all of which must be met:
- Administrative or clerical services are integral to a project or activity
- Individuals involved can be specifically identified with the project or activity
- Such costs are explicitly included in the budget or have the prior written approval of the federal awarding agency
If all these requirements are met, then administrative/clerical expenses may be included in the proposal budget justification that ties the administrative effort to the projects aims. It must also confirm that the costs are not recovered as indirect costs.
Agency Specific Guidelines
- National Science Foundation - Grant Proposal Guide - Chapter II.C.2.g.(i)(b), Administrative and Clerical Salaries & Wages Policy
- National Institutes of Health - Grants Policy Statement - Part II, Section 8.1.1.5 Direct charging Salaries of Administrative and Clerical Staff
Proposal Stage Requirements
Administrative salaries approval must be flagged in the GMAS request at the proposal stage. OSP will review for the following:
- Reviewing GMAS to determine if admin salaries were included in the budget at the proposal stage
- Reviewing requests and proposals for direct charging of admin salaries to ensure they meet the required criteria
- Ensuring sponsor approval is received prior to initiating award or approving newly added admin salaries (e.g., award includes budget with administrative salaries or other written approval is received)
Award Stage
At the award stage, OSP will ensure sponsor approval is received prior to initiating an action memo or approving newly added admin salaries.
The OSP Awards Management Team will review any budgets submitted with the proposal to determine whether the administrative salaries were approved as part of the submitted budget. If the salaries were not included at the time of the proposal or are added during the life of the award, sponsor written approval will be required. In order to obtain approval, the Department Administrator must upload a revised budget with justification into GMAS.
Once the salaries have been confirmed and approval is documented, the OSP Awards Management Team portfolio owner adds a comment to the GMAS Administrative Salary approval outlining the budget justification for the salaries. The Awards Management Portfolio Owner then marks the approval as “Done.”
It is the responsibility of the PI and Department Administrator to notify OSP if administrative salaries are added or removed from the project during the life of a federally funded award. These restrictions apply only to Federal prime sponsors.