OMB Uniform Guidance states that “the salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs.” Harvard University’s policy for Administrative and Clerical Salaries on Federal Awards follows the same principle outlined in Uniform Guidance Part 200.413(c). Administrative and clerical staff should be included as direct costs on federal awards ONLY when they meet the following Uniform Guidance criteria:
- 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; and
- The costs are not also recovered as indirect costs.