ALLOWABILITY OF ADMINISTRATIVE/CLERICAL SALARIES ON FEDERALLY SPONSORED PROJECTS

1. ALLOWABILITY OF ADMINISTRATIVE/CLERICAL SALARIES ONFEDERALLY SPONSORED PROJECTS Guidance for the University of Washington research community in preparation ofgrant and contract applications and post-award administration

2. Administrative & Clerical Salaries Presented by: Carol Rhodes, Associate Director, Office of Sponsored Programs Ted Mordhorst, Assistant Director, Research Accounting and Analysis

3. Administrative & Clerical Salaries The costs incurred by the university for Administrative and Clerical salaries are included in our negotiated Facilities & Administrative (F&A) cost recovery.

4. Administrative & Clerical Salaries Because these costs are included in the F&A rate, direct charging them to a sponsored award means we are charging the sponsor twice for the same cost. This is a cost area that is susceptible to abuse and therefore federal examiners have targeted this as an area to review.

5. Administrative & Clerical Salaries OSP and GCA have developed guidance for departments to assist in proposing and charging these costs to sponsored projects. This is in addition to GIM 23 which includes a list of job codes designated as administrative/clerical in our latest F&A rate proposal.

6. Proposal Review OSP will review the circumstances that are being presented to the sponsor in support of the direct charging of administrative/clerical salaries in light of the federal cost principles and GIM 23. Administrative/clerical salaries proposed in a grant or contract budget as a direct cost or as cost-share must meet each of the following criteria:

7. Proposal Review • The salary falls within the special circumstances specified by OMB, Circular A-21 Section.F.6.b Interpretation (see GIM 23 for text); • The title, effort level and salary of the position are stated in the proposal; and • The special circumstances warranting direct charging of the services are explained in the proposed budget justification -OR- • The Sponsor specifically allows the direct charging of administrative/clerical costs due to the type of grant or contract and this is documented in the funding opportunity announcement (FOA).

8. Post Award It is the Principal Investigator’s responsibility to document the roles, duties, and effort devoted to a sponsored project for all personnel. Therefore, the duties of any administrative or clerical position described in the justification to OSP should be reflected in the departmental record as the project is carried out.

9. Post Award At the time of budget set-up, OSP notifies GCA when administrative and clerical salaries have been appropriately justified and funded. GCA denotes this in the accounting system by activating Grant Control Flag #2 Subsequent compliance checks may be performed to ensure that administrative and clerical salaries are appropriate when charged to a federal award.

10. Post Award Rebudgeting If charging an administrative/clerical salary was unforeseen at the time of proposal but the need to do so arises after time of award, the same criteria for including them in the proposal budget apply. The PI/dept must send an appropriate justification to OSP for review and to notify GCA to add Flag #2.

11. Post Award If an administrative/clerical payroll title is necessary for an individual with research or technical -based effort on the project, notification to OSP is required. OSP will document the role of the individual and will notify GCA. Flag #2 will not be added to the budget.

12. Frequently Asked Questions Q. Is direct charging small percentages of administrative/clerical effort (salaries) among several off-campus sponsored agreements allowable per OMB Circular A-21 guidelines? A. Not Generally, A-21 allows the direct charging for large complex projects that require an exceptional level of administrative support. Small percentages of effort would not indicate an exceptional level of administrative support.

13. Frequently Asked Questions • If administrative/clerical salaries were proposed in the application and the sponsor did not specifically disallow them in the award, are they allowable? A. In most cases the answer is probably yes. Q. What about the treatment of administrative and clerical costs on non-federal awards? A. They are allowable if the sponsors of those projects do not specifically disapprove the cost in the award or in other notices it gives to the University.

14. QUESTIONS?