Post Award
Research CCHIP #003
CLARIFICATION OR CHANGE IN PROCEDURE (CCHIP)
Direct Charging Administrative and Clerical Costs to Sponsored Projects
OVERVIEW
This document sets forth USF’s procedures regarding the direct charging of administrative or clerical salaries and other types of general administrative expenses to federally funded (including federal prime subawards received by USF through another entity) sponsored projects. These types of expenses are more commonly known at USF as Cost Accounting Standards (CAS) Exceptions.
DEFINITIONS
Administration – General administration & general expenses, departmental administration, sponsored projects administration, student administration and services, and all other types of expenditures not listed specifically under one of the subcategories of facilities.
Equipment – An article of nonexpendable, tangible personal property having a useful life of more than one year and an acquisition cost which equals or exceeds $1,000, the capitalization level established by the USF for financial statement purposes.
F&A Costs – Facilities & Administrative costs means costs that are incurred for common or joint objectives that cannot be identified readily and specifically with a particular sponsored project, instructional activity, or any other institutional activity. F&A costs are synonymous with indirect costs.
Facilities – Depreciation and use allowances, interest on debt associated with certain buildings, equipment and capital improvements, operation and maintenance expenses, and library expenses.
General Purpose Equipment – Equipment that is not limited to research, medical, scientific or other technical activities.
Special Purpose Equipment – Equipment that is used only for research, medical, scientific, or other technical activities.
Sponsored Project – Any grant, contract, or other agreement between the University of South Florida and a sponsoring agency.
CLARIFICATION OR CHANGE
This clarification is issued to define the appropriate charging of administrative or clerical salaries and other administrative expenses consistent with the Uniform Guidance (2 CFR §200).
Definition
Under federal regulations and sponsor requirements, administrative expenses including
but not limited to administrative or clerical salaries, office supplies, postage,
local telephone costs, photocopy costs, cell phones, etc. should normally be treated
as a Facilities and Administrative (F&A) cost and recovered through the F&A cost rate
(also known as indirect cost rate).
In exceptional circumstances where the nature of the work performed requires extensive
administrative support (defined as an unlike circumstance), administrative costs may
be treated as direct charges.
Administrative or clerical salaries and other general administrative costs must directly
benefit and be easily identified with the particular sponsored project.
Costs Normally Included in the F&A Cost Rate
Administrative or clerical salaries and other expenses that fall within the routine services normally provided by departmental administration are treated as F&A costs. As a general rule, such routine services cover the general business of the department as a whole, and may include some limited support to faculty to enable them to conduct their teaching and scholarly activities. For additional information see F&A Costs Rates.
General business functions include activities such as:
- basic financial management and accounting; purchasing;
- human resource management; facilities management;
- administrative or clerical support for course instruction; and
- secretarial support for professional correspondence, preparation of grant applications, etc.
Direct Charging of Administrative or Clerical Salaries and Other Departmental Expenses
The direct charging of administrative or clerical salaries 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 the department.
Uniform Guidance ((2 CFR § 200.413(c)(1)-(4)) that states:
”The salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs. Direct charging of these costs may be appropriate only if all of the following conditions are met: (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 or have the prior written approval of the Federal awarding agency; and (4) The costs are not also recovered as indirect costs.”
Additionally, Uniform Guidance (2 CFR §220 Appendix A, Exhibit C) provides examples of circumstances where the direct charging of salaries of administrative or clerical staff may be appropriate. They are as follows:
- Large complex programs, such as general clinical research centers, primate centers, program projects, environmental research centers, engineering research centers, and other grants and contracts that entail assembling and managing teams of investigators from a number of institutions.
- Projects which involve extensive data accumulation, analysis and entry, surveying, tabulation, cataloging, searching literature, and reporting (such as epidemiological studies, clinical trials, and retrospective clinical records studies).
- Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars.
- Projects whose principal focus is the preparation and production of manuals and large reports, books and monographs (excluding routine progress and technical reports).
- Projects that are geographically inaccessible to normal departmental administrative services, such as research vessels, radio astronomy projects, and other research field sites that are remote from campus.
- Individual projects requiring project-specific database management; individualized graphics manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications.
Additional examples might also include certain research epidemiological studies, computer science studies of large database management, clinical trials, computational biology studies, retrospective clinical records studies, and astronomical surveys.
The examples above are illustrative of the same criteria that are applied to the treatment of items such as office supplies, postage, local telephone costs, photocopying, network charges, cell phones, etc. Direct charging of such expenses may be justifiable when the expenses are related specifically to the technical substance of a project or there is an unusually high level of expense because of the nature of the activity.
As required by federal regulations, costs incurred for the same purpose in like circumstances must be treated consistently as either direct or F&A cost.
Principal Investigators and business offices must exercise caution in applying the guidelines contained herein.
PROCEDURES
Principal Investigators (PI)
- Consult with Sponsored Research regarding the appropriateness of including administrative and clerical salaries and other departmental expenses in proposals.
- Interpret and ensure compliance with sponsored project terms and conditions with respect to the appropriateness of direct charging administrative or clerical salaries and other departmental types of costs.
Department Administrator
- Provide guidance and assist PIs with proposal preparation.
- Assist with interpretation and compliance with sponsored project terms and conditions with respect to the appropriateness of direct charging administrative or clerical salaries and other departmental types of costs.
Sponsored Research
- Provide guidance in the interpretation of federal requirements.
- Assist departments in determining appropriate treatment of direct vs. F&A types of costs.
- Provide guidance to PIs and Department Research Administrators in sponsored projects proposals that include administrative or clerical salaries or other administrative expenses required to support the proposed project.
- Approve requests for CAS exceptions.
CONTACT
Please address your comments or questions regarding this CCHIP to Sponsored Research Compliance.
RELATED REFERENCES
AGENCY GUIDELINES
OMB Circular A-21 (Federal awards issued prior to 12.26.14)
Uniform Guidance (2 CFR §200) (Federal awards issued on or after 12.26.14)
NIH Grants Policy Statement
EFFECTIVE DATE
This CCHIP is effective as of the date of revision and rescinds all previous versions pertaining to the Direct Charging Administrative and Clerical Costs to Sponsored Projects.
ISSUED: June 30, 2007
LAST REVISION: August 16, 2018