OMB A21: Charging Administrative & Clerical Salaries and other Administrative Expenses to Federal Grants and Contracts
The following guidelines are based on OMB Circular A-21, entitled Cost Principles for Educational Institutions, section F.6.b. This Circular requires university accountability for federal funds and a high degree of consistency with which institutions must treat expenditures. These guidelines address salaries and fringe benefits of administrative and clerical staff and certain general expenses, including office supplies, postage, local telephone costs, and memberships in professional and scientific organizations.
The salaries and fringe benefits of administrative and clerical staff and other general administrative expenses are not allowed as direct charges to federally sponsored agreements except in special circumstances. Examples of projects where the direct charging of administrative and secretarial salaries and other administrative expenses may be approved include major, complex, multi-investigator projects such as Center Grants, Program Project Grants, and other sponsored projects that entail assembling and managing teams of investigators. It may also be permissible to charge these expenses to single investigator projects that require an extraordinary level of clerical and administrative support, such as the following:
- Projects that involve extensive data accumulation, analysis and entry, surveying, tabulation, cataloging, searching, and reporting, such as data reduction, epidemiological studies and clinical trials.
- Projects that require making extensive travel and meeting arrangements for a large number of participants, such as conferences and seminars.
- Projects whose principal focus is the preparation and production of manuals and large reports (other than routine progress and technical reports), books, and monographs.
- Projects that are geographically inaccessible to normal departmental administrative services (e.g, off-campus research).
- Projects that require project-specific database management, individualized graphics or manuscript preparation, human or animal protocols, IRB preparations, and/or other project-specific regulatory protocols, and multiple project-related investigator coordination and communications.
The following guidelines should be observed when preparing budget proposals or directly charging costs under federally sponsored agreements:
Administrative and Clerical Salaries and Fringe Benefits
Administrative and clerical salaries and fringe benefits associated with routine services such as typing reports, filing, handling mail, making travel arrangements, answering telephones, etc., should not be budgeted or charged as direct costs, even when there is a direct benefit to the project.
Office Supplies
Office supplies that are normally used in the general administrative support of a project should not be included in the budget. Office supplies that are used exclusively for project-specific activities may be included in the budget. Since many items of office supplies are used for both general administrative support and project-specific activities, it is important that these items, when included in the budget, be described in terms of their proposed use.
Local Telephone Costs
Local telephone rentals used to conduct routine business of the project should not be included in the budget. Telephone lines, including data lines, modems, and telephones, used to conduct surveys or to maintain contact with project activities conducted at remote locations may be included in the budget.
Telephone Toll Calls
Telephone toll calls (long distance) may be included in the budget. However, care must be taken to ensure that calls are directly related to project-specific activities.
Memberships in Professional and Scientific Organizations
Memberships in professional and scientific organizations are unallowable as a direct cost on federal funds unless the membership is specifically identified and requested as a part of the project budget and the budget line item is allowed or the cost is specifically approved in writing by the federal agency. Your justification to the agency may be acceptable if, for example, membership is the sole means for getting a subscription to a journal that is necessary solely for the conduct of the project.
Postage
Postage may be included in the budget when it is directly related to the conduct of the study, including correspondence with the sponsor and project participants. Additional postage may be included in the budget to disseminate surveys and materials produced as a result of the project activities.
When any of the above costs are included in proposal budgets, they should be explicitly justified and explained. Before any of these charges will be allowed against sponsored agreements, awards must provide evidence that the budget has sponsoring agency approval.
Responsibility for Compliance
Principal investigators and their units (department, center, etc.) are responsible for ensuring that costs assigned to federal projects are appropriate. Restricted cost categories and other inappropriate charges can be readily detected in audits, and resulting disallowances must be reimbursed to the federal government from the funds of the responsible unit.