Purpose
The intent of this procedure is to provide clear information that will enable university staff to determine how to account for administrative or clerical services for sponsored awards in accordance with OMB 2 CFR §200.413 (c) Direct Costs. 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 the following conditions are met:
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Administrative or clerical services are integral to a project or activity;
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Individuals involved can be specifically identified with the project or activity;
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Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
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The costs are not also recovered as indirect costs.
Proposal coordinators and grant administrators will consider information that pertains to a specific proposal and these guidelines when determining direct charging to a sponsored award.
ORSP and Grants Accounting will document the formal approval of this designation in their files through an approved Authorization to Direct Charge Administrative and Clerical Staff Form .
Routine Administrative and Clerical Support
All sponsored projects receive a baseline level of routine administrative or clerical support for their sponsored projects. Departments incur expenses to support normal core operations of the unit. Costs include salaries and benefits of clerical and administrative positions that perform a broad range of baseline general support activities including secretarial assistance, procurement of materials and services, general accounting and bookkeeping, proposal preparation for new awards, payroll, and human resource tasks. It also includes routine office supplies, postage for mailings that do not require special handling, local recurring telephone costs, office and general equipment, non-project specific repair and maintenance costs. Routine baseline academic or research support costs are normally included in the department administrative pools used to develop the indirect cost rate applied to sponsored projects to reimburse the university for at least a portion of those costs.
General Criteria for Direct Charge of Administrative and Clerical Support
The size, nature, and complexity of sponsored projects, although not the final determining factors, are important considerations in determining circumstances where department administrative and clerical expense may be considered as direct and appropriately charged to sponsored projects. Due to the unique requirements of each sponsored agreement (research, instruction, or other institutional activity) we evaluate the existence of unlike circumstances on a case-by-case basis.
Scope
This procedure is applicable to all federally funded sponsored programs and contract services where administrative and clerical salaries, normally treated as indirect costs, are proposed to be direct charged to the project. This does not apply to positions in the “Research” job category.
Procedure
There is no universal rule for classifying certain costs as either direct or indirect under every accounting system. A cost may be direct with respect to some specific service or function, but indirect with respect to the Federal award or other final cost objective. Therefore, it is essential that each item of cost incurred for the same purpose be treated consistently in like circumstances either as a direct or an indirect cost in order to avoid possible double charging of Federal awards (2 CFR §200.412 Classification of costs).
The services provided by these costs must be integral (i.e., they are essential, vital, or fundamental) to the project. Individuals that are classified as administrative or clerical are required to have a minimum of 25% FTE budgeted to sponsored project, or there are documented special circumstances to qualify as integral.
Pre-award (Proposal) Phase
Prior to submission of the proposal to the federal agency, the PI/PD is responsible for ensuring the Authorization to Direct Charge Administrative and Clerical Staff form is completed and routed for approval. The request must demonstrate that the proposal substantially satisfies the criteria and key factors listed above for administrative or clerical administrative support costs to be included in the project budget. The CFAO or authorized designee should consider all factors in their review and approval process and ensure that the criteria are consistently applied to all programs and projects submitted for review and approval. ORSP must receive the approval prior to proposal submission.
PI/PD or administrative delegate will complete the form, route for approval, and submit to orsp@ohio.edu or create an ORSP Service Center Ticket through LEO.
PI/PD will ensure proposal budget narrative explicitly includes administrative costs.
Include the support costs with the other organized research costs in the budget and apply the organized research indirect cost rate to the total research costs.
ORSP will review for completeness, sign, and forward to Grants Accounting.
Grants Accounting will review for adherence to the federal regulations, sign, and return to ORSP.
The ORSP Manager will upload the completed form to the eRA system.
Post-award Phase
ORSP receives the award document and reviews the budget forms from the unit.
ORSP will route the award to Grants Accounting for account setup with the CAS exemption under special terms and conditions.
The program support costs must be accounted for using an organization code (org) with an organized research program code.
Use the organized research rate to recover indirect costs under the grant.
The support costs are included with the other organized research costs under a single organized research org unless the department needs to segregate the costs for internal management purposes.
After-the Fact Requests
PI/PD or administrative delegate will complete the form and submit to orsp@ohio.edu .
PI/PD or administrative delegate will secure prior approval from the agency project officer.
Include the support costs with the other organized research costs in the budget and apply the organized research indirect cost rate to the total research costs ORSP will review for completeness, sign, and forward to Grants Accounting.
Grants Accounting will review for adherence to the federal regulations, sign, and return to ORSP.
The ORSP Manager will upload the completed form to the eRA system.
Questions
Questions regarding this procedure can be sent to orsp@ohio.edu .
Forms/Templates
Authorization to Direct Charge Administrative and Clerical Staff
Roles and Responsibilities
OWNER: PI/PD
CONTRIBUTOR: Department Chair, CFAO
APPROVER: ORSP, Grants Accounting
References
OMB 2 CFR §200.413 (c) Direct Costs
OMB 2 CFR §200.412 Classification of costs