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11.
Administrative Salaries and Other Clerical Expenses
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Major
Projects or Significant Effort
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The
September 1, 1994 revision of Circular A-21 established
the principle that administrative and clerical expenses
are normally considered indirect costs. However,
there are now two instances when administrative and clerical
costs may be charged directly to Federal funds received
either directly from the Federal Government or indirectly
as a subrecipient under another entity's federal agreement;
one, where the project is defined as a major project
or activity; or, two, where the employee is providing
a substantive contribution to the research project (defined
below as significant research effort ).
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Major
Project or Activity
A
project which is multi-purpose and multi-investigator
or interdisciplinary, and requires a core administrative
budget to ensure the project's operation and effectiveness.
Examples of such major projects and activities include
center grants or contracts ("P" series
grants
for PHS), cooperative agreements made for the purpose
of running large programs (such as the LLE cooperative
agreement
with DOE) and other major awards with an agency-approved
administrative support portion (such as the DOD University
Research Initiative or the NSF Science and Technology
Center), projects in remote locations where departmental
administrative support is not possible, conference
grants, and similar activities. Where these projects
are established with a master administrative account
and several subaccounts, administrative and clerical
salaries should be charged to the core administrative
account.
Refer to OMB
Circular A-21, Exhibit C for further examples
of major projects. The key to this definition and
these examples is the concept of "administrative
intensity" beyond routine levels. If the technical
nature of the work to be done includes components
that are "administratively intensive", then
A-21 allows the definition of the project as "major".
The direct charging of those allocable administrative
costs which make the project "major" is
then appropriate. A project may be "major"
regardless of its size or the amount of its funding.
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Significant
Research Effort
Salaries
of administrative and clerical personnel may be directly
charged to a federal agreement if it can be demonstrated
that the person is performing a research service to
the agreement. Administrative and clerical activities
involving data collection (such as surveys), statistical
analysis, literature searches, or similar efforts
are examples of such extraordinary services. Routine
account monitoring, meeting arrangements, or typing
of general correspondence or project reports are not
research services as used herein.
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In
either case (major project or significant research effort),
the following criteria must be met for the charge to be
allowable as a direct cost:
- the
salaries are requested as part of the original project
budget ( and are not specifically disallowed in the
resultant award), or are subsequently explicitly
approved
by the funding agency; or
- sufficient
justification is made in the project budget to show
other than routine administrative or clerical support
to the project.
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that this "major project" or "significant
research effort" requirement applies to federal sponsors
only. With respect to non-federal sponsors, administrative
and clerical expenses that are allowable, allocable and
reasonable may be charged without demonstrating the existence
of a "major project" or "significant research
effort". |
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