The following guidelines are based on OMB Circular A-21, entitled Cost Principles for Educational Institutions, Section F.6.b, Section J, and Exhibit C. 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. OMB Circular A-21 states that costs charged to a project must be allowable, allocable, reasonable, and consistently treated. A cost is allocable to a sponsored project if it is incurred solely to advance the work under the sponsored agreement; or it benefits both the sponsored project and other work and a portion of the cost can be reasonably and proportionally assigned to the project. 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 from a number of institutions. 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, remote field sites).
- 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
OMB Circular A-21 states: "The salaries of administrative and clerical staff should normally be treated as F&A costs." 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. OMB Circular A-21 states: "Items such as office supplies, postage, local telephone costs, and memberships shall normally be treated as F&A costs." 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 that would not exist but for the project, 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) related to a project may be charged to a project. However, care must be taken to ensure that calls are directly related to project-specific activities. Memberships in Professional and Scientific Organizations
OMB Circular A 21 states that costs of the institution’s membership in business, technical, and professional organizations are allowable, and costs of the institution’s subscriptions to business, professional, and technical periodicals are allowable. However, in order to be charged to a project, the costs must also be shown to be allocable to the project. Postage
Postage may be charged to a project when it is directly related to the conduct of the study, including correspondence with the sponsor and project participants. 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.
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. back to top |
