FEDERALLY SPONSORED PROJECTS Guidance for the University of Washington research community in preparation of grant and contract applications and postaward administration Administrative amp Clerical Salaries ID: 160772
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ALLOWABILITY OF ADMINISTRATIVE/CLERICAL SALARIES ONFEDERALLY SPONSORED PROJECTS
Guidance for the University of Washington research community in preparation of
grant and contract applications and post-award administrationSlide2
Administrative & Clerical Salaries
Presented by:
Carol Rhodes
, Associate Director, Office of Sponsored Programs
Ted Mordhorst
, Assistant Director, Research Accounting and AnalysisSlide3
Administrative & Clerical Salaries
The costs incurred by the university for Administrative and Clerical salaries are included in our negotiated Facilities & Administrative (F&A) cost recovery.Slide4
Administrative & Clerical Salaries
Because these costs are included in the F&A rate, direct charging them to a sponsored award means we are charging the sponsor twice for the same cost.
This is a cost area that is susceptible to abuse and therefore federal examiners have targeted this as an area to review.Slide5
Administrative & Clerical Salaries
OSP and GCA have developed guidance for departments to assist in proposing and charging these costs to sponsored projects.
This is in addition to GIM 23 which includes a list of job codes designated as administrative/clerical in our latest F&A rate proposal.Slide6
Proposal Review
OSP will review the circumstances that are being presented to the sponsor
in support
of the direct charging of administrative/clerical salaries in light of the federal
cost principles
and GIM 23
.
Administrative/clerical salaries proposed in a grant or contract budget as a direct cost
or as
cost-share must meet each of the following criteria:Slide7
Proposal Review
The salary falls within the special circumstances specified by OMB
, Circular
A-21 Section.F.6.b Interpretation (see GIM 23 for text
);
The title, effort level and salary of the position are stated in
the proposal
; and
The
special circumstances warranting direct charging of the
services are explained
in the
proposed
budget justification
-OR-
The
Sponsor specifically allows the direct charging
of administrative/clerical
costs due to the type of grant or contract and
this is
documented in the funding opportunity announcement (FOA).Slide8
Post Award
It is the Principal Investigator’s responsibility to document the roles, duties, and
effort devoted
to a sponsored project for all personnel. Therefore,
the duties of
any administrative
or clerical position described in the justification to OSP should
be reflected
in the departmental record as the project is carried out.Slide9
Post Award
At
the time of budget set-up, OSP
notifies
GCA
when administrative and clerical salaries have been appropriately justified
and funded
. GCA denotes this in the accounting
system by activating Grant Control Flag #2
Subsequent compliance
checks
may be performed to
ensure that administrative and clerical salaries are
appropriate when
charged to a federal award.Slide10
Post Award Rebudgeting
If charging an administrative/clerical salary was unforeseen at the time of proposal
but the
need to do so arises after time of award, the same criteria
for including them in the proposal budget apply
.
The PI/dept
must send an appropriate justification to OSP for
review
and
to notify GCA to add Flag #2.Slide11
Post Award
If an administrative/clerical payroll title is necessary for an individual with research or technical -based effort on the project, notification to OSP is required.
OSP will document the role of the individual and will notify GCA. Flag #2 will not be added to the budget.Slide12
Frequently Asked Questions
Q.
Is direct charging small percentages of administrative/clerical effort (salaries
) among
several off-campus sponsored agreements allowable per OMB
Circular A-21
guidelines
?
A. Not Generally, A-21 allows the direct charging for large complex projects that require an exceptional level of administrative support. Small percentages of effort would not indicate an exceptional level of administrative support.Slide13
Frequently Asked Questions
If
administrative/clerical salaries were proposed in the application and
the sponsor
did not specifically disallow them in the award, are they allowable?
A. In most cases the answer is probably yes.
Q.
What about the treatment of administrative and clerical costs on
non-federal awards
?
A. They are allowable if
the sponsors of those projects do not
specifically disapprove
the cost in the award or in other notices it gives to the University.Slide14
QUESTIONS?