I. Procedural Statement
This document is intended to serve as formal guidance for CU Boulder regarding the use of funds from sponsored projects for direct charging of administrative and clerical salaries in like circumstances. The university is committed to ensuring that costs incurred in support of sponsored research are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored research. Procedural statements support the CU Boulder Cost Principles Policy by providing definitions and processes for meeting those standards in like circumstances.
II. Definitions
CU Boulder defines administrative staff as:
Staff are considered administrative or clerical, for purposes of sponsored projects, if their primary responsibilities include routine duties that are not in direct support of the sponsored project. Examples include, but are not limited to, general accounting tasks, filing, payroll processing, purchasing, or routine data entry.
III. Procedures
A. Federal Awards
Under the guidelines imposed by the U.S. Office of Management and Budget’s Uniform Guidance 2 CFR §200.413(c), administrative and clerical salaries should normally be treated as indirect costs. Direct charging of these costs may be appropriate only if all four of the following conditions are met. If any one of these conditions is not met, the cost of the administrative or clerical salary will be borne by the department.
- Administrative or clerical services are integral to a project or activity, and
- Individuals involved can be specifically identified with the project or activity, and
- Such costs are explicitly included in the budget, or have the prior written approval of the federal awarding agency when required, and
- The costs are not also recovered as indirect costs. At CU Boulder, if requirements 1-3 are met, this fourth requirement will be managed by the Campus Controller’s Office (CCO).
If the four conditions above are met, the salary expense must be adequately documented, with a description of activities performed, in order to comply with 2 CFR §200.430. The documentation should be retained by the department.
B. Non-Federal Awards
Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. Therefore, CU Boulder’s Cost Principles Policy, and related procedural statements, are also applicable to non-federal awards. The basic criteria for charging administrative or clerical salaries are similar for non-federal sponsored projects, but it is also important to be familiar with the particular requirements or restrictions of each non-federal sponsor. When allowed by the non-federal sponsor, a written justification for the inclusion of administrative or clerical salaries should be provided in order to explain why these are necessary to fulfill the research objective of the project, and to ensure that the cost directly benefits the project being charged, even when the non-federal sponsor may follow more flexible spending guidelines.
C. Process
At Proposal
The administrative and clerical salaries cost should be identified in the proposal budget justification, and justified as to why it is necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the cost. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.
After an Award is Funded
In the event that unbudgeted administrative or clerical personnel are required after an award is funded, the PI should work directly with their OCG grant or contract officer to explain the benefit of this cost, and determine if sponsor prior approval is required. The written sponsor approval, as well as the justification explaining the purpose and benefit of the administrative or clerical salary to the specific project, will be retained in Boulder eRA (BeRA) for future reference should the expenditure be questioned at a later date.