Budgeting Administrative and Clerical Salaries as a Direct Cost
UG Sections 200.413, 200.430
The Uniform Guidance (UG) applicable to federal funding clearly states salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs however, direct charging of administration and clerical costs may be appropriate to a federal award only if all of the following conditions are met:
- Administrative or clerical services are integral❶ to a project or activity;
- Individuals involved can be specifically identified with the project or activity;
- Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
- The costs are not also recovered as indirect costs.
❶UF considers integral to mean: (1) circumstances exist where administrative or clerical services being provided are necessary for the performance of the project or activity being supported by the federal award; AND (2) a minimum of 20% FTE is budgeted in the grant’s budget year or if less than 20% FTE special circumstances are documented and approved by the Sponsor.
Budgeting: If you believe your project meets all the conditions above, you must specifically budget for the effort and salary of the administrative or clerical position that will be devoted to the project and provide in the budget justification a narrative that explains how these administrative and clerical services are integral or necessary for the performance of the project or activity.
CAS Exemption Needed: If awarded, UF will require a CAS exemption form be completed, reviewed, and approved for administrative and clerical salaries to be direct charged to federally funded projects.