Policy

Under OMB's Uniform Guidance Section 200.413, the salaries and wages of administrative and clerical staff are still considered indirect costs and should not be charged directly to a Federal grant unless all of the following conditions are met:

  • Administrative or clerical services are integral 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 recovered as indirect costs.

If all of the above requirements are met, the principal investigator (or their designee) must include a clear and concise description of these services in the budget justification statement to facilitate the required agency approval. A proposal without such clear and concise description in the budget justification may result in the need for additional prior approval by the agency.

Where the above requirements have not been met, administrative and clerical salaries including fringe benefits associated with routine services such as typing reports, filing, handling mail, making travel arrangements, answering telephones, etc., should not be budgeted for or charged as direct costs, even when there is a direct benefit to the project.

Effective Date

This policy will be effective for all grants and contracts (including continuation awards) made to the Colleges by Federal agencies commencing on or after July 1, 2015.