Administrative or clerical staff must be integral to a project in order to be direct charged to a federal award and must be budgeted and justified or have prior written sponsor approval. Under the Uniform Guidance, a project no longer needs to be identified as “major” to include administrative salary, but in general such expenses should be treated as indirect (F&A) costs unless the following conditions apply:
To be integral to the project, the administrative activity should be:
- essential or vital to the project, and described accordingly in the justification;
- budgeted at a percentage of a person-month that reflects that essential nature (a minimum of 10% FTE)
- performed by individuals specifically identified with the project or activity
- costs that are not also recovered as indirect costs
For non-federally sponsored projects, administrative or clerical staff may be direct charged provided they benefit the project and follow those sponsors’ requirements for the award.
For more information, contact Richard Lay in OSP