GAP 200.360, Charging Clerical and/or Administrative Expenses to Federally Funded Projects
- Criteria for Charging Administrative Expenses Directly to a Project
- Timing and Approvals
Federal awards issued prior to December 26, 2014 should be managed in accordance with OMB Circulars A-21, A-110, and A-133. Federal awards issued on or after December 26, 2014 should be managed in accordance with 2 CFR Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for federal Awards (The Uniform Guidance). It is important to verify the appropriate regulations applicable to your award. Documentation of appropriate regulations may be found in the Award Notice issued by the funding agency. Note that subawards issued under this GAP follow the same regulatory applicability as the prime award.
These guidelines pertain to federally sponsored projects and should be used as guidance for all sponsors unless specifically addressed in a non-federal sponsor’s policies and/or procedures.
This GAP supersedes previous GAP versions, Duke Policies, Guidelines, etc. Unless otherwise noted, this GAP applies to all sponsored projects, unless superseded by guidelines from fon-federal sponsors.
Administrative and clerical expenses (for example, salaries of clerical & administrative personnel, office supplies, postage, local telephone costs, and memberships) should normally be treated as Facilities and Administrative (F&A) or Indirect Costs and should not be directly charged to federally sponsored projects. This guiding principle for handling administrative expenses is established and clarified in OMB Circular A-21, now 2 CFR Part 220. (This document will refer to these guiding principles as A-21.) With the release of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for federal Awards, 2CFR Part 200 (referred to as the Uniform Guidance) on December 26, 2014, there are now two distinct requirements for managing clerical and administrative expenses charged directly to federal awards.
A. Administrative/Clerical Salary Support for Projects Awarded prior to December 26, 2014:
For projects awarded prior to December 26, 2014, Duke will follow guidance outlined in A-21 when charging administrative/clerical salary directly to a sponsored project. Administrative/clerical salary support is ordinarily treated as an F&A cost. It may be appropriate to charge these costs directly to federally sponsored projects only under certain circumstances:
- The administrative salary expense is for the performance of one or more of the activities or projects listed in the examples of “major projects” in OMB Circular A-21. In order for the administrative activity to qualify for direct charging for federally sponsored projects, it generally must be greater than the routine level of such services typically provided by the academic departments.
- The administrative expense must be identified specifically with a particular sponsored project or activity, or can be directly assigned to the project or activity relatively easily with a high degree of accuracy, and must provide direct benefit to the project.
- Costs are incurred in unlike circumstances, i.e., the actual activities direct charged are not the same as the actual activities normally included in the institution's F&A cost pool.
- The administrative expense should not have been specifically disapproved in the award notice.
To secure approval for this type of expense, departments should prepare Rebudgeting/CAS Form found on the Grants Management tab in the Duke@Work Portal at the time of award. A Rebudgeting/CAS Form is required each time new funding is awarded, whether for an already existing WBSE or a new WBSE. For additional information on completing a Rebudgeting/CAS Form, please consult the step-by-step instructions.
- Sometimes, it is necessary to rebudget CAS expenses during the life of the award: CAS items were not included in the original budget OR there is need for additional CAS items that were not anticipated in the original budget. Recognizing that sponsored research is dynamic, unanticipated clerical and administrative costs may become necessary; departments should justify these items and rebudget so that the budget plan in SAP reflects the approved CAS items.
In these instances, complete a Rebudgeting/CAS form and route through workflow approvals, taking care to provide specific information regarding the need for the expense in terms of the purpose and scope of the project.
B. Administrative/clerical Salary Support for Projects Awarded on or after December 26, 2014 (includes incremental funding to existing awards):
For projects awarded on or after December 26, 2014, Duke will follow guidelines outlined in the Uniform Guidance for charging administrative and clerical expenses directly to a sponsored project:
The salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs. Direct charging of these costs may be appropriate only if 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 also recovered as indirect costs.
At time of award, if the CAS expense was included in the proposal budget and approved by the sponsor, the Office of Research Administration (ORA) or the Office of Research Support (ORS) will make best efforts to identify these items and to advise Treasury Billing Services (TBS) to load the amount budgeted for these clerical/administrative salaries in to SAP. The approved CAS budget will appear on G/L 600066. If the budget plan does not reflect sponsor approved clerical/administrative salaries, a Rebudgeting/CAS form must be submitted that includes the approved sponsor budget showing the clerical/administrative costs as an approved budget item.
If, during the life of the award, CAS items that were not approved by the sponsor become necessary:
Submit a request for prior approval to the sponsor. The letter must specify:
- The nature of the change (the budget categories to be increased and decreased)
- Justification for the change
- The award identification number or agency identification
- The beginning and ending dates of the budget period(s) affected
Once approval is obtained from the sponsor, complete the Rebudgeting/CAS form, with the sponsor approval uploaded.
Unapproved clerical/administrative salary charges must be removed from the federally funded project and charged to a non-federal, university source.
Departments are strongly encouraged to ensure that the need for clerical/administrative salary support is fully documented and justified in the proposal budget submitted to the federal agency. Failure to anticipate and include these costs will necessitate formal sponsor prior approval, and may result in these costs being removed from the sponsored project.
If awarded under Uniform Guidance rules, prior sponsor approval to exceed the approved plan is required.
C. Non-salary and Administrative Expenses
Administrative non-salary support (e.g. office supplies, postage, local telephone costs, and memberships) is ordinarily treated as an F&A cost. Please note that these administrative costs must be planned and used exclusively for a project's technical scope of work.
Duke has developed special guidance relating to the purchase of computers and computer-related equipment on federal awards. Please refer to this guidance when making these types of purchases.
For approval of these types of non-salary administrative expenses, departments should prepare the Rebudgeting/CAS Form at the time of award. A Rebudgeting/CAS Form is required each time new funding is awarded, whether for an already existing WBSE or a new WBSE. The form should provide sufficient justification for each expense category. It should also include a description of the project, in sufficient lay terms to provide an educated reader with a basic understanding of the purpose and scope of the funded project, and the direct relationship of the expense to the project's activities.
Each Unit/Department has established a review process for approving the Rebudgeting/CAS form. The form will route from the initiator through the departmental workflow. The form initiator can utilize the Management Form Overview Tool to view the progress of the form through workflow. Final form approval is either ORA/ORS. Once the pre-award office approves the rebudget, the plan in SAP is updated in real-time.
Departments will have up to three accounting periods following the accounting period in which a non-approved charge posts to submit a Rebudgeting/CAS Form. Research Costing Compliance will monitor all federal projects for compliance, and will notify the Management Centers of all non-compliant charges one month prior to write off. Clerical and administrative charges not approved within the stated time frame will be removed from the federal award. Exception to this process is only allowed by petition to the Management Center. Note that the Management Centers have imposed a threshold on the categorical dollar amount of clerical and administrative charges that will be reviewed. Please refer to Section VI. Thresholds for further information.
It is the responsibility of each Department/Unit to monitor CAS expenses to ensure compliance with Duke and sponsor policies. Departments should run the CAS Compliance Report found on the Grants Management Tab of the Duke@Work Portal regularly (monthly, at minimum) to ensure all unremediated CAS expenses are addressed.
Research Costing Compliance (RCC) periodically monitors for unapproved CAS and Administrative/Clerical salary expense. This monitoring process includes monthly reporting for required removal of unapproved items and reporting to Management Centers regarding inappropriate charging without approval. OSP will ensure that CAS expenses have been properly budgeted at the time of closeout and will write off any expense that is not appropriately justified and approved. (See GAP 200.180, Closeout of Sponsored Projects.) The Office of Audit Risk and Compliance (OARC) has responsibility for periodic institutional review of departmental and central office practice in regards to the conditions of this GAP, and of current and/or modified federal standards.
The University has imposed a threshold of $500 per General Ledger category of non-salary CAS items. Direct Cost Exception forms should only be submitted if the Principal Investigator can reasonably justify at least $500 in total charges in a specific General Ledger cost category. This means that no Direct Cost Exception form will be approved if the costs requested are LESS than $500 per category. CAS charges totaling less than $500 per G/L group in a budget period cannot be requested and cannot be charged. If charged, they are required to be removed or written off. The only exception to this policy will be by Management Center approval.
In addition to a $500 per G/L group minimum, the University also requires the submission of a revised CAS form if actual non-salary CAS expenditures exceed the approved budget by $2,500 AND 200%. If awarded under Uniform Guidance rules, prior sponsor approval to exceed the approved plan by $2,500 and 200% is required. Charges beyond the approved budget plan for clerical and administrative salaries may not be exceeded without sponsor prior approval.
Note that ORS/ORA will reject any form that does not meet this criteria; exception only by Management Center approval.
For Pre-Award administration, contact either:
|Office of Research Support||919 684-3030|
|Office of Research Administration||919 684-5175|
For Post-Award administration contact:
|Office of Sponsored Programs||919 684-5442|
Exception to the processes described above is only allowed by petition to the Management Center.
Note: This guidance is administrative in nature and is not a cost reimbursement policy. Failure to comply may or may not result in adjustments of charges to the award. Noncompliance with this policy does not mean this cost is unallowable from an external perspective. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.