Policy on Directly Charging Clerical and/or Administrative Costs to Federal Awards

I. SCOPE

This policy applies to all federally-funded sponsored projects, which includes:

  • All federal awards
  • All awards that contain any federal flow-through funds
  • Awards with terms and conditions which reference OMB Circular A-21 or CAS
  • Sponsored projects whose funds are being used as cost sharing on a CAS covered  project (only the individual cost(s) being used as cost sharing will be subject to the definitions of direct costs and “unlike circumstances”)

II. POLICY

Duke University is required to comply with the Cost Accounting Standards (CAS) set forth in the Office of Management and Budget (OMB) Circular A-21.  OMB Circular A-21 states that Facilities and Administrative (F&A) costs are “costs that are incurred for common or joint objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other institutional activity.”  Costs that are normally considered F&A costs cannot be charged to a federally-funded sponsored project as a direct cost, unless the expenditure meets the applicable regulatory guidance. 

To comply with the aforementioned guidance, Duke University has instituted a process whereby these types of expenditures must be documented in accordance with GAP 200.360.

III. GUIDELINE

The following costs cannot be charged as direct costs to a federally-funded sponsored project unless sponsor approval and/or institutional approval from the pre-award offices (ORA or ORS) have been obtained:

  • Salaries, wages and fringe benefits for clerical and administrative positions
  • Office supplies
  • Copier supplies
  • Freight or postage
  • Subscriptions
  • Memberships
  • Library books
  • Periodicals 
  • Local telephone or internet services
  • Photocopying services (for general business use)
  • Other similar Clerical and/or Administrative Costs (please refer to SPCAS_PR & SPCAS_NOPR cost element groups for full list) 

If CAS items are necessary for the project and can be justified, GAP 200.360 must be followed.

Unapproved CAS charges will be written off.

IV. EXCEPTIONS

Exceptions to this policy may only be made at the Management Center level.

V. ADDITIONAL RESOURCES

GAP 200.360, Charging Clerical and/or Administrative Expenses to Federally Funded Projects
GAP 200.320, Direct Costing on Sponsored Projects
GAP 200.330, Facilities and Administrative (Indirect) Costs on Sponsored Projects
GAP 200.340, Cost Accounting Standards (CAS) on Sponsored Projects
CAS Direct Cost Exception Form
CAS Exception Form FAQs
Office of Research Support (ORS):  (919) 684-3030
Office of Research Administration (ORA):  (919) 684-5175
Office of Sponsored Programs:  (919) 684-5442
RCC Policies
G/L Groups Used for Monitoring CAS (pdf)
Summary of Processing Cost Accounting Standard (CAS) Expenditures