GAP 200.360, Charging Clerical and/or Administrative Expenses to Federally Funded Projects

I.     General

II.    Criteria for Charging Administrative Expenses Directly to a Project

III.   Internal Approval Process for Rebudgeting

IV.   Remediation

V.    Thresholds

VI.   Federal Regulations

 

 

I. General

While administrative and clerical expenses incurred in support of sponsored projects should normally be treated as Facilities and Administrative (F&A) Costs, when the expenses represent items integral to the completion of the scientific aims and goals of the project and specifically approved by the award sponsor, these costs may be direct charged to a project. This procedure describes the internal and external process for requesting and documenting the direct charging of clerical and administrative expenses to reportable awards.

Clerical and administrative expenses could include items such as salaries of clerical & administrative personnel, office supplies, postage, local telephone costs, and memberships, subscriptions, and professional activities costs. For further examples, consult Subpart E of 2 CFR 200 or the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

Departments are strongly encouraged to fully document and justify the need for clerical and administrative expenses in the proposed budget of an award application. However, the department should not consider approval of a proposed budget as the sponsor approving specific charges of clerical/administrative costs as direct costs. Departments should also review the planned budget to verify any approved clerical and administrative expenses appear in SAP. Throughout the life of the project, it is the department's responsibility to monitor clerical and administrative expenditures to spend to the planned amount and to remediate non-approved charges in a timely manner.

Management Centers may remove any clerical and administrative expenses that are not properly documented and approved.

 

II. Criteria for Charging Administrative Expenses Directly to a Project

In some situations outlined below, Grant Managers may be asked to complete a CAS/Rebudget form in the Duke@Work portal. In other situations, Duke may be required to seek prior approval from the sponsor. These processes rely on documents and procedures described in GAP 200.160, Rebudgeting Funds on Sponsored Projects.

A. Salaries

These costs include salaries for staff that would generally be considered administrative in nature and therefore an indirect cost to a sponsored project.  This may include project management, administrative, or clerical staff if they are integral to the project or activity.  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 (allocable);
• Such costs are explicitly included in the budget or have the prior written approval of the federal awarding agency;
• The costs were not explicitly disallowed; and 
• The costs are not also recovered as indirect costs.

Clerical and administrative salaries included in the proposal budget and not specifically disallowed by the sponsor should be loaded into the SAP budget on G/L 600066.

If the expense is included in the proposed budget but not loaded into SAP, then the department must complete a Rebudgeting/CAS form in the Duke@Work portal. This form should include the approved sponsor budget showing the clerical/administrative costs as an approved budget item.

If the expense is not included in the proposed budget, but the award sponsor does not require Duke to seek prior approval, the department should complete a Rebudgeting/CAS form in the Duke@Work portal. The fededral sponsors that have waived prior approval of clerical/administrative costs within the Research Terms & Conditions matrix are the national Institutes of Health (NIH) the Department of Energy (DOE), the Department of Agriculture (USDA), and the Department of Homeland Security (DHS); but not the National Science Foundation (NSF) or the Department of Defense (DOD).

When the sponsoring agency does require prior approval for clerical and administrative salary expenses that were not included in the proposed budget, the department (Principal Investigator, GM and Business Manager) should draft a letter, including PI approval and submit it to the applicable pre-award office for approval and submission by an authorized official of Duke University.

B. Non-salary and Administrative Expenses

Administrative non-salary support refers to expenses such as office supplies, postage, local telephone costs, and memberships. As stated in Appendix III of the Uniform Guidance (UG) (2 CFR 200), these types of costs “must normally be treated as indirect F&A cost in order to avoid possible double-charging of Federal awards. Directly charging these expenses to sponsored funds requires departments to complete the Rebudgeting/CAS form in the Duke@Work portal at the time of award. These administrative costs must and used exclusively for a project's technical scope of work, and the justification presented to charge these as direct costs must clearly demonstrate that these items used for the same purpose in like circumstances are always treated as direct costs.

 

III. Internal Approval Process for Rebudgeting

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 by Managment Center. If approved, the plan in SAP is updated.

 

IV. Remediation

If a charge posts on a CAS G/L account that was not included in the budget or is not accompanied by a completed Rebudgeting/CAS Form, departments will have up to three accounting periods following the accounting period in which a non-approved charge posts to submit the Rebudgeting/CAS Form or cost transfer the expense to institutional funds. 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.

To identify and ensure any such non-approved charges are addressed, departments should run the CAS Remediation Report, on the Grants Management Tab of Duke@Work on a monthly basis. It is the responsibility of each Department/Unit to monitor CAS expenses to ensure compliance with Duke and sponsor policies.

The Office of Post Award Administration (OPAA) monitors for charges in budget categories where there is no planned CAS expense, which includes providing monthly reports to Management Centers. The Management Centers review, manage and will remove any non-approved or improperly documented charges. As an institution, Duke ensures projects do not have unapproved administrative expense on sponsored research projects.

 

V. Thresholds

Management Centers may set and implement thresholds at which a project may submit a Rebudgeting/CAS form for budget items that are non-salary clerical and administrative expenses. These thresholds are set and managed based on the funding mechanism and activity.

 

VI. Federal Regulations

This GAP reflects the provisions of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Part 200, otherwise referred to as the Uniform Guidance. The UG became effective as of December 26, 2014, and revised as of November 12, 2020, and all awards issued on or after this date must be managed in accordance with its provisions. It is important to verify the applicable regulations for an individual award, which may be found in the Award Notice issued by the funding agency.

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.

 

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.