A. Administrative and Clerical Salaries (200.413(c))
The University normally treats these costs as indirect costs. Direct charging of these costs may be allowable only if all of the following conditions are met:
i. Administrative or clerical services are integral to a project or activity;
ii. Individuals involved can be specifically identified with the project or activity;
iii. Such costs are explicitly included in the budget or have the prior written approval of the federal awarding agency; and
iv. The costs are not also recovered as indirect costs.
All requests for administrative and clerical salaries must be included in the proposal budget with an explanation of how the services are integral to the project. If administrative or clerical expenses are identified after an award is received, prior approval must be obtained from the sponsor. Such requests must be signed by a representative of the Office of Sponsored Programs (“OSP”).
You may not include the salaries of administrative personnel conducting such activities as financial reconciliations, general office clerical work and proposal preparation. Examples of projects where administrative and clerical costs could be included as direct costs in a proposal, with proper justification, include, but are not limited to:
i. Large, complex programs, such as program projects, research centers, and other similar sponsored projects that require significant administrative management;
ii. Projects that involve extensive data accumulation, data analysis, surveying, and tabulation;
iii. Projects with complex project management requirements, e.g., managing multiple subawards; and
iv. Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences.
Costs for managing substances and chemicals, securing project-specific data, or coordinating research subjects, are not considered “administrative and clerical.” Therefore, these costs may be directly charged to a project without obtaining prior approval, provided that they are directly related to work under a federal award and meet all the standard costing requirements. See Section B.6.b to Appendix III to the Uniform Guidance.
The following tasks are considered routine administrative activities and should not be charged as direct costs to a sponsored project:
i. General departmental administration;
ii. Personnel Activities/Payroll/Human Resources;
iii. Accounting and budgeting activities;
iv. Financial monitoring;
v. Processing vouchers and payments;
vi. Administrative data entry;
vii. Processing and tracking routine purchase orders; and
viii. Miscellaneous departmental activities.
B. Computing Devices (200.20, 200.58, 200.94)
Computing devices are defined as machines used to acquire, store, analyze, process, and publish data and other information electronically, including accessories/peripherals for printing, transmitting and receiving, or storing electronic information.
Computing devices should be included under the budget category “Other Expenses” in proposals. Computing devices costing less than $5,000, which are essential and allocable (even if not solely dedicated to the performance of a federal award), may be charged 100% to an award, or may be allocated to several awards. While no prior agency approval is required, computing devices should be itemized in the proposal budget. In addition, the project must not have reasonable access to other devices that can achieve the same purpose. Devices may not be purchased for reasons of convenience or preference.
C. Conferences (200.432)
The Uniform Guidance defines a “Conference” as meeting, retreat, seminar, symposium, workshop or event whose primary purpose is the dissemination of technical information beyond the University and is necessary and reasonable for successful performance under the sponsored award. Allowable conference costs when the University acts as a conference sponsor or host include:
i. Rental of facilities;
ii. Speakers’ fees;
iii. Costs of meals and refreshments served at the conference;
iv. Local transportation;
v. Other items incidental to the conferences, unless restricted by the award terms and conditions; and
vi. As needed, the costs of identifying (but not providing) locally available dependent-care resources.
Networking and social activities pre- or post-conference are considered entertainment costs and are unallowable on sponsored projects unless the sponsor has provided written approval for this type of event.
D. Entertainment Costs (200.438)
Entertainment costs are allowable only when the cost has a programmatic purpose to the award, and is authorized either in the approved budget or with the prior written approval of the federal awarding agency. In all other cases, costs of entertainment, including amusement, and social activities, and any associated costs are unallowable.
E. Goods or Services for Personal Use (200.445)
Costs of goods or services for personal use are unallowable regardless of whether the cost is reported as taxable to the employee.
F. Memberships and Subscriptions (200.454)
The costs of the University’s membership in business, technical, and professional organizations, and subscriptions to business, technical, and professional periodicals are allowable when they provide a direct benefit to the project. The cost of memberships in any civic or community organization is allowable with the prior approval of the federal awarding agency or pass-through entity. These costs must be itemized in the budget and described in the budget justification, or receive prior written approval from the sponsor before the incurrence of such costs.
Membership fees or dues, such as airline, social, dining and country club dues, cannot be charged directly to federal or non-federal sponsored projects.
G. Laboratory Supplies
Lab supplies that are project-specific may be charged to a sponsored project. Examples of allowable lab supplies might include lab notebooks, glassware, chemicals and syringes. Lab supplies are frequently used for multiple projects and, therefore, require the costs to be appropriately allocated. See Part VII of this guide for more information.
H. Office Supplies
Office supplies (pens, pencils, paper, staples, clips, binders, folders, toner cartridges, etc.) are normally indirect costs, as they are used for routine activities of the University. Exceptions may be allowed as direct costs when the purchase of supplies is extensive and is specifically identified to the purpose of the project. An example might be purchasing envelopes to mail a large number of questionnaires.
I. Participant Support Costs (200.75, 200.456, 200.68)
Participant Support costs are allowable with prior written approval from the sponsor. These costs should be explicitly listed in the proposal budget or approved by the funding agency after the award has been made. Participant Support costs include stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects. Participant Support costs are not routinely allowed on research projects, but can be charged if the project includes an education or outreach component and the agency approves such costs. Participant Support costs do not include payments to individuals involved in human subjects testing.
Under the Uniform Guidance, Participant Support costs should be excluded from the Modified Total Direct Cost (“MTDC”) calculation.
Postage for general business use may not be charged to a sponsored project. These costs are typically indirect costs. However, when a project has postage requirements that are related to its scope of work, goals and activities, they may be allowable. An example might be a project that includes the dissemination of surveys or materials produced as a result of the project activities. Postage to mail the surveys would be allowable.
K. Proposal Costs (200.460)
The cost of preparing proposals or applications to sponsoring agencies is not allowable as a direct cost. This includes the development of data necessary to support the proposal.
L. Telephone Costs
Communication costs incurred to support routine activities of the University are not allowable as a direct charge to a sponsored project. Some exceptions might be long distance charges to contact research subjects, or setting up and maintaining a hotline if that is specifically required by the project.
M. Travel & Dependent Care Costs (200.474)
Travel costs include expenses for transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official University business. They are allowable on sponsored awards when participation is necessary for the project, and the costs are reasonable and consistent with University’s documented travel policies. The University’s travel policy does not allow for the reimbursement of dependent care costs while traveling. Since the Uniform Guidance requires consistent treatment across all fund types, these dependent care costs remain unallowable on sponsored awards at the University.
N. Visas, Short-term (200.463(d))
Short-term visas (as opposed to longer-term immigration visas) are issued for a specific period and purpose, and therefore can be clearly identified as directly connected to recruitment of personnel for a federal award. For the costs to be directly charged to a federal award, they must be critical and necessary for the conduct of the project.