NIH GUIDE, Volume 23, Number 34, September 23, 1994

P.T. 34


  Grants Administration/Policy+ 

National Institutes of Health

In July 1993, OMB Circular A-21, "Cost Principles for Educational

Institutions," Section F.6.b., was revised to define the criteria for

charging salaries of administrative and clerical staff to Federally

sponsored grants and cooperative agreements. This revision clarified

the principle that the salaries of administrative and clerical staff

should usually be treated as indirect costs, but that direct charging

of these costs may be appropriate where the nature of the work

performed under a particular project requires an extensive amount of

administrative or clerical support that is significantly greater than

the routine level of such services provided by academic departments.

The charging of these costs directly would need to meet the general

criteria for direct charging in Section D.1. - i.e., "be identified

specifically with a particular sponsored project ... relatively

easily with a high degree of accuracy," and the special circumstances

requiring direct charging of these services would need to be

justified to the satisfaction of the awarding agency in the grant or

cooperative agreement application.

Some examples of circumstances where direct charging the salaries of

administrative or clerical staff may be appropriate are as follows:

o  Large, complex programs, such as General Clinical Research

Centers, primate centers, program projects, environmental research

centers, engineering research centers, and other grants and contracts

that entail assembling and managing teams of investigators from a

number of institutions.

o  Projects that involve extensive data accumulation, analysis and

entry, surveying, tabulation, cataloging, searching literature, and

reporting, such as epidemiological studies, clinical trials, and

retrospective clinical records studies.

o  Projects that require making travel and meeting arrangements for

large numbers of participants, such as conferences and seminars.

o  Projects where the principal focus is the preparation and

production of manuals and large reports, books and monographs

(excluding routine progress and technical reports).

o  Projects that are geographically inaccessible to normal

departmental administrative services, such as seagoing research

vessels, radio astronomy projects, and other research field sites

that are remote from the campus.

o  Individual projects requiring significant amounts of project-

specific database management; individualized graphics or manuscript

preparation; human or animal protocol, IRB preparations and/or other

project-specific regulatory protocols; and multiple project-related

investigator coordination and communications.

These examples are not exhaustive nor are they intended to imply that

charging of administrative or clerical salaries would always be

appropriate for the situations illustrated in the examples above.

Where direct charges for administrative and clerical salaries are

made (as with other administrative type costs, e.g., telephones,

postage, books and journals), care must be exercised to assure that

costs incurred for the same purpose in like circumstances are

consistently treated as direct costs for all activities.  This should

be accomplished through a "Direct Charge Equivalent" or other

mechanism that assigns the costs directly to the appropriate


NIH Implementation

For those institutions subject to OMB Circular A-21, the NIH will

implement the revision effective with budget period start dates on or

after October 1, 1994, for competing grants and cooperative

agreements.  For noncompeting grants and cooperative agreements, the

NIH will not make any adjustments to the committed level, nor will

future year commitments be adjusted.  Nonetheless, the principles of

A-21 address the appropriate allocation of these costs with

implementation based on the negotiated indirect cost rate agreement

in effect for each institution.  Thus, grantee institutions that have

negotiated indirect rates based on the revised principles contained

in Section F.6.b may not directly charge administrative or clerical

salaries when inconsistent with the Circular, even though these costs

may not have been deleted from the noncompeting award.

This revision also affects any postaward rebudgeting of funds for the

purpose of charging administrative or clerical salaries.  Where grant

or cooperative agreement applications do not anticipate the need to

directly charge administrative and clerical salaries, institutions

may rebudget funds, without awarding office prior approval, to cover

these costs when consistent with the criteria and examples described

above.  For example, administrative or clerical salaries not

identified in the application could be charged to the Training

Related Expenses associated with Institutional National Research

Service Awards (T32) when the activity involves a large amount of

tracking and completion of forms directly related to the purpose of

the grant.

The implementation of this revision will not have any impact on the

peer review of grant applications.  Reviewers will continue to base

any recommended budget reduction on whether the cost requested is

warranted or justified for the project.  Reviewers should not

recommend deletion of requested administrative and clerical staff

salary support based solely on the provisions contained in Circular

A-21.  The awarding unit staff will determine, in accordance with A-

21, whether or not the costs are allocable as a direct cost under the

particular project.


Questions should be addressed to the awarding agency's Grants

Management Officer when it is unclear whether or not administrative

or clerical staff salaries may be charged directly.


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