Administrative salaries funded by Rice University sponsored programs
This document is intended to serve as formal guidance for Rice University regarding the use of funds from sponsored programs for direct charging of administrative and clerical salaries in like circumstances. The university is committed to ensuring that costs incurred in support of sponsored programs are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored programs. Procedural statements support the Rice University Cost Principles Procedure by providing definitions and processes for meeting those standards in like circumstances.
Rice University defines administrative staff as:
Staff are considered administrative or clerical, for purposes of sponsored programs, if their primary responsibilities include routine duties that are not in direct support of the sponsored program. Examples include, but are not limited to, general accounting tasks, filing, payroll processing, purchasing, or routine data entry.
Under the guidelines imposed by the U.S. Office of Management and Budget’s Uniform Guidance 2 CFR §200.413(c), administrative and clerical salaries should normally be treated as Facilities & Administrative costs. Direct charging of these costs may be appropriate only if all four of the following conditions are met. If any one of these conditions is not met, the cost of the administrative or clerical salary will be borne by the department.
- Administrative or clerical services are integral to a program or activity.
- Individuals involved can be specifically identified with the program or activity.
- Such costs are explicitly included in the budget, or have the prior written approval of the Federal awarding agency when required.
- The costs are not also recovered as Facilities and Administrative costs.
If the four conditions above are met, the salary expense must be adequately documented, with a description of activities performed, in order to comply with 2 CFR §200.430. The documentation should be retained by the department.
Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-funded and other activities of the university. Therefore, Rice University Cost Principles Procedure, and related procedural statements, are also applicable to non-Federal awards. The basic criteria for charging administrative or clerical salaries are similar for non-Federal sponsored programs, but it is also important to be familiar with the particular requirements or restrictions of each non-Federal sponsor. When allowed by the non-Federal sponsor, a written justification for the inclusion of administrative or clerical salaries should be provided in order to explain why these are necessary to fulfill the objective of the program, and to ensure that the cost directly benefits the program being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.
The administrative and clerical salaries cost should be identified in the proposal budget justification and justified as to why it is necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the cost. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.
After an award is funded
In the event that unbudgeted administrative or clerical personnel are required after an award is funded, the PI should work directly with SPARC to explain the benefit of this cost and determine if sponsor prior approval is required. The Office of Sponsored Projects and Research Compliance and will review the justification to verify whether or not the costs meet the conditions of this procedure. In many cases, the terms and conditions of the award will require prior approval of the sponsor before implementing this change. In this event, SPARC will notify the investigator when sponsor approval has been given and the change may be implemented.
The written sponsor approval, as well as the justification explaining the purpose and benefit of the administrative or clerical salary to the specific program, will be retained by the department for future reference should the expenditure be questioned at a later date.
The Principal Investigator (PI) bears primary responsibility for management of the sponsored programs that are awarded to him/her. Management involves budgetary and cost compliance as well as technical compliance. This includes not only staying within the total program budget and time period, but also staying within specific budget.