Sponsored Programs Charging Administrative Expenses to Federal Awards Policy

Responsible Unit: OSA | Executive lead: CRO
Created: 10/20/21 | Reviewed/Revised: N/A | Effective: 06/2024
Compliance: 2 CFR 200.414(f); OMB Uniform Guidance, section 200.413(c), COCA 8.2 
Approving Body: PPC | Classification: Institution-wide

Policy:  
It is the policy of Pacific Northwest University (PNWU) to comply with all regulations concerning awards for research, training and related activities from the Federal Government.  The Federal Office of Management and Budget Uniform Guidance (OMB Uniform Guidance) imposes strict limitations on the direct charging of administrative and clerical salaries and certain other costs to federal awards. 

OMB Uniform Guidance, section 200.413(c) states that the salaries of administrative and clerical staff should normally be treated as Facilities and Administration (F&A, or indirect) costs.  

PNWU does not have a current negotiated federal indirect cost rate and has elected to charge Facilities and Administration costs to sponsored projects at the federal de minimis indirect cost rate of 10% of modified total direct costs (MTDC) pursuant to  2 CFR 200.414(f). PNWU uses this rate consistently for all Federal awards. Because PNWU has chosen to charge only the de minimus indirect cost rate, special indirect cost accounting fields are unnecessary.  However, care must be taken that PNWU policies regarding: 04 Sponsored Programs – Award Costing; 05 Charging Administrative Expenses to Federal Awards, 06 Sponsored Programs – Cost Sharing, 07 Accounting for Unallowable Costs and other applicable PNWU policies and applicable federal regulations regarding Post Award Accounting be followed.  

Salaries associated with routine services such as preparing proposals, making routine travel arrangements and typing reports should not be budgeted or charged as direct costs, even when there is a direct benefit to the project.  Similarly, items such as office supplies, postage, local telephone costs and memberships should normally be treated as F&A/indirect costs. 

However, direct charging of administrative and clerical salaries and other administrative items may be appropriate when it can be demonstrated that they largely meet Uniform Guidance standards for classifying the expenses as direct costs, i.e., they can be closely identified with the project and fulfillment of its objectives.  In these cases, the related costs can be allocated to the project based on the proportional benefit as long as they are treated consistently in like circumstances.  

When a detailed budget is required by the Federal sponsor, requests for any of the foregoing costs must be itemized in the proposal budget and accompanied by a clear and concise justification. When an agency does not call for a categorical budget, the internal budget developed at the pre-award stage should include a corresponding justification. Post-award requests to re-budget into administrative cost categories must be addressed to the PNWU Finance and OSA Departments, which will determine whether such post-award changes may be considered internally or should be routed to the sponsor for prior written approval. 

Administrative and Clerical Effort 
To charge administrative and clerical effort directly to a Federally funded project all four of the following conditions must be met: 

  • Administrative or clerical services are integral to a project or activity; 
  • Individuals involved can be specifically identified with project objectives; 
  • Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and 
  • The costs are not also recovered indirectly (through the F&A rate). 

OMB has not established a minimum (or maximum) level of project effort for an administrative or clerical employee whose salary may be direct charged. Given the concern in this area, however, the smaller the percent of effort requested, the greater the difficulty in justifying the charge. Budget line items of 5%-10% effort or less are unlikely to be regarded as integral to the project.  Likewise, the direct allocation of such modest amounts of administrative effort over multiple projects is not an indication of consistent treatment, nor that specific individuals can be clearly identified with project objectives. 

Data Management and Sharing Expenses (NIH Only): Reasonable, allowable costs may be included in budget requests when associated with: 

  • Curating data and developing supporting documentation, including formatting data according to accepted community standards; de-identifying data; preparing metadata to foster discoverability, interpretation, and reuse; and formatting data for transmission to and storage at a selected repository for long-term preservation and access. 
  • Local data management considerations, such as unique and specialized information infrastructure necessary to provide local management and preservation (e.g., before deposit into an established repository). 
  • Preserving and sharing data through established repositories, such as data deposit fees necessary for making data available and accessible. For example, if a Data Management and Sharing Plan proposes preserving and sharing scientific data for 10 years in an established repository with a deposition fee, the cost for the entire 10-year period must be paid prior to the end of the period of performance. If the Plan proposes deposition to multiple repositories, costs associated with each proposed repository may be included. 

Unallowable costs associated with Data Management and Sharing include infrastructure costs that are included in institutional overhead (e.g., Facilities and Administrative costs) or costs associated with the routine conduct of research. Costs associated with collecting or otherwise gaining access to research data (e.g., data access fees) are considered costs of doing research and should not be included in scientific data management and sharing budgets. Costs may not be double charged or inconsistently charged as both direct and indirect costs. See PNWU Data Management and Sharing Policy. 

Non-Personnel Administrative Costs 
Whenever non-salary administrative costs are to be charged, they must be explicitly justified and explained.  The costs must be essential to the project, which creates a special or unique need for the item that is clearly different from normal circumstances.  For example: 

  • Office supplies that are used exclusively for project-specific activities may be direct charged when appropriately described in terms of their proposed use. 
  • Computing devices, such as laptops, may be charged if it can be clearly demonstrated that they are essential to fulfill project objectives (even if not used exclusively for those objectives). Computing devices are defined as equipment that is used to acquire, store, analyze, process and publish data and other information electronically, including accessories (or peripherals) for printing, transmitting and receiving, or storing electronic information. 
  • Costs specifically associated with NIH Data Management and Sharing as noted above and in PNWU Sponsored Programs Data Management and Sharing Policy.  

Definitions:          
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Related Documents:
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Policy Resources

For assistance with policies and procedures contact:

Lori Fulton
lfulton@pnwu.edu