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It is the policy of New York University (NYU, “the University”) to comply with all regulations concerning awards for research, training and related activities from the Federal Government. The Federal Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions (http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html) prohibits direct charging of administrative and clerical salaries and certain other costs to federal grants and contracts, except in special circumstances.
The purpose of this policy is to provide guidance on special purposes or circumstances for charging administrative and clerical salaries, as well as certain other non-salary administrative costs to federal grants and contracts.
This policy is applicable to all schools, departments, units and personnel of the University involved in administering federally-sponsored awards.
OMB Circular A-21 states that the salaries of administrative and clerical staff should normally be treated as Facilities and Administration (F&A or indirect) costs. 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, A-21 states that items such as office supplies, postage, local telephone costs and memberships shall normally be treated as F&A costs.
However, direct charging of administrative and clerical salaries and supplies and other costs may be appropriate where the nature of the work performed under a particular project requires an extensive amount of administrative or clerical support or where the project requires more than routine use of administrative expenses, e.g., supplies, postage. Examples of such projects that meet the special circumstances rule include:
For these types of projects, the Federal agency will fund indirect costs at a specified percentage.
Whenever such costs are identified by the Principal Investigator (PI), these costs must be explicitly justified and documented:
For administrative charges, the costs must be attributable to a particular project which meets one of the examples cited above and the project must create a special or unique need for the item, which is clearly different from normal circumstances. Examples of specific allowances are listed below.
Cell phone expenses are usually considered “local telephone costs” and generally not included in the budget. If, however, a cell phone is necessary to maintain contact at remote sites for logistical or safety reasons it may be directly charged.
General-purpose computers, especially laptops, can be used to support a variety of activities and are rarely dedicated to one specific purpose. As a result, general-purpose computers and laptops are typically F&A costs and are seldom proposed in budgets or directly charged to awards. In order to be considered as direct costs, a computer must be:
Memberships in professional and scientific organizations may not be included in the budget unless:
Office supplies that are normally used in the general administrative support of a project may not be included in the budget or charged to the award. Office supplies that are used for project-specific activities outlined in the proposal may be included in the budget and charged to the project. Because many items of office supplies are used for both general administrative support and project-specific activities, it is important that these items, when included in the budget, be justified in terms of their relevance to the methods used in conducting the project. Examples of when supplies may be charged directly are:
Postage costs may be included in the budget and charged directly when they are necessary for the conduct of the study. A postage meter or log should be used to document such support. Shipping costs not classified as ordinary postage are acceptable direct costs. Examples include:
These costs used in routine general administrative support of a project may not be included in the budget or charged to the award unless the project scope clearly indicates a need for a volume of activity beyond routine and their usage can be tracked.
Local telephone costs used to conduct routine business of the project may not be included in the budget. Telephone lines including handsets and data lines may be charged directly if required to:
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|Effective Date:||September 01, 2013|
|Supersedes:||Guidelines for Including Administrative and Clerical Salaries in Federal Grant and Contract Proposals, 4/94|
|Issuing Authority:||Sponsored Programs Administration|
|Responsible Officer:||Assistant Vice President for Post-Award Administration; Associate Vice Provost for Research Compliance and Administration|
Expenses that directly further the programmatic objectives of a sponsored project with a high degree of accuracy.
General business expenses that are not specifically identifiable to a sponsored project but rather support the project indirectly. This term is also referred to as Facilities and Administrative Costs (F&A) or Overhead. Examples of F&A/Overhead expenses include space costs, utilities, and general, sponsored projects and departmental administration costs.
OMB Circular A-21, Cost Principles for Educational Institutions
The set of Federal regulations which establishes the principles for determining costs applicable to Federal grants, contracts and other agreements with educational institutions.