As a recipient of federal funding, New York University (NYU) must comply with policies that define costs as either direct or indirect to ensure consistency with charging costs and compliance with sponsor requirements.
OMB Circular A-21 states that the salaries of administrative and clerical staff should normally be treated as Facilities and Administrative (F&A; indirect) costs. Salaries associated with routine services such as preparing proposals, making routine travel arrangements, typing reports, etc. should normally not be budgeted or charged as direct costs. Similarly, 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 calls for more than routine use of supplies, postage, etc.
Administrative and clerical salaries, as well as certain other non-salary administrative expenses are generally treated as F&A Costs. However, in special circumstances, direct charging of F&A costs may be appropriate. These costs must meet the “special purpose or circumstance” criteria.
Listed below are some examples of projects that may meet the exception criteria:
- Large, complex programs
- Projects which involve extensive data accumulation and analyses
- Project that require making travel and meeting arrangements for large numbers of participants
- Projects requiring the production of large manuals and reports
- Projects that are geographically inaccessible to normal departmental administrative services support
- Training and Planning Grants