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 Uniform Guidance, 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. 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 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 the 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.

NYU Approach

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. Please refer to the Charging Administrative Expenses Policy for guidance.

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