Additional information, recommended wording, and FAQs
Charging Administrative and Clerical (200.413)
AT TIME OF PROPOSAL
- If it is determined that (1) the administrative and clerical services are essential, vital, or fundamental to the project or activity; AND (2) a minimum of 10% FTE* is budgeted in each year or there are documented special circumstances**, PIs/departments must explicitly list in the proposal budget and budget justification the administrative and clerical costs that meet the direct charging definitions, explain why these costs are integral to the project, and include the statement below shown in bold. For example:
- “This project includes funds for the planning, coordination, and delivery of 10 workshops/conferences. A program assistant is needed to oversee these activities, including identifying workshop locations, making travel arrangements for a large number of participants, preparing workshop materials, coordinating the catering arrangements needed, and scheduling the speakers’ itinerary. We are therefore requesting agency approval for a [List % time appointment here] [List position title here] as an administrative/clerical cost in accordance with 2 CFR 200.413.”
*A percentage of effort below 10% FTE is unlikely to be viewed as “integral” to the project and may not be direct charged to it.
**There may be special circumstances where a brief, intense period of administrative or clerical support is needed that does not equate to at least 10% FTE per year. If this is the case, explain the special circumstances. An example might include a conference that needs a high percentage of administrative support for a brief time immediately before or during the conference.
AT TIME OF AWARD/DURING AWARD PERIOD
- If a proposal is submitted with the required statement/justification (as shown above), and an award is subsequently issued by the federal agency without explicitly deleting the administrative/clerical cost, the costs will remain in the budget and will be deemed allowable.
- After award issuance, any addition to the percentage of effort may need approval from the sponsor.
- Reductions to the percentage of effort may be incurred without agency approval; however, PIs must recognize that this may still be questioned by auditors since the proposal indicated that such costs were necessary. If the effort falls below the 10% FTE, the PI must be prepared to explain how the function was performed and why the effort was not incurred at the approved level.
- If new administrative or clerical support is needed during the life of the award, PIs must complete a Request for Modification form with a detailed explanation as to how the services are essential, vital, or fundamental to the project or activity; AND must include a minimum of 10% FTE in each year.