Uniform Guidance 200.413 only allows for Administrative and Clerical (A&C) employees’ salaries to be charged to a federal award when such positions are “integral” to carrying out the scope of the award. Generally, “integral” is defined as:
- Personnel costs must be essential, vital, or fundamental to the performance of the award or activity as documented in the award proposal or scope amendment.
- Generally administrative and clerical support as individual annual effort must not be less than 10% per year as documented in their effort report.
CGA Compliance conducts quarterly compliance reviews to determine where there is less than 10% A&C individual effort per year on an award and to ensure that budget justifications on the award proposal or scope amendment clearly demonstrate that the A&C personnel costs are essential, vital, or fundamental to the performance of the award or activity. It is the department’s responsibility to ensure all such costs are properly documented and justified in the award budget justifications.
When justifying A&C salaries, the budget justification on the award proposal should address the issues listed below by describing how the administrative role is essential or vital to the project:
- Are the administrative support needs of this project significantly greater than the routine level of administrative support provided for all projects? If yes, why? Also, describe how the administrative support activities of the administrative/clerical personnel working on the project are necessary for the successful performance of the project.
- Does a job title or payroll classification imply that an individual’s work is administrative in nature? If yes, but the employee will not be engaged in administrative work on a sponsored project, describe the specific non-administrative work the individual will be performing, as well as how such work is necessary for the technical performance of the project.
If you have any questions regarding the allowability of A&C salary expenses, please contact CGA Compliance at [email protected]