Responsible Official: Associate Controller, SPFA; Executive Director, OSP
Responsible Office: Sponsored Projects Financial Administration (“SPFA”); Office of Sponsored Projects (“OSP”)
Effective Date: November 1, 2000
Revision Date: July 11, 2025
Policy Sections
1403.1 Administrative and Clerical Salaries and Other Costs Normally Included in the F&A Cost Rate
1403.3 Conditions Under Which Administrative and Clerical Salaries May be Charged Directly
1403.4 Direct Charging of Telecom and ITS Costs
Scope
While administrative and clerical salaries incurred in support of sponsored projects should normally be treated as Facilities and Administrative (“F&A”) Costs, when the expenses represent items integral to the completion of the scientific aims and goals of the project and approved by the award sponsor, these costs may be direct charged to a project. This document sets forth Yale’s policy regarding the direct charging of such administrative costs or clerical salaries and other types of general administrative expenses, usually recovered through the F&A cost rate (also known as indirect cost rate), to federally funded sponsored awards (including federal prime subawards) received by Yale from another entity.
Policy Statement
Under federal regulations and sponsor requirements, general administrative expenses include but are not limited to, administrative or clerical salaries, office supplies, postage, local telephone costs, photocopy costs, network charges, telecom infrastructure and ITS costs, cell phones, etc. and should normally be treated as an F&A cost and recovered through the F&A cost rate.
In exceptional circumstances where the nature of the work performed requires extensive departmental support (defined as an unlike circumstance) the F&A type cost may be treated as a direct charge. Costs such as administrative or clerical salaries and other general administrative costs must directly benefit and be easily identified with the particular sponsored project.
Principal Investigators (“PIs”) and department administrators must ensure that the direct charging of F&A type costs comply with sponsor requirements, University policy, and the applicable cost principles, 2 CFR Part 200. Departments are expected to fully document and justify the need for clerical and administrative expenses in the proposal budget justification. Note: Throughout the life of the project, it is the department’s responsibility to monitor clerical and administrative expenditures and to spend to the planned amount.
Reason for the Policy
This policy is issued to define the appropriate charging of administrative or clerical salaries and other general administrative expenses consistent with 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.
Policy Sections
1403.1 Administrative and Clerical Salaries and Other Costs Normally Included in the F&A Cost Rate
Administrative or clerical salaries and other expenses that fall within the category of routine services or general business functions normally provided by academic departments, are treated as F&A costs and are typically not direct charged to federally sponsored awards. As a general rule, such routine services cover the general business of the department as a whole and may include some limited support to faculty to enable them to conduct their teaching, scholarly, and research activities.
General business functions include activities such as:
- basic financial management and accounting;
- purchasing;
- human resource management;
- facilities management;
- administrative or clerical support for course instruction; and
- secretarial support for professional correspondence, preparation of grant applications.
1403.2 Direct Charging of Administrative or Clerical Salaries and Other General Administrative Expenses
The direct charging of administrative or clerical salaries may be appropriate when the nature of the work performed under a particular project requires an extensive amount of administrative or clerical support which is significantly greater than the routine level of such services provided by the academic department.
Examples of circumstances where the direct charging of salaries of administrative or clerical staff and other department expenses may be appropriate are as follows:
- Large complex programs, such as General Clinical Research Centers, Primate Centers, Program Projects, environmental research centers, engineering research centers, and other grants and contracts that entail assembling and managing teams of investigators from a number of institutions.
- Projects which involve extensive data accumulation, analysis and entry, surveying, tabulation, cataloging, searching literature, and reporting (such as epidemiological studies, clinical trials, and retrospective clinical records studies).
- Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars.
- Projects whose principal focus is the preparation and production of manuals and large reports, books and monographs (excluding routine progress and technical reports).
- Projects that are geographically inaccessible to normal departmental administrative services, such as research vessels, radio astronomy projects, and other research field sites that are remote from campus.
- Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications.
Additional examples might also include certain research epidemiological studies, computer science studies of large database management, clinical trials, computational biology studies, retrospective clinical records studies, and astronomical surveys.
The examples above are illustrative of the same criteria that are applied to the treatment of items such as office supplies, postage, local telephone costs, photocopying, network charges, cell phones, etc. Direct charging of such expenses may be justifiable when the expenses are related specifically to the technical substance of a project or there is an unusually high level of expense because of the nature of the activity.
1403.3 Conditions Under Which Administrative and Clerical Salaries May be Charged Directly
Administrative and clerical staff salaries should normally be treated as indirect costs. The direct charging of administrative and clerical salaries may be appropriate ONLY IF ALL of the following conditions are met (§ 200.413 Direct costs):
1. Administrative or clerical services are integral to a federal award;
2. Individuals involved can be specifically identified with a federal award; and
3. The costs are not also recovered as indirect costs.
Care should be exercised to ensure costs incurred for the same purpose in like circumstances are treated consistently as either a direct or F&A (indirect) cost. For example, salaries of technical staff, laboratory supplies, animals, animal care costs, travel costs, and specialized service center costs should be treated as direct costs whenever identifiable to a particular cost objective. Other general administrative items such as office supplies, postage, and memberships should normally be treated as F&A (indirect) costs unless:
- The expenses are essential, vital, or fundamental to the project’s goals and objectives; and
- Such costs are explicitly included in the budget and budget justification or if required by the sponsor’s terms and conditions, received prior approval of the sponsor.
Form 1403 FR.02 Justification to Direct Charge Facilities and Administrative (“F&A”) Costs to a Federal Award must be completed by the Department Business Office (“DBO”) and PI when:
1. certain direct charge administrative or clerical salaries were not included in the original proposal budget/budget justification and have been identified as necessary after the award was made to Yale, and/or,
2. when charging F&A (indirect) type costs that do not require prior approval of the sponsor. Form 1403 FR.02 must be retained in the department’s records. If the sponsor requires prior approval, the OSP Award Manager must first review and approve of the request.
Note: To assist in determining sponsor requirements regarding the direct charging of F&A type costs, check the sponsor’s policy guidelines for assistance. For all other non-federal sponsors, check the terms and/or conditions of the award and contact OSP for assistance.
1403.4 Direct Charging of Telecom and ITS Costs
Due to the unique nature of expenses recorded in ledger accounts 90001 (ITS – Telecom Infrastructure Bundle) and 90000 (ITS FTE Billing – Internal Expense) the PI, department, or business support unit must request and receive prior approval from OSP Award Management for direct charging these costs. The Telecom Infrastructure Bundle and ITS FTE Billing charges may be appropriate in limited situations such as dedicated server connection or hotline in order to accomplish the specific aims of the project(s). Except in these situations approved by OSP Award Management in advance via Form 1403 FR.02, Telecom Infrastructure Bundle and ITS FTE Billing are to be treated as F&A costs and are not to be directly charged to federally-sponsored awards. Consequently, as a normal course of business, these costs may no longer be included in proposal budgets to sponsoring agencies. This treatment of such costs allows for consistent recovery through the F&A rate mechanism. As required by federal regulations, costs incurred for the same purpose in like circumstances must be treated consistently as either a direct or an F&A cost.
PIs and DBOs must exercise caution in applying the guidelines contained in this policy.
Roles & Responsibilities
Principal Investigators (“PIs”)
- Under the DBO guidance, complete Form 1403 FR.02 Justification to Direct Charge Facilities and Administrative (“F&A”) Costs to a Federal Award documenting and justifying F&A type expenses when charging administrative or clerical salaries and other types of general administrative expenses on federal awards when sponsor prior approval is unnecessary.
- Consult with OSP regarding the appropriateness of including administrative and clerical salaries and other general administrative expenses in proposals.
- Provide the DBO with appropriate justification for sponsor required prior approval requests.
Department Business Office (“DBO”)
- Provide guidance and assistance to PIs with proposal preparation when charging administrative or clerical salaries and other types of general administrative expenses on federal awards when sponsor prior approval is unnecessary.
- Complete Form 1403 FR.02 documenting and justifying F&A costs on federal awards when prior approval by the sponsor is not required.
- Ensure that all completed 1403 FR.02 forms are retained in the department’s award file.
- Submit prior approval requests to OSP for the direct charging of 90001 (ITS – Telecom Infrastructure Bundle) and 90000 (ITS FTE Billing – Internal Expense), as appropriate.
Sponsored Projects Financial Administration (“SPFA”)
- Provide guidance on the interpretation of federal requirements when charging administrative or clerical salaries and other types of general administrative expenses on federal awards when sponsor prior approval is unnecessary.
- Assist departments in determining appropriate treatment of direct vs. F&A types of costs when charging administrative or clerical salaries and other types of general administrative expenses on federal awards when sponsor prior approval is unnecessary.
Office of Sponsored Projects (“OSP”)
- Provide guidance on the interpretation of federal requirements when charging administrative or clerical salaries and other types of general administrative expenses on federal awards when sponsor prior approval is unnecessary.
- Provide guidance to PIs, business managers, and/or Business Support Unit in drafting sponsored project proposals that include administrative or clerical salaries or other departmental expenses required to support the proposed project.
- Interpret sponsored project terms and conditions with respect to the appropriateness of direct charging administrative or clerical salaries and other general administrative types of costs.
- Review direct charging of F&A type of costs at the proposal stage.
- Review and approve/disapprove requests to directly charge 90001 (ITS – Telecom Infrastructure Bundle) and 90000 (ITS FTE Billing – Internal Expense), as appropriate.
- Review, approve, and submit prior approval requests to federal agencies for the direct charging of administrative or clerical salaries not included in the budget and budget justification of the original proposal or that may be identified in the award. All requests must receive the prior approval of OSP – Award Management via Form 1403 FR.02.
- Assist departments in determining the appropriate treatment of direct vs. F&A types of costs when charging administrative or clerical salaries and other types of general administrative expenses on federal awards when sponsor prior approval is unnecessary.
Contact Information
- Determination of Allowability of Costs on Sponsored Projects: Office of Sponsored Projects Financial Administration: Online Intake Portal / Office of Sponsored Projects: 203-785-4689
Related Resources
Federal Research Terms and Conditions