While OMB Circular A-21 establishes the principle that the salaries of administrative and clerical staff should normally be treated as indirect costs, the Circular also states:
Direct charging of these costs may be appropriate where a major project or activity explicitly budgets for administrative or clerical services and individuals involved can be specifically identified with the project or activity. "Major project" is defined as a project that requires an extensive amount of administrative or clerical support, which is significantly greater than the routine level of such services provided by
Exhibit C of the Circular provides the following examples of "major projects" where direct charging of administrative or clerical staff salaries may be appropriate.
- 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.
These examples are not exhaustive nor are they intended to imply that direct charging of administrative expenses would always be appropriate for the situations illustrated in the examples.
The key to this definition and these examples is the concept of "administrative intensity" beyond routine levels. If the technical nature of the work to be done includes components that are "administratively intensive," then A-21 allows the definition of the project as "major." The direct charging of those allocable administrative costs which make the project "major" is then appropriate. A project may be "major" regardless of its size or the amount of its funding.
The PI determines whether or not to classify a proposed project as "major." This is indicated on the SU-42, and must also be stated explicitly in the budget justification section of the proposal. (See sample language.)