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This section provides supplemental interpretation of federal regulations contained in Circular A-21 concerning charging administrative and clerical personnel costs to federal research and training grants. This interpretation will be used to assess the appropriateness of charges on research and training grants administered by Harvard.
A. Qualifying Grants
The types of federal awards that typically may include activities similar to the activities cited in OMB A-21 - Exhibit C and thereby where it is possible that administrative salaries will be allowable, if those activities are required, include:
- P01 / Program Projects
- R01's with multiple subcontracts and project sites (whether internal or external to Harvard)
- Cooperative Agreements or Contracts with multiple subcontractors and project sites (whether internal or external to Harvard)
- Training grants - T series
- Multiple slot F series fellowships
B. Qualifying Positions
When a sponsored project is sufficiently large or complex or requires extensive administrative or clerical support, we must nevertheless take care in distinguishing the nature of services provided from general administrative support. The nature of specialized administrative or clerical positions that might appear on a sponsored project include:
- Grant Coordinator
- Research Coordinator
- Research Assistant
- Lab Administrator
Job titles that we would normally not expect to be supported on a federal project include:
- Secretary
- Grants manager
- Grants administrator
- Grant accountant
C. Appropriate Amount of Effort
Normally, if a project's size, complexity or requirements are sufficient to permit direct charging of administrative or clerical salaries, that project will also require a significant amount of that effort. If the sponsor has specific guidelines on effort for a project, then those guidelines must be followed. Otherwise, normally, at least 25% of an individual's effort should be charged to a single project.
D. Benefits
Caution should be exercised when charging benefits to federal awards
Key applicable NIH and A-21 principles:
- NIH: "established organizational policy consistently applied regardless of the source of funds"
- A-21: "expenses…are equitably distributed among the institution's activities during that period"…"equitably apportioned to all activities of the institution."
Types of benefits most needful of examination:
- Overtime: possible changes in exempt status require anticipation of overtime; budget proposals should anticipate in straight time
- Leave (Sabbatical, Parental), severance pay, and accrued vacation payouts are allowable under guidelines of allocability and consistency with institutional practice/policy.
E. Additional Resources
There are two useful checklists developed by FAS and KSG that can help you in the administration of your sponsored award/project salaries. They are:
1. FAS Administrative Checklist
On the FAS Research Conduct and Administration web site, there is a link to the FAS Administrative checklist. For direct charging of clerical/administrative salaries to federal projects, include this checklist with the Dean's Approval Form for Sponsored Research.
- This form must be completed and attached to any federally sponsored research proposal that includes administrative or clerical salary expenses.
2. KSG Administrative Checklist
KSG ResearchCentral Online Forms page includes the Checklist for Direct Charging of Administrative Salaries to Federal Grants.
3. For HMS/Dental School-specific information regarding this and other topics, go to:
http://www.hms.harvard.edu/spa/index.htm
4. For SPH-specific information regarding this and other topics, go to:
