Valrey,

I think the key would be that the administrative people have a system in which
they can clearly demonstrate what time they spend on the project and what time
they spend elsewhere.  The tough ones are when it's administrative staff who
also perform duties for the educational mission of the university (such as
departmental staff).  At Lehigh, the individuals who divide their time between
the academic department and research activities actually keep time sheets on
which they record chunks of their day to each activity/account.

If the administrative people are fully supportive by projects and they keep a
record of how much time is devoted each day to each activity, the feds should
accept it.

Ruth

Ruth Tallman
Office of Research and Sponsored Programs
Lehigh University
526 Brodhead Avenue
Bethlehem, PA  18015
Phone:   (610)758-3024
FAX:    (610)758-5994
E-mail:   xxxxxx@lehigh.edu

Valrey Kettner wrote:

> Question:  we have a proposal budget in to a federal agency for Phase II of
> a project.  In Phase I we included administrative support as a direct cost
> under A-21 F.6.b major project.  We replicated this in Phase II.  The
> agency is now questioning these costs in our Phase II budget, and do not
> feel that it meets all the criteria under Exhibit C.
>
> We disagree and are looking at providing a further written justification
> for direct charging these expenses to this project.  For those of you that
> have gone through this before, what type of justification did you
> provide?  Were there particular phrases or examples that proved to be
> especially effective/persuasive?
>
> Any assistance the group could provide would be greatly
> appreciated!  Please respond either to me directly or to the listserve (I'm
> sure there are other institutions that are facing this!!)
>
> Thanks!
>
> Valrey V. Kettner
> Assistant Vice President
> Sponsored Programs Administration
>
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