A-21 (fwd) Norman A Meeks 06 Jul 1994 14:49 EST
> Subject: A-21 > > ONR-Col/NAM:nm > 4260/A-21 > June 30, 1994 > > MEMORANDUM > > From: Office of Naval Research Resident Representative/Columbus > > To: Research Administrator's Bulletin Board > > Subject: Direct Charging of Administrative and Clerical Salaries > > Encl: (1) Interpretation of Section F.6.b. of OMB Circular A-21 > > 1. Attached is the OMB discussion of the subject A-21 provision. > Although this information was received via ONR channels, it was > distributed with the cautionary not that this may not be the > "final" interpretation. > > 2. By the way, I learned my lesson on the proper way to offer > information through this medium. So far, I have had over 65 > requests for this document. Once all of you have had an opportunity > to digest this memo, please feel free to call me if I can be of any > further assistance. > > > > NORMAN A. MEEKS > ONR Resident Representative > The following is taken from a memorandum issued by OMB on May 17, > 1994 going to ONR, NSF, and DHHS concerning OMB's interpretation of > the new provision of A-21 at F.6.b. > > " > OMB CIRCULAR A-21 > > TREATMENT OF ADMINISTRATIVE AND CLERICAL SALARIES > > M > > M Section F.6.b. of the July 1993 revision of Circular A-21 says that > the salaries of administrative and clerical staff should normally > be treated as indirect costs. This section goes on to say that > direct charging of these costs may be appropriate where a major > project activity explicitly budgets for administrative or clerical > services and the individuals involved can be specifically > identified with the project or activity. > > What is the intent of this provision and under what circumstances > may these costs be directly charged to sponsored agreements? > > M > > M This provision is intended to establish the principle that the > salaries of administrative and clerical staff should usually be > treated as indirect costs, but that direct charging of these costs > may be appropriate where 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 academic departments. The costs > would need to meet the general criteria for direct charging in > Section D.1. --i.e., "be identified specifically with a particular > sponsored project ..relatively easily with a high degree of > accuracy," and the special circumstances requiring direct charging > of the services would need to be justified to the satisfaction of > the awarding agency in the grant application or contract proposal. > > The following examples are illustrative of circumstances where > direct charging the salaries of administrative or clerical staff > 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 principle 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 seagoing > research vessels, radio astronomy projects, and other research > sites that are remote from the campus. > > These examples are not exhaustive nor are they intended to imply > that direct charging of administrative or clerical salaries would > always be appropriate for the situations illustrated in the > examples. Where direct charges for administrative and clerical > salaries are made, care must be exercised to assure that costs > incurred for the same purpose in like circumstances are > consistently treated as direct costs for all activities. This > should be accomplished through a "Direct Charge Equivalent" or > other mechanism that assigns the costs directly to the appropriate > activities." > >