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
> 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
>  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."