To: Principal Investigators, Deans, Directors, Department Chairs, and Administrative Assistants

Subject: Clerical/Administrative Salaries Charged to Federal Research Projects

This is a reminder memorandum to you concerning the charging of clerical and administrative salaries to federally sponsored research projects. I refer you to the April 25, 1994 memorandum from Provost Jonathan Cole, "University Policies on Charging Administrative Personnel and Other Costs to Federal Grants and Contracts" as well as the Controllers Officer's Policy Statement No. 92-3 issued April 20, 1994.

In spite of the July 1993 revision to OMB A-21 whereby clerical and administrative salaries are normally to be treated as indirect costs, universities may charge these directly for major projects or in situations where the individual can be exclusively identified with the research project or activity. The Office of Management and Budget has provided clarification which is incorporated in the Columbia policy referred to above. The OMB guidance provides examples of acceptable research situations where direct charging of salaries can be approved by federal program officers:

• Large, complex programs, including program projects, general clinical research centers, primate centers, environmental 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, literature searches, 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 Lamont's research vessel, radio astronomy projects and other research field sites that are remote from the campus.

These are merely examples; any direct charging of clerical and administrative salaries could be acceptable, if the effort is directly related to the project's research and is more than a minimum amount. This does mean that routine apportioning of secretarial time is no longer possible.

OMB has informed all agencies that direct charging of clerical and administrative time may be acceptable. NSF, for example, has notified its program officers in all Directorates that these are acceptable: "In all situations where proposed clerical and administrative salaries meet these criteria and are consistent with OMB guidance, they should be included in approved award budgets." This is from a March 12, 1995 letter signed by Joseph L. Kull, Chief NSF financial officer.

Questions on this matter may be directed to the undersigned, or to your OPG projects officer.

To:	Deans, Directors, Chairpersons, Principal Investigators and Administrative Assistants
From:	Jonathan Cole
Subject:	University Policies on Charging Administrative Personnel and other Costs to Federal Grants and Contracts

Several months ago, Vice Provost Michael Crow wrote to advise you of a number of changes to Federal OMB Circular A-21, "Cost Principles for Educational Institutions" which will take effect on July 1, 1994, and of the appointment of a special A-21 task force comprised of both faculty and administrative staff to develop, as necessary, University policies which comply with the Federal requirements while providing the maximum flexibility possible to our academic units and individual investigators.

Although I had hoped that this process would have been completed sooner, the work of the task force was delayed because of protracted discussions between various groups representing Universities and Federal officials aimed at re-aching a consensus on interpreting the extremely restrictive language contained in the A-21 revision regarding circumstances under which it would be appropriate to charge administrative and clerical personnel to Federal grants and contracts. In the absence of those discussions, the perrogative of the various Federal agencies to either fund or not fund administrative and clerical support would have been removed. Columbia was in the forefront of these discussions, and although the outcome is less than ideal, I believe that we were very successful in insuring that our investigators, who are best suited to determine whether their individual grants and contracts require such support, will be able to present to their Federal counterparts, the justification for providing funding for these costs.

Attached hereto are the new University policies governing the charging of administrative costs (both salary and other costs) to Federal grants and contracts. Please take the time to read both documents very carefully, and to raise questions. My office is prepared to conduct briefing sessions to schools and departments on the application of these policies. Please contact Vice Provost Michael Crow to arrange a briefing.

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