General Information
Clerical and administrative activity is defined as general operational support provided that benefits departmental objectives in the delivery of its academic and research programs. Costs in this category are not specifically identifiable to a particular program. Routine secretarial and operational duties performed to initiate personnel actions, procure supplies and equipment, conduct travel arrangements, keep records of and monitor financial transactions, respond to inquiries, transcribe and edit reports are general administrative functions; although the list of these activities is not all-inclusive or exhaustive, the list is presented to illustrate the types of activities that support university operations. Oakland categorizes clerical and administrative support for sponsored programs as an indirect cost.
Regulatory or Institutional References
Office of Management and Budget (OMB) Circular A-21 defines direct costs as costs that can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy. OMB Circular A-21 requires that costs which are not specifically identifiable as direct be classified as and recovered through the university’s negotiated facilities and administrative (alternatively termed F&A or indirect) reimbursement; therefore, general clerical and administrative costs are generally not permitted as a direct charge to federally sponsored agreements.
Specific information on University policies and procedures regarding direct costing and expenditure documentation are found in the Oakland University Administrative Policies and Procedures manual accessible via the internet address http://www2.oakland.edu/audit/.
Research Administration Guidelines
General Guideline
Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or indirect costs. Oakland categorizes clerical and administrative costs of sponsored programs as indirect because the costs are not characteristically associated with a specific measurable benefit to a program. Clerical and administrative costs are not separately budgeted in a proposal to a sponsored organization.
Proposing Costs for Administrative and Clerical Support
Indirect costs of all proposal submissions are proposed at the applicable federally negotiated rate and are assumed to support a normal level of administrative activity. In cases where the normal level of administrative support does not apply, case-by-case consideration will be applied to the circumstances. Special circumstances are rare and must meet the guidelines of OMB Circular A-21 as determined by the Director of Office of Research Administration.
In the rare circumstance that clerical and administrative costs are categorized as direct, prior approval through a budget justification reviewed and approved by the Director of Office of Research Administration is required. A detailed budget disclosing proposed effort (percentage FTE or hours) and supporting narrative disclosing proposed tasks must be provided. The level of detail required to support internal approval for direct costing of administrative support may exceed the sponsor’s requirements to support the budget. Sponsoring organizations rely upon Oakland to fairly, accurately and consistently cost proposed work in conformity with its policy on the direct and indirect allocation of expense. Salary, wages and fringe benefits are applied as direct charges as a percentage of effort for salary (exempt) personnel or actual hours worked for hourly personnel (non-exempt).
Standard Pay Rates and Apportionment
Rates of pay for all work associated with sponsored agreements is paid at the employee’s contracted rate for the period of service. The employee’s contracted rate may be institutional base salary or hourly rate dependent upon the employment contract.
Overtime Pay Rates (Non-Exempt Employees)
Overtime rates for non-exempt employees must be paid at the contracted overtime rate for the period and in compliance with university policy and procedure, bargaining agreements and any federal or state regulations or contractual obligations under a sponsored agreement, where applicable. Overtime pay must follow the employee’s base assignment funding source(s). Overtime charges, where allowable by the sponsor, are apportioned using the base allocation of salary and wages for an employee’s normally assigned work schedule. Sponsored agreements often restrict or prohibit overtime charges, therefore, overtime charges are subject to disallowance if found to violate the terms of a sponsored agreement or to result in inequitable cost allocation. Overtime separately directed to a grant or contract agreement is not permitted.
Supplemental or Miscellaneous Pay
In rare circumstances, an employee may receive supplemental pay or miscellaneous pay for work performed unrelated to normal job duties. Approval is subject to all organizational reviews necessary to approve supplemental or miscellaneous pay and records documentation should be maintained to substantiate the circumstances. The conditions for approving supplemental or miscellaneous pay are not affected by the funding source, but are solely determined by the activity. Disparate treatment based on funding source will result in disallowance. Supplemental or miscellaneous pay for activity that is necessary and directly related may only be charged to a sponsored agreement if prior approved by the Director of the Office of Research Administration in compliance with all university and sponsor restrictions for supplemental or miscellaneous pay. Hourly employees must be paid at the contracted rate for the documented period of service.