The Federal Office of Management and Budget (OMB) Circular A-21 prescribes cost principles for federal projects conducted at universities and addresses how to handle administrative, clerical and secretarial salaries for federal sponsors. OMB Circular A-21 states that administrative, clerical, and secretarial salaries expenses are generally considered indirect costs.

If PIs/PDs are considering directly charging administrative, clerical and/or secretarial costs in their proposals, they must discuss with their OSR GCA* their intention to do so. In order for these to be allowable costs, the following must occur:

1. The position duties must contribute directly to the programmatic purpose of the project.
2. The position justification must be specifically included in the proposal budget narrative and clearly explained.
3. The OSR GCA’s approval for this budget line item must be obtained by the PI/PD.
4. The sponsor must either explicitly approve or not explicitly exclude the budget line item in the award.

If the administrative, clerical, or secretarial costs will be allowable under UNH policy, the OSR GCA will document UNH’s approval for direct charging these salaries in a letter to the PI/PD and the official file prior to the award being accepted by UNH.

For examples of where administrative salaries can be charged as direct costs, see UNH Guidance on OMB Circular A-21.

OMB Circular A-21 also requires that costs are handled consistently in “like circumstances” across an institution. That is, direct and indirect expenses must be handled the same way in like circumstances across units within UNH, regardless of the sponsor type (i.e., federal or non-federal). If a non-federal sponsor does not address how to handle such costs, PIs/PDs should seek assistance from their OSR GCA*.

*PIs/PDs in EOS should contact their BSC.