The COGR Board also has issued a statement that it is reasonable for institutions to include direct salary charges for administrative and clerical salaries in ARRA grant applications. According to COGR the inclusion of such costs as a direct charge will not jeopardize the application from being selected for funding.
In response, SPO recommends the following if you are planning to charge departmental administrative/clerical salaries to your ARRA funded project:
1. The project budget should include salary support for specific administrative and/or clerical personnel needed to comply with ARRA requirements.
2. The amount budgeted for administrative and/or clerical personnel salaries should be based on an estimate of the percentage of time each of these staff members will directly devote to ARRA responsibilities. COGR is recommending a 5% to 10% level of effort.
3. The proposal budget justification should include a rationale for requesting departmental administrative support costs in the form of administrative and/or clerical salaries. Here is sample language recommended by COGR:
Due to the extraordinary administrative oversight and reporting activities associated with awards made under the American Recovery and Reinvestment Act, this proposal includes (insert appropriate percentage of effort) salary support for the additional administrative services required by the Act should an award be issued. Regulatory support for this request is located at OMB Circular A-21 F.6. a. (2.), which states: “Direct charging of salaries of administrative and clerical staff costs may be appropriate where administrative or clerical services required by the project are significantly greater than the routine level of such services provided by academic departments.”4. Here is an alternative version:
Due to the extraordinary administrative oversight and reporting activities associated with awards made under the American Recovery and Reinvestment Act, this proposal includes a request for ___ positions @ ___% time or ___ FTE to support the data collection and reporting requirements specified by the terms of the Recovery Act. The administrative responsibilities and clerical duties of these personnel will support the collection, organization, interpretation and/or reporting of the required ARRA data elements including funding received and expended, completion status of project, jobs created or retained, infrastructure investment impact, and information on subrecipients and subrecipient funding.