CAS Major Project Exemptions:
Under normal circumstances, neither salary for Administrative/Clerical personnel or non-salary Administrative Expenses can be directly charged to a project. Such charges are F&A costs (“indirect” costs) and generally must be paid by the department/ PI overhead or balance account. CAS exemptions provide exceptions to this rule.
[expand title=”What types of personnel/expenses need a CAS exemption in order to be paid from a project?“]
Administrative and Clerical personnel may include positions such as secretaries, receptionists, accountants, bookkeepers, or any other administrators.
Administrative expenses include expenses such as office supplies, postage, telephone bills, computer supplies, software, and membership dues.
[expand title=”Under what circumstances does a project qualify for a CAS exemption?“]
If a faculty wishes to be able to charge these types of expenses to a project, the project in question must be classified as a “Major Project”
A project may be considered a “Major Project” if it meets one or more of the following criteria:
- 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).
- 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 research vessels, radio astronomy projects, and other research field sites that are remote from campus.
- Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications.
All criteria are judged on a case-by-case basis and are highly subjective.
[expand title=”How are CAS exemptions applied for and when?“]
All prospective exemptions must be outlined in the award agency budget. Each expense to be directly charged should be explicitly set forth in the budget as a line item in the project proposal budget. For example, if a project proposes to direct charge both postage and local telephone costs, the budget must contain a specific line item for each cost.
To apply for a CAS Exemption, PIs should complete the CAS Exemption form (found above) and submit the forms to a Department Chair or Dean for approval. Completed forms should then be submitted to ORC at the time of proposal submission.
[expand title=”Special hiring considerations for CAS projects“]
To request approval for charging Administrative/Clerical salaries, a narrative must be attached to their epaf at the time of hire. The following information will be needed:
- Name, Job title/code, Position number, percentage of effort to be devoted to the project, and amount of support requested for each employee.
- Description of how each employee will benefit the project.
- Why the employee’s activities are not routine.
- The manner in which their salary charges will be documented.