Whenever you propose a budget to a federal sponsor which includes clerical and administrative expenses, it is essential to include a clear and compelling budget justification for those expenses. In addition, you must establish that the project being proposed meets the A-21 definition of a "major project."
The following language is suggested for inclusion in the budget justification section of the proposal to establish this point:
. . . The PI has determined that this is a major project, as defined by OMB Circular A-21, and it meets A-21 requirements for direct charging of administrative expenses. All effort and expenses charged to this project will be for services specific to the project, and not for general support of the academic activities of the faculty or Department. In addition, effort charged to this project can be specifically identified to the project.
NOTE that this requirement to establish a "major project" in order to charge clerical and administrative expenses applies to FEDERAL SPONSORS ONLY. When being charged to a non-federal sponsor, these expenses must still be allowable, allocable to those projects, and reasonable, but they do not have to pass the "major project" test.