An Overview of Sponsored Programs Administration at Harvard by yaoyufang

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									Compelling and Challenging:
An Overview of Sponsored Programs
Administration at Harvard Kennedy School
and Harvard University
     May 28, 2009



  Co-hosted by Harvard Kennedy School’s
  Research Administration Office (RAO)
  and Harvard’s Office for Sponsored Programs (OSP)
 Overview: Agenda
Greeting – Matt Alper, HKS
Welcome - Deloris Pettis, Associate Vice President,
            Sponsored Programs Administration
Harvard University Office for Sponsored Programs (OSP) Overview - Ethlyn O’Garro
HKS Research Administration Office (RAO) Sponsored Programs Overview - Matt Alper


Pre-Award Administration
Proposal review and submission - Charlene Arzigian, HKS; Helia Morris, OSP
                    -- BREAK --
Award Negotiations - Sarah Holtz, OSP


Post-Award Administration
- Allowable Costs, Effort Reporting, Audits - Judith Ryan, OSP
-Post-Award Financial Management – Judy McSweeney, Ana Garcia, OSP
-Training Opportunities – Lorraine Kiley, HKS
Wrap-up and Final Questions
             Office for
             Sponsored
             Programs (OSP)
Ethlyn O’Garro
Director, Sponsored Programs Administration


                                              3
Our Mission
   To partner with Harvard’s research and scholarly
    community in the support and advancement of
    Harvard’s educational, research and public
    service missions through provision of
     Pre-through post-award expertise and consultation
     Value-added customer service




                                                          4
What we do
   Pre-award (University area only)
     Review and approval of proposals
     Negotiating terms and conditions of   awards
   Post-award (across entire University)
     Accurate and compliant accounting of income and
      expenditures
     Completion and submission of financial reports
   Cash management
     Receive  checks and wire transfers and draw down
      funds > $600 million


                                                         5
            Harvard University Sponsored
                   Administration
                             Pre-Award*


       Office for                Harvard                 Harvard
      Sponsored                   Medical               School of
       Programs                   School               Public Health
        (OSP)                   (HMS SPA)              (HSPH SPA)



                School of                                        Other
 Faculty                         Harvard         Graduate
               Engineering                                       (Law,
of Arts &                        Kennedy         School of
                & Applied                                       Divinity,
Sciences                          School         Education
                Sciences                                        Design,
  (FAS)                           (HKS)           (GSE)
                 (SEAS)                                           etc.)



*pre-award= proposals and other requests to sponsor                         6
Harvard
                                      Medical
University                            School
Post-Award                                         Faculty
                     Kennedy
Administration        School
                                                  of Arts and
                                                   Sciences


                                     Office for
                                    Sponsored
                 Graduate            Programs             School of
                 School of                                 Public
                 Education                                 Health


                                             School of
                               Other
                                            Engineering
                             Schools &
                                             & Applied
                             Affiliates
                                             Sciences
                                                                 7
Sponsored Programs Officer and
Manager
   Responsible for managing the entire
    lifecycle of the team’s portfolio to include:
     HKS
     SEAS
     FAS-Physical   and Social Sciences
     Law School
     Radcliffe


                                                8
Grants and Contracts Officer
   Responsible for negotiating terms and conditions of sponsored awards and
    sub-contracts. Federal and Non-Federal.
        Serves as liaison between the University’s interests and the sponsor’s needs
        Coordinates with other Harvard offices to ensure compliance with University
         research policies
        Drafts sub agreements and amendments
        Provides training and guidance to pre award staff on contract negotiations
        Responsible for the interpretation of Federal and non-Federal rules and
         regulations (i.e. FAR, export controls, anti-terrorism clauses and Intellectual
         Property rights as they relate to the University)
        Works closely with Faculty and Department Administrators during the negotiation
         process to ensure compliance with specific school policies and in support of
         individual faculty needs
        Authorized to sign on behalf of the President and Fellows of Harvard College

HKS Representative: Sarah Holtz



                                                                                       9
Senior Grants and Contracts
Specialist
   Responsible for the management of a complex sponsored research portfolio as
    follows:
        Serves as primary contact to clients, PI’s, departments and sponsors on grant related
         matters
        Reviews proposals for compliance with sponsor and Harvard policies
        Maintains complete management of the pre award life cycle of an award
        Provides financial and technical expertise to PI’s, Directors of Administration and other
         department contacts (lab managers, grant managers, etc.)
        Works with several Federal and Non-Federal sponsors in the development and management
         of proposals and contracts
        Interprets federal and other granting institution guidelines to ensure compliance with
         regulations
        Responsible for submission of Electronic documents through Fastlane and ECommons
        Under mentorship of Grants and Contracts Officer, may negotiate awards and draft sub-
         agreements
        Is responsible for the interpretation of advanced compliance issues

HKS Representative: Rebekah Coble




                                                                                                10
Lead Sponsored Specialist
   Responsibilities for this position are the same as those of the Senior Grants and
    Contracts Specialists with the additional duties being:
        University Signing Authority
        Responsible for submission of electronic proposals (i.e. Grants.gov, Fastlane and Nspires)
        Serves as back up for the University area Life Cycle Managers
        Pre-award support and oversight across University Area Life Cycle teams
        Participates in strategic planning and special projects as needed
        Training and mentoring of Grants and Contracts Specialists
        Participates in the development of presentations and trainings to clients and to other OSP
         staff
        Subject matter expert with demonstrated leadership skills and proven ability to work with
         shifting priorities

HKS Representative: Marrybell Ramos




                                                                                                      11
Senior Financial Analyst
   Manages a sponsored research post-award
    portfolio as follows:

        Reviews, approves and signs invoices and
         financial reports on behalf of the President
         and Fellows of Harvard College
        Establishes strategic direction of training
         initiatives to Financial Analysts and clients
         regarding financial reporting, data warehouse,
         GMAS and sponsored policies and
         procedures
        Responsible for mentoring and training
         Financial Analysts
        Provides training for clients
        Provides GMAS expertise level support
        Responsible for documenting and
         implementing best practices across the
         University

HKS Representative: Ana Garcia




                                                          12
Financial Analyst
   Manages a sponsored research post-
    award portfolio to include:
      Oversight and management of financial
       policy, compliance and reporting issues
       that arise through the life cycle of an
       award
     Interprets complex terms and
       conditions
     Performs quality control checks to
       ensure compliance with terms and
       conditions, sponsor and Harvard
       guidelines and policies
     Captures essential reporting
       requirements
     Schedules financial reports
     Performs timely financial analysis of
       Federal and Non-Federal sponsored
       grants and contracts
     Performs timely financial reporting and
       invoicing of sponsored awards
     Reviews cost transfers to ensure
       compliance with Harvard and Federal
       regulations
     Coordinates A/R and collection
       activities and account close out
       procedures for portfolio
HKS Representatives: Ana Garcia & Leela
   Joseph                                        13
Sponsored Programs Administrator
   Responsibilities include:
       Data entry for all proposals including budgets, approvals, and
        scanning all proposals and relevant supporting documentation
       Data entry for all account set up including maintaining expert
        level knowledge of sponsored Chart of Accounts
       Processing all subcontracts and amendments
       Reviewing proposal and award data for completeness, quality
        assurance, and compliance with Harvard and sponsor policies
       Administrative tasks as needed


    HKS Representative: Wendy Cazavelan


                                                                         14
Internal Collaboration
   HKS
       Research Administration Office (Pre-award)
       HKS Center Administrators and PI’s
       HKS Office of Financial Services (Post-award)
   Office of Technology Development (OTD)
   Office of the General Counsel (OGC)
   The Office of the Provost
   Risk Management and Audit Services (RMAS)
   Recording Secretary’s Office (RSO)
   FAD Systems Solutions (FSS)

                                                        15
Questions?




             16
HKS Sponsored Proposals By Sponsor Type



  SPONSOR TYPE    FY06    FY07    FY08




                   38      36      29
     Federal
                   32%     35%     27%


                   79      66      78
   Non-Federal
                   68%     65%     73%


     TOTAL
                   117     102     107
   PROPOSALS

                                          17
HKS Sponsored Proposals Overview
FY 2006-FY 2008


   OVERVIEW            FY06   FY07   FY08


        PIs             52     46     50

   Prospectively        68    48      30
 Processed Proposals   58%    47%    28%


  Retrospectively       49     54     77
 Processed Proposals   42%    53%    72%

      TOTAL
                       117    102    107
   PROPOSALS
                                            18
HKS Sponsored Proposals Submitted
     BY CENTER          FY07   FY08   FY09 (Q. 1-3)

         Ash            4%      4%        10%

       BCSIA            18%    15%        12%

        Carr             1%     3%         0%

         CID            9%      7%        10%

        CPL             8%      4%         0%

 Executive Education    12%    8%          8%

       Hauser            1%    11%        13%

      M-RCBG            15%    14%        16%

     Shorenstein         1%     3%         3%

      Taubman           9%     11%        14%

       WAPPP            0%      1%         0%

       Wiener           16%    17%        11%

 Unaffiliated & Other   6%      2%         2%

 TOTAL PROPOSALS        102    107         87         19
HKS Total Sponsored Program Expenditures
FY 2006-FY 2009 (Projected)


      Sponsored Program                                             FY09
                               FY06         FY07        FY08
      Expenditures ($m)*                                           (Proj.)



                                $26.1       $27.4       $25.3       $25.3
            Total
                                +5%         +5%         -8%         0%

                                $11.8       $9.4        $7.4         $5.4
      Federal Sponsors
                                +13%        -20%        -21%         -27%


                                $14.4       $18.1       $17.8       $19.9
    Non-Federal Sponsors
                                -1%         +26%        -2%         +11.8%

  * These data reflect only those proposals submitted and awards accepted by OSP;
  the percent change from the prior fiscal year is indicated.                       20
             Sponsored Expenditures by School
             OSP FY 2008 Annual Report ($000)
                                                                                                                Sponsored
                                                                             School as a                         as % of
                                             Total Non-    Total Sponsored      % of           Total School      School
                         Total Federal        Federal         Program        Sponsored          Operating       Operating
         School            Expenses          Expenses         Expenses        Expenses          Expenses        Expenses


HMS (including HSDM)      $   195,552    $        38,889   $      234,442        35.50%    $         623,595       37.60%


SPH (including PEPFAR)    $   202,400    $        30,023   $      232,423        35.20%    $         308,865       75.30%


FAS                       $    88,468    $        24,639   $      113,107        17.10%    $        1,013,578      11.20%


SEAS                      $    30,070    $         4,903   $       34,973         5.30%    $          74,459       47.00%


HKS                       $     7,433    $        17,843   $       25,277        3.80%     $         137,393       18.40%


GSE                       $     3,185    $         7,393   $       10,578         1.60%    $          71,871       14.70%


Other Tubs                $     1,591    $         7,691   $        9,282         1.40%    $        1,235,135       8.00%


Total Expenditures        $   528,700    $       131,381   $      660,082      100.00%     $        3,464,895      19.10%


  Source: FY 2008 OSP Annual Report
                                                                                                                        21
  A Cross Section of New HKS Sponsored
  Awards – FY 2009 to date

 Graham Allison    Government of Dubai: The Dubai Initiative
 Graham Allison    Office of the Director of National Intelligence: Intelligence Training Program
 Anthony Braga     Boston Police Department:     Analysis of Serious Violent Crime in Boston
 Merilee Grindle   Instituto Tecnologico y de Estudios Superiores de Monterrey:    Mexico Initiative
 John Holdren      Nuclear Threat Initiative:   Preventing Nuclear Terrorism
 Asim Khwaja       Google.org: Entrepreneurial Finance Lab
 Jennifer Lerner   National Science Foundation: Leadership Decision Making
 Robert Putnam     Institute for Global Development: Research on Happiness, Social Capital, & Religion
 Tony Saich        US Dept of State: Vietnam Economics Teaching Program
 Bruce Western     The Elfenworks Foundation: The Collaborative Initiative on Poverty and Inequality




                                                                                                     22
   Alphabet Soup…..
DASH – Digital Access to Scholarship at Harvard (see OSC)
FCOPP – HKS Faculty Committee on Projects and Proposals
GPC – HKS Gifts Policy Committee
IPAC – Harvard’s International Projects Administrators Committee
IRB – Harvard University’s Institutional Review Board (aka –
Committee on the Use of Human Subjects, CUHS)
OSC – Harvard’s Office for Scholarly Communication (see DASH)
SALC – Harvard’s Sponsored Administration Leadership Committee
SRPHSPC – HKS’s Student Research Projects Human Subjects
Protection Committee (OK, we made up the acronym, but the committee
is real…)
UCIPS – Harvard’s University Committee on International Projects
and Sites


                                                                   23
Questions?




             24
About RAO: Who We Are

      Matthew Alper
Associate Dean for Research



                        Charlene Arzigian
                        Assistant Director



                                            Jody Blackwell
                                       Research Communications
                                              Coordinator


                                           Martha Goldberg
                                        Research Administration
                                              Coordinator

                                                                  25
What is the Role of the RAO?
   The RAO supports HKS faculty and staff in:

    Finding funding

    Applying for funding

    Accepting funding

    Disseminating results of funding



                                                26
Finding Funding
   Funding opportunity distribution via email

   Custom searches

   Funding opportunity table on ResearchCentral

  Managed by: Jody Blackwell
  Research Communications Coordinator




                                                   27
Applying for Funding – RAO
Responsibilities
    Work with faculty PIs and staff on proposal
   preparation, including advice on fulfilling sponsor
   requirements, review of budget and other proposal
   components

    Manage review and approval process at HKS

    Work with OSP to answer any questions and
   resolve outstanding issues before OSP’s submission
   of proposal to sponsor

   Managed by: Martha Goldberg
   Research Administration Coordinator
                                                         28
    Applying for Funding – Centers’
    Responsibilities
 Careful attention to sponsor requirements

 Clear communication with RAO, e.g., has the sponsor been contacted or
even seen a version of the proposal; what is the sponsor expecting and
when

 The Center grants/finance manager takes initial responsibility for
working closely with the PI on all aspects of the proposal development and
engagement with the RAO on review and approval, including careful
attention to sponsor requirements and adherence to HKS and Harvard
policies (e.g., fringe benefits, overhead rate)

 Ensure engagement of center executive director for all Center
commitments (e.g., space, overhead contribution)                        29
Accepting Funding
   OSP receives notification of awards, reviews and
  negotiates terms and conditions if necessary, and
  accepts awards on behalf of the University.

   RAO maintains information on status of award
  negotiations and account set ups, and serves as
  liaison between OSP and PIs/Centers, facilitating
  resolution of issues




                                                       30
What Else Does the RAO Do?
   Provides informal “Drop-In Sessions” that offer
  information on specific topics of interest, e.g., “The
  ABCs of the DAF (Dean’s Approval Form),
  “What is FCOPP?”

   Provides information and updates on rates (fringe
  benefit and indirect cost), School and University
  policies




                                                           31
            Office for
            Sponsored
            Programs (OSP)
OSP Proposal Review and Submission Process
Helia Morris
Sponsored Programs Officer and Manager

                                         32
Award Lifecycle

         Award          Proposal
        Closeout       Preparation




                         HU Review
        Award           & Submission
      Administration      Through
                        Award Set-Up


                                       33
Proposal Preparation
   Proposal preparation is a joint
    collaboration between the HKS Research
    Administration Office and the Office for
    Sponsored Programs




                                               34
        Internal Approvals
   Internal Approval Forms carry signatures of
     Principal
              Investigator
     School and Center

   Signatures show that each entity has
    reviewed and approved the proposal
   Forms can be found at:
    RAO Website:
     http://www.hks.harvard.edu/research/researchce
     ntral.htm
    OSP Website:
     http://vpf-web.harvard.edu/osp/

                                                      35
             Institutional Approval

 OfficialSignature takes place at OSP
 Tells the sponsor that Harvard
  Has thoroughly reviewed the proposal
  Plans to support the research if awarded

 May include other assurances required
 by sponsor


                                              36
Proposal Submission Types
 Paper  copies are still needed sometimes
 Electronic submissions are more and
  more common
 The Office for Sponsored Programs
  must review and approve all
  submissions!


                                             37
Internal Deadlines
   HKS/RAO:
       In order to ensure adequate time for approval of proposals by
        HKS, proposals are due at RAO 3 full working days before
        the OSP deadline
   OSP:
       The complete and final proposal, accompanied by the
        appropriate Dean’s Approval Form and any other required
        sponsor- or university-required attachments must be
        submitted to OSP three (3) business days prior to the
        sponsor’s due date
             The “sponsor’s due date” is defined as: 1) the submitting
              institution’s due date, if Harvard is a subcontractor; 2) the prime
              sponsor’s mail-by date; or 3) the actual due date if a post-mark
              date or electronic submission



                                                                                    38
Standard Questions For All
Proposals
   Has authorized party signed DAF or other approval?
   Have sponsor and Harvard guidelines been met?
   Is this a new sponsor?
   Are institutional approvals needed?
   Is cost sharing involved?
   Does PI eligibility and appointment meet criteria?
   Is set-up required for electronic submission?
   Is the budget accurate with corresponding justification?
   Is the institutional information accurate?
   Are letters of support needed?
   Is this a final version consistent with guidelines?




                                                               39
If/Then Considerations
   If subcontracts: are all necessary documents
    included?
   If inter-faculty: is supporting information
    included?
   If approvals are needed: refer to HKS DAF
   If New Sponsor: were approvals obtained?
   If Foreign travel is included: Check the U. S.
    Department of State for travel restrictions

                                                     40
If Sponsor is Federal
Government
 Are there export control issues?
 Is PI certification on file (if NSF or PHS)?
 Is there proprietary information?
 Have required reps/certs been obtained?




                                                 41
At Award Stage Questions?
   3 question subcontract questionnaire reviewed
   Are any “Just in Time” (JIT) documents required
    by the sponsor
     IRB approval
     Cost sharing, etc

   Are Harvard JIT approvals needed?
   Is a Participation Agreement needed?


                                                  42
Collaborative Research
 More   and more prevalent
  Between  HKS & other Harvard
   schools/departments
  With other institutions

 Please   remember that:
  A  project description, a budget and
   budget justification, and an approval
   from the other institution, school, or
   department is required
 Contact RAO ASAP because
  coordination takes time!                  43
Questions?




             44
             Office for
             Sponsored
             Programs (OSP)
Review of Grant Agreement
Sarah Holtz
Grants and Contracts Officer

                               45
REVIEW OF GRANT AGREEMENT
   Before accepting an award on behalf of the
    University, OSP reviews all terms and
    conditions.
       Consistency with proposal submitted
            Scope of Work
            Award Amount
            Project Dates


       Deliverables and other requirements




                                                 46
Review of Grant Agreement
Problematic Terms
   Publications and Confidentiality
   Intellectual Property
   Academic Freedom
   Payment Terms
   Acceptance of Deliverables
   Termination
   Audit
   Indemnification and Insurance
   Use of Harvard’s Name
   International Issues (governing language, governing law, foreign
    currency)


                                                                       47
Review of Grant Agreement

   Examples of Recent Issues
     Subcontract  from the New School under United
      Nations Development Programme prime: Harvard
      negotiated the terms of the prime award.
     Google.org:  Harvard had to indemnify sponsor for
      costs for which Harvard is not insured.
     Multinational Development Banks: African
      Development Bank, Asian Development Bank, and
      World Bank all want to own deliverables and require
      that results be kept confidential.


                                                            48
Review of Grant Agreement

   Recent Negotiation Issues (continued)
     “Unauthorized” negotiators: Harvard negotiates with
      a sponsor contact not actually authorized to change
      the terms and conditions.

     InternationalSponsors: Often try to require Harvard
      to have an independent audit of project expenditures.



                                                            49
Review of Grant Agreement

   Review of award terms often requires
    input from:
     Office of Technology Development (OTD)
     Office of the General Counsel (OGC)
     Office of the Provost
     Risk Management and Audit Services (RMAS)




                                             50
Questions?




             51
             Office for
             Sponsored
             Programs (OSP)
Allowable Costs/Effort Reporting and Audits
Judith Ryan
Director of Cost Analysis and Compliance

                                              52
Federal and Non-Federal
   Both are audited and reviewed
      Multiple reviews last year – agencies and foundations
      A-133 audit now includes non-federal awards




   Both rely on University systems such as payroll,
    effort reporting, equipment management

   Both will be considered as part of SAS 112
    Communicating Internal Control Related Matters Identified in an
    Audit
                                                                      53
                                OMB A-21 Section A
                                    Florida International         Johns Hopkins University
   University of Minnesota            University 2005                       2004
            1998                    Effort Certification &           Effort Certification
    Misuse federal funds                Direct Costs                     $2.7 million
         $32 million                    $11.5 million
                                                                   University of Connecticut
                                  Florida A&M University                      2006
George Washington University               2005
                                       Cost Sharing              Cost Sharing/Overstate federal
             2005                                                            funds
    Theft of federal funds              $1.4 million
         $1.8 million                                                     $2.5 million


    East Carolina                 Results of Non-                             University
   University 2004                 Compliance:                         Alabama/Birmingham
  Questioned Costs                                                               2005
     $2.4 million
                                    Significant                         Effort Certification &
                                 Audits/Settlements                   Clinical Research Billing
                                                                             $3.4 million
     Mayo Foundation
            2005                                                        Cornell Medical
 Mischarging federal grants                                                  2005
        $6.5 million                                               Clinical Research Issues
                                                                          $4.4 million
                               Yale University            2008
         Harvard/BIDMC            Unallowable Costs & Direct       Northwestern University
               2004                         Costs                          2003
         Costing Issues                  $7.6 million               Committed Time/Effort
          Self-Reported                                                 $5.5 million
          $3.25 million                                                                      54
Sub-recipient Monitoring

    A-133 D400d(3). Monitor the activities of sub-
     recipients as necessary to ensure that
     Federal awards are used for the authorized
     purposes in compliance with laws,
     regulations, and the provisions of the
     contracts or grant agreements and that
     performance goals are achieved




                                                     55
                  OMB A-21 Section C.4
Sub-recipient Monitoring

 As prime grantee, HKS and PI are
  responsible for entire award
 PI monitors programmatic performance
 PI approves invoices and certifies
  performance and appropriateness of
  charges
 Grantee could be liable for disallowed
  costs of subcontractor
                                           56
Effort Reporting Policy
Effort : the amount of time spent on a particular award, expressed as
    a % of the total amount of time spent on work related activities
    (teaching, research, service) for which the University compensates
    an individual

Effort reporting is a federal requirement
(A-21 Sec. J.10.c):
   Effort Reporting is a process mandated by the Federal government
    to verify that direct labor charges to Federally sponsored projects
    are reasonable and reflect actual work performed
   Faculty and staff salaries charged to sponsored research projects
    should be commensurate with the direct effort provided to the
    project
   As a requirement of receiving federal funding, institutions must
    maintain an accurate system for reporting the percentage of time
    (i.e., effort) that employees devote to federally sponsored projects
                                                                           57
Effort Reporting: Here at
Harvard
   In Harvard's decentralized environment, effort reporting and salary
    certification methods are accomplished in different ways by the
    Schools


    HKS Monthly Salary Certification for Research Staff:
    http://www.hks.harvard.edu/ofs/
        Under Policies




                                                                    58
OMB A-21 Key Concepts
   Chief Aim: to have the federal government pay
    its “fair share” of the costs of research
    conducted at the University
   Means for achieving this aim: principles for
    determining the costs applicable to research and
    development, training, and other sponsored
    work performed by universities under sponsored
    agreements (grants, contracts, and other
    agreements) with the Federal Government
                                                  59
                      OMB A-21 Section A
Concerns with Faculty Effort

 100% Research – government assumes
  faculty have duties related to instruction
  and administration
 Impact of unfunded committed faculty
  effort in sponsored programs
     Lowers  the indirect cost rate
     Impairs academic freedom
     Creates administrative and reporting burdens
      for department and University
                                                 60
Stipends v. Salary for Graduate
Students and Post Docs
   http://vpf-web.harvard.edu/osp/quick_links/policies/#stipends


   Stipend payments are not compensation
    for services rendered and, therefore, are
    not allowable on federal awards unless the
    purpose of the agreement is to provide
    training to selected participants and the
    charge is approved by the sponsoring
    agency (OMB Circular A-21, Section J45)
                                                                    61
Stipend v. Salary

 Appointments and job codes determine
  object codes
 Cannot simply move $ between object
  codes
 Scope of work must contain explicit
  intention to train specific individuals – not
  educate the public
 Allowability does not depend on budget
                                                  62
Tuition Remission

 Tuition remission is the payment of tuition
  in lieu of salary – it is compensation
 Must be accompanied by an employment
  appointment
 Must reflect $ in 6140 – Students in
  Professional Positions to comply with
  effort reporting requirements

                                                63
OMB A-21 Key Concepts
ALLOWABLE Costs:
   They must be reasonable
   They must be allocable to sponsored
    agreements under the principles of A-21
   They must be given consistent treatment
    through application of those generally
    accepted accounting principles appropriate to
    the circumstance
   They must conform to any limitations or
    exclusions set forth in A-21 or in the
    sponsored agreement
                                             64
                    OMB A-21 Section C.2
OMB A-21 Key Concepts
ALLOCABLE Costs:

    A cost is allocable to a particular cost
     objective if the goods or services involved are
     chargeable or assignable to such cost
     objective in accordance with relative benefits
     received




                                                 65
                     OMB A-21 Section C.4
OMB A-21 Key Concepts
REASONABLE Costs:
    A cost that a prudent person would have
     incurred under the circumstances prevailing
     when the purchase was made




                                                   66
                    OMB A-21 Section C.3
OMB A-21 Key Concepts
CONSISTENCY:
    An institution must use the same practices for
     estimating costs in budgeting a proposal and
     for accumulating and reporting costs
    Each type of cost may be allocated only once
     and on only one basis to any sponsored
     agreement or cost objective




                                                                        67
     OMB A-21 Appendix A - Cost Accounting Standards 9905.501 and 502
Questions?




             68
            Office for
            Sponsored
            Programs (OSP)
Post Award Financial Management
Judy McSweeney
Director, Financial Services
Ana Garcia
Senior Financial Analyst          69
Introduction to Post-Award
Management
   Responsible for all aspects of financial
    management
       Billing
       Collections
       Oversight
       Reporting
       Account Reconciliation/Close-out
       Interest Credit & Debit
       Customer Service
       Training & Outreach (including SPOC)
       Systems Support
       Data Integrity




                                               70
Transformative initiatives
   Billing
     Transitioning   standard invoices to admin team
   Collections
     AR  group in Office of the Controller effective
      7/1/09
   Cash
     Lock    box for deposits

                                                        71
OVERVIEW
   OSP is the central financial administration office
    for all of Harvard’s sponsored awards
   Financial analyst and senior financial analyst
          26 analysts located in both Cambridge and Longwood
   $660.1 million in sponsored funding in FY08
   In FY08, OSP completed 5879 financial reports




                                                                72
REPORTING FY08




                 73
Required Reports
 Technical   Reports (PI)
  Annual  & Final
  Patent/Invention (PI, OSP, & OTD)
 Administrative
  Periodic  fiscal reports (OSP)
  Final fiscal and property reports
 Late   reporting can hold up
  Funding for multi-year projects
  Payment of expenses already charged to
   Harvard accounts
                                            74
Reporting-Continued
   Types of Federal Reports
     SF 269
     SF 272
     SF 270

   Types of Non-Federal Reports
     Non-Federal   Reports vary by sponsor



                                              75
Harvard University Standard
Invoice




                              76
INFORMATION MANAGEMENT

   Transition from pre-award to post-award

   Action Memos
     Review   Terms & Conditions

   Scheduling Reports & Receivables in
    GMAS

                                              77
Scheduling Reports in GMAS




                             78
ACCOUNT MONITORING
   Federal and Non-federal Accounts

   Financial Reporting, CAS Compliance

   Cost Transfers

   Aging Receivables

                                          79
CAS COMPLIANCE
(Cost Accounting Standards)
6050, 6070   Admin personnel
6570         Food, alcohol, beverage
6630         Non-library books, reprints, subscriptions
6640         Office supplies and materials
6710-6816    Make sure equipment is budgeted and coded +/- $5000
767x         Foreign travel
8260         Other services
8267         Parking
8510-8515    Local telephone/telecom
8540         Copying
8550         Printing, publishing
8620         Training- not on research grant
8680         Dues, memberships
8700, 8702   Postage, express mailing, shipping

                                                                   80
Cost Transfer Policy
   Policy Statement
        To comply with the requirements of OMB Circular A-21, the policy of
         NIH, our largest source of federal research funding, and the
         requirements of other federal sponsors, Harvard University has
         established the following policy and procedures for the processing of
         cost transfers
   Definition
        A cost transfer is a transfer to a federally funded sponsored account of a
         charge previously recorded elsewhere on Harvard's General Ledger
         Examples:
             Transfer pre-award costs from departmental holding account
             Correct clerical error
             Reallocate salary and fringe to reflect actual effort
             Reallocate shared services that were previously charged elsewhere




                                                                                  81
AWARD CLOSEOUT
   Unreconciled Report

   Disabling Accounts

   Web Vouchers for Refunds

   Fixed Price and Surplus

   Transfers to Other Universities

                                      82
Cash Management
   OSP performs various functions related to
    accounts receivable management
     Scheduling   payment
     Invoicing and applying cash
     Collection Follow-up
     Identifying issues of non-payment


   HKS also performs cash related functions
    such as:
     AccountReconciliation
     Management of award
     Submission of deliverables
                                                83
Audits: Be Prepared
         Anticipate the project will be audited
         Manage the award correctly from the
          beginning
         Audits often take place several years
          after the project is completed
         A-133 audits are performed annually
         If an auditor contacts you or your PI,
          call your OSP representative before
          answering anything!

                                              84
Office for Sponsored Programs (OSP)




                                              85
            http://vpf-web.harvard.edu/osp/
Questions?




             86
       OPPORTUNITIES FOR TRAINING IN
    SPONSORED PROGRAMS ADMINISTRATION
• University-Wide Sessions                        On-Line Modules (via OSP
• University Research                                 website to Eureka! training modules)

  Administration Training
  Committee (URATC)                               •   Sponsored Programs
                                                      Administration Overview
                                                  Course length: 30 minutes
•   Currently offers periodic one-day sessions
                                                  •   The Regulatory Environment
    “Overview of Sponsored Programs
    Administration”                               Course length: 45 minutes
•   Led by research administrators from various   •   Cost Principles
          schools throughout the university       Course length: 1 hour
  •  Offers comprehensive training addressing
        the entire award lifecycle at Harvard           Access through OSP website:
           •    For more information:                  http://vpf-eb.harvard.edu/osp
           RASLearn@fas.harvard.edu




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