Compelling and Challenging

Compelling and Challenging: An Overview of Sponsored Programs Administration at Harvard Kennedy School and Harvard University

• May 28, 2009

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

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

• 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

Pre-award (University area only)

• 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

Responsible for managing the entire lifecycle of the team’s portfolio to include:

• Responsible for managing the entire lifecycle of the team’s portfolio to include:

• HKS
• SEAS
• FAS-Physical and Social Sciences
• Law School
• Radcliffe

Responsible for negotiating terms and conditions of sponsored awards and sub-contracts. Federal and Non-Federal.

• 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

Responsible for the management of a complex sponsored research portfolio as follows:

• 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

Responsibilities for this position are the same as those of the Senior Grants and Contracts Specialists with the additional duties being:

• 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

• 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

Manages a sponsored research post-award portfolio to include:

• 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

Responsibilities include:

• 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

HKS

• 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)

• Questions?

HKS Sponsored Proposals By Sponsor Type

HKS Sponsored Proposals Overview FY 2006-FY 2008

HKS Sponsored Proposals Submitted

HKS Total Sponsored Program Expenditures FY 2006-FY 2009 (Projected)

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

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

Questions?

About RAO: Who We Are

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

Finding Funding

• Funding opportunity distribution via email

• Custom searches

• Funding opportunity table on ResearchCentral

• Managed by: Jody Blackwell

• Research Communications Coordinator

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

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)

•  

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

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

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

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

Internal Approval Forms carry signatures of

• 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/researchcentral.htm
• OSP Website:
• http://vpf-web.harvard.edu/osp/

Official Signature takes place at OSP

• Official Signature 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

Paper copies are still needed sometimes

• Paper copies are still needed sometimes

• Electronic submissions are more and more common

• The Office for Sponsored Programs must review and approve all submissions!

HKS/RAO:

• 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

Has authorized party signed DAF or other approval?

• 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?

If subcontracts: are all necessary documents included?

• 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

Are there export control issues?

• Are there export control issues?

• Is PI certification on file (if NSF or PHS)?

• Is there proprietary information?

• Have required reps/certs been obtained?

3 question subcontract questionnaire reviewed

• 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?

More and more prevalent

• 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!

• Questions?

Before accepting an award on behalf of the University, OSP reviews all terms and conditions.

• 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

Problematic Terms

• 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)

Examples of Recent Issues

• 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.

Recent Negotiation Issues (continued)

• Recent Negotiation Issues (continued)

• “Unauthorized” negotiators: Harvard negotiates with a sponsor contact not actually authorized to change the terms and conditions.
• International Sponsors: Often try to require Harvard to have an independent audit of project expenditures.

Review of award terms often requires input from:

• 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)

• Questions?

Both are audited and reviewed

• 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

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

• 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

As prime grantee, HKS and PI are responsible for entire award

• 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

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 : 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

In Harvard's decentralized environment, effort reporting and salary certification methods are accomplished in different ways by the Schools

• 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

Chief Aim: to have the federal government pay its “fair share” of the costs of research conducted at the University

• 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

100% Research – government assumes faculty have duties related to instruction and administration

• 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

http://vpf-web.harvard.edu/osp/quick_links/policies/#stipends

• 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)

Appointments and job codes determine object codes

• 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

Tuition remission is the payment of tuition in lieu of salary – it is compensation

• 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

They must be reasonable

• 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

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

• 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

A cost that a prudent person would have incurred under the circumstances prevailing when the purchase was made

• A cost that a prudent person would have incurred under the circumstances prevailing when the purchase was made

An institution must use the same practices for estimating costs in budgeting a proposal and for accumulating and reporting costs

• 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

• Questions?

Responsible for all aspects of financial 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

Billing

• Billing

• Transitioning standard invoices to admin team

• Collections

• AR group in Office of the Controller effective 7/1/09

• Cash

• Lock box for deposits

OSP is the central financial administration office for all of Harvard’s sponsored awards

• 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

Technical Reports (PI)

• 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

Types of Federal Reports

• Types of Federal Reports

• SF 269
• SF 272
• SF 270

• Types of Non-Federal Reports

• Non-Federal Reports vary by sponsor

Transition from pre-award to post-award

• Transition from pre-award to post-award

• Action Memos

• Review Terms & Conditions

• Scheduling Reports & Receivables in GMAS

Federal and Non-federal Accounts

• Federal and Non-federal Accounts

• Financial Reporting, CAS Compliance

• Cost Transfers

• Aging Receivables

Policy Statement

• 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

Unreconciled Report

• Unreconciled Report

• Disabling Accounts

• Web Vouchers for Refunds

• Fixed Price and Surplus

• Transfers to Other Universities

OSP performs various functions related to accounts receivable 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:

• Account Reconciliation
• Management of award
• Submission of deliverables

Anticipate the project will be audited

• 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!

http://vpf-web.harvard.edu/osp/

• http://vpf-web.harvard.edu/osp/

• Questions?

OPPORTUNITIES FOR TRAINING IN SPONSORED PROGRAMS ADMINISTRATION

• University-Wide Sessions

• University Research Administration Training Committee (URATC)

• Currently offers periodic one-day sessions “Overview of Sponsored Programs Administration”

• Led by research administrators from various schools throughout the university

• Offers comprehensive training addressing the entire award lifecycle at Harvard

• For more information: [e-mail]