Office for Sponsored Programs

KSG / OSP Information Session

July 28, 2005

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Roles & Responsibilities

What do members of the OSP team do related to KSG sponsored research?

Responsibilities of OSP vs. Dept. vs. PI

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Considerations in Proposal Review

OSP will review the proposal for the following general criteria:

– Is it clear who is sponsoring the project? – Are the PI and other key personnel identified? – Is there a defined scope of work? – Does the budget make sense?

Current fringe rates Appropriate overhead rate Allowable costs Justification of all costs

– Are the core principles of our academic freedom and other key university research policies maintained with the proposal/award?

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Considerations in Proposal Review

Additional general criteria OSP reviews for:– Have the proper approvals been initiated? – Is there a dean’s approval form that the appropriate designated

local official has signed off on? Approvals are needed from all tubs involved

– Could someone not familiar with the project pick up the proposal and know what it is fairly easily?

OSP will also review against sponsor guidelines (e.g. font size, page limit, etc.) and advise PI of any potentially problematic issues, but will not edit or hold signatures based on such items (PI decides if/how to address these)

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Provost Review Criteria

OSP will also review for items that fall within the “Provost Criteria for Review” list:

– $ amount of request is 5M or more– Previous problems with sponsor– Degree to which the project deviates from Harvard’s existing

mission of teaching, research, and service (i.e. clinical care vs. basic research; clinical trials vs. basic research)

– Amount of int’l participation in project (particularly if there are foreign subcontractors)

– Relationship of project to current world events (State Dept List)– Mechanics within the program announcement that may deviate

from standard protocol (i.e. large federal project awarded in three weeks through an expedited review)

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Provost Review Criteria

“Provost Criteria for Review” list continued:– Anything about the project that would automatically trigger local

or national news coverage (i.e. non-approved human embryonic stem cells, any project studying terrorism, etc.)

– Any exceptions to current University research policy (i.e. publication restriction, clauses that threaten academic freedom or prohibit inclusion of foreign nationals)

– Previous issues/problems with a previous segment of the award– Extent to which the project may create genuine health/safety

risk to Harvard personnel– Project w/large number of subcontracts where vast majority of

work is not being conducted by Harvard

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Internal Approvals

Cost Sharing– http://vpf-web.harvard.edu/osr/proposal/prop_bud_sharing.shtml

Human Subjects in Research– http://www.fas.harvard.edu/~research/humsub.html

Participation Agreements– http://www.techtransfer.harvard.edu/ParticipationAgree.html

Other– Use of Animals in Research– Biohazardous Materials– Conflict of Interest

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OSP Review of Grant Award

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

– Reviews terms for consistency with proposal submitted Budget Project Dates Deliverables

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OSP Review of Grant Award

Reviews terms for compliance with University’s policies on sponsored research, including:

– Payment Terms– Acceptance of Deliverables– Use of Harvard’s Name– Intellectual Property

http://www.fas.harvard.edu/~research/greybook/patents.html   

– Publication Restrictions– PI Independence– Indemnification and Insurance

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Action Memos

When the Notice of Grant Award and related terms and conditions are accepted, the account activating the award is set up in the system and an action memo is generated, displaying the information representing this award.

– The PI, Dept. Admin, RAO, and OFS receive action memo

– Details the account number and award dates and dollars– Includes comments detailing the action type and other

relevant information

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OSP Roles & Responsibilities for Financial Reporting

University Policy & Procedures for Sponsored Financial Reporting: http://vpf-web.harvard.edu/osr/managing/man_fin_reporting.shtml

Generate Outstanding Report Schedule Prioritize all Billings and Federal Reports Send monthly reports to dept (Discontinued due to Crew)

– “Awards Ending in 4 Months”– “Award Ending 60 Days”

If required, send a draft of “Final Financial Report” for dept. review & approval

– 30-60 days after award ends– Includes only expenses posted to the GL

If no response 5 business days, notify dept./tub level manager

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OMB Circular A-21

http://www.whitehouse.gov/omb/circulars/a021/a021.html

NIH is cognizant agency Regulatory framework OMB Circulars

– A-110 Uniform Administrative Requirements– A-133 Audits– A-21 Cost Principles(Selection of Cost.J Section)

CAS DS-2

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OMB Circular A-21

Basic Considerations– Expenses must be Reasonable AND Allocable AND

Allowable Direct Costs

– Can be identified specifically with a sponsored project– Can be directly assigned to sponsored activities

Easily Highly accurately

– PI salaries– Travel costs– Lab supplies

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OMB Circular A-21

F&A Costs– F = Facilities (buildings, security)– A = Administrative (finance office, local telephone

service)– Incurred for common/joint objectives– Cannot easily & specifically ID with sponsored project– Examples:

Administrator’s salary Communications costs President,Provost and CFO’S Offices Building utility and maintenance cost.

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Department Roles and Responsibilities for Financial Reporting

Review monthly Outstanding Reports– Take necessary actions for extending/closing award. 

Complete account reconciliation process – Ensure all outstanding expenses have posted.– Ensure all expenses are allowable/allocable.– Reconcile to proposed budget– Remove any over expenditures.– Review Income and Interest Income

Review & Approve Final FSR and/or respond to OSP’s email for all post award issues 5 days.

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Department Roles and Responsibilities for Financial Reporting

Interim Reports– Most often done by OSP, but may require detail needing dept.

approval– Dept. may request to prepare Non Federal FSRs, subject to

OSP approval, prior to submission

Final Reporting– OSP works w/dept. on confirmation of final figures, approval of

expenses, and other related items

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Final Reporting

Most sponsors require a Final Financial Status Report 90

days after award ends. – Late FSR’s can result in loss of Expanded Authority, loss of LOC, delays

in award payments and/or loss of funding. If no report required, final review of expenditures is done by

OSP. Some final reports merely require confirmation of final figure by

the dept. Final Reports/Invoices that require a breakdown of expenses

by budget item/object code are prepared by OSP & approved by dept.

Other Reports: (Closeout Documents): OSP/Dept.– Cost share reports, completed by dept. – Assignment & Release forms,Patent &Property completed by OSP/Dept.

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Cost Transfers

Cost Transfer Policy– http://vpf-web.harvard.edu/osr/managing/

man_cos_transfer.shtml

Cost Transfer Presentation – http://vpf-web.harvard.edu/osr/support/cost_transfer/

sup_tra_cost.html

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Need

Federal regulations require that transfers to federally funded sponsored accounts be timely and properly documented

To demonstrate that adequate financial controls are in place, cost transfers should be kept to a reasonable minimum

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Under 90 days old

Cost transfers made within 90 days of the 15th of the month following that in which the original charge was recorded

– Transferred by journal entry at the departmental level– Accompanied by the Cost Transfer Explanation form with

questions 1 and 2 answered and signed as indicated– Journal explanation: “See related Cost Transfer form”– Documentation was sent to OSP for review and approval– Returned to originator for posting to GL

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Over 90 days old

Cost transfers made more than 90 days after the 15th of the month in which the original charge was recorded

– Transferred by journal entry at the departmental level– Accompanied by the Cost Transfer Form w/questions 1

through 4 answered and signed as indicated (Note: additional approvals required)

– Attach supporting documentation– Documentation sent to OSP for review and approval– ONLY granted in extenuating circumstances

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School/Unit Responsibilities

Each school or local unit should:– Ensure compliance with the University Cost

Transfer policy– Ensure cost transfer journals– Retain hard copies of all related documentation

in accordance with applicable record retention regulations

– Ensure that all personnel engaged in financial administration of federally funded accounts are familiar with the University Cost Transfer Policy

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OSP Responsibilities

OSP will:– Be available to assist in interpretation and

implementation of the University Cost Transfer Policy

– Train in the application of the Cost Transfer Policy

– Review cost transfers– Approve cost transfers