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KSG/OSP Training and Information Session. May 17, 2007. Overview: Agenda. Welcome - Stew Uretsky Kennedy School Sponsored Programs Overview - Matt Alper University Office for Sponsored Programs Overview - Ethlyn O’Garro

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KSG/OSP Training and Information Session

May 17, 2007


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Overview: Agenda

Welcome - Stew UretskyKennedy School Sponsored Programs Overview - Matt Alper

University Office for Sponsored Programs Overview - Ethlyn O’Garro

Pre-Award Administration-Proposal review and submission - Charlene Arzigian

- Jen Mahoney -Negotiations - Sarah Holtz -- BREAK --    Post-Award Administration-A-21 Key Concepts, Effort Reporting, New Vacation Policy - Judy Ryan 

    -Cost Transfers, Financial Reporting, Award Closeout - Ana GarciaWrap-up and Final Questions


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Welcome: Sponsored Programs Management

Strong communication and coordination between the Research Centers and/or Departments, the Research Administration Office (RAO), the Office of Financial Services (OFS), and the Office for Sponsored Programs (OSP) is essential.

Financial Reporting

Effort Reporting

Cost Transfers

Negotiations

OSP

RAO

RC/ Dept

Audits

Gift vs. Grant

Award Close-Out

Sponsored Payment

OFS

Proposal Development

Proposal Review & Submission


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About OFS: Who We Are

Associate Executive

Dean & CFO

Stewart Uretsky

Staff Assistant

Marita Terefenko

Associate Director for

Financial Operations

Connie Mugnai

Assistant Director of

Planning & Systems

Nancy Guisinger

Assistant Director of Finance

Kelly Boyle

Financial Analyst

Heather Fusco

Accounting Associate

John Caetano

Faculty Awards

Accounting Associate

Rashida Nisbett

Financial Analyst

Jeff Hudson

Accounting Assistant

Wanda Grady

IOP, WAPPP & CPL

Accounting Assistant

Edna Pierre

Financial Analyst

Lorraine Kiley

Accounting Assistant

Elaine Romano

OSP Liaison; SPOC

All other KSG Centers



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KSG SPONSORED PROPOSALSFY 2002 – FY 2006


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KSG SPONSORED PROPOSALS SUBMITTEDFY 2003 – FY 2007 (Q1-Q3) OVERVIEW


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KSG SPONSORED PROPOSALSFY 2003 – FY 2006 OVERVIEW


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KSG SPONSORED PROPOSALSFY 2002 – FY 2006


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KSG SPONSORED PROPOSALSFY 2002 – FY 2006

* Yield Rate refers to new funded awards as a percentage of all new proposals submitted in a given fiscal year.


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KSG TOTAL SPONSORED PROGRAM EXPENDITURESFY 2003 – FY 2007 (Projected)

* These data reflect only those proposals submitted and awards accepted by OSP; the percent change from the prior fiscal year is indicated.


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Q: Is this a “Gift” or is it a “Sponsored Agreement?”

Gifts- administered via Harvard University Recording Secretary’s Office (RSO)

  • In general, a gift does not have terms that specify how the funding must be spent.

  • The funding received may be utilized at the full discretion of the recipient.

  • Unexpended funds not returned to the donor at the expiration of the gift period.

  • Financial reporting, if any, is limited, and for donor stewardship purposes only.

    Sponsored Agreements (administered as grants, contracts, or cooperative agreements through OSP) - typically have one or more of the following:

  • Scholarly terms or Statement of Work to define line of scholarly/scientific inquiry.

  • Formal deliverables such as annual progress reports or performance objectives.

  • Specified terms regarding fiduciary responsibility or payment contingencies.

  • Specified terms regarding disposition of property (including intellectual property) upon conclusion of the project.

  • Proposal typically submitted in a sponsor-required format.


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Q: If this looks like a Gift, where do I turn for help? Agreement?”

A: The KSG Gifts Policy Committee (GPC)!

Q: Great! What the heck is that?

The GPC includes senior representatives of the KSG Financial Services, External Affairs, and Research Administration Offices. The GPC meets regularly and advises the Dean, Academic Dean, Executive Dean, Centers, and faculty on financial and administrative matters related to selected gift opportunities.

The GPC is charged with reviewing certain gift proposals and term sheets, and advising the Dean and others on questions of donor affiliation and stewardship, financial analysis, connection to and consistency with the KSG mission, and other risk management or compliance-related concerns.

Q: Sounds great. How do I find out more?

A: Glad you asked. For more information, see: http://www.ksg.harvard.edu/research/gifts_policy.htm


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About OSP: Who We Are Agreement?”

VP for Finance

Beth Mora

Director, OSP

Bev Simmonds

Director, Cost Analysis and Compliance

Judy Ryan

Business Process Training Specialist

Amy Maltzan/Victoria Wallace

Associate Director

Ethlyn O’Garro

Associate Director

Judy McSweeney

Grants.Gov Business Process Manager

Simone Alpen

Lifecycle Teams

Sponsored Programs Officer and Manager – Cash Management

Diane Harwood

Sponsored Programs Officer and Manager – FAS Life Sciences

Scott Blackwell

Sponsored Programs Officer and Manager – FAS Phys/Soc Sciences

Helia Morris

Sponsored Programs Officer and Manager – HMS

Min Xiao

Sponsored Programs Officer and Manager – SPH

Roseann Luongo

Sponsored Programs Officer and Manager – GSIA

Jen Mahoney

G&C Officers

Sr. Financial Analysts

Sr. G&C Specialists

G&C Specialists

Financial Analysts

Sponsored Programs Administrators

Sponsored Programs Coordinators

G&C Officers

Sr. Financial Analysts

Sr. G&C Specialists

G&C Specialists

Financial Analysts

Sponsored Programs Administrators

Sponsored Programs Coordinators

G&C Officers

Sr. Financial Analysts

Sr. G&C Specialists

G&C Specialists

Financial Analysts

Sponsored Programs Administrators

Sponsored Programs Coordinators

Sr. Financial Analysts

Financial Analysts

Sr. Financial Analysts

Financial Analysts

Financial Analysts


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About OSP: What We Do Agreement?”

  • Support effective management of awards throughout their lifecycle

  • Provide institutional signature on all University-area proposals

  • Receive, review and negotiate awards

  • Act as primary liaison with Sponsor, along with Principal Investigator (PI)

  • Assist in interpretation of policies; disseminate information on new policies

  • Provide institutional signature on all sponsored financial reports for entire University


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OSP GOALS/INITIATIVES Agreement?”

  • Operations/Data Integrity

  • Client Outreach

  • On-line Trainings

    GMAS

  • System of Record

  • Electronic Action Memos


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Proposal Development Agreement?”

ID Funding & Write Proposal

Institutional Clearances

Sponsor Review

Not Funded: Reviewers’ Comments and Resubmit

Funded: Award Terms & Conditions

Establish Project Account

Incur Award Expenses

Accounting and Monitoring

Request Additional Funding!

Sponsor Reports and Close-out

The Award Lifecycle and Related Policies

This diagram shows how the policies we’ll discuss in this session relate to the Award Lifecycle.

Submission Policy and Provost’s Review Criteria

Financial Reporting

Award Closeouts

Gifts vs. Grants

Effort Reporting

Cost Transfers

Direct Charging (OMB A-21)

UPAS


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Proposal Development Agreement?”

ID Funding & Write Proposal

Institutional Clearances

Sponsor Review

Funded: Award Terms & Conditions

Establish Project Account

Incur Award Expenses

Accounting and Monitoring

Request Additional Funding!

Sponsor Reports and Close-out

Submission Policy and Provost’s ReviewCriteria


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RAO Proposal Review Process Agreement?”

  • The Dean’s Approval Form (DAF) is the internal Harvard document that must be attached to all proposals.

  • The RAO reviews proposals for compliance with KSG and Harvard University policies and procedures. RAO obtains OFS approval of the budget and KSG approval of the proposal from the Academic Dean, via signatures on the DAF.

  • A fully-signed DAF represents KSG approval of a proposal and is required in order for OSP to submit a proposal.


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Elements of RAO Proposal Review Agreement?”

  • Proposal conforms with KSG and Harvard policies, and all applicable sponsor guidelines.

  • Budget is accurate, including salary, fringe benefit and overhead calculations.

  • All requested costs are reasonable and allowable, particularly on federal proposals where not all usual direct costs are allowable under A-21 regulations.

  • Overhead less than 20% requires approval by the Academic Dean.


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Elements of RAO Proposal Review Agreement?”

  • If use of human subjects is involved, what is status of approval?

  • Is cost-sharing involved, and if so, is a form required?

  • If there is direct charging of administrative salaries to federal grants, is a checklist completed?

  • Does proposal require approval of the KSG Faculty Committee on Projects and Proposals (FCOPP)?FCOPP is a senior faculty advisory committee to the Dean that assesses a subset of proposals for potential risks to the University, the School, and its faculty, staff and students.


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Items Likely to Complicate Proposal Review Agreement?”

Common Problems

  • Last-minute proposals

  • Lack of editing/proofreading by preparer

  • Inattention to University and sponsor budget guidelines, requirements, and instructions

  • Insufficient information provided to RAO/OSP, e.g., a copy of the program announcement or other instructions


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Items Likely to Complicate Proposal Review Agreement?”

Missing Items

  • Subcontractor participation without documentation

    of institutional commitment

  • Human subjects approval or exemption

  • Conflict of Interest Form

  • Approval of appropriate Dean(s) for faculty participation from other Harvard Schools


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Items Likely to Complicate Proposal Review Agreement?”

Budget Issues

  • Overhead shortfall (<20% ) issue not addressed and resolved

  • Incorrect fringe benefit rates

  • Salary and vacation fringe calculations incorrect

  • Inconsistencies between budget and budget justification/lack of budget justification or detail.


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Proposal Submission Agreement?”

  • Proposals receive final review and are formally submitted by duly authorized representatives of Harvard in OSP.

  • CAUTION! OSP is the only office authorized to submit proposals to external sponsors on behalf of the President and Fellows of Harvard College and its faculty members.

  • A PI can submit a proposal (which should be labeled as preliminary) directly to a non-federal sponsor, but it will not be considered a formal Harvard University proposaluntil it has been submitted through the KSG Dean's Approval process to OSP.


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Award Negotiation/Account Set Up Agreement?”

  • If a proposal is funded, OSP negotiates the terms and conditions of the award with the sponsor. RAO serves as liaison between OSP and Center/Program and is kept up to date on status of negotiations.

  • An Advance Account may be requested to set up an account string during award negotiation. This is done at the risk and request of the Center/Program.

  • When negotiations are complete, OSP accepts the award on behalf of the University and sets up an account for the award.


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OSP Staff Agreement?”

  • Sponsored Programs Officer and Manager – Jen Mahoney

  • Grants and Contracts Officer – Sarah Holtz

  • Sr. Grants and Contracts Specialist

    - Debby Dunlap

  • Sponsored Programs Administrator – Wendy Cazavelan

  • Financial Analysts

    - Leela Joseph

    - Ana Garcia


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Submission Policy: Timeline and Purpose Agreement?”

5/3 Day Memo from Steve Hyman and Beth Mora can be found on the ERA website: http://isites.harvard.edu/fs/docs/icb.topic38276.files/5daymemo.pdf

*Local dept./school review time not included

Timely proposals assured priority over late submissions which are reviewed after “on time” submissions in order received.


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Considerations in Proposal Review Agreement?”

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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Vice Provost for International Affairs Criteria Agreement?”

  • Review Criteria

    - Proposed budget exceeds KSG threshold

    $1.1 Million

    - Proposed project supports the establishment of any new international site

    - Proposed project is deemed unusual, complex or high risk

    - The project includes travel to countries on the Dept. of State Warning List

    http://travel.state.gov/travel/cis_pa_tw/tw_1764.html



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OSP Review of Grant Award Agreement?”

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

  • Reviews terms with PI and Department Administrators

  • Reviews terms for consistency with proposal submitted

    • Budget

    • Project Dates

    • Deliverables


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OSP Review of Grant Award Agreement?”

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

    • Payment Terms

    • Acceptance of Deliverables

    • PI Independence

    • Termination

    • Audit

    • Indemnification and Insurance

    • Use of Harvard’s Name

    • Intellectual Property

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

    • Publication Restrictions

    • Confidentiality

    • Anti-terrorism Language

    • Export Control


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OSP Review of Grant Award Agreement?”

  • Review of award terms may require input from:

    • Office of the Provost

    • Office of the General Counsel

    • Office of Technology Development

    • Risk Management and Audit Services


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OSP Review of Grant Award Agreement?”

Examples of Recent Issues

At Proposal Stage:

  • NSF/Department of Homeland Security: Students Supported by Project must be U.S. Citizens or Permanent Residents

    At Award Stage:

  • USAID and MacArthur Foundation: Compliance Plans for Checking Suspected Terrorist Lists

  • USAID: Requirement to have “Policy Opposing Prostitution and Sex-Trafficking”


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Intermission Agreement?”


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Proposal Development Agreement?”

ID Funding & Write Proposal

Institutional Clearances

Sponsor Review

Funded: Award Terms & Conditions

Establish Project Account

Incur Award Expenses

Accounting and Monitoring

Request Additional Funding!

Sponsor Reports and Close-out

Incur Award Expenses


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A-A-R-C Direct Cost Analysis Agreement?”

Allowability

Allocability

Reasonableness

Consistency

Conclusion

Does A-21 say this type of cost is allowable?

Does this item or activity specifically benefit the project?

Would a prudent person have paid this price?

Has this cost been double-counted as both a direct and indirect cost?

Is the cost allowable as a direct cost?


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May the cost of this item or activity be treated as a Agreement?”DIRECT cost?

A-A-R-C Direct Cost Analysis

Allowability

Does A-21 say this type of cost is allowable?

Allocability

Does this item or activity specifically benefit the project?

Reasonableness

Would a prudent person have paid this price?

Consistency

Has this cost been double-counted as both a direct and indirect cost?

Conclusion

Is the cost allowable as a direct cost?

Explicitly

NOT

Allowable

(e.g., J3. Alcoholic Beverages)

STOP

Reasonable Test:

Would a prudent person pay this price for this item or activity for the performance of the sponsored agreement?

If YES then the cost is Reasonable.

Consistency Test:

1. Have you used different practices for estimating costs in the proposal budget and for accounting/billing/

reporting costs?

2. Have you charged the same cost both indirectly and directly when it is incurred for the same purpose and circumstance?

If NO to both questions, then the cost passes the Consistency Test.

The cost is allowable as a direct cost in the measure to which it benefits the project

Allocability Test:

1. Was the cost incurred solely to advance the work under the sponsored agreement? If YES, then the cost is allocable.

2. Does the cost benefit the work under the sponsored agreement and other projects as well? If YES, then the cost must be allocated in the measure to which it benefited the work under the sponsored agreement and a written allocation plan must be in place.

Allowable as Direct Cost

(e.g., J31. Materials & Supplies)

NOT explicitly in

A-21

(e.g., Specific Gizmos)

Different Purpose & Circumstance Test:

1. Is this a non-federal grant?

OR

2.a. Can the cost be identified specifically with the project?

b. Is it required by the project’s scope?

c. Is it a line item in the proposal budget and included in the budget justification?

If YES to 1 or 2 ( all 3 questions), the cost is allowable and allocable as a direct cost.

Normally allowable only as an indirect cost

(e.g., F6. Departmental Administration)


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Federal and Non-Federal Agreement?”

  • 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


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Florida International Univ Agreement?”Effort Certification & Direct Costs$11.5 million

Johns Hopkins UnivEffort Certification$2.7 million

University of MinnesotaMisuse federal funds$32 million

Univ California/San Francisco

Animal Care Allegations$92,500 fine

New York University Medical CenterInflated research grant costs$15.5 million

Univ of Southern CaliforniaQuestioned Costs HHS/OIG Audit$400,000

Results of Non-Compliance: Significant Audits/Settlements

Mayo FoundationMischarging federal grants$6.5 million

East Carolina UnivQuestioned Costs HHS/OIG Audit$2.4 million

Cornell MedicalClinical Research Issues$4.4 million

Univ Alabama/BirminghamEffort Certification & Clinical Research Billing$3.4 million

Harvard/BIDMC

Costing Issues Self-Reported$3.25 million

Northwestern University

Committed Time/Effort

$5 million


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Sub-recipient Monitoring Agreement?”

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.


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Sub-recipient Monitoring Agreement?”

  • As prime grantee, KSG 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


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Effort Reporting Policy Agreement?”

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


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Effort Reporting: Here at Harvard Agreement?”

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

    KSG Monthly Salary Certification for Research Staff:

    http://www.ksg.harvard.edu/ofs/policies_procedures/research.htm


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Proposal Development Agreement?”

ID Funding & Write Proposal

Institutional Clearances

Sponsor Review

Funded: Award Terms & Conditions

Establish Project Account

Incur Award Expenses

Accounting and Monitoring

Request Additional Funding!

Sponsor Reports and Close-out

Cost Transfers


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Cost Transfers – Policy Overview Agreement?”

Cost Transfer Policy can be found in the Policies section of the OSP website:

http://vpf-web.harvard.edu/osr/managing/man_cos_transfer.shtml

Definition: A cost transfer is a transfer to a federally funded sponsored account of a charge previously recorded elsewhere.


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Cost Transfers – Purpose of Policy Agreement?”

  • Federal regulations require that transfers to federally funded sponsored accounts be timely and properly documented (see OMB Circular A21 section C 4 (b))

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

  • Late, frequent, and inadequately explained cost transfers:

    • Suggest poor financial management

    • Lead to questions on the overall reliability of KSG’s internal controls and accounting systems

    • Cause audit issues

  • Monthly monitoring of accounts using the Period Expense Report and Detail Listing is encouraged to identify incorrectly allocated expenses


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Cost Transfers – Policy Overview Agreement?”

  • The policy addresses ALL debit transfers to Federal Awards that were previously recorded elsewhere

    • Cost transfers are identified by a journal naming convention, the journal name starts with “CT”

      • Example: “CT STA Allocate glass washing OCT-04”

    • The description field of a CT journal indicates that a CT form has been processed or the reason why a CT form is not required is identified

  • Different procedures are followed for cost transfers made under 90 days and over 90 days from the 15th of the month following that in which the original charge was recorded

  • There are also special categories of cost transfers that require only a journal entry – see the Cost Transfer policy for more information on these

    Situations that DO NOT allow for Cost Transfers:

    • “Zeroing Out” accounts

    • Solve funding problems

    • Meet deficiencies caused by cost overruns

    • Balancing the budget

    • Shifting costs to avoid budget restrictions


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Cost Transfers Under 90 Days Agreement?”

  • Example

    Original charge posted September 4th

    • 90 days counted from October 15th

    • Cost Transfer should be transacted on or before January 12th

  • 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 departmental level

    • Accompanied by the Cost Transfer Explanation Form with questions 1 and 2 answered and signed as indicated

    • Journal description: “See related Cost Transfer form”

    • Documentation sent to OSP for review and approval

    • Returned to originator for posting to GL and retention with other accounting records


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CT Explanation and Justification Form Agreement?”

Valid explanations should include:

Question 1

  • Description of expense being transferred (include why and when original charge occurred)

  • Why the expense was originally charged incorrectly

    Question 2

  • Why expense(s) is allowable on the receiving account (direct benefit to the receiving account)

    Would an outside auditor reviewing the Cost Transfer Explanation & Justification Form 3 years from now understand the cost transfer ?


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Cost Transfers Over 90 Days Agreement?”

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

ONLY GRANTED IN EXTENUATING CIRCUMSTANCES

NOT EXTENUATING CIRCUMSTANCES:

  • Absence of

    • Principal Investigator

    • Responsible administrator

  • Shortage of staff

  • Lack of experience of staff

    EXTENUATING CIRCUMSTANCES:

  • Late issuance of an Action Memo (45 day limit!)

  • Late issuance of a notice of grant award

  • Failure of another department to take action

    NOTE: ALL CT FORMS REQUIRE SUPPORTING DOCUMENTATION


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Cost Transfers Over 90 Days Agreement?”

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

  • Transferred by journal entry at departmental level

  • Accompanied by the Cost Transfer Explanation Form with questions 1 - 4 answered and signed as indicated

  • Journal description: “See related Cost Transfer form”

  • Documentation sent to OFS for review and approval

  • Forwarded by OFS to OSP for signature

  • Returned by OSP to originator for posting to GL and retention with other accounting records


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Cost Transfers – Roles & Responsibilities Agreement?”

Center/Department:

  • Ensure compliance with the University Cost Transfer Policy

  • Complete/enter draft cost transfer journals

  • Complete cost transfer package and forward to OSP (under 90 days) or OFS ( over 90 days)

  • 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

    OFS:

  • Review cost transfers over 90 days to ensure compliance with University Cost Transfer Policy

  • Provide required Financial Dean signature, if all criteria are met

  • Forward signed form to OSP, retain copy of cost transfer documentation in appropriate fund file

  • If necessary, upload journal entry when cost transfer is approved

    OSP:

  • 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


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Proposal Development Agreement?”

ID Funding & Write Proposal

Institutional Clearances

Sponsor Review

Funded: Award Terms & Conditions

Establish Project Account

Incur Award Expenses

Accounting and Monitoring

Request Additional Funding!

Sponsor Reports and Close-out

Financial Reporting


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Sponsored Financial Reporting Policies Agreement?”

The University Policy and Procedures for Sponsored Financial Reporting can be found at:

http://vpf-web.harvard.edu/osr/managing/man_fin_reporting.shtml

Policy Objectives:

  • Clarify reporting roles and responsibilities

  • Identify which expenses will be included on financial reports

  • Reduce number of unreconciled accounts and revised Financial Reports

  • Develop consistent reporting practices across departments


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OSP Responsibilities in Financial Reporting Agreement?”

  • Each month, the OSP Financial Analysts run the “Scheduled Reports” in CREW identifying which financial reports and invoices are due within next 30-90 days

  • Review and prioritize outstanding financial reports list and communicate with departments for upcoming reporting deadlines, including annual reports or final invoices for the budget periods

  • Draft periodic invoices or reports and submit directly to sponsors

  • Draft final Financial Status Reports (FSRs) or final invoices based on latest PER figures and send to department for review

  • Work with department to resolve various issues and prepare necessary adjustments ( remove unallowable transactions, over spent or under spent, carry forward, overhead etc. )

  • Submit FSR to sponsor before deadline


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Center/Program Responsibilities in Financial Reporting Agreement?”

  • Each month, the departmental administrators should run the “Segments” report in CREW identifying those awards with anticipated end dates within next 120 days

  • Ensure all outstanding expenses have posted (e.g. web vouchers from affiliates, salaries, subcontract final invoices etc.)

  • Review expenses for cost compliance - remove any unallowable/non-allocable charges (contact OSP for cost transfer issues)

  • Remove any over-expenditures and reconcile to budget

  • Review and approve draft FSR (5 business days)


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Federal and Non-Federal Reporting Agreement?”

  • Types of Federal Reports:

    • SF 269 Financial Status Report (FSR)

    • SF 272 Federal Cash Transactions Report

    • SF 270 Request for Reimbursement

    • SF 1034/1035 Voucher for Reimbursement

  • NIH typically requires SF 269

  • Non-federal reporting requirements vary by sponsor, as a result the reporting format/template may differ


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Reporting Roles & Responsibilities Agreement?”

*Dept responsible for final reconciliation


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Proposal Development Agreement?”

ID Funding & Write Proposal

Institutional Clearances

Sponsor Review

Funded: Award Terms & Conditions

Establish Project Account

Incur Award Expenses

Accounting and Monitoring

Request Additional Funding!

Sponsor Reports and Close-out

Award Closeouts


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Closeout of Sponsored Accounts Agreement?”

Information can be found on the OSP website:

http://vpf-web.harvard.edu/osr/closing/clos_how_award.shtml

  • Prudent financial management of sponsored accounts includes timely and accurate reporting and account/award close out. These functions are tested as part of the annual OMB A-133 audit as well as by other sponsoring agencies when they make periodic visits to Harvard.

  • Approximately 60 days prior to the expiration of the project account, the OSP Financial Analyst will contact the local unit regarding the status of the account. The administrator should ensure that all project costs are appropriately charged to the account. As the project nears termination it is important to review all costs and clear those which are unallowable or inappropriate to this account.


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Considerations w/Account Closeout and Disabling Agreement?”

  • GMAS monthly automatic disabling process

  • Activity-Subactivity Disabling: GL expenses = GL income = Final Figure

  • Segments Close-out in GMAS (manually)

  • Funds Disabling automatically

  • If problems arise, OSP team member will work with department administrators to resolve issues


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Potential Problems with Disabling Agreement?”

  • Expenses posted in the current month

  • Invalid code combinations

  • Charges to non-sponsored funds and sponsored activity/subactivity

    • Cost sharing

    • Work study

    • Travel advances



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Additional Materials Agreement?”


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OMB A-21 Key Concepts Agreement?”

  • 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.


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ALLOWABLE Agreement?”Costs:

OMB A-21 Key Concepts

  • 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


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ALLOCABLE Costs: Agreement?”

OMB A-21 Key Concepts

  • 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.


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REASONABLE Costs: Agreement?”

OMB A-21 Key Concepts

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


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CONSISTENCY: Agreement?”

OMB A-21 Key Concepts

  • 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.

OMB A-21 Appendix A - Cost Accounting Standards 9905.501 and 502


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Case 1 Agreement?”

Case 1: Administrative salaries

The Facts:

Professor Academia is writing a proposal to the NIH for an Obesity Project involving human subjects. She’d like to have an administrator to provide support for the Obesity Project. Here are the tasks she’s thinking of assigning to the new hire:


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Case 1 Agreement?”

Proposed Obesity Project administrator tasks (abbreviated):

  • Proposal preparation

  • Coordinating human subjects

  • Project Survey preparation (administrative)

  • Arranging travel to a conference on obesity

  • Course and committee materials

  • Food for weekly lab meeting

  • Filing/keeping desk in order

  • Administering a journal

  • Work related to “Education and Obesity”


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Case 1 Agreement?”

The Issue

May Professor Academia put some or all of the admin’s compensation on the proposed Obesity Project budget?

In other words…

Which of the listed tasks would constitute allowable effort on the Obesity Project?


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Case 1 Agreement?”

ALLOWABILITY Summary of Conclusions:


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Case 1 Agreement?”

CONCLUSION:

  • Salary and fringe equal to the proportion of an administrator’s time spent finding and coordinating human subjects, preparing the survey, and arranging travel to the obesity conference may be charged to the grant (i.e., they’re ALLOWABLE), provided that:

    • The proportion is at least 25% of an FTE; and,

    • The salary and fringe are a specific line item in the proposal budget and discussed in the budget justification.


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Case 1 Agreement?”

But what do I do with the rest of the administrator’s salary and fringe?

  • Determine whether his or her effort spent on other projects passes the A-A-R-C analysis (i.e, it is allowable as a direct expense on another grant.)

  • Charge remaining amounts to the appropriate departmental account.


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Case 2 Agreement?”

Case 2: Computers and Communications

The Facts:

Professor Moose just received funding from the USAID to do field work in a Distant Land on the Far Away Project. He and his research staff will be collecting data at the Project site and analyzing it there and here in Cambridge. Professor Moose often uses his cell phone to stay in contact with his research staff in the field and with collaborators on the Far Away Project. He also does a significant amount of his work by email from his home computer, in part because of the time difference between Cambridge and the site of the Far Away Project, and would like to charge the costs of his Internet service to the Project award. He’d like to charge the costs of the following items or activities directly to his Project grant.


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Case 2 Agreement?”

Proposed charges to the Far Away Project:

  • a laptop computer to take with him to record data in the field

  • a desktop computer for his lab (it’ll sit in the open, common area of his lab so his post-docs and students have access to it) for analyzing results using a special software program, once he returns from the field

  • the specialized software

  • the cell phone and monthly cell phone service fees, including roaming charges

  • the costs of his home Internet service


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Case 2 Agreement?”

The Issue

May Professor Moose put some or all of his computer and communications charges on the proposed Far Away Project budget?


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Case 2 Agreement?”

ALLOWABILITY Summary of Conclusions:


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Case 2 Agreement?”

CONCLUSIONS:

  • If Professor Moose purchases a laptop specifically for the purpose of advancing (benefiting) the work of the Far Away Project, then the item is “readily identified specifically with the project with a high degree of accuracy” and its full cost may be allocated to the Project. To treat its cost as a direct charge, he should include the cost of laptop in the proposal budget under “Materials and Supplies” and describe it in the budget justification.

  • The entire cost of the specialized software is allowable as a direct cost because it was incurred solely to advance the work under the Far Away Project.


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Case 2 Agreement?”

But what do I do with the costs of computers and communications that are not allowable as direct charges on the Project?

  • Charge them to the appropriate departmental account, unless they are personal expenses, which should be covered by the individual faculty member.


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