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

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

2. 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 AdministrationProposal review and submission - Charlene Arzigian, HKS; Helia Morris, OSP -- BREAK --��� Award Negotiations - Sarah Holtz, OSPPost-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

3. Office for Sponsored Programs (OSP) Ethlyn O�Garro Director, Sponsored Programs Administration

4. 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

5. 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

6. Pre Award Administration Post Award� All OSPPre Award Administration Post Award� All OSP

7. Harvard UniversityPost-AwardAdministration Pre Award Administration Post Award� All OSPPre Award Administration Post Award� All OSP

8. 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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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

15. 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)

16. Questions?

17. HKS Sponsored Proposals By Sponsor Type

18. HKS Sponsored Proposals OverviewFY 2006-FY 2008

19. HKS Sponsored Proposals Submitted

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

22. 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

23. 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

24. Questions?

25. About RAO: Who We Are

26. 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

27. Finding Funding Funding opportunity distribution via email Custom searches Funding opportunity table on ResearchCentral Managed by: Jody Blackwell Research Communications Coordinator

28. 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 sponsorManaged by: Martha Goldberg Research Administration Coordinator

29. 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) �

30. 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

31. 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

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

33. Award Lifecycle

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

35. 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/researchcentral.htm OSP Website: http://vpf-web.harvard.edu/osp/ Internal approval forms are called: Dean�s Approval Form (FAS & most Cambridge area schools) Proposal Routing Form (HMS & HSDM) Transmittal Form (HSPH) Importance of signatures implication of non-compliance Should review the transmittal form Tell people why this approval is important PI is not authorized to submit proposalsInternal approval forms are called: Dean�s Approval Form (FAS & most Cambridge area schools) Proposal Routing Form (HMS & HSDM) Transmittal Form (HSPH) Importance of signatures implication of non-compliance Should review the transmittal form Tell people why this approval is important PI is not authorized to submit proposals

36. Institutional Approval 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 Your local central sponsored programs office is generally responsible for ensuring that these are submitted to the sponsor. They will work closely with the department to make sure this happens. May include other Institutional assurances required by sponsor such as Debarment and Suspension Lobbying Delinquent on Federal Debt Your local central sponsored programs office is generally responsible for ensuring that these are submitted to the sponsor. They will work closely with the department to make sure this happens. May include other Institutional assurances required by sponsor such as Debarment and Suspension Lobbying Delinquent on Federal Debt

37. 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! Regardless of electronic of paper, central admin still needs to sign off Examples: Fastlane (NSF) NSPIRES (NASA) Grants.gov Regardless of electronic of paper, central admin still needs to sign off Examples: Fastlane (NSF) NSPIRES (NASA) Grants.gov

38. 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 Gold stars are given for proposals submitted on time! Why it�s important to submit on-time � Risks Rejection Warnings and errors Quality of proposals Heavy volume Quality of review Emergencies/Catastrophes happen � plan ahead! Ex. Internet failure (MIT), floods (HMS), fire (HC) War Stories ---what is the worst that can happen if something is not submitted within the internal deadlines Suggestions on how to ensure that proposals are submitted time (KWM) 1 minute late = late/rejected proposal Gold stars are given for proposals submitted on time! Why it�s important to submit on-time � Risks Rejection Warnings and errors Quality of proposals Heavy volume Quality of review Emergencies/Catastrophes happen � plan ahead! Ex. Internet failure (MIT), floods (HMS), fire (HC) War Stories ---what is the worst that can happen if something is not submitted within the internal deadlines Suggestions on how to ensure that proposals are submitted time (KWM) 1 minute late = late/rejected proposal

39. 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?

40. 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 1] LOI, Scope of Work, Budget with justification, contract and debarment information, non-discrimination form if NSF prime. [2] School, PI, Org Depart. Administration, record of approval from department. [3] Provide the Sponsor�s Institutional Information and Secure approval to submit. 1] LOI, Scope of Work, Budget with justification, contract and debarment information, non-discrimination form if NSF prime. [2] School, PI, Org Depart. Administration, record of approval from department. [3] Provide the Sponsor�s Institutional Information and Secure approval to submit.

41. 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?

42. 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?

43. 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!

44. Questions?

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

46. 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

47. 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)

48. 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.

49. 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. International Sponsors: Often try to require Harvard to have an independent audit of project expenditures.

50. 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)

51. Questions?

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

53. 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

55.  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

56. 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

57. 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

58. 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

59. 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

60. 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

61. 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)

62. 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

63. 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

64. 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

65. 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

66. REASONABLE Costs: A cost that a prudent person would have incurred under the circumstances prevailing when the purchase was made

67. 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

68. Questions?

69. Office for Sponsored Programs (OSP) Post Award Financial Management Judy McSweeney Director, Financial Services Ana Garcia Senior Financial Analyst

70. 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 Judy Judy

71. 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 JudyJudy

72. 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 Ana Ana

73. REPORTING FY08

74. 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

75. Reporting-Continued Types of Federal Reports SF 269 SF 272 SF 270 Types of Non-Federal Reports Non-Federal Reports vary by sponsor

76. Harvard University Standard Invoice

77. INFORMATION MANAGEMENT Transition from pre-award to post-award Action Memos Review Terms & Conditions Scheduling Reports & Receivables in GMAS Intro to AwardIntro to Award

78. Scheduling Reports in GMAS

79. ACCOUNT MONITORING Federal and Non-federal Accounts Financial Reporting, CAS Compliance Cost Transfers Aging Receivables

80. CAS COMPLIANCE(Cost Accounting Standards)

81. 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

82. AWARD CLOSEOUT Unreconciled Report Disabling Accounts Web Vouchers for Refunds Fixed Price and Surplus Transfers to Other Universities

83. 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: Account Reconciliation Management of award Submission of deliverables Federal: usually reimbursed Non-Federal: usually pre paid Cost Reimbursable: Department spends, expenses incurred on the GL OSP Invoices either monthly, quarterly, etc. based on GL expenses per fund Sponsor reimburses Harvard upon receipt of invoice OSP Cash Team receives check and money is deposited in specific fund Fixed Price: Sponsor and Harvard negotiate a payment schedule Schedule usually tied to deliverable, but doesn�t have to be OSP invoices based on payment schedule; checks with Department if tied to deliverable Sponsor reimburses Harvard upon receipt of invoice OSP Cash Team receives check and money is deposited in specific fund Federal: usually reimbursed Non-Federal: usually pre paid Cost Reimbursable: Department spends, expenses incurred on the GL OSP Invoices either monthly, quarterly, etc. based on GL expenses per fund Sponsor reimburses Harvard upon receipt of invoice OSP Cash Team receives check and money is deposited in specific fund Fixed Price: Sponsor and Harvard negotiate a payment schedule Schedule usually tied to deliverable, but doesn�t have to be OSP invoices based on payment schedule; checks with Department if tied to deliverable Sponsor reimburses Harvard upon receipt of invoice OSP Cash Team receives check and money is deposited in specific fund

84. 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! Remember we�re held to Harvard policy� not just sponsor and federal policiesRemember we�re held to Harvard policy� not just sponsor and federal policies

85. Office for Sponsored Programs (OSP) http://vpf-web.harvard.edu/osp/

86. Questions?

87. 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: RASLearn@fas.harvard.edu On-Line Modules (via OSP website to Eureka! training modules) Sponsored Programs Administration Overview Course length: 30 minutes The Regulatory Environment Course length: 45 minutes Cost Principles Course length: 1 hour Access through OSP website: http://vpf-eb.harvard.edu/osp