Transcript Document

Office for Sponsored Programs
KSG / OSP Information
Session
July 28, 2005
Roles & Responsibilities
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What do members of the OSP team do
related to KSG sponsored research?
Responsibilities of OSP vs. Dept. vs. PI
Considerations in Proposal Review
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OSP will review the proposal for the
following general criteria:
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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?
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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?
Considerations in Proposal Review
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Additional general criteria OSP reviews for:
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Have the proper approvals been initiated?
Is there a dean’s approval form that the appropriate designated
local official has signed off on?
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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)
Provost Review Criteria
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OSP will also review for items that fall within
the “Provost Criteria for Review” list:
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$ 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)
Provost Review Criteria
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“Provost Criteria for Review” list continued:
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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
Internal Approvals
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Cost Sharing
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Human Subjects in Research
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http://www.techtransfer.harvard.edu/ParticipationAgree.html
Other
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http://www.fas.harvard.edu/~research/humsub.html
Participation Agreements
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http://vpf-web.harvard.edu/osr/proposal/prop_bud_sharing.shtml
Use of Animals in Research
Biohazardous Materials
Conflict of Interest
OSP Review of Grant Award
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Before accepting an award on behalf of the
University, OSP reviews all terms and
conditions in an award
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Reviews terms for consistency with proposal submitted
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Budget
Project Dates
Deliverables
OSP Review of Grant Award
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Reviews terms for compliance with
University’s policies on sponsored research,
including:
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Payment Terms
Acceptance of Deliverables
Use of Harvard’s Name
Intellectual Property
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http://www.fas.harvard.edu/~research/greybook/patents.html
Publication Restrictions
PI Independence
Indemnification and Insurance
Action Memos
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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.
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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
OSP Roles & Responsibilities for Financial
Reporting
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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)
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If required, send a draft of “Final Financial Report” for dept.
review & approval
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“Awards Ending in  4 Months”
“Award Ending  60 Days”
30-60 days after award ends
Includes only expenses posted to the GL
If no response  5 business days, notify dept./tub level
manager
OMB Circular A-21
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http://www.whitehouse.gov/omb/circulars/a021/a021
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NIH is cognizant agency
Regulatory framework
OMB Circulars
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A-110 Uniform Administrative Requirements
A-133 Audits
A-21 Cost Principles(Selection of Cost.J Section)
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CAS
DS-2
OMB Circular A-21
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Basic Considerations
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Expenses must be Reasonable AND Allocable AND
Allowable
Direct Costs
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Can be identified specifically with a sponsored project
Can be directly assigned to sponsored activities
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Easily
Highly accurately
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PI salaries
Travel costs
Lab supplies
OMB Circular A-21
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F&A Costs
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F = Facilities (buildings, security)
A = Administrative (finance office, local telephone service)
Incurred for common/joint objectives
Cannot easily & specifically ID with sponsored project
Examples:
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Administrator’s salary
Communications costs
President,Provost and CFO’S Offices
Building utility and maintenance cost.
Department Roles and Responsibilities
for Financial Reporting
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Review monthly Outstanding Reports
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Complete account reconciliation process
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Take necessary actions for extending/closing award.
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.
Department Roles and Responsibilities
for Financial Reporting
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Interim Reports
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Final Reporting
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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
OSP works w/dept. on confirmation of final figures, approval of
expenses, and other related items
Final Reporting
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Most sponsors require a Final Financial Status Report  90
days after award ends.
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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.
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Late FSR’s can result in loss of Expanded Authority, loss of LOC, delays
in award payments and/or loss of funding.
Cost share reports, completed by dept.
Assignment & Release forms,Patent &Property completed by OSP/Dept.
Cost Transfers
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Cost Transfer Policy
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Cost Transfer Presentation
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http://vpf-web.harvard.edu/osr/managing/man_cos_transfer.shtml
http://vpfweb.harvard.edu/osr/support/cost_transfer/sup_tra_cost.html
Need
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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
Under 90 days old
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Cost transfers made within 90 days of the 15th of
the month following that in which the original charge
was recorded
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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
Over 90 days old
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Cost transfers made more than 90 days after the
15th of the month in which the original charge was
recorded
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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
School/Unit Responsibilities
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Each school or local unit should:
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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
OSP Responsibilities
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OSP will:
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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