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Billing Agreements

Is it possible for a billing agreement to be issued from a non-sponsored source of funds, such as a gift account (a “non-sponsored billing agreement”)? If so, who is the appropriate contact?

It is possible for a billing agreement to be issued from a non-sponsored source of funds under similar circumstances as sponsored billing agreements but with variations in the process based on the specific circumstances.  Contact the SPA SRA assigned to your department for more information on non-sponsored billing agreements.

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In a sponsored billing agreement arrangement, who has the responsibility for compliance with the terms and conditions of the prime award and compliance requirements? How is this different from a subaward agreement?

A billing agreement does not flow down any of the terms of the prime award to the non-grantee institution; it is simply a mechanism whereby the grantee institution can reimburse the non-grantee institution for the salary and fringe of certain project personnel....

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When Harvard is issuing an outgoing sponsored billing agreement, should the individual be included on the Research Team in GMAS?

Yes. Since a subaward agreement is not being issued, compliance requirements are not being flowed down to the individuals’ payroll institution (see above).  Thus, individuals being paid through a billing agreement should remain on the Research Team in GMAS.  Please work with SPA to clear any approvals generated as a result (COI, Participation Agreement, and Human Research Participant Protection Training).
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What are the criteria for when use of a billing agreement is appropriate?

  • Harvard has an agreement with another institution (the affiliate hospitals, the Broad Institute, National Bureau of Economic Research (NBER)) that allows for and governs the joint appointment of faculty at the institutions.
  • PI with dual appointment status (or supporting staff member) receives salary exclusively from the non-grantee institution...
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What issues should I consider in situations that are not covered by a joint appointment?

The current recommendation is that these support staff sign the Risk and Release form.  OTD’s preference is that these individuals would also sign the Visitor’s IP Agreement; however, many of the institutions with whom we execute billing agreements would not be willing to sign off on the Visitor’s IP Agreement for their staff.  Thus, if there is the potential that the individual will be involved in the development of IP in the course of the project, a subaward agreement should be used in place of a billing agreement.
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I am preparing a research award budget which involves issuing a BA for an affiliate’s employee. Whose FB rates should be used when budgeting the individual’s salary and fringe? Who will recover F&A on the salary and FB for the employee?

Because the grantee institution will reimburse the non-grantee institution for both salary and fringe, fringe for the individual should be budgeted using the non-grantee institution’s rate.  For example, if an individual whose primary appointment is at BWH is...

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Will SPA process an outgoing sponsored billing agreement under an advance account or when continuation funding is anticipated but not yet received?

The risk of issuing a billing agreement is the theoretical equivalent of setting up Harvard personnel to be paid from the advance account.  However, there is the added element of the agreement being through an outside organization.  The risk of issuing the billing agreement under these circumstances should be evaluated on a case by case basis so that the department who administers the award can determine whether they are willing to accept the financial risk under the specific circumstances.
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What back-up documentation is needed in order for an outgoing sponsored salary billing agreement to be issued? What back-up documentation is needed in order for an incoming salary billing agreement to be approved and signed?

The assumption of the billing agreement guidance is that the personnel covered by the billing agreement will have been included in the budget and the grantee and non-grantee institution will have agreed that a billing agreement is appropriate at the time of proposal...

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What are the criteria for use of a billing agreement for trainees (BA4T) is appropriate?

A Billing Agreement is generally appropriate under the following circumstances in the case of a training award:

  • Trainee will have/has an appointment at the non-grantee institution.
  • The trainee’s Mentor has an appointment at the trainee’s institution (non-grantee) or the grantee...
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