Source: OSP Website

The PI and department/local level managing unit assume primary responsibility for ensuring transactions posted to sponsored accounts comply with: 

• The terms and conditions of the award
• Harvard policies
• Federal regulations 

The PI is responsible for confirming that transactions align with the scope of work and meet the requirements of allowability, allocability, reasonableness and consistency in the treatment of costs. The PI provides approval of transactions and coordinates the posting of transactions with the department/local level managing unit. The department/local level managing units provides regular and ongoing reconciliations of accounts to ensure sponsored expenditures are posted correctly.

Transactions on Federal awards are governed by “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; Final Rule” (Uniform Guidance), published by the Office of Management and Budget (OMB). Additionally, Federal contracts may be subject to the Federal Acquisition Regulations (FAR). 

Harvard must comply with the Cost Accounting Standards (CAS) located at 48 CFR 9905.501, 9905.502, 9905.505, and 9905.506. The purpose of the CAS is to ensure consistency in: 

• Estimating, accumulating and reporting costs (CAS 501) 
• Allocating costs incurred for the same purpose in like circumstances (CAS 502) 
• Accounting for unallowable costs (CAS 505) 
• Cost accounting periods (CAS 506)

The Harvard Sponsored Expenditure Guidelines is a resource for anyone responsible for managing sponsored funds. It provides guidance for appropriately budgeting expenditures of Federal or Non-Federal sponsored awards, whether they are directed toward research, training, or other purposes. The guidance helps with assessing the allowability, allocability, reasonableness, and consistent application of expenditures to ensure compliance with Federal regulations and sponsor requirements.