Administrative and Clerical Salaries on Federal Awards

Administrative and clerical salaries charged improperly to federal awards result in unallowable costs, requiring reimbursement to the government and, depending on severity, additional penalties for Harvard University. See Appendix A for detailed procedures.

Subject Matter Resource:  Your SRA

Cost Sharing

Cost sharing is funded by Harvard or a third-party, which is generally a non-federal resource.  Harvard strongly discourages cost sharing, unless such a commitment is required by the federal or non-federal sponsor. All committed cost sharing must be tracked and adhere to the same accounting, financial, legal, and regulatory requirements as direct cost expenditures on sponsored awards, federal/non-federal sponsored award terms and conditions, federal regulations including restrictions for procurement and airfare, University and school/tub-level sponsored policies and guidelines, donor restrictions.

Subject Matter Resource: Kristie Froman

Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR)

This guidance is applicable to faculty and investigators at the University who participate in an SBIR or STTR collaboration in which they have a significant financial interest, such as serving as a co-founder or having an equity interest in the small business collaborator. Each of the School’s Conflict of Interest Officer shall manage conflict in accordance with the School’s policies and procedures.

Subject Matter Resource:  Your SRA

Gift vs Sponsored Research Policy

The University must manage all funds received in accordance with applicable federal, state, and local laws, and with the specific terms and conditions of any gift, grant or contract. The University’s approval, negotiation and agreement processes and mechanisms, accounting, budget practices, oversight, and compliance practices differ depending on whether funds received are categorized as a gift or as a sponsored award.

Subject Matter Resource: Your AD

Harvard University Financial Guidance on Fixed Price Sponsored Awards

Fixed price sponsored awards are awards in which an agreed upon set price is determined for the project to be accomplished.  Principal Investigators (PIs) and administrators must prepare accurate, detailed proposal budgets, and costs associated with the fixed price sponsored award to fully capture all resources necessary for the work performed on the project.   The University guidance addresses what happens when the project exceeds the awarded amount or the project is performed at a cost below the awarded amount.  The Harvard Chan School Procedure for Fixed Price Balances details the business process that must be followed during the closeout if there is a balance at the end of the fixed price award.

Subject Matter Resource:  Your AD

Harvard Chan School Effort Management Policy

Making and keeping responsible commitments on sponsored projects (page 2 of policy)

An effort commitment represents the sponsor’s understanding of the amount of time the researcher will need to devote to accomplish the project’s aims. This understanding is established via the proposal or other written documents exchanged between the business official in SPA and the sponsor. When making commitments on federal proposals, researchers should keep in mind that the government is explicit in their expectation that the commitment be a reasonable estimate:

The applicant organization is responsible for verifying its eligibility and the accuracy, validity, and conformity with the most current institutional guidelines of all the administrative, fiscal, and scientific information in the application, including the Facilities and Administrative rate. Deliberate withholding, falsification, or misrepresentation of information could result in administrative actions, such as withdrawal of an application, suspension and/or termination of an award, debarment of individuals, as well as possible criminal and/or civil penalties. The signer further certifies that the applicant organization will be accountable both for the appropriate use of any funds awarded and for the performance of the grant-supported project or activities resulting from this application. The grantee institution may be liable for the reimbursement of funds associated with any inappropriate or fraudulent conduct of the project activity. (SF-424 R&R Application Instructions, page G -47

The PI’s signature on the proposal in GMAS represents their concurrence with this language. Although sponsor policy may allow effort changes, all researchers and grant managers should keep in mind the certification language above before making substantive changes in effort regardless of key person status

Subject Matter Resource:  Kristie Froman

Independent Contractors Policy

A worker providing services to the University must be properly classified as either an employee or an independent contractor.  If a worker is classified as an independent contractor, all supporting documentation referenced in the policy must be completed and signed before services are rendered. 

Subject Matter Resource: Your Human Resources Partner

International Projects Guidance

This resource provides faculty and administrators with clear, simple guideposts for international projects, including the policies, guides and contacts at Harvard to learn more.  Due to the complexities associated with international projects, you should always consult with your local research administrator and/or one of the offices listed in the International Project Planning Considerations document regarding potential and proposed projects abroad - the earlier, the better.

Subject matter resource:  Your AD and Harvard Global Services

Late Proposal Notification Policy (formerly Proposal Submission Deadline Policy or Exception Request Policy)

This policy is designed to ensure optimal customer service for PIs and smooth, error-free proposal submission while providing the SPA office and the Provost's office with adequate time to identify, assess and mitigate compliance risks for the PI and the School.

To effectively manage the review and submission process on behalf of faculty, the following Harvard Chan School policy must be adhered to:

• 10 business days out from Sponsor Due Date, by 10am EST: Draft of application (including sub materials) is due from PI to GM.
• 7 business days out from Sponsor Due Date, by 10am EST: Final Application is due from GM/ADF to SRA. RPPRs and Subaward applications are due from PI to GM.
• 5 business days out from Sponsor Due Date, by 10am EST: Final versions of RPPRs and Subaward applications are due from GM/ADF to SRA.

Sponsors often limit applications for a grant or fellowship by instructing universities to nominate only one or a small number of candidates. This requirement places the task of selection of the nominee(s) on us. The eligibility and nomination rules of these programs, many of which are established annual competitions, vary widely. Management of these opportunities is the responsibility of the Office of the Vice Provost for Research. See the Limited Submissions section for a description of the application process and a list of opportunities.

Faculty may not apply directly for Limited Submission without the endorsement of the Harvard Chan School or University according to sponsor guidelines.

Participation Agreements for Research Performed at Harvard  Individuals who perform research at Harvard and/or who may create intellectual property through the use of Harvard resources are subject to certain University policies and, in some cases, to the terms of agreements between Harvard and third parties.  Such policies cover, the ethical conduct of research, publication of research results, retention of research records and the University’s “Statement of Policy in Regard to Intellectual Property”  which governs patentable inventions, copyrightable works and tangible materials made through the use of funds, facilities or other resources provided by or through Harvard. 

PI Eligibility

The Harvard T.H. Chan School of Public Health faculty have a range of appointment and employment arrangements as a result of the extent of our collaborations across Harvard and affiliated institutions. These circumstances require that we make decisions about PI status on grant submissions. The purpose of this policy is to articulate the Harvard Chan School’s determination of appointees’ eligibility to serve as PI on grants submitted through the Harvard Chan School. 

Subject Matter Resource:  Heather Conrad, Office of Research Strategy and Development (ORSD)/, and Your SRA

Policy on Use of Harvard Names and Insignias

The University and its members have a responsibility to ensure that any implied association with the University is accurate and that the activities with which it is associated maintain standards consistent with its educational purposes.

Subject Matter Resource:  Eileen Nielsen

Policy on Tobacco-Related Companies

The Faculty of the Harvard School of Public Health voted on January 24, 2002, not to accept any grant or anything else of value from any tobacco manufacturer, distributor, or other tobacco-related company.

Subject Matter Resource:  TBD

Provost Criteria

The Provost's Office aims to facilitate academic programs, projects and research at Harvard by providing clear criteria and procedures for University-level review of research proposals that pose management challenges and/or reputational risk and by providing reasonable review and oversight of major projects and programs. This process is intended to streamline the review process for PIs and administrators,improve management and administration, and reduce risks for program participants, for individual researchers, for Schools, and for Harvard as an institution. This document describes the criteria that determine whether a proposal requires Provostial review.

Subject Matter Resource: Your SRA

Principles Governing Research at Harvard (Grey Book)

In 1974, a Report of a Committee on Criteria for Acceptance of Sponsored Research in the Faculty of Arts and Sciences was presented to the Faculty. It consisted of a preamble, a set of principles governing the conduct of research, and commentary on these principles.

Subject Matter Resource: Your AD

Stipends on Federal Awards

Harvard has developed this guidance related to the charging of stipends to sponsored awards.

• Stipends are payments made to individuals for subsistence support or to defray expenses during a period of academic appointment.
• 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 Uniform Guidance, Subpart E). 

Subrecipient vs Contractor Guidance

Before entering into a relationship with another entity under a sponsored award in which the other entity will provide goods or services or substantive, programmatic work to Harvard as the prime recipient of funding, a determination must be made as to the nature of the legal relationship of Harvard and other entity, which in turn will determine the type of legal agreement required to document the relationship.  This is significant because it determines the allocation of responsibilities and influences the appropriate application of indirect cost rates.  

Subject Matter Expert: 

Tuition Policy

Tuition remission is the payment of tuition expense as part of compensation to students performing necessary work on federal research awards.  Unlike salaries and wages, tuition remission must be excluded from the application of indirect costs. Students whose work benefits research awards granted to Harvard University will be placed on payroll and their salaries will be charged in the payroll object code for “students in professional positions.” Remission for tuition and fees will be recorded as “graduate tuition and fees.” 

All compensation charged to federal research awards, whether it is paid as salaries and wages or as tuition remission, is subject to effort reporting. In order to meet this requirement without including tuition remission payments explicitly on salary certification forms, the allocation of tuition remission costs on research awards must match the distribution of work effort as reported through salary charges.

Subject Matter Resource: