Academic Service Center Policy

Academic Service Centers are units within Harvard departments or centers that charge for goods or services that directly support the research or academic mission of the University and recover costs through charges to internal and external users.  The rules around expense recovery must be followed.

Subject matter resource:  Kristie Froman

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

Financial Management of Property, Plant and Equipment (Capital Assets and Equipment

This policy provides guidance for the management and control of capital equipment that is owned by the University, titled to the University, under the custody of the University, or for which the University is accountable to the federal government or other sponsors.

Capital Equipment: Summary of Policy for Capital Equipment in Schools with Sponsored Research

• Appendix A: Summary of Policy for Capital Equipment in Schools with Sponsored Research
• Government Owned Property Overview and Procedures
• University Sponsored Equipment Roles and Responsibilities Matrix

Subject Matter Resource:  Kay Sullivan

Cost Sharing Policy

Cost sharing is any project cost that is not reimbursed by the sponsor to support the scope of the work defined by the federal or non-federal sponsored award.   Cost shared costs are funded by Harvard or a third-party cost, 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 may require reporting.  

Subject matter resource:  Kristie Froman

Cost Transfer Policy

In accordance with OMB, it is necessary to explain and justify transfers of charges onto federally funded sponsored awards, when the original charge was previously recorded elsewhere on Harvard's GL. Timeliness and completeness of the explanation of the transfer are important factors in supporting allowability and allocability in accordance with federal requirements.

Subject matter resource:  Kristie Froman

Fellowship Payments and Reimbursements for Students and Non-employee Postdocs/Fellows

Per the IRS, a fellowship is an amount paid to or allowed for the benefit of an individual to aid in the pursuit of that individual’s own study or research. At Harvard, we use the term “fellowships” to refer to a host of payments: awards, stipends, grants, and allowances. This policy is intended to clarify when payments to fellows should be treated as gross income, as qualified payments for tuition or fees for a degree program, or as reimbursements for bona fide University business expenses that the individual incurred on Harvard’s behalf.

Subject Matter Resource:  

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

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 University Fraud Policy

The Harvard University Fraud Policy was developed to define roles and responsibilities for detecting and presenting fraud, reinforce personal responsibility and accountability, and detail the procedures for reporting and investigating suspected fraud.

For questions, or to report fraudulent activity, you should contact:

• your supervisor
• your HR partner
• the HCSPH Controller (Vicki Johnson, 617-432-3527), or
• the University compliance Hotline (877-694-2275)

If someone has reported fraudulent activity to you, contact the HCSPH controller (Vicki Johnson at 617-432-3527).

Harvard University Whistleblowing Policy

The Harvard University Whistleblowing Policy encourages members of the Harvard community to report suspected violations of law or University policy to their supervisor, to a local tub finance officer, to a local or central human resources officer, or to the Compliance Hotline.  This policy reinforces Harvard's retaliation policy for any member of the community who in good faith voices concerns, seeks advice, files a complaint or grievance, seeks the aid of Human resources, testifies or participates in investigations, compliance reviews, proceedings or hearings, or opposes actual or perceived violations of Harvard University's policy or unlawful acts.

Interest Income Paid on Non-Federal Sponsored Funds

The interest rates and interest income paid annually on Non-federal Exchange (NE) and Non-federal Grant Funds (NG) are reassessed annually.  This document covers the policies and procedures of interest income paid on non-federal sponsored funds.

Subject Matter Resource:  Min Xiao, OSP

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

NIH Public Access Policy

Effective May 25, 2008, anyone submitting an application, proposal, or progress report to NIH must include the PubMed Central reference number (PMCID) when citing articles that arise from their NIH funded research.

Subject matter resource:  TBD

Procurement

It is a compliance requirement to follow the University Procurement Policy when procuring goods and services using sponsored funds. Appendix B of the Procurement Policy gives a high-level table summarizing purchasing procedures for standard purchases. Additionally, you should pay attention to individual sponsor award terms and conditions to ensure that award procurement requirements are noted and followed.

Subject Matter Resource: 

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

Responsibilities of Purchasers, Preparers and Approvers (ROPPA)

One of Harvard’s fundamental internal controls is the proper review and approval of transactions.  Preparing or approving any part of a transaction is a significant responsibility.  This policy defines and codifies the responsibilities of individuals who spend Harvard funds and who prepare and approve transactions.  

Subject matter resource: 

Severance on Sponsored Awards Guidance

Federal guidance regarding severance expenses comes from the NIH Grants Policy Statement and the OMB Circular.  Based on this guidance, and in keeping with Harvard's own internal policies, this document outlines the conditions under which the charging of severance expenses against federal awards is allowable.

Sponsored Expenditures Guidelines (SEG)

The SEG guidance is based on the interpretation of federal regulations, and adherence is required for all federal awards.  For any costs to be charged directly to a federal award the expense must be:  (1) Allowable under both the provisions of federal guidance AND the terms of a specific award (2) Allocable: the expense can be associated to a project with a high degree of accuracy (3) Reasonable: the cost reflects what a “prudent person” would pay in a similar circumstance (4) Charged consistently as direct expense (versus an indirect cost).

Subject matter resource:  TBD

Sponsored Financial Reporting and Closeout Policy

As the recipient of sponsored funding from federal and non-federal sources, Harvard University is required to provide accurate, timely, and complete disclosure of the financial results of sponsored awards and programs:  By accepting sponsored funding, Harvard agrees to manage and use these funds in accordance with sponsor terms and, if applicable, federal regulations.

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: 

Subrecipient Monitoring Policy

Harvard University is responsible for monitoring the programmatic and financial activities of its subrecipients to ensure proper stewardship of sponsor funds. This policy applies to all subawards issued under sponsored programs made to the President and Fellows of Harvard College, without regard to the primary source of funding. Failure to adequately monitor the compliance of subrecipients could result in reputational damage to the University and Schools, and jeopardize current and future funding. It is the responsibility of Harvard, as the pass-through entity, to ensure the good stewardship of sponsored funding.

Subject Matter Resource:  Angie Suriel

Sponsored Travel Guidance and Policy

The Sponsored Travel Guidance and Policy contains information on charging the lowest economy airfare,  Fly America Act overview, helpful travel resources, contacts, frequently asked questions and CONCUR.

Federal Awards:  Additional rules relating to travel charged to federally funded awards.

• Sponsored Expenditures Guidelines (Travel and Related Expenses, Air Travel, Appendix A: Special Considerations for Federal Training Grants)
• Harvard Univeristy Travel Policy:  Appendix G: Requirements for Travel Expenses Charged to Federal Awards,
• Harvard University Travel Policy (full policy)

Subject Matter Resource: 

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: 

NIH Grant Policy Statement

The following sections are particularly important for Award Management

7.  Cost Considerations:  This chapter addresses the general principles underlying the allowability of costs, direct costs, F&A costs, and highlights some of the specific costs and categories of cost fo NIH applicants and recipients.

8. Administrative Requirements:  This chapter covers things such as changes in project and budget, prior approval requirements, monitoring, special award conditions and enforcement actions, and closeout.