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Administrative and Clerical Costs Charged to Federal Grants: An Update
NIH Policy Changes Around Conflict of Interest
American Recovery and Reinvestment Act (ARRA) Update
Announcements:
1) RAS Fridays are open to all administrators. Please sign up for the invitation list at: http://www.fas.harvard.edu/~research/training/RAS_Fridays.html
2) Next one-day Overview of Sponsored Projects Administration workshop will take place on October 27th. For more information, please go to: http://www.fas.harvard.edu/~research/Overview.html
3) The Dean's Approval Form and Guidelines have been updated. FY09 Fringe Rates have been removed and the DAF and Guidelines reflect the new requirement that any proposals with administrative and clerical costs must now be approved by FAS RAS. For more information please go to: http://www.fas.harvard.edu/~research/approvals/cvrsht.html
Administrative and Clerical Costs Charged to Federal Grants: An Update
This is a follow-up to the discussion at the RAS Friday in September. For background information, please see the September notes at http://www.fas.harvard.edu/~research/training/
RAS_Friday_Summaries/09_Sep/Notes.html#admin.
This subject seems to have caused some concern in departments. Given the economic climate, please be assured that even though changes are coming, the jobs of the current research administration staff in your departments are safe. If you or people in your department have questions, RAS will be happy to answer them to the best of our ability.
In response to recent events (e.g. Duke University audit and settlement) and increased occurrences of agencies (primarily the National Institutes of Health (NIH) ) “redlining” administrative costs in budget proposals, Harvard is conducting a University-wide reassessment on the direct-charging of administrative and clerical costs on federal awards. The University Cost Analysis Group, which is chaired by Judy Ryan of OSP and includes Alan Long, Nuala McGowan, and Nissa Knight, has been charged with drafting a new policy. The target date for the new policy is December 1, 2009.
The new policy is likely to be more conservative than the current FAS policy. A communication beginning the transition to the projected new policy was sent last month to FAS Administrators. Details are below:
Effective Immediately: Any federal proposals that include administrative and clerical costs must be reviewed and approved by FAS RAS. To ensure that the process goes as smoothly as possible, please submit an FAS Administrative Checklist, name the individual to be charged (or use "To Be Hired"), and include a detailed explanation in the budget justification saying what the individual will be doing and why extra administrative support is needed for that specific project over and above that normally provided by the department. The Dean’s Approval Form and Guidelines have been updated to reflect this new review.
By October 15th: Reviewof any administrative and clerical personnel currently being direct-charged to federal projects must be completed to ensure that effort was budgeted in the proposal and submitted with an Administrative Checklist.
Beginning October 15th: FAS will start to transition to the potential new Harvard-wide policy by adopting a more conservative approach to determining “major projects,” thereby restricting the direct charging of administrators and the use of the Administrative Checklist. FAS RAS will notify Department administrators and PIs when administrative salaries are not approved for inclusion in the proposal budget.
In most cases, FAS will assume responsibility for the salaries of the administrators that may no longer be charged to federal awards. On Friday October 9th, lab directors were asked to forward a notification of this new review process to faculty. Download a copy of the email here: http://www.fas.harvard.edu/~research/training/RAS_Friday_Summaries/09_Oct/Admin_Costs_PI_Email.pdf. Russ Porter and Pat Fitzgerald will be meeting with Lab Directors in the science departments to plan for the transfer of administrative salaries from research grants to institutional funds. Existing awards made under the current policy which include administrative salaries in the budget will continue to direct-charge these costs for the remainder of the project period, assuming they remain compliant with FAS policy. New proposals will be submitted under the new policy.
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American Recovery and Reinvestment Act (ARRA) Update: David Norcross
As of Friday, October 9th, FAS has received about twenty four million dollars in federal American Recovery and Reinvestment Act (ARRA) research funding, with an additional five million in anticipated funding. This constitutes about 25% of all Harvard ARRA funding to date. Awards have been made to sixteen FAS departments and centers. Twenty awards came from NIH and thirty-two from NSF, for a total of fifty-two awards.
The first federal reporting deadline was October 10th, with a Harvard internal deadline of October 1st. A key element of the data requested is "jobs created and retained." This first quarter, FAS reported that approximately seven jobs were created and/or retained, with Harvard reporting a total of sixty-nine. These numbers do not include graduate students. However, graduate students will be included in future reports.
If you would like more information about ARRA funding or reporting, please contact the FAS RAS ARRA Project Specialists, Yulanda Quinlan (yulanda_quinlan@harvard.edu) and Hannah Coache (hcoache@fas.harvard.edu), or RAS Assistant Dean for Research Administration Services David Norcross (norcross@fas.harvard.edu).
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National Institutes of Health (NIH) Policy Changes Around Conflict of Interest (COI): Dean Gallant and Melissa Siegel
Financial conflict of interest is currently a hot topic for NIH and, more broadly, all federal sponsors. More recently, congressional probes into the misuse and accountability of federal money have uncovered situations at major research institutions, including Harvard Medical School, Stanford University, and Emory University, in which NIH principal investigators allegedly failed to report income received from pharmaceutical companies. In addition, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) has been camped out at the NIH, investigating NIH oversight of awardees’ compliance with COI regulations. As an initial response to recommendations from the OIG, in April 2008 NIH began including language about its policies promoting objectivity in research (download handout by clicking here) on the front of each Notice of Award. To address this new language, which requires the reporting of any conflicts to NIH prior to commencing spending on each award, and reporting of new conflicts within 60 days of discovery, we have modified our conflict of interest reporting procedures in the FAS: OSP is sending an e-mail out to the PI (copying Dean Gallant and the appropriate department administrator) asking whether conflict of interest information on file is accurate or must be updated. This is an interim FAS solution, pending a likely change to proposal-based disclosure for all sponsored awards, regardless of funding source. Also, in an effort to standardize conflict of interest procedures across the University, Vice Provost for Research Dr. David Korn has gathered a committee to assess all schools' current policies regarding COI and to craft a University-wide policy. Finally, in further response to the OIG investigation, NIH issued an advance notice of proposed rulemaking on financial conflicts of interest earlier this year, and revision to their policies seems assured. Please stay tuned -- the only certainty is change itself.
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Overhead Calculation: An Update
This fall Alan Long, the RAS Finance group, and the Cost Analysis group in OSP are working very diligently to prepare for the upcoming federal overhead-rate negotiations. There are four prongs to these preparations: space survey data must be provided, equipment must be inventoried, faculty effort must be certified, and all financial data must be analyzed. Space surveys will be completed by the administrative heads of FAS departments and centers, using data provided by the FAS Office of Physical Resources and FAS RAS. Equipment inventories are being completed in departments this month. Financial data has been loaded into the CRIS (Comprehensive Rate Information System) program and will be analyzed and massaged by Alan, Nissa Knight from FAS Finance, and the OSP Cost Analysis group. The final prong is the FY 09 faculty effort certification process. Departments will use grant proposals and progress reports to pre-populate faculty effort commitments in FASERS by November 13th, and faculty members will certify their FY 09 effort in November and December.
