PrintAdministrative and Clerical Costs Process Change
ARRA Update
Monthly Status Review: A Job Aid for Post Award Grants Management
Announcements:
1) FASERS Update
2) E-verify
3) The next NCURA Region I Research Administrator's Discussion Group (RADG) will take place this Thursday, September 24, 2009
4) New RAS Director of Research Development
5) New University Chief Research Compliance Officer
6) New Grammar Blog
Administrative and Clerical Costs Process Change
A recent federal audit of administrative and clerical costs at Duke University has resulted in a 1.6 million dollar settlement. For this reason, Harvard and FAS are looking more closely at administrative and clerical costs being charged directly to grants.
According to the federal Office of Management and Budget's Circular A-21, administrative and clerical costs should not be direct-charged to federal grants unless the grant is a "major project" AND the proposal budget includes administrative or clerical services AND the individual(s) involved "can be specifically identified with the project... 'Major project' is defined as a project that requires an extensive amount of administrative or clerical support, which is significantly greater than the routine level of such services provided by academic departments."
FAS has had a process in place for the past several years, involving submission of the FAS Administrative Checklist with each proposal that budgets for administrative support. However, we expect that a University-wide policy on direct-charging of administrative costs will be in effect by December 1, 2009, and it is likely that the new policy will be somewhat different than the current FAS policy. In the meantime, please see below for specific directives concerning proposals and post-award management of administrative and clerical costs...
Proposals: 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.
Post-award: By October 15th, please review any administrative and clerical personnel being direct-charged to federal projects and ensure that the effort was budgeted in the proposal and submitted with an Administrative Checklist. It’s also important to make sure that each direct-charged administrator is paid at least 25% from the federal grant and that he or she is devoting an amount of effort that matches the percentage of pay – this is a particularly auditable requirement of the FAS policy. As additional backup to reinforce the Administrative Checklist, we are asking departments to send an explanation to FAS RAS documenting the need for extra administrative support for that specific project over and above that normally provided by the department. Nuala McGowan has identified a list of personnel currently being direct-charged, and she will be contacting affected departments individually.
Click here to download relevant sections of OMB Circular A-21
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ARRA Update
FAS has received over 16 million dollars in federal American Recovery and Reinvestment Act (ARRA) research funding this year. Because the federal fiscal year ends on September 30th, RAS expects a huge influx of ARRA awards in the next week and a half.
If you would like more information about ARRA funding in general, please contact the FAS RAS ARRA Project Specialists, Yulanda Quinlan (yulanda_quinlan@harvard.edu) and Hannah Coache (hcoache@fas.harvard.edu). They are here to help departments with, among other things...
- Any questions you may have about ARRA funding
- Quarterly reporting
- Reporting on jobs created and retained
- Setting up ARRA templates to send to departments for verifications
- Reviewing Detail Listings to ensure Cost Accounting Standards (CAS) Compliance
Deadlines of note: September 28th all templates are due to FAS RAS via email to Yulanda & Hannah with a cc: to David Norcross (norcross@fas.harvard.edu).
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Monthly Status Review: A Job Aid for Post Award Grants Management
Nuala McGowan has spearheaded the creation of a new job aid designed to help administrators prepare for monthly meetings with the Principal Investigators of the awards they manage. The job aid is an Excel spreadsheet containing separate worksheets with
- an overview of things to keep in mind when prepping for the monthly meeting, with spaces for notes and talking points,
- a personnel checklist,
- an award set-up checklist,
- an award close-out checklist.
This job aid is meant for anyone dealing directly with faculty and can be found on the RAS Website by clicking the Job Aids link on the left- hand side. You can also download it directly by clicking here. Please encourage use of the Monthly Status Review in your department and direct comments and suggestions to Nuala McGowan at nmcgowan@fas.harvard.edu.
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Announcements
1) FASERS
Alan Long announced that the faculty effort certification process for FY 09 will be taking place early this year, since the results have to be used for the overhead-rate calculation due early this winter. Departments will be asked to pre-populate faculty effort commitments in October, and faculty members will certify their FY 09 effort in November.
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2) E-verify
Effective Sept 8, 2009, all recipients of federal contracts over $100,000 and federal subcontracts over $3,000 which contain FAR 52.222-54 must verify the employment eligibility of those employees working under the federal contract. This check goes beyond the normal I-9 process and requires the employer to check the employee's information in the Department of Homeland Security's E-Verify system. All employees working on the federal contract are affected: new hires, current employees, and current employees who are later assigned to the contract; the verification also applies to faculty.
Employment Services, the Office of General Counsel, and OSP have been working together to create a process to comply with this new federal requirement. The process will undergo some fine tuning in the coming weeks. For now, OSP will have the primary responsibility for identifying which awards contain the E-Verify requirement and will communicate with the school/department. The school/department will then need to contact its local HR representative, who must then take the necessary steps to check employees against the E-Verify system. The penalties are potentially extreme, so it is everyone's responsibility to be aware of this issue and be prepared to identify it independently. Once the process is finalized, there will be further discussion at an RAS Friday.
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3) The next NCURA Region I Research Administrator's Discussion Group (RADG) will take place this Thursday, September 24, 2009
Discussion Topic:
Interactions with Industry: Massachusetts and Federal Conflict of Interest Requirements
Speakers:
David Korn, M.D., Vice Provost for Research and Professor of Pathology, Harvard University
Mary Mitchell, Director of Research Compliance, Partners Healthcare
Please visit http://web.mit.edu/osp/www/ncura/radgmeetings.htm for more information. Registration is available at the door.
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4) New RAS Director of Research Development
RAS is pleased to announce that Kathryn Coughlin has joined us as Director of Research Development, the position formerly held by Tara Murphy. For the past ten months Kathryn has worked as an outside consultant for the Harvard Center for Middle Eastern Studies, identifying potential funding sources, and performing grant writing and project development for the Islamopedia project. Kathryn served previously as Director of Middle East and North Africa Programs and Director of Operations for the American Islamic Congress, Inc. Kathryn's professional experience also includes a position at Georgetown University as the Assistant Director of the Al-Waleed bin Talal Center for Muslim-Christian Understanding. Kathryn has a B.A. from Berea College, a M.A. from Georgetown University, and a Ph.D. ABD from Georgetown U.
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5) New University Chief Research Compliance Officer
Effective September 29th, Mark Barnes has been hired as the University’s Chief Research Compliance Officer and Senior Advisor to the Provost. Working closely with the Vice Provost for Research, Mark will play a leading role in reviewing and revising research administration policies across the University to ensure consistency, and in facilitating comprehensive educational and training programs for Harvard’s research faculty, students, and staff. Mark will develop close collaborations with many University constituencies, including faculty members, Deans, senior School and University administrators, and staff in key areas such as Risk Management and Audit Services, Environmental Health and Safety, and School compliance functions - all in the service of ensuring compliance with both University policy and existing and emerging external regulations across a range of high-risk areas. Mark will be a member of the FAD senior leadership team, will assume direct managerial responsibility for FAD's Office of Sponsored Programs, and will have faculty appointments in the School of Law and the School of Public Health.
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6) New Grammar Blog
Just to prove that research administration can be fun, Alan Long has started a grammar blog. The weekly postings are intended to point out common mistakes that people make in their writing and to suggest ways of avoiding them. A link to the blog has been added to the Job Aids section of the RAS website -- the URL is http://aklgrammar.blogspot.com.
