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What is the role of the Principal Investigator (PI)?
The Principal Investigator (PI) is responsible for ensuring that a sponsored project is carried out in full compliance with the terms, conditions and policies of both the sponsor and the University. The principal investigator must signify his or her willingness to accept direct, active responsibility for all aspects of the proposed project, including the conduct of the research program and the administrative and fiduciary responsibilities that accompany an award.
Who is eligible to be a Principal Investigator?
At the Harvard Kennedy School (HKS), only individuals with full-time faculty appointments or others explicitly designated by the Academic Dean can serve as principal investigators or co-principal investigators. Faculty who are adjuncts, visiting, or whose primary appointment is at another Harvard school are generally not HKS principal investigators.
How should I make a request for PI status?
If you are not currently a principal investigator and would like to request PI status, the request should be made via an e-mail to the Academic Dean, Iris Bohnet, copying Matthew Alper and Charlene Arzigian.
What is the role of the Research Administration Office (RAO)?
Reporting to the Academic Dean and the Executive Dean, and under the direction of the Associate Dean for Research, the HKS Research Administration Office manages the review and approval process for all externally funded grant and contract proposals (the Dean's Approval Process for Sponsored Proposals).
The RAO reviews proposals and accompanying budgets for compliance with all HKS and Harvard University policies and procedures; submits proposals to the Academic Dean for approval, and works with research faculty, staff and Harvard's Office for Sponsored Programs (OSP) to address all issues before a proposal is submitted to a sponsor.
Other RAO activities include:
What is the Role of Harvard University's Office for Sponsored Programs (OSP)?
The Office for Sponsored Programs (OSP) is the only office authorized to submit proposals to external sponsors on behalf of the President and Fellows of Harvard College and its faculty members. In collaboration with HKS faculty PIs and the Research Administration Office, OSP also negotiates all award terms and conditions, and officially signs and accepts awards on behalf of the President and Fellows of Harvard College.
What is the Dean's Approval Process for Sponsored Proposals?
The Dean’s Approval Process for Sponsored Proposals refers to the internal HKS review and approval of all sponsored proposals before they are submitted to OSP. The RAO manages the Dean’s Approval Process, reviewing proposals to ensure compliance with Harvard University, HKS, and sponsor policies. This includes policies on use of human subjects, allowable expenses, cost sharing, and subcontracts. The RAO submits proposals to the HKS Academic Dean for final School approval. Please see the Checklist for Putting Together a New Proposalfor additional information.
How will I know when the OSP has processed the proposal?
OSP/RAO will ensure that the PI and Center staff are copied on or forwarded email or other electronic submissions of proposals. For hard copy submissions, Fedex delivery confirmation will be forwarded to the PI and Center staff.
How Far in Advance Do I Need to Submit a Proposal to the RAO?
For all submissions, to both federal or non-federal sponsors, the complete and final proposal must be submitted to the RAO at least 7 full working days in advance of the sponsor's due date; and
For all submissions, whether a federal or a non-federal sponsor, OSP must receive the complete and final proposal reviewed by the RAO at least 5 full working days in advance of the sponsor's due date. The RAO will forward the proposal to OSP via GMAS once the review is complete.
The sponsor’s due date is defined as the date and time after which the sponsor will no longer accept proposals. In cases in which Harvard is a subcontractor, the sponsor’s due date will be determined by the submitting institution. Schools may impose additional requirements regarding review and approval by School-specific committees of sponsored programs proposals, including international proposals.
These deadlines assume that RAO has been working with the PI and/or staff on the proposal in advance. This includes review of the budget; obtaining approval, if necessary, from the Faculty Committee on Projects and Proposals (FCOPP); overhead shortfall waiver requests; and issues regarding the use of human subjects. RAO will also work with OSP to begin the University-level review as early as possible, prior to OSP receiving the final proposal.
If Harvard internal deadlines are not met and OSP does not have sufficient time for a thorough review, the proposal may not be submitted.
Requests for an exception to this policy must be made in writing by the RAO in coordination with the PI.
Read the complete submission guidelines (including NSF guidelines) here: https://www.hks.harvard.edu/research-publications/research-central/policies/submission-guidelines
What if I am asked to send a preliminary proposal to a foundation?
Often faculty are asked to send a preliminary proposal (or concept letter) to a foundation for review by a program officer who will decide whether a formal proposal should be submitted to the foundation's Board of Directors. All such proposals should be marked as preliminary. Occasionally, a sponsor may respond directly to a PI with an award letter based upon what was considered a preliminary proposal, but most foundations as well as government agencies require proposals to be submitted formally by OSP before they are considered for funding or before an award can be made.
If a sponsor responds to a preliminary proposal with an award, the proposal and award will still need to be submitted through the normal channels outlined above before funds can be accepted and a new account established. OSP will need to review the award and will negotiate any terms and conditions that are not acceptable to the PI, the School, or that are inconsistent with Harvard's sponsored research policies before accepting the award.
What fringe benefit rates should be used in a proposal budget?
Listed below are the University Area FY17 fringe benefit rates approved by the Department of Health and Human Services. Please budget all years using the approved rates for FY17.
What indirect cost rate should I use on a proposal to a federal agency?
If you are submitting a proposal to a federal agency, you must use the Harvard Facilities and Administrative costs rate that has been negotiated with and set by the Department of Health and Human Services.
Listed below are the federal facilities and administrative (indirect) cost rates per Harvard’s rate agreement with the Department of Health and Human Services, dated April 7, 2016:
|Type of Proposal||FY17 and beyond|
|On-Campus Organized Research||69%|
|Other Sponsored Activity (Primary activity is not research)||34%|
|Off-Campus (Preponderance of activity takes place off-site)||26%|
Click for more information about Harvard's policy regarding treatment of staff vacation time.
Does Harvard University collect indirect costs on subcontracts to other institutions?
Per the University's rate agreement with the Department of Health and Human Services, indirect costs are charged on the first $25,000 of each subcontract in a proposal to a federal sponsor; the remaining amount of each subcontract is exempt from Harvard overhead. For non-federal sponsors, indirect costs should be calculated on the total direct costs, including the subcontract, unless prohibited by the sponsor.
What indirect cost rate should I use on a proposal to a foundation or other non-federal sponsor?
Many foundation web sites include information on the indirect cost rate allowed on proposals. If this information is not readily available, the Office for Sponsored Programs now has information on their website on overhead rates for many non-federal sponsors: http://osp.fad.harvard.edu/content/fa-cost-rates-non-federal-sponsors
In addition, OSP has a searchable database which returns both the highest and lowest indirect cost rate received from each non-federal sponsor by school in the past three years:http://osp.fad.harvard.edu/non-federal-sponsors-rates
If the foundation does not specify an indirect cost rate and no further information can be found, the Kennedy School recommends using a 20% indirect cost rate.
Does HKS have minimum indirect cost requirements for sponsored proposals, and what if a sponsor will not allow those costs?
Facilities and Administrative costs (also F&A, Indirect Costs, or Overhead) are actual expenses incurred by the institution that cannot be directly and specifically allocated to an individual grant or contract with a high degree of accuracy. When external sponsors cap the OH recovery rate they will allow in their sponsored proposals, HKS policy requires an internal agreement to reconcile this overhead under-recovery. In all such agreements, the School must ensure it is making conscious, informed decisions about when and under what circumstances subsidies (if any) are provided.
HKS policy requires that proposals which do not include the normally required minimum indirect cost rate of 20% compensate for the overhead “shortfall” through one of the methods described below. The overhead shortfall compensation method must be confirmed at the proposal stage, and is managed as part of the Dean’s Approval Process for Sponsored Proposals by the HKS Research Administration Office.
Overhead shortfalls may be reconciled by one or more of the following methods:
Center/Program unrestricted funds offset by grant direct costs:refers to Center/Program funds that are freed up by grant direct costs. In these cases, Centers are held harmless as the grant has covered expenses normally covered by the Center. All such expenses need to be allowable, allocable and appropriate to include in the grant.
Other Center/Program funds:refers to Center/Program funds (e.g., unrestricted) that subsidize the overhead shortfall independent of any direct connection to the grant budget.
Grant direct costs directly credit HKS core budget:refers to allowable and allocable expenses charged to grants to offset fixed costs the School’s budget would otherwise bear. In most cases, such charges are limited to faculty term time salary and benefits, faculty assistant salary and benefits, or faculty/FA office rent.
Overhead Shortfall Waiver:refers to approval by the Academic Dean to waive all or part of the overhead shortfall. In reviewing these requests, the Academic Dean will in most cases give relatively greater weight (and preference) to the following factors:
Other factors are given due consideration, including:
The Academic Dean will look first to Centers to subsidize all or part of an overhead shortfall through methods 1-3 above, before approving a waiver. All overhead shortfall agreements will be documented at the proposal stage by the RAO and included in the permanent file.
Who is Authorized to Sign Documents Related to Proposals and Awards?
Only certain officers in the Office for Sponsored Programs have the legal authority to sign documents relating to proposals and awards on behalf of the President and Fellows of Harvard College.
Principal investigators are not authorized to sign sponsored award documents nor does the PI's signature signify Harvard's acceptance of the terms and conditions of any award. OSP staff and the PI review the award and OSP negotiates any terms that are not acceptable to the PI, the School, or Harvard before signing to accept the award on behalf of the University. While in some cases a principal investigator's signature may be required on a sponsored research award document, such documents are also required by University policy to be co-signed by an authorized signatory of the University.
Please forward all award letters to the Research Administration Office upon receipt.
Can I charge expenses to a project before an official award is made or before OSP completes its negotiations on an award?
Yes, an At-Risk Accountallows OSP to establish an account string before an official award has been made or before OSP completes its negotiations on an award. This kind of account is requested with the understanding that the award is very likely and/or the negotiations will eventually be successful. It also helps the accounting situation by eliminating the need for journals, as the account string remains the same when the award is finalized.
An At-Risk Account Request can only be completed if a proposal has been processed.
How do I create an At-Risk Account?
At-Risk Account requests are created in GMAS by going to the segment home page for a submitted proposal and clicking the create requestbutton at the top of the page.
Then click internal requestand you will see an option for At-Risk Accounts. Please note that you will need to submit evidence that the proposal is likely to be funded (e.g., an award document or an email from a program officer that an award is forthcoming).
All At-Risk Account requests are approved by Nancy Guisinger, HKS Controller.
The Center/Program requesting the At-Risk Account assumes responsibility for expenses that have been incurred in the event that an award is not made or accepted, or if certain expenditures are unallowable under the terms of an award.
What is the process for requesting a no-cost extension of a sponsored project?
If additional time is required to complete work on a sponsored project, a no-cost extension must be requested from the sponsor. The standard procedure for requesting a no-cost extension is to send a letter (or email) to the sponsor, explaining the need for additional time and requesting a new end date. No-cost extension requests are submitted in GMAS by going to the segment home page for an award and clicking the “create request” button at the top of the page. Then click “changes to existing segment” and you will see an option to select “no-cost extension.” Note that you will be asked whether it is a retroactive request and if the request has already been submitted to the sponsor (and in some cases the approval will have been received as well), you should select “yes.” Only if OSP needs to submit the no-cost extension request to the sponsor should “no” be selected.
What is the Faculty Committee on Projects and Proposals (FCOPP)?
FCOPP, composed of senior members of the HKS faculty, was established by the Dean to provide oversight of proposals and projects to minimize risks to the School and to the University. The Committee's recommendations are strictly advisory to the Dean and the Academic Dean. Ultimately, it is the Dean who decides whether proposals receive Kennedy School approval. The Committee focuses exclusively on the flow of new, renewed, and significantly amended projects, not the stock of existing ones, except when special problems or circumstances indicate the wisdom of doing otherwise (e.g., by request of the Dean).
FCOPP consideration is not a substitute for the standard HKS review and approval process; rather, it is another step in that process, to be deployed only in certain circumstances. The FCOPP chair, working in consultation with the Associate Dean for Research, and individual, selected Committee members, will identify those proposals that may require additional review. At this stage, attention is given to at least five characteristics, any one of which might indicate that the full Committee should undertake a review:
In its reviews of projects, FCOPP addresses three key issues:
How will I know if a proposal requires FCOPP review?
Based on the FCOPP scope and standards, the Research Administration Office will review all proposals submitted through the Dean's Approval process to determine whether FCOPP review is required. In most cases, proposals in question will be given expedited review and will not require consideration by the full committee. The RAO will consult with principal investigators and their staff if further information is required, and will notify PIs of expedited approval or the need for full committee review. All efforts will be made to ensure that the review process does not adversely affect the timing of proposal submissions.
What is the Policy on the Use of the Harvard and Kennedy School Names and Insignias?
Harvard University has strict regulations regarding the use of the Harvard names and Insignias. A proposed new activity can only be labeled as "the Harvard Program on X" or anything similar under certain specific circumstances and only with advance permission of the Provost. Similarly, a proposed new activity can be labeled "the John F. Kennedy School of Government Program on Y" only with advance permission of the Academic Dean. This policy applies to use of the Harvard/Kennedy School names and insignias both in print and on the web.
Please direct all inquires on the use of Harvard and/or Kennedy School names to Matthew Alper.
For the complete policy, please see the Provost's Guidelines on the Use of Harvard Names and Insignias.
What is the Policy Governing Commercial Activities?
Proposed partnerships with an outside entity and other similar arrangements involving a substantial commercial element must be approved in advance by the Provost or President, and in some cases, the Corporation. The Provost's Principles Governing Commercial Activities are directed principally at proposed partnerships with for-profit entities and not-for-profit entities that involve a substantial commercial element. The principles also apply when a unit of the University proposes to undertake activities on its own that incorporate a commercial element, such as soliciting commercial sponsorship of an academic conference or including commercial advertising in a University publication.
Please direct all inquiries on the Principles Governing Commercial Activities to Matthew Alper.
For the complete policy, please see the Provost's Guidelines on Commercial Activities.
What is the difference between a sponsored project and a gift?
Research that is funded by external sources falls into one of two categories: one is sponsored research. The other is research supported by gift money. The distinction between the two is important because different guidelines and different roles and responsibilities apply to the different categories. Sponsored projects must have a principal investigator and proposals must be approved and submitted by the Office for Sponsored Programs. Harvard's Recording Secretary's Office, the HKS Office of Alumni Relations an Resource Development, and the HKS Gifts Proposal Advisory Committee manage the review and approval of gift funds.
If one or more of the following criteria applies, the award is normally considered a sponsored project and must be processed through the HKS Dean's Approval and OSP channels:
The Office for Sponsored Programs uses the following criteria when determining whether an award is a sponsored project or a gift:
What is the Gifts Proposal Advisory Committee (GPAC)?
The Gifts Proposal Advisory Committee (GPAC) oversees the institutional review, approval, and processing of certain categories of new restricted gifts at HKS. GPAC is advisory to the Dean, Academic Dean, and Executive Dean, and is comprised of senior representatives of the HKS Financial Services (OFS), Alumni Relations and Resource Development (ARRD), Research Administration (RAO), Academic Dean, and Dean’s Offices. It seeks to ensure that new initiatives advance the School’s mission with a clear understanding of the associated costs and benefits. GPAC will also engage the standing HKS Faculty Committee on Projects and Proposals (FCOPP) for a subset of new gift proposals requiring additional review and discussion. The GPAC focus on coordinated advance review of selected new gift proposals mirrors in many ways the standard policies and procedures already in place for the review and approval of new sponsored program proposals (grants and contracts) at HKS and at Harvard University.
For more information, please see: Gifts Proposal Advisory Committee