What is the role of the Principal Investigator?
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.
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.
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, Mary
Jo Bane, copying Matthew
Alper and Charlene
HKS Research Administration Office
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). The RAO reviews proposals and accompanying budgets for
compliance with all HKS and Harvard University policies and procedures;
obtains required approval signatures from the HKS Office of Financial
Services and the Academic Dean; 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.
RAO activities include:
Managing the Overhead Support Fund and interacting with the Academic
Dean, HKS Finance Dean, Centers, Programs and individual faculty
members on related overhead issues;
with the faculty chair, managing the Faculty Committee on Projects
and Proposals (FCOPP) for risk assessment of selected domestic
or overseas research, training, and/or outreach proposals.
and marketing the Dean's Research Fund for internal faculty seed
Developing and maintaining the HKS
Faculty Research Working Paper series and the HKS electronic
research paper series published by the Social Science Research
Producing and distributing (hardcopy and electronic) the HKS
Research Report, including publication citations from all
HKS faculty, centers and programs, and other activities.
Faculty Committee on Projects and Proposals (FCOPP)
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:
(1) the project is of very large scale (indicated by a total annual
budget in excess of $1,000,000);
the project involves substantial engagement and coordination with
the level of (budgeted plus unbudgeted) effort devoted by the
projectís Principal Investigator (PI) is less than 10% of the
PIís total time and less than 10% of the total professional time
on the project;
the project involves an off-site (domestic or overseas) "presence"
for the School, meaning a resident presence of significant duration
by at least one professional, or where the preponderance of activity
is off site (e.g., where the federal off-site indirect cost rate
might apply); or
the project may pose particular risks for the School, the University,
its faculty, students, or staff.
its reviews of projects, FCOPP addresses three key issues:
Is the project directed by a Principal Investigator (PI) with
a long-term interest in the School?
Is the project consistent with the educational mission of the
University, and does it thereby link back to teaching and research
(such as through the meaningful involvement in the project of
the principal investigator); and
Does the project pose no more than reasonable risk to the School,
the University, its faculty, students, or staff?
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
Committee on Projects and Proposals Scope, Standards, and Procedures
Harvard University Office
for Sponsored Programs
is the Role of Harvard University's Office for Sponsored Programs
OSP is the only office authorized to submit research 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.
Dean's Approval Process
is the Dean's Approval Process?
A sponsored proposal, budget and Dean's Approval Form should be
submitted to the Research Administration office at the earliest
possible date. (See: How Far in Advance Do I Need
to Submit a Proposal to the RAO?) This will ensure sufficient
time for HKS and OSP review and follow-up. The original and three
copies of the proposal are required for internal purposes; if additional
copies are required by the sponsor they should be included. The
RAO reviews the proposal and budget and works with the PI and staff,
the HKS Office of Financial Services, and the Academic Dean's Office
if there are issues to be resolved. The RAO then submits the proposal
to the HKS Office of Financial Services and Academic Dean for final
review and signature and submits the proposal to the Office for
Sponsored Programs. OSP reviews the proposal and works with the
RAO if there are additional, remaining, or unforeseen issues to
be resolved. OSP prepares the official transmittal letter and submits
the proposal to the sponsor on behalf of the University. The RAO
confirms submission of the proposal to the PI and staff via e-mail.
is the Dean's Approval Form?
Approval Form (DAF) is an internal form that must accompany
all proposals when they are submitted to the Research Administration
Office and the Office for Sponsored Programs. The form provides
information on various aspects of a proposal, including: date due
at the sponsor; Principal Investigator and staff contact; sponsor
name and contact; amount requested; overhead rate; and project dates.
It also asks the PI to answer questions relating to conflict of
interest, use of human subjects, cost sharing, subcontracting, and
overseas activity. The form is signed by the Principal Investigator
and Center/Program Director (when applicable), as well as the HKS
Office of Financial Services and for the Dean. The signed Dean's
Approval Form is considered the official HKS authorization for the
proposal. OSP is not able to submit a proposal or accept an award
if a proposal/award has not been submitted through the Dean's Approval
are the elements of review of the Dean's Approval Process?
The RAO reviews proposals and budgets for compliance with policies
on the following:
space required for TBN or existing personnel
Use of Human Subjects in Research
Use of the Harvard Name
Potential Conflict of Interest
Direct Charging of salaries/administrative costs to federal grants
Review by the Faculty Committee on Projects and Proposals
a faculty PI ever submit a formal proposal directly to a sponsor
with no prior HKS/HU review?
Although a faculty PI can submit a proposal directly to a sponsor,
it will not be considered a formal Harvard University proposal until
it has been submitted through the HKS Dean's Approval process to
the Office for Sponsored Programs. Many foundations and all government
agencies require proposals to be submitted formally by the University
(OSP) before they are considered for funding or before an award
can be made. In addition, if the sponsor responds to a proposal
sent by the PI with an award, the proposal still must be retroactively
processed through HKS. OSP will need to review the award and will
also serve to 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. A proposal that has
been sent preliminarily directly to the sponsor should be submitted
through the HKS Dean's Approval process as soon as possible.
will I know when the RAO has processed the proposal?
the RAO receives confirmation from OSP that the proposal has been
submitted to the sponsor, an email is sent to the Principal Investigator
and staff contact notifying them of the proposal submission. Included
in the email is the date the proposal was sent by OSP and a copy
of the OSP transmittal letter.
the RAO is retroactively processing an award that has been received,
an email is sent to the Principal Investigator and staff contact
when the materials have been submitted to the Office for Sponsored
Proposal Submission Guidelines
Far in Advance Do I Need to Submit a Proposal to the RAO?
to ensure adequate time for approval of proposals by the HKS Office
of Financial Services and the Academic Dean, proposals are due at
RAO 3 full working
days before the OSP deadline.
Please note the following new submission guidelines, effective January
for all submissions to a federal sponsor, the complete
and final proposal, accompanied by the appropriate Dean's Approval
Form and any other required attachments, must be submitted to
RAO at least eight (8) full working days in advance of
the sponsor's due date; and
(2) for all submissions to a non-federal sponsor, the same
materials must be submitted to RAO no later than six (6) full
working days in advance of the sponsor's due date.
further information, please see the RAO
Proposal Submission Guidelines.
is the process for requesting a no-cost extension of a sponsored
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
to the sponsor, explaining the need for additional time and requesting
a new end date. The letter should be submitted with the HKS Request
for No-Cost Extension of Sponsored Project form to the Research
Administration Office. The RAO processes the no-cost extension request
and it is formally submitted to the sponsor by the Office for Sponsored
Programs. Upon sponsor approval the end date of the project is extended
by OSP. If a PI has communicated via email or letter to the sponsor
and has already received approval for the no-cost extension, the
extension must still be processed through HKS and OSP using the
Request for No-Cost Extension of Sponsored Project form.
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. We ask that you send copies of preliminary proposals
to the Research Administration Office, so that we will be able to
anticipate possible complications as well as review potential sponsor
terms that may not be compatible with School or University requirements.
the foundation requests a formal proposal, the PI will need to submit
the proposal through the HKS Dean's Approval Process. Occasionally,
a sponsor may respond directly to a PI with an award letter based
upon what was considered a preliminary proposal. Please note that
the proposal/award will still need to be submitted through the normal
channels outlined above before funds can be accepted and a new account
I charge expenses to a project before an official award is made
or before OSP completes its negotiations on an award?
an Advance Account allows OSP to establish an account string before
an official award has been made or before OSP completes its negotiations
on an award. An Advance Account is requested with the understanding
that the award is very likely and/or the negotiations will eventually
be successful. The Advance Account helps the accounting situation
by eliminating the need for journals as the account string remains
the same when the award is finalized. The Advance Account Request
Form can only be completed if a Dean's Approval form and proposal
have been processed. The Advance Account form can be included with
the Dean's Approval at the time of the proposal or submitted later
to the Research Administration Office.
The Center/Program/individual PI requesting the Advance 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.
download the Advance Account form, please click on the following
of Human Subjects in Research
can I determine whether my proposed use of human subjects or human
subjects data needs review by the Committee on the Use of Human
Research Administration Office has designed a preliminary questionnaire
that will help us determine whether the proposed use of human subjects
or human subjects data (including for survey research) requires
review by Harvard's Committee on the Use of Human Subjects. The
questionnaire is posted on the ResearchCentral Policies and Procedures
The questionnaire is a Word document on which you can enter replies
and return as an email attachment. Please direct all inquires on
the use of human subjects to Charlene
of Harvard/Kennedy School Names and Insignias
is the Policy on the Use of the Harvard and Kennedy School Names
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.
direct all inquires on the use of Harvard and/or Kennedy School
names to Charlene
the complete policy, please see the Provost's website:
Governing Commercial Activities
is the Policy Governing Commercial Activities?
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.
direct all inquiries on the Principles Governing Commercial Activities
to Charlene Arzigian.
For the complete policy, please see the Provost's website:
Fringe Benefit & Facilities and Aministrative (Indirect/Overhead) Cost Rates
fringe benefit rates should be used in a proposal budget?
In addition to the current FY09 fringe benefit rates, listed below are the FY10 rates as negotiated with the Department of Health and Human Services. The rates for FY11 and FY12 are estimates and subject to change. Please use these rates in all new sponsored proposal budgets.
Faculty (object codes 6010-6040)
|Exempt Staff Vacation Fringe (6050)
|Union Staff Vacation Fringe (6070)
|Temporary (Casual) (6120)
Compensation: Pensionable (6190)
Compensation: Non-Pensionable (6200)
* Not final - subject to change. Final rate will be announced as soon as it is available.
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 10, 2009. Rates are determined through FY10; for FY11 and beyond please use the FY10 rates.
Type of Proposal
FY11 and beyond
On-Campus Organized Research
Other Sponsored Activity (Primary activity is not research)
Off-Campus (Preponderance of activity takes place off-site)
The Kennedy School minimum required overhead rate for non-federal proposals is 20%. If the overhead rate allowed by a sponsor is less than 20%, please see details on how to address the overhead shortfall at: http://www.hks.harvard.edu/research/hvhpolicies.htm
for a printable version of the above chart. Click
[here] for more information about Harvard's new policy regarding treatment of staff vacation time.
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; the remaining amount of each subcontract is exempt from Harvard overhead.
indirect cost rate
should I use on a proposal to a foundation?
The Kennedy School requires that all proposals include indirect
costs at a minimum of 20%. If a foundation has a published policy
(e.g. on a web site) to pay less than 20% overhead, the overhead
shortfall must be addressed (see below).
foundation web sites include information on the indirect cost rate
allowed on proposals. If this information is not readily available,
the Research Administration Office may be able to provide historical
information on the overhead rate paid by foundations on past HKS
grants. If the foundation does not specify an indirect cost rate,
the Kennedy School recommends using a 20% indirect cost rate.
if the sponsor's firm policy is to pay less than 20% overhead, or
no overhead at all?
There are three ways to compensate for the overhead shortfall on
1) Center/Program unrestricted funds offset by grant direct costs
will subsidize the overhead shortfall.
2) Other Center/Program funds will directly subsidize the overhead
3) A waiver from the Sponsored Research Overhead Support Fund
is requested and approved
proposed method of compensating for an overhead shortfall should
be addressed via e-mail to Matthew
Alper, copying Charlene
Arzigian, at the earliest possible stage. The overhead shortfall
must be addressed before a proposal and Dean's Approval can be processed.
reviewing sponsored overhead shortfalls, the Academic Dean will
give due consideration to a variety of factors. These include, but
are not limited to:
The degree of direct engagement of the project PI and of other
HKS faculty members;
specific connection of the new proposal to other HKS research,
teaching and outreach activities;
degree to which the new proposal would impose incremental costs
(financial and otherwise) on HKS infrastructure services.
is the Sponsored Research Overhead Support Fund?
Sponsored Research Overhead Support Fund is an internal Kennedy
School fund created as one way to address the shortfall on sponsored
research proposals that do not include the normally required minimum
indirect cost rate of 20%. A memo describing the Sponsored Research
Overhead Support Fund is posted on ResearchCentral: http://www.HKS.harvard.edu/research/hvhpolicies.htm
should I calculate the indirect costs in a proposal budget?
Overhead is calculated on the modified total direct cost base, which
includes all direct costs that are eligible for overhead. Examples
of direct costs that would be excluded from the modified total direct
cost base are subcontracts above the first $25,000 to other institutions and equipment valued
a proposal budget with a MTDC base of $80,000, no costs that are
exempt from overhead, and a 20% overhead rate, the overhead is calculated
as follows: $80,000 * .20 = $16,000.
project budget = $80,000 direct costs + $16,000 overhead = $96,000
a proposal budget with a MTDC base of $125,000, a $30,000 subcontract, and a 68% overhead rate, the overhead
is calculated as follows:
direct costs $125,000 - $5,000 of subcontract exempt from overhead = MTDC of $120,000.
* .68 = $81,600
project budget = $125,000 direct costs + $81,600 overhead = $115,950.
should I calculate indirect costs when I am creating a budget based on a fixed total
you are developing a proposal budget based on a fixed total project
amount that you will request from a sponsor, the breakdown between
direct and indirect costs is calculated as follows:
project budget is capped at $100,000. Overhead rate paid by the
sponsor is 20%.
= $83,333 direct costs.
direct costs * .20 = $16,667 overhead
$83,333 direct costs + $16,667 overhead = $100,000 total project
project budget is capped at $50,000. Overhead rate paid by the sponsor
= $29,762 direct costs.
direct costs * .68 = $20,238 overhead
$29,762 direct costs + $20,238 overhead = $50,000 total project
Signing Documents Related To Proposals And Awards
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.
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.
Sponsored Project Or Gift?
is the difference between a sponsored project and a gift?
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
and the Kennedy School's Office of External Affairs manage the administrative
details for research supported by gift money.
Office for Sponsored Programs has designated certain criteria for
determining whether an award is a sponsored project or a gift. 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:
Proposal terms: a formal proposal or a simple letter proposal requesting
funding for a specific project is submitted to a sponsor.
Scholarly terms: terms that bind the University to a line of scholarly
or scientific inquiry specifying a substantial level of detail.
Deliverables: Sponsor requires annual progress reports/technical
reports. Similarly, sponsor may define performance objectives such
as a detailed report and a timetable for meeting objectives including:
a) terms which specify the time and place for delivery; and b) terms
which detail milestones.
Fiduciary Responsibility: Terms that specify adherence to a line-item
budget that details expenses by activity, function, and/or project
period. The designation of facilities and administrative costs (or
indirect costs) qualifies a budget as "line item." Terms that require
financial reports; terms that require that the award be subject
to external audit; terms requiring unexpended funds be returned
to the sponsor at the conclusion of the project.
Property: Sponsor may provide for the disposition of tangible and
intangible property that results from the project. Tangible property
includes equipment; records; technical reports; theses and dissertations,
etc.; Intangible property includes data; copyrights and/or inventions.
Gifts Policy Committee
is the Gifts Policy Committee (GPC)?
gifts to the Kennedy School are reviewed by the Gifts Policy Committee
(GPC). Comprised of senior representatives of the HKS Financial
Services, External Affairs, and Research Administration Offices,
the GPC is well positioned to advise the Dean, Academic Dean, and
Executive Dean on financial and administrative matters related to
selected gift opportunities.
for GPC review may be submitted to any Committee member by faculty
or a senior staff member at any time (via email with relevant attachments).
A GPC member will acknowledge receipt of a proposal for review,
and will circulate the material to the other Committee members.
If no issues are identified, expedited approval notification will
be given quickly. Otherwise, the proposal will be discussed at the
next GPC meeting. Follow up questions, comments and next steps will
be returned as quickly as possible following committee discussion.
At the conclusion of the discussion and follow-up process, the Committee
will make a recommendation to the Dean that: a) the gift opportunity
be pursued (or accepted) as proposed, b) the gift be accepted but
only with specific modifications, or c) the gift be declined and
solicitation discussions discontinued. A final decision will then
be relayed to the Center/Program/faculty member requesting the initial
more information, please see: Gifts