Principal Investigator

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.

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, Mary Jo Bane, copying Matthew Alper and Charlene Arzigian.

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HKS Research Administration Office

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). 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.

Other 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;
• Along 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.
• Managing and marketing the Dean's Research Fund for internal faculty seed grants;
• Developing and maintaining the HKS Faculty Research Working Paper series and the HKS electronic research paper series published by the Social Science Research Network (SSRN);
• Producing and distributing (hardcopy and electronic) the HKS Research Report, including publication citations from all HKS faculty, centers and programs, and other activities.

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Faculty Committee on Projects and Proposals (FCOPP)

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:

(1) the project is of very large scale (indicated by a total annual budget in excess of $1,000,000);

(2) the project involves substantial engagement and coordination with non-Harvard organizations;

(3) the level of (budgeted plus unbudgeted) effort devoted by the project’s Principal Investigator (PI) is less than 10% of the PI’s total time and less than 10% of the total professional time on the project;

(4) 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

(5) the project may pose particular risks for the School, the University, its faculty, students, or staff.

In its reviews of projects, FCOPP addresses three key issues:

(1) Is the project directed by a Principal Investigator (PI) with a long-term interest in the School?

(2) 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

(3) Does the project pose no more than reasonable risk to the School, the University, its faculty, students, or staff?

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.

Faculty Committee on Projects and Proposals Scope, Standards, and Procedures

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Harvard University Office for Sponsored Programs

What is the Role of Harvard University's Office for Sponsored Programs (OSP)?
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.

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Dean's Approval Process

What 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.

What is the Dean's Approval Form?
The Dean's 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 Process.

What are the elements of review of the Dean's Approval Process?
The RAO reviews proposals and budgets for compliance with policies on the following:

• Additional space required for TBN or existing personnel
• Overhead rate
• Use of Human Subjects in Research
• Use of the Harvard Name
• Potential Conflict of Interest
• Cost Sharing
• Direct Charging of salaries/administrative costs to federal grants
• Review by the Faculty Committee on Projects and Proposals
• Subcontracts

Can 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.

How will I know when the RAO has processed the proposal?
When 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.

When 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 Programs.

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RAO Proposal Submission Guidelines

How Far in Advance Do I Need to Submit a Proposal to the RAO?
In order 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 1, 2007:

(1) 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.

For further information, please see the RAO Proposal Submission Guidelines.

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No-Cost Extensions

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 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.

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Preliminary Proposals

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. 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.

If 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 established.

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Advance Accounts

Can I charge expenses to a project before an official award is made or before OSP completes its negotiations on an award?

Yes, 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.

To download the Advance Account form, please click on the following link.

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Use of Human Subjects in Research

How can I determine whether my proposed use of human subjects or human subjects data needs review by the Committee on the Use of Human Subjects?

The 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 page: http://www.HKS.harvard.edu/research/hvhpolicies.htm. 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 Arzigian.

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Use of Harvard/Kennedy School Names and Insignias

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 Charlene Arzigian.

For the complete policy, please see the Provost's website:
http://www.provost.harvard.edu/policies_guidelines/useofname/names_insignias.php

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Principles Governing Commercial Activities

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 Charlene Arzigian.

For the complete policy, please see the Provost's website:
http://www.provost.harvard.edu/policies_guidelines/commercial_activities_summary.php

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Fringe Benefit & Facilities and Aministrative (Indirect/Overhead) Cost Rates

What fringe benefit rates should be used in a proposal budget?

In addition to the current FY08 fringe benefit rates, listed below are the FY09 rates as negotiated with the Department of Health and Human Services. The rates for FY10 and FY11 are estimates and subject to change. Please use these rates in all new sponsored proposal budgets.

* Not final - subject to change. Final rate will be announced as soon as it is available.

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 February 20, 2008.  Rates are determined through FY10; for FY11 and beyond please use the FY10 rates.

Click [here] for a printable version of the above chart. Click [here] for more information about Harvard's new policy regarding treatment of staff vacation time.

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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; the remaining amount of each subcontract is exempt from Harvard overhead.

What 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).

Many 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.

What 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 a proposal:

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 shortfall.
3) A waiver from the Sponsored Research Overhead Support Fund is requested and approved

The 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.

In 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;
• The specific connection of the new proposal to other HKS research, teaching and outreach activities;
• The degree to which the new proposal would impose incremental costs (financial and otherwise) on HKS infrastructure services.

What is the Sponsored Research Overhead Support Fund?

The 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

How 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 to other institutions and equipment valued over $5000.

For 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.

Total project budget = $80,000 direct costs + $16,000 overhead = $96,000

For a proposal budget with a MTDC base of $75,000, a $10,000 subcontract that is exempt from overhead, and a 63% overhead rate, the overhead is calculated as follows:

Total direct costs $75,000 - $10,000 exempt from overhead = MTDC of $65,000.

$65,000 * .63 = $40,950

Total project budget = $75,000 direct costs + $40,950 overhead = $115,950.

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How should I calculate indirect costs when I am creating a budget based on a fixed total project amount?

If 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:

Example 1:

Total project budget is capped at $100,000. Overhead rate paid by the sponsor is 20%.

$100,000/1.20 = $83,333 direct costs.

$83,333 direct costs * .20 = $16,667 overhead
$83,333 direct costs + $16,667 overhead = $100,000 total project budget.

Example 2:

Total project budget is capped at $50,000. Overhead rate paid by the sponsor is 63%.

$50,000/1.63 = $30,675 direct costs.

$30,675 direct costs * .63 = $19,325 overhead
$30,675 direct costs + $19,325 overhead = $50,000 total project budget.

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Signing Documents Related To Proposals And Awards

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.

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Sponsored Project Or Gift?

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 and the Kennedy School's Office of External Affairs manage the administrative details for research supported by gift money.

The 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:

1. Proposal terms: a formal proposal or a simple letter proposal requesting funding for a specific project is submitted to a sponsor.

2. Scholarly terms: terms that bind the University to a line of scholarly or scientific inquiry specifying a substantial level of detail.

3. 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.

4. 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.

5. 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.

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Gifts Policy Committee

What is the Gifts Policy Committee (GPC)?

Potential 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.

Proposals 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 review.

For more information, please see: Gifts Policy Committee

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