Harvard OSP || Disclosure Statements and A-133 Audits

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Disclosure Statements and A-133 Audits

The Department of Cost Analysis, located within the Office for Sponsored Programs, has the primary responsibility for developing, supporting and negotiating the University Area F&A proposals and Disclosure Statements. This office works very closely with the Cost Analysis and Compliance units at HMS and SPH in driving cost policy and resolving compliance issues. Additionally, OSP-Cost Analysis coordinates the annual OMB A-133 audit, performed by external auditors to test the University's compliance with federal regulations.

Documents

In the early 1970's, the Cost Accounting Standards Board (CASB) was created by Congress to address allegations of inconsistent costing practices by recipients of federal awards, e.g. Defense Department contractors, and to develop costing standards. In 1996 OMB formally incorporated CASB cost accounting standards into OMB A-21, which requires universities to confirm their compliance with the standards and to complete a formal Disclosure Statement (DS-2) if the university receives over $25 million in federal funding. The DS-2 must be on file with the U.S. Department of Health and Human Services in Washington D.C. Because Harvard has three F&A rates due to differences in costing policies, the University is considered to be three segments under CASB: University Area (Cambridge-based schools and Harvard Business School), HMS, and SPH. Each area must submit its own DS-2.

OMB A-133 Audit Reports
OMB Circular A-133 requires annual audits of States, Local Governments, and Non-Profit Organizations who receive federal funding exceeding $500,000. Harvard University's A-133 report includes Harvard Medical School and Harvard School of Public Health. The audit of selected federal awards is done by external auditors, Pricewaterhouse Coopers, LLP, and ultimately approved by Harvard. If any audit findings are made, Harvard must respond with a corrective action plan. Please refer to Section IV for findings and corrective action plans.

The A-133 report is due annually by March 31 and is submitted to a federal clearinghouse. Any agency or individual with access to the federal clearing house may receive Harvard's or other A-133 reports. It is presented here for reading or printing.

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