The American Recovery and Reinvestment Act (ARRA) of 2009 was signed by President Obama on February 17, 2009. The ARRA commits $787 billion in stimulus funds, a portion of which will be allocated towards sponsored research.

The Office of the Vice Provost for Research (VPR) has established a webpage to support faculty in their effort to respond to ARRA. Agency websites are posting any agency-specific information and are linking to www.recovery.gov. Please refer to the VPR site for up to date information on funding opportunities and agency links: http://research.harvard.edu

We have been getting questions on specific elements of cost in budgets for Stimulus funds. We provide this information to reflect the University's current position on some key cost issues.

Tuition - Tuition and tuition remission are important elements of research training and research. Provost Steven Hyman has decided that Harvard University will permit graduate student tuition to be charged as appropriate on ARRA-funded research projects.

Indirect costs on subcontracts issued on NIH supplements - Indirect costs should be applied to the first $25k of expenses on new subawards. The University's three rate agreements with the federal government state that indirect costs should be applied to total direct costs excluding "that portion of each subaward in excess of $25,000." We understand that depending on the scope of work for each subaward, there could be differing degrees of clarity about whether a subaward is a new award or a continuation of the subaward issued under pre-stimulus funds. The decision should be driven by the scope of work on the subaward, but a reasonable presumption would be that stimulus-funded supplements will require the creation of new scopes of work with different deliverables; accelerated timetables; additional and more frequent reporting; and, expedited billing.

Direct Charging Research Administration costs (updated 5/20/2009) - The NIH has announced that “the ARRA requirements do not provide sufficient justification to support the provision of direct costs for administrative support in addition to the [indirect] Facilities and Administrative costs in the award budget.”  The announcement adds that “when direct costs have been requested to address ARRA administrative and reporting requirements in requested budgets, NIH staff will make appropriate adjustments.” http://grants.nih.gov/recovery/faqs_recovery.html#If4

The Schools, of course, will need to comply with these guidelines which do not allow for the inclusion of Stimulus Specialist positions in proposal budgets. As such proposals being submitted for ARRA funding opportunities should not include budgeting for administrative staff.   At the same time, however, Harvard maintains there exists a clear need for enhanced and focused administrative support to effectively manage the workload associated with Stimulus awards.  The increased volume of expenditures over sharply compressed time frames, coupled with expanded reporting requirements, demands prudent risk management on the part of the University.  Despite the unfortunate decision against allowing the direct charging of such costs, we expect the Schools to move forward and designate appropriate resources (whether by new hiring or reassignment) to support the effective administration of ARRA awards. These Specialists will be responsible and accountable for ARRA award spending, data collection, and data analysis required for mandatory quarterly reporting. Use of a single position description and targeted training for designated Stimulus Specialists is still planned. 

Carryforwards and supplements - We have gained clarification regarding the April 3, 2009 NIH NOT-OD-09-080 on carryforwards and supplements. Specifically, the guidance seemed to imply that parent grants needed to be financially closed in order to transact to ARRA supplements. The NIH Division of Grants Policy confirmed that the purpose of the announcement was to emphasize that the funds could not be co-mingled. The parent grant and supplement can be in sync with each other or out of sync, but there is no policy requiring that only one be open at a time. Carryover from a budget period funded with "regular" money into a budget period with ARRA funds is not allowable and carryover from an ARRA budget period into a budget period funded with "regular" money is not allowable. We will continue to work with NIH to obtain clarity whenever necessary.

There is an unprecedented level of transparency and accountability associated with ARRA funding that is beyond standard practice typically associated with a federal award. In addition, the agencies have only two years to spend the funding. Final guidance with detail on specific reporting and collection instructions on this information is still to come. However, to date we know the following:

• The government will require quarterly ARRA reporting with quick turn-around times (i.e., within 10 days after the end of the quarter),
• Inclusion of Sub recipients in those reports,
• A reporting of an estimate of the number of jobs created and jobs preserved
• Timely expenditure of funds; close adherence to purpose of spending and monitoring to ensure that fraud or waste does not occur
• Expectation of a government response if funds are not being spent "fast enough",
• Accurate tracking of each award and award completion status; and
• Cash management, including the draw down of ARRA funds, on an award-specific basis; as well as
• Anticipated implications for the A-133 audit

These expanded reporting responsibilities will make it important to distinguish a recovery act fund from other non recovery act funding. In addition, they clearly have significant implication on university pre and post-award functions as well as our information systems that support sponsored research; particularly as relates to maintaining unique attributes for ARRA funds. As we await greater clarity on specific reporting, the Office for Sponsored Programs (OSP) is taking steps to understand and prepare for the additional assurances and compliance responsibilities associated with these awards based on what we do know. This involves working together with our sponsored offices across the university to actively assess administrative practices necessary to support these reporting responsibilities and the most efficient delivery mechanisms.

As the agencies begin to release more details on reporting requirements OSP will utilize this site as well as other internal communiqués to share the most current information. In the meantime, as questions arise in your local areas related to ARRA proposal submission and reporting requirements, please contact your designated sponsored leadership for guidance.

To facilitate transparency and reporting, agencies will be establishing pages on their existing website dedicated to the Recovery Act, which will link to Recovery.gov and will provide a single portal for all agency-specific information related to the Act. More websites will be listed as they become available.