The American Recovery and Reinvestment Act of 2009

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.

Guidance on Key Costing Issues

In response to inquiries about specific costing elements in Stimulus budgets, we have provided the following 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

Each school accross the University must comply with these guidelines which do not allow for the inclusion of School ARRA Specialist (SAS) positions in proposal budgets.Additionally, proposals being submitted for ARRA funding opportunities cannot include budgeting for administrative staff. However, Harvard maintains that a need exists 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 administrative costs, we expect the Schools to move forward and designate appropriate resources (whether by hiring new employees or reassigning existing staff) to support the effective administration and monitoring of ARRA awards. These SASs will be responsible and accountable for ARRA award spending, data collection, and data analysis required for mandatory quarterly reporting. The use of a single job description and targeted training for designated SASs facilitated a consistent reporting methodology accroess the University. 

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.

Compliance and Assurances

There is an unprecedented level of transparency and accountability associated with ARRA funding that is beyond the standard practice typically associated with a federal award. In addition, the agencies have only two years to obligate the ARRA funding (by September 30, 2010). Guidance with detail on specific reporting and collection instructions on this information continues to be updated. 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 and vendors in those reports,
  • A reporting of an estimate of the number of jobs created /retained
  • 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 in a timely manner,
  • Accurate tracking of each award and project status
  • Cash management, including the draw down of ARRA funds, on an award-specific basis
  • Additional A-133 audit implications

These expanded reporting responsibilities will make it important to distinguish Recovery Act funding from other non -Recovery Act funding. As a result there are clearly significant implications on university pre and post-award functions as well as our information systems that support sponsored research; particularly as they relate to maintaining unique attributes for ARRA funds. The Office for Sponsored Programs (OSP) has worked closely with the sponsored offices accross the university to actively assess administrative practices necessary to support the ARRA reporting responsibilities and develop the most efficient delivery mechanisms.

As questions realted to ARRA proposal submission and reporting requirementsarise in your local areas, please contact your designated School ARRA Specialist (SAS). Should you receive any audit inquiries or audit requests, please contact marc_todesco@harvard.edu

School Contact Email Phone Number
FAS Rady Rogers rmrogers@fas.harvard.edu 781-697-9215
FAS Charlotte Mallio cmallio@fas.harvard.edu 857-998-2051
FAS Samantha Schwartz sschwartz@fas.harvard.edu 857-998-2071
GSE Tiffany Cott tiffany_cott@gse.harvard.edu 617-495-6342
HMS Lorraine Stringer lorraine_stringer@hms.harvard.edu 617-432-2664
SEAS Ann Cahill acahill@seas.harvard.edu 617-495-9057
SPH Kristie Froman kfroman@hsph.harvard.edu 617-432-8141

ARRA News

Reporting

Internal Reporting Resources

Resources

Agency Recovery Websites

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

School Websites

Presentations