Billing Agreements

Will SPA process an outgoing sponsored BA4T under an advance account or when continuation funding is anticipated but not yet received?

In the case of training awards, certain appointment paperwork for the trainee is often required before the trainee can be paid (such as an appointment via xTrain for trainees on an NIH award).  Because this paperwork often cannot be submitted until an initial award or continuation funding has been received, this would prevent the billing agreement from being established.  However, each case would be handled based upon the terms of the particular training award and the risks of the situation at hand.

What are the criteria for when use of a billing agreement for trainees (BA4T) is appropriate?

A Billing Agreement is generally appropriate under the following circumstances in the case of a training award:

  • Trainee will have/has an appointment at the non-grantee institution.
  • The trainee’s Mentor has an appointment at the trainee’s institution (non-grantee) or the grantee institution.
  • Reimbursement may be requested by the trainee’s institution for the direct costs of the trainee stipend, tuition/fees, travel and training related expenses.

What back-up documentation is needed in order for an outgoing sponsored salary billing agreement to be issued? What back-up documentation is needed in order for an incoming salary billing agreement to be approved and signed?

The assumption of the billing agreement guidance is that the personnel covered by the billing agreement will have been included in the budget and the grantee and non-grantee institution will have agreed that a billing agreement is appropriate at the time of proposal.  In the event that this is not the case, we should confirm with the other party that a billing agreement is appropriate before proceeding.  In order to do so, SPA/OSP will need confirmation that the following conditions are met:

Read moreWhat back-up documentation is needed in order for an outgoing sponsored salary billing agreement to be issued? What back-up documentation is needed in order for an incoming salary billing agreement to be approved and signed?

Will SPA process an outgoing sponsored billing agreement under an advance account or when continuation funding is anticipated but not yet received?

The risk of issuing a billing agreement is the theoretical equivalent of setting up Harvard personnel to be paid from the advance account.  However, there is the added element of the agreement being through an outside organization.  The risk of issuing the billing agreement under these circumstances should be evaluated on a case by case basis so that the department who administers the award can determine whether they are willing to accept the financial risk under the specific circumstances.

I am preparing a research award budget which involves issuing a BA for an affiliate’s employee. Whose FB rates should be used when budgeting the individual’s salary and fringe? Who will recover F&A on the salary and FB for the employee?

Because the grantee institution will reimburse the non-grantee institution for both salary and fringe, fringe for the individual should be budgeted using the non-grantee institution’s rate.  For example, if an individual whose primary appointment is at BWH is included in a Harvard budget via a billing agreement, BWH’s fringe rate should be used in the budget for that individual.

Read moreI am preparing a research award budget which involves issuing a BA for an affiliate’s employee. Whose FB rates should be used when budgeting the individual’s salary and fringe? Who will recover F&A on the salary and FB for the employee?

What issues should I consider in situations that are not covered by a joint appointment?

The current recommendation is that these support staff sign the Risk and Release form.  OTD’s preference is that these individuals would also sign the Visitor’s IP Agreement; however, many of the institutions with whom we execute billing agreements would not be willing to sign off on the Visitor’s IP Agreement for their staff.  Thus, if there is the potential that the individual will be involved in the development of IP in the course of the project, a subaward agreement should be used in place of a billing agreement.

When Harvard is issuing an outgoing sponsored billing agreement, should the individual be included on the Research Team in GMAS?

Yes. Since a subaward agreement is not being issued, compliance requirements are not being flowed down to the individuals’ payroll institution (see above).  Thus, individuals being paid through a billing agreement should remain on the Research Team in GMAS.  Please work with SPA to clear any approvals generated as a result (COI, Participation Agreement, and Human Research Participant Protection Training).

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