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.
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:
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.
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.
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.
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).