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Professional Employment Organizations (PEOs) – Attestation of Contract Employees on Federal Awards

Overview

This document outlines the business process for the attestation of expenses for contract employees paid via a Professional Employment Organization (PEO) on federal awards.  These contract employees are hired by the PEO and not employees of Harvard and typically reside in a state that Harvard University is not registered, or they are international. 

Business Process

Proposal Preparation

When developing a proposal, costs for PEOs should be budgeted as “Other Services” not as personnel costs. 

Receiving and distributing the Attestation Statements

  1. PEO reports have been built in BI Publisher and will be distributed quarterly to identified School Reps via email.
    1. PEOs were built pulling object code 8221 on federal awards or object code 7980 for Harvard Global (International)
  2. School reps will distribute the attestation statements to the department/Unit responsible for managing the award. 
  3. The PI will review the expenses for accuracy and sign the attestation statement(s).   
    1. Note:  DZConnex/YoH provides a 1% credit for each line item charged.
  4. The local unit is responsible for uploading the signed statement(s) in GMAS* in line with quarterly effort cert dates (see GMAS steps below)
  5. Once these are signed, if the charge needs to be moved to another federal award, they need an approved CT to move charges on to the federal award, please refer to the Cost Transfer Policy. 

Timeline of Quarterly Release

  1. The BI Publisher Reports will follow the ecrt quarterly attestation dates.

Storage/Retention

Signed attestation statements will need to be uploaded to GMAS to the applicable award.  Please tag the document as a PEO, please reference Appendix A to learn how to tag a document in GMAS

Ongoing Monitoring of PEOs

The Financial Compliance Working Group will be responsible for annual monitoring of PEOs to ensure they are signed and uploaded to GMAS.

Journals

When journaling expenses for PEOs (object code 8221 or 7980) please remember to debit/credit the 1% credit that accompanies the debit.

  • If you are crediting a federal award, you must also debit the 1% credit
  • If you are debiting a federal award, you must also journal the 1% credit

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