Guidance for Harvard Administrators

policies and guidance

Agencies and Organizations Following the PHS fCOI Regulations

The Harvard University Policy on Individual Financial Conflicts of Interest for Persons Holding Faculty or Teaching Appointments (pdf) was approved in May, 2010. It was revised in May, 2012 and later supplemented by Procedures for the Implementation of the U.S. Public Health Service Final Rule on the Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought (pdf).

Under both the University Policy and the PHS regulations, individuals with faculty and teaching appointments and PHS "investigators" must file with their School an annual disclosure of significant financial interests in related outside entities.  This disclosure must be on file before an individual may submit a proposal for sponsored funding, and must be updated within 30 days of the discovery or acquisition of a new significant financial interest.

To facilitate compliance with the new PHS regulations and the University policy, a working group of representatives from the Office of the Vice Provost for Research (OVPR), the Office for Sponsored Programs (OSP), Harvard University Information Technology (HUIT), and Financial Systems Solutions (FSS), has implemented upgrades to the conflict of interest business process and electronic form that collects annual disclosures under the University policy ("the annual fCOI system"), and GMAS.  As part of these upgrades, all individuals covered by the University policy in schools using the annual system, as well as PHS investigators in those schools, after August 24, 2012, will disclose significant financial interests related to their University activities using the annual system.  

As an administrator, you should be familiar with the PHS regulations, the University policy, and your School's "implementation plan" (describing the COI process at the School).  To facilitate the transition to the new business process and systems, the Office of the Vice Provost for Research will provide policies, guidance and other information on this site as they become available. For any questions that you are not able to answer by reference to materials on this site, please contact your School's Conflict of Interest Officer (pdf), or Jodi Barry in the Office of the Vice Provost for Research.