FAS Research Administration Services

Conflicts of Interest and Conflicts of Commitment


Conflicts of Interest and Conflicts of Commitment Policies

FAS Policies Relating to Research and Other Professional Activities Within and Outside the University (Nov 2000)
This document outlines FAS rules regarding potential conflicts of commitment, gives examples of activities and situations that could lead to potential conflicts, and explains where individuals should go for further information.
Statement on Outside Activities of Holders of Academic Appointments (July 2000)
This document summarizes University policies regarding the outside activities of academic appointees, with particular reference to teaching, research, consulting, the use of Harvard identification, and the production of electronic teaching materials.
University Policy on Individual Financial Conflicts of Interest for Persons Holding Faculty and Teaching Appointments (May 2012)
This policy establishes a University-wide system for identifying, evaluating, and managing financial conflicts of interest and applies to all holders of Faculty or teaching appointments in the University.
University Procedures for the Implementation of the PHS fCOI Regulations (August 2012)
This document provides procedures specific to 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 (42 CFR Part 50).
FAS Policy on Financial Conflicts of Interests Disclosures (May 2013)
This document represents the FAS policy and implementation plan and includes the FAS fCOI disclosure reporting, review, and determination procedures.

Financial Conflict of Interest Disclosure for Federal Support

In accordance with the Public Health Service (PHS) and the National Science Foundation (NSF) financial conflict of interest regulations, all Investigators applying for funding from the PHS (including NIH, CDC, HRSA, and AHRQ), sponsors adopting the PHS regulations (including the American Heart Association, American Cancer Society, Arthritis Foundation, Susan G. Komen Foundation, and the Alliance for Lupus Research), or the National Science Foundation (NSF) must submit a financial conflict of interest (fCOI) disclosure form. Investigators (defined as "project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research”) for each proposal must be identified by the Principal Investigator early in the proposal preparation process. At a minimum, “Investigators” must include “key persons” listed in the research proposal.


As of August 24, 2012, proposals cannot be submitted to the PHS, sponsors adopting the PHS regulations, or NSF until all listed Investigators’ financial disclosures are on file with the University.


Spending on new PHS (including sponsors adopting the PHS regulations) and NSF awards received after August 24, 2012 cannot begin until all listed Investigators have taken fCOI training, which is part of the disclosure process, and all listed Investigators’ financial disclosures have been fully reviewed by the University.

Travel for PHS Investigators

The revised PHS fCOI regulations now include a requirement for Investigators on PHS projects to disclose the occurrence of travel paid by outside entities (where the aggregate of significant financial interests and travel reimbursements from the single entity exceeds $5,000 in the previous twelve months), which can be done using the online Financial Interest Disclosure application. Any Investigator receiving PHS funding must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid by a third party directly to or on behalf of the Investigator so that the exact monetary value may not be readily available), related to their institutional responsibilities; provided, however, that this disclosure does not apply to travel that is reimbursed or sponsored by a federal, state, or local government agency, a U.S.-based institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education. In addition, this disclosure does not apply to travel that is reimbursed through the University.
Please refer to the Travel Disclosure Quick Guide for step-by-step instructions on submitting a travel disclosure.

Important Links



Questions about this process should be addressed to Denise Moody (x6-3090) or Sam Schwartz (857-998-2071).


[Last modified: 03/07/14]

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