FAQs

HMS is submitting a proposal that includes a mentor from an institution outside of Harvard. The mentor can’t access the OAR system; how do they submit a COI certification?

 

If the mentor included on your proposal cannot access the OAR system, complete the following steps:

  • Complete a “person of interest” form to obtain a HUID
  • The mentor should choose the Consultant Role on the person of interest form.
  • Once the HUID has been issued, the individual will need to set up their login through the PIN system (
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My PI is out of town and hasn’t submitted a COI certification for his/her proposal, which is due soon. If the PI doesn’t certify before the proposal due date, can the proposal still be submitted? Who can I speak to for an exception to the policy?

 

The outside activity disclosure certification must be completed by proposal submission. If the PI is having difficulty completing their submission, he/she should contact ARI for assistance.  Additionally, you can let your SPA contact know and they will alert ARI is well. 

ARI can be reached at outside_activities@hms.harvard.edu or (617)432-1343.

I’m submitting a proposal with a subaward whose PI is considered an investigator, and the subrecipient is a small organization that doesn’t have a PHS compliant COI policy in place. How should we handle this at time of submission to be compliant?

When you add an individual to the research team and answer the question “Is this person responsible for the design, conduct or reporting?”, answer “No” for subcontractor investigators.

HMS is responsible for ensuring that any sub-recipient's institution affirms that the institution has a PHS compliant COI policy and will report any FCOIs identified to HMS in a timely manner.  HMS will be responsible for reporting it to PHS prior to any spending on subaward (or prior to commencement of new investigator participation).  If sub-recipient institution does not have a COI policy

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