FAQs

HMS is submitting a proposal with an investigator from another Harvard school or affiliated institution. Since HMS has distinct COI policies and procedures, should the investigator follow their own school's/affiliated institutions' or ours using OAR?

If the investigator is from another Harvard school or an affiliated institution but listed as an investigator on a grant proposal submitted through HMS, the investigator must follow the HMS process. When the investigator is added to the research team in GMAS, an OAR certification will be automatically created and the investigator will receive an email notification to complete the certification and upload their school or affiliated institution’s disclosure form. Alternatively, the investigator may give ARI permission… Read more about HMS is submitting a proposal with an investigator from another Harvard school or affiliated institution. Since HMS has distinct COI policies and procedures, should the investigator follow their own school's/affiliated institutions' or ours using OAR?

A consultant (or Other Significant Contributor) on my proposal has been designated as an investigator. They can’t access the OAR system; how do they submit a COI certification?

If the consultant (or Other Significant Contributor) on your proposal has been designated as an investigator, and they cannot access the OAR system, complete the following steps:

The PI on a new application is not yet Harvard employee but listed on the grant proposal to do research here, so (s)he doesn’t have access to Harvard’s systems, including GMAS and OAR. What do I do if they can’t submit a COI certification using OAR?

If the PI is not yet employed by Harvard, he/she must fill out a paper COI Disclosure Statement form and an Outside Activities Reporting form. Once the PI completes both forms, they will be uploaded to GMAS. For approval to submit, ARI must review and approve. Once the PI has started employment at Harvard and is set up in OAR, the disclosure forms will be uploaded to the OAR system.

Is the PI of an award always considered an investigator?

Yes.  Investigators include any individual who is responsible for the design, conduct, or reporting of research. PI’s will always be responsible for the design, conduct, or reporting of research and therefore will always be considered an investigator.

I’m a grant manager, if my PI didn’t tell me which personnel on their grant proposal should be marked as an investigator, can I figure it out by the role they play on the grant? Is there guidance about which roles are investigators and which aren’t?

 

You should always ask the PI which personnel on their grant proposal should be marked as an investigator as, ultimately, it is the PI’s responsibility to identify other investigators on the project.

You can find additional information about who is considered an investigator under the PHS regulations in the Frequently Asked Questions posted on the NIH website (http://grants.nih.gov/grants/policy/coi/coi_faqs.htm#D). According to the NIH, investigators are any individual, regardless of title or position, who… Read more about I’m a grant manager, if my PI didn’t tell me which personnel on their grant proposal should be marked as an investigator, can I figure it out by the role they play on the grant? Is there guidance about which roles are investigators and which aren’t?

What back-up documentation is needed in order for an outgoing sponsored trainee billing agreement to be issued? What back-up documentation is needed in order for an incoming trainee billing agreement to be approved and signed?

In order to approve an outgoing trainee billing agreement, SPA will need the completed billing agreement template (provided by SPA) with the completed Statement of Appointment for the covered trainee.

In order to accept an incoming sponsored trainee billing agreement, SPA will need a copy of the completed Statement of Appointment for the covered trainee and for the department to confirm in writing (via email when forwarding the billing agreement for review is OK) that the information contained in the billing agreement is correct and that the department is willing to accept the… Read more about What back-up documentation is needed in order for an outgoing sponsored trainee billing agreement to be issued? What back-up documentation is needed in order for an incoming trainee billing agreement to be approved and signed?

Will SPA process an outgoing sponsored BA4T under an advance account or when continuation funding is anticipated but not yet received?

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.

What are the criteria for when use of a billing agreement for trainees (BA4T) is appropriate?

A Billing Agreement is generally appropriate under the following circumstances in the case of a training award:

  • Trainee will have/has an appointment at the non-grantee institution.
  • The trainee’s Mentor has an appointment at the trainee’s institution (non-grantee) or the grantee institution.
  • Reimbursement may be requested by the trainee’s institution for the direct costs of the trainee stipend, tuition/fees, travel and training related expenses.

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