# Compliance ## expand\_more Open all sections Close all sections ### Cost Sharing expand\_more Cost sharing is an arrangement where certain project costs are not funded by the sponsor, but are instead covered by Harvard or a third party, to support the scope of work of a sponsored award. **For more information:** [Cost Sharing Policy](https://osp.finance.harvard.edu/cost-sharing-policy) ### Data Security expand\_more Responsible data handling is critical, and requirements depend on several variables including the sensitivity of data, where data is collected, the parties accessing/handling data, and any additional sponsor requirements. The University’s Information Technology office has resources for determining [data security levels](https://privsec.harvard.edu/classify-risk) as well as guidance on [protecting digital and physical data](https://privsec.harvard.edu/shield-data), which outlines systems and tools that can be used for different security levels. Sharing data with other institutions often requires a Data Use Agreement and a Data Safety/Security Plan. Data Use Agreements formalize the parameters governing data sharing between parties; Data Safety/Security Plans document the management of research data such as storage, access, and protections. These are tracked and managed through the [Data Use Agreement system](https://dua.harvard.edu) and [Data Safety System](https://researchsafety.harvard.edu), respectively. **For more information,** please visit the Office of the Vice Provost for Research resources: [Research Data Management and Policy Compliance Resources](https://research.harvard.edu/research-policies-compliance/research-data-management/) [Research Security Program](https://research.harvard.edu/research-policies-compliance/research-security/) ### Disclosures expand\_more You are responsible for disclosing certain information as a condition of conducting research at Harvard University. **For more information:** [OAIR (Outside Activity and Interest Reporting)](https://ras.fss.harvard.edu/oair) MFTRP (Malign Foreign Talent Recruitment Program) [COI (conflict of Interest)](https://ogc.harvard.edu/pages/conflict-interest) ### Effort expand\_more The Federal government requires that faculty members report and certify compensation and cost shared effort on federal awards. Harvard University uses a web-based system called ecrt to report and certify effort. **For more information:** [Effort Reporting Policy](https://osp.finance.harvard.edu/effort-reporting-policy) [Access ecrt](https://ecrt.harvard.edu/ecrt/initWelcomeRedirect.action) ### Expenses expand\_more When transacting on a grant, it is best practice to consult sponsor guidance, the award agreement, and the approved budget. Below are some other resources that may be helpful to review when spending sponsored funds. **For more information:** [Uniform Guidance](https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1) [Sponsored Expenditure Guidance](https://osp.finance.harvard.edu/sponsored-expenditures-guidelines) [Travel and Entertainment Policy](https://policies.fad.harvard.edu/pages/travel-0) [Tuition Policy](https://osp.finance.harvard.edu/tuition-policy) [Equipment Policy](https://osp.finance.harvard.edu/capital-equipment-policy) ### Human Subjects expand\_more Research involving people always requires an Institutional Review Board (IRB) determination. Harvard has two IRB offices overseeing human research activities: HGSE is part of the Harvard University Area IRB; Longwood Medical Area has its own IRB office. Human subject research requests, documents, and approvals are managed in the Electronic Submission, Tracking and Reporting system ([ESTR](https://irb.harvard.edu)). **For more information:** [Committee on the Use of Human Subjects (Harvard University Area Institutional Review Board)](https://cuhs.harvard.edu/) ### Intellectual Property expand\_more In the course of research, novel intellectual property is often created, such as curricula, software applications, or educational interventions. Harvard’s [Office of Technology Development](https://otd.harvard.edu/) provides guidance on innovations developed at the University, including copyrights, patents, and collaborations with industry partners. **For more information:** [Statement of Policy in Regard to Intellectual Property (IP Policy)](https://otd.harvard.edu/faculty-inventors/resources/policies-and-procedures/statement-of-policy-in-regard-to-intellectual-property/) [Office of Technology page for Faculty & Inventors](https://otd.harvard.edu/faculty-inventors/) ### International Individuals (Restricted Party Screening) expand\_more Based on requirements from the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), U.S. Department of State (“State Department”) and the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”), Harvard University has set forth certain guidelines and processes to ensure the University, including schools like HGSE, are taking reasonable measures to avoid engaging with entities or individuals who are a restricted party or employed by or affiliated with a restricted party and are listed on a Restricted Parties Lists (“RPLs”). Specifically, HGSE is expected to screen all international individuals and entities (including learners, attendees, speakers/panelists, organizers/vendors, clients, program and event hosts, and banks) participating in “educational programs” that HGSE, alone or with others, (1) hosts online or in person with an online option, or (2) sponsors, hosts or organizes outside the United States prior to engaging with them to ensure they are not on a RPL. Additionally, (3) for programs hosted in the U.S., screening is required if the content to be presented is subject to export control; certain technologies, software, and data, among other content, could fall into this category. “Educational program” is broadly defined to include executive and continuing education, not-for-credit summer courses, online programs, workshops, conferences, symposia, and other services and events that have an educational component, regardless of source of funding (sponsored or non-sponsored). Such “educational programs” may be embedded as an element of a sponsored activity, such as a research grant; some may be a single offering or in a series of offerings. All such dimensions require a screening duty if the criteria are met above. If screenings are required, those should be done before any payment is accepted from the individual and/or before the educational offering is provided to the individual. This may require units to build in an additional step into their registration processes. The screening requirement supports enforcement of economic, and trade sanctions put in place by the U.S. Treasury Department and the U.S. Department of State. Their sanctions lists are regularly updated, so screening must take place prior to the start of each program. At HGSE, the primary duty to screen rests with HGSE’s Export Control Officer (ECO) who is informed of the screening need by Principal Investigators (PIs), faculty, administrators and those who have knowledge of the “educational offerings.” However, if the volume and frequency of screenings is over a certain amount, an individual within the HGSE center, lab or unit can be assigned a screening role and granted access to the Visual Compliance software used to screen. The guidance below is for use by such an individual assigned to complete Restricted Party (also known as Visual Compliance) Screenings . **For more information:** [Specially Designated Nationals (SDN) List Screening Process and Monitoring guidance](https://bpb-us-e1.wpmucdn.com/websites.harvard.edu/dist/f/106/files/2022/10/ec_sdn_screening_and_monitoring_guidance_3_21_17-1.pdf) [Export Control Policies and Procedures](https://research.harvard.edu/research-policies-compliance/export-control-policies-procedures/) Screening of Attendees Not Required Screening of Attendees Required ## Screening of Attendees Not Required - Program is hosted by Harvard University\* and is: - Exclusively in-person on Harvard’s campus in the U.S. **OR** - Offered online (including hybrid) or outside the U.S. and: - Open to the public, and - No registration beyond name and email address to access livestream, and - No registration fee or other financial transaction. - Program or event is **NOT hosted**, sponsored, funded, or organized by Harvard (alone or with others\*.) \***NOTE: Screening is REQUIRED** if program content is export controlled or if the program or event is physically taking place in a country subject to comprehensive sanctions (currently: Cuba, Iran, North Korea, or the Crimea Donetsk People’s Republic, or Luhansk People’s Republic areas of the Ukraine.) **\*Screening is required of non-Harvard hosts, sponsors, funders, and organizers.** ## Screening of Attendees Required **DO NOT PROCEED** without screening if one or more apply: - Providing online (including hybrid) education to non-U.S. persons, other than described above in “No Screening Required.” - Hosting, sponsoring, funding, or organizing (alone or with others) a program, conference, or other event abroad. - Providing honoraria or travel reimbursements to non-U.S. persons. - Program content is export controlled.\* \*Most catalogue course content is not considered export controlled. However, when in doubt, contact your School or Institute’s ECO (Export Control Officer.) ### International Activities (Export Controls) expand\_more Projects and activities with international dimensions - including those with international travel, engagement with foreign entities, international funders and the combination of such foreign activities - require additional review, approvals and disclosures, beyond standard review processes for domestic activities. The starting point for the review of such activities with an international dimension should be HGSE’s Committee on International Projects and Sites (CIPS) process \[LINK\], which can also help to inform the University’s [International Collaborations and Activities Approval](https://osp.finance.harvard.edu/international-collaborations-and-activities-approval) . Please keep in mind that during the review process for international activities, many review elements relate to Export Control requirements. At a high level, Export Controls are the federal laws and regulations governing the transfer of items, technology, software, and services to foreign countries or foreign nationals, designed to protect national security, foreign policy interests, and economic competitiveness. They cover both physical shipments and "deemed exports" (sharing technical data with foreign nationals within the U.S.). **For more information:** [Export Control Policies & Procedures](https://research.harvard.edu/research-policies-compliance/export-control-policies-procedures/) [International Collaborations and Activities Approval](https://osp.finance.harvard.edu/international-collaborations-and-activities-approval) [HGSE CIPS Policy](https://hu.sharepoint.com/:b:/r/sites/HGSE-OSP/Shared%20Documents/Website/03_Manage%20Your%20Grant/Research%20Compliance/cips_policy_revised_final_4-11-2023.pdf?csf=1&web=1&e=tQnEHP) [HGSE CIPS Form](https://hu.sharepoint.com/:b:/r/sites/HGSE-OSP/Shared%20Documents/Website/03_Manage%20Your%20Grant/Research%20Compliance/CIPS%20FORM_REVISED_3.5.2024.pdf?csf=1&web=1&e=6pKzoZ) ### Records Retention expand\_more Harvard requires research records to be retained for at least seven years after the end of the project. **For more information:** [Retention of Research Data and Materials](https://osp.finance.harvard.edu/retention-research-data-and-materials). ### Subrecipient Monitoring expand\_more Active subawards are reviewed quarterly to monitor subrecipient performance, including whether work is proceeding satisfactorily, invoices are timely and accurate, and if there are any concerns around noncompliance with applicable regulations. **For more information:** [Subrecipient Monitoring Policy and Resources](https://osp.finance.harvard.edu/subrecipient-monitoring-policy) ### Trainings, Attestations, and Certifications expand\_more [### Collaborative Institutional Training Initiative (CITI) ](https://about.citiprogram.org/)Collaborative Institutional Training Initiative (CITI) training provides essential, web-based education on research ethics, compliance, and regulations, especially for human subjects research. [### Export Control Laws and Regulations (University-Wide) ](https://trainingportal.harvard.edu/Saba/Web_spf/NA1PRD0068/app/me/learningeventdetail/cours000000000015861)This 30-minute course provides administrators and researchers with an introduction to export control laws and regulations, and how they may impact University research activities. [### Field Research Compliance, Safety and Security, and Fieldwork Best Practices ](https://science.fas.harvard.edu/training-videos-field-research-compliance-safety-and-security-and-research-best)Harvard university considers field research, field studies, and fieldwork an essential component of its scholarly activities, therefore, whether research and scholarship occur in the field or on campus, the University expects that all activities will be conducted in a safe and compliant manner aligned with the university expectations and policies. [### Outside Activity and Interest Reporting (OAIR) ](https://ras.fss.harvard.edu/oair)The OAIR application is Harvard University’s electronic system of record for the reporting and review of faculty and researchers' outside professional activities and other relevant interests, automating the submission and review process, storing documents, and providing reports. [### Participation Agreement and Visiting Participation Agreement ](https://osp.finance.harvard.edu/participation-agreement)This policy applies to all members of the University and visitors who perform research in Harvard facilities. [### Research Security Training (University-Wide) ](https://trainingportal.harvard.edu/Saba/Web_spf/NA1PRD0068/app/me/learningeventdetail/cours000000000044202?regId=regdw000000001508478&context=user&learnerId=emplo000000000083066&returnurl=catalog%2Fsearch%3FsearchText%3Dresearch%20security%2526filter%3D%7B%7D)This training provides recipients of federal research funding with information on risks and threats to the global research ecosystem. [### Responsible and Ethical Conduct of Research (RECR) ](https://www.nsf.gov/policies/responsible-research-conduct)The responsible and ethical conduct of research (RECR) is critical for excellence, as well as public trust, in science and engineering. RECR involves not only a responsibility to generate and disseminate knowledge with rigor and integrity, but also a responsibility to: 1\. Conduct peer review with the highest ethical standards. 2\. Diligently protect proprietary information and intellectual property from inappropriate disclosure. 3\. Treat students and colleagues fairly and with respect. Education in RECR is considered essential in the preparation of future scientists and engineers. [### Responsible Conduct of Research Program (RCR) ](https://about.citiprogram.org/series/responsible-conduct-of-research-rcr/)RCR consists of a basic course, refresher course, communicating research findings course, and facilitator guides. While particular emphasis is given to the educational needs of graduate students and postdoctoral researchers, the RCR series is suitable for any person involved in research ranging from upper-level undergraduates to established faculty and other professionals.