Compliance

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

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. Data security is also part of handling a data use agreement. 

The University’s Information Technology office has resources for determining data security levels as well as guidance on protecting digital and physical 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 and Data Safety System, respectively.

For more information, please visit the Office of the Vice Provost for Research resources:
Research Data Management and Policy Compliance Resources
Research Security Program

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)
MFTRP (Malign Foreign Talent Recruitment Program)
COI (conflict of Interest)

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
Access ecrt

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 
Sponsored Expenditure Guidance
Travel and Entertainment Policy
Tuition Policy
Equipment Policy

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).

For more information: 
Committee on the Use of Human Subjects (Harvard University Area Institutional Review Board)

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 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)
Office of Technology page for Faculty & Inventors

Faculty, academic appointees, students, and staff at HGSE participate in a broad range of innovative and important international engagements. Please visit our International Engagements page to learn more.

For more information:
Specially Designated Nationals (SDN) List Screening Process and Monitoring guidance
Export Control Policies and Procedures
Export Control Policies & Procedures
International Collaborations and Activities Approval
HGSE CIPS Policy
HGSE CIPS Form

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.

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