#  Compliance 

 



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###    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. Data security is also part of handling a [data use agreement](/data-use-agreements "Data Use Agreements").

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 Activities  expand\_more  

Faculty, academic appointees, students, and staff at HGSE participate in a broad range of innovative and important international engagements. Please visit our [**International Engagements** ](https://prod-gseosp.drupalsites.harvard.edu/international-activities)page to learn more.

**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/)  
[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.