Harvard University is committed to upholding its core mission and values, including the assurance of personal and institutional academic integrity.  Among these assurances is the need to identify and appropriately manage potential financial conflicts of interest and conflicts of commitment. As such, it is important for faculty to disclose all significant financial interests and external professional commitments in accordance with the Faculty of Medicine Policy on Conflicts of Interest and Commitment and the HMS/HSDM Policy on Financial Conflicts of Interest in Sponsored Research.

Under these policies, faculty are required to disclose external professional activities and financial interests that are related to their institutional responsibilities to Harvard.  External professional activities are those with entities outside of Harvard or one of its affiliate institutions.  You should report any relationship that relies upon the experiences and professional expertise that serve as the basis for your faculty appointment. Faculty members whose primary appointment is with an HMS-affiliated hospital only need to disclose their outside activities to their primary institution and do not need to disclose their activities through the HMS disclosure system.  If you have questions about how to disclose your outside activities, please contact ARI at coiforms@hms.harvard.edu. 

You can access the online Outside Activities and Interests Reporting portal by clicking on: https://oair.harvard.edu/.  You can return to the link at any time to update your reports or submit additional reports.

The Reporting Basics

  • HMS has a zero dollar reporting threshold. This means that you must report ALL relevant outside activities, including those for which you do not receive compensation.
  • You must include relevant interests held by your partner/spouse and your dependent children.
  • Not Just Conflicts. The reporting requirement is independent of whether your financial interests represent potential, perceived or actual conflict of interest.
  • Entity Reporting. You are required to report each entity with which you have an outside relationship and/or a financial interest.
  • You must report relationships with and financial interests in pharmaceutical, device, biotechnology, and medical education and communication companies.

Exclusions - You do not have to report the following outside activities:

  • Payments by or ownership in an entity that is unrelated to your institutional responsibilities. (e.g., a geneticist does not need to report payments received for playing the saxophone at a local watering hole).
  • Any ownership in mutual funds, retirement accounts or other investment vehicles where you do not directly control the investment decisions.
  • Any ownership in or payments from your own private clinical practice.
  • Situations where the only relationship is through Harvard or a Harvard affiliated institution (such as sponsored research agreements) do not need to be reported.  For example, you receive sponsored research support from a pharmaceutical company to conduct research at Harvard or a Harvard affiliated institution, and you have no other relationship to that company, there is no need to report it.
  • Payments from a local, state or United States federal agency do not need to be reported.  However, paid and unpaid relationships and positions with foreign governments and agencies must be reported.
  • Salary support, honoraria or other income paid by Harvard or an affiliated institution, or any other academic teaching hospital, medical center, or a research institute that is affiliated with a charitable institution of higher education located in the United States.  Paid and unpaid relationships and positions with foreign institutions must be reported.

Please see OAIR What to Include  and OAIR Definition Guidance for details on what to report.