Dear Members of the HMS Faculty:

I know you agree that that the integrity of Harvard Medical School faculty as they pursue their clinical, research and teaching missions is of paramount importance. As a result, the challenge posed by potential conflicts of interest is one we all take extremely seriously.
Relationships between academia and industry play a significant role as we work toward our shared mission to alleviate human suffering and eradicate disease. We must work together in order to develop therapies that benefit men, women and children around the world. It is fundamental that these collaborations between our faculty and industry be transparent and governed by a policy that further codifies and enforces our high standards. Compliance with the Faculty of Medicine Policy on Conflicts of Interest and Commitment was established to assure the continued integrity of and trust in those relationships.

Today marks the beginning of a new mandatory cycle of outside activity reporting for each member of the HMS and/HSDM faculty, both full and part time. I ask that you review the following information and complete the required electronic submission, regardless of when you last submitted a disclosure form.

You are expected to complete your on-line HMS report no later than June 15, 2012.

Thank you for your compliance in completing this necessary and important documentation. I know you share our commitment to ensure that our works adheres to the highest standards possible.
Sincerely,

Jeffrey S. Flier, M.D.
Dean of the Faculty of Medicine

Faculty of Medicine Policy on Conflicts of Interest and Commitment

Complete by June 15, 2012

As you prepare to submit your required outside activity report, please keep in mind the following:

• Tutorial and Quiz. There is a short tutorial (link to tutorial) and quiz that you must complete prior to submitting information about your outside activities. I hope this clarifies some of the common misconceptions about the HMS policy as well as what you need to report.
• Report ALL Outside Activities Related to your Role as a Faculty Member. Please submit reports for all outside activities that relate to your role as a faculty member (this includes your clinical, academic and research responsibilities) regardless of the amount of financial interest involved.
• Update Reports as Circumstances Change. Please remember to update your reports throughout the reporting cycle as your circumstances change. Enhancements to the electronic reporting system make it easy for you to review your past reports and to keep them updated.
• Working Toward One Point of Entry Reporting. We are working toward a single entry mechanism that will allow faculty to report outside activities to HMS and all of its affiliated institutions at one time. Until this is accomplished, however, you must continue to report your outside activities directly to HMS to maintain your faculty appointment in addition to any reporting obligations you may have to affiliate institutions. We are working hard to eliminate this dual reporting obligation before the next mandatory reporting cycle.

Directions for Electronic Reporting

To access the Calendar Year 2011 Outside Activity Report, go to http://ecommons.med.harvard.edu/gopage.asp?aoa.asp. You will be prompted to log in using your eCommons username and password and then directed to the Outside Activity Reporting interface. You can return to the link at anytime to update your reports or submit additional reports. Again, please complete your on-line HMS report no later than June 15, 2012.

If you don't have an eCommons account, go to http://ecommons.med.harvard.edu and select the "Obtaining an account" link. You must register for an account using your Harvard ID number. If you need assistance, please contact the HMS IT Help Desk at 617-432-2000 for assistance.

Questions?

If you have questions about the online reporting process or any part of the HMS Policy, please review the frequently asked questions below. Additionally, you may contact the HMS Office for Professional Standards and Integrity by clicking this link: outside_activities@hms.harvard.edu.

Frequently Asked Questions

Who is required to report?

The COI policy applies to any person possessing either a full- or part-time academic or fellowship appointment at the Faculty of Medicine. As such, you must report your outside activities if you have a full or part time academic of fellowship appointment.

How do I report my outside activities?

To access the Calendar Year 2011 Outside Activity Report, go to http://ecommons.med.harvard.edu/gopage.asp?aoa.asp. You will be prompted to log in using your eCommons username and password and then directed to the Outside Activity Reporting interface. You can return to the link at anytime to update your reports or submit additional reports.

What if I do not know my eCommons account information?

If you do not know your password, click on the "I forgot my password" link on the eCommons login page.

If you do not know your username, please contact the HMS Information Technology Help Desk by emailing help_desk@hms.harvard.edu or calling 617-432-2000.

What if I don't know my Harvard ID number?

If you do not know your Harvard University ID number, please contact Faculty Services by emailing facserve@hms.harvard.edu or calling 617-432-2035.

I just received a similar request for reporting from an institution affiliated with HMS. Do I have to complete both?

You must report your outside activities and financial interests to HMS to meet your obligations as a faculty member. If you are affiliated with another Harvard affiliated institution, your institution may have additional disclosure requirements. Please refer to your institution's research administration or compliance office for further information. We are working with our Harvard Affiliates to consolidate the different annual reporting processes and systems so that you are required to complete only one annual report in the future. (Check our website for regular updates).

Why does HMS need this information?

Since 1990, the HMS Policy on Conflicts of Interest and Commitment (COI) has required periodic reporting to ensure transparency and impartiality in all faculty activities. Public trust in academic medicine and its continued legitimacy requires transparency. Moreover, HMS uses the information to ensure compliance with HMS Policy.

Are outside activities discouraged?

Absolutely not. Translation of knowledge and innovative technology from academia to the public requires increased collaboration between faculty and outside entities. HMS supports and encourages these interactions. Engaging in reportable outside activities does not signify that you have done anything wrong or unethical.

What am I required to report?

You are required to report outside professional income, uncompensated activities, royalties and equity holdings relevant to your role as a HMS faculty member. The reporting requirement is independent of whether your financial interests represent potential, perceived or actual conflict of interest. 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 are required to report each entity with which you have an outside relationship and/or a financial interest. Additionally, you must report relevant interests held by your partner/spouse and your dependent children (family).

What is relevant to my role as a HMS faculty member?

All relationships that rely upon the experiences and professional expertise that serve as the basis for your faculty appointment are relevant and must be disclosed. Additionally, you must report relationships with and financial interests in pharmaceutical, device, biotechnology, and medical education and communication companies.

What don't I have to report?

You do not have to report the following:

• Financial interests or uncompensated activities from a charitable institution of higher education located in the United States.
• Financial interests in or uncompensated activities with federal, state or local government agencies.
• Sponsored research support to HMS or an affiliated institution.
• Salary support or other income paid by HMS, 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.

Unless you have received payments from one of the above entities on behalf of a commercial entity that would otherwise have to be disclosed.

Who has access to my report?

The Office for Professional Standards and Integrity at HMS and liaisons at Harvard's Affiliates will have access to your report to ensure compliance with institutional rules. Additionally, your supervisors and/or Chair may be provided with your report. HMS may also compare your report with information available on public websites to identify common reporting errors and to provide ongoing education. Finally, portions of your report will be publicly disclosed on the Harvard Catalyst Profiles website.

What will be publicly disclosed?

• Starting this year, certain information reported to HMS will be publicly available as part of the Harvard Catalyst Profiles website. Only your financial interests (not those of your family) will be disclosed as follows:
  • Income that equals or exceeds $5,000 (excluding reimbursement for travel, lodging and other reasonable expenses) earned as a result of:
  • Consulting arrangements, including expert witness fees;
  • Membership on scientific advisory boards;
  • Service on boards of directors of pharmaceutical, device, software or biomedical companies; and
  • Honoraria payments from for-profit pharmaceutical, device, software and biomedical companies, non-profit foundations, medical education companies and promotional or marketing firms.
• Equity interests:
  • In any privately held pharmaceutical, device, software or biomedical company; and
  • That equal or exceed a value of $5,000 in a publicly traded pharmaceutical, device, software or biomedical company.