Outside Activity

Have you acquired a new financial interest not previously reported in your Outside Activity Report? For example, new travel or consulting services? Are you joining an existing study and have yet to submit your research certification?


  • Remember to update and submit your Outside Activity Report if you have acquired a new financial interest not previously reported in your Disclosure statement.

  • The PHS FCOI regulations require that you update your disclosure(s) within 30 days to reflect any changes to your reported financial interests, including reimbursed or paid travel expenses, for federally funded research.

  • Remember you also need to submit a research certification if you are joining a study already in progress.

  • Update your Outside Activity Report and remove any disclosures that are 13 months old or older.

  • Access Click Commerce at esupport.hms.harvard.edu/COI to update your Outside Activity Report within 30 days of the new relationship.

  • If you have any questions, please contact COI_Administrator@hphc.org.


If you need to request a research certification, please follow the steps below. Please be sure to send requests to COI_Administrator@harvardpilgrim.org. If you need to add someone to a project, the process is the same as requesting the initial certification. Please send the request the same way.


How to create a research certification in Click Commerce:

Email the COI Administrator at COI_Administrator@harvardpilgrim.org, and cc your Grant Manager, with a request to set-up a research certification. Include the following in this email:

  • Project ID (Grant # or # from Oracle, if available)

  • The full study title

  • A list of all persons responsible for the design, conduct or reporting on your study (known as disclosers). Indicate the role for each discloser (e.g. PI, Co-I, etc.)

The COIA will create the certification and each discloser will be notified via email that action in their Click Commerce inbox is required. Disclosers will complete the certification as required.

Have you received an email reminder that your CITI Conflicts of Interest training is expiring soon? Login to your CITI account to complete the COI Refresher training. Click here for detailed instructions on how to access the training or contact  Alice Wadley, Training Coordinator at alice.wadley@point32health.org.

Financial Conflict of Interest Resources