Outside Activity

NOTE: The Annual disclosure reporting period (for 2019) has begun as of May 20, 2020. All who are responsible for the design, conduct, and reporting of research are required to complete the Annual Certification to report on last year’s (2019) external activities. If you received the notification of the Annual Certification in your inbox, you must complete the request as the COI Administrator has triggered notifications specifically to those who need to complete it. Disclosure notifications have been issued through Click Commerce as of May 20, 2020 and should have arrived to the email  assigned to your Click account. The disclosure notification will also be available in your Click account inbox https://esupport.hms.harvard.edu/COI. If you have any questions, please contact the COI_Administrator@hphc.org or visit https://www.hphcinstituteosp.org/fcoi. Thank you.

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.


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@harvardpilgrim.org.

Financial Conflict of Interest Resources

Research Study Concerns?

  • If you have questions or concerns regarding the rights of a research participant, you may leave a message anonymously on the Harvard Pilgrim Health Care IRB Hotline: 800-807-6812.

  • If you suspect research misconduct at Harvard Pilgrim, contact the Research Integrity & Compliance Officer at 617-867-4817.

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