Research and Academic Compliance Officer

Department Profile:

Harvard’s Office of Research and Academic Compliance (ORAC) within the Office of the Vice Provost for Research aims to promote and support a culture of integrity in research and education by providing specialized administrative and operational expertise, including proactive risk assessment, consultation, and mitigation, to help Harvard’s schools, departments, and research communities comply with applicable laws, regulations, and institutional policies.

ORAC leads and directs risk and compliance activities for various schools and units across campus and is responsible for a broad spectrum of risk assessment and mitigation, compliance, research security, operations, and education/training in the major compliance domains, including financial conflicts of interest, conflicts of commitment, outside activities, export controls, and international collaborations and activities. ORAC works as a central administration clearinghouse for non-financial compliance issues and operates in close collaboration with the research and academic community and the relevant administrative units (e.g., School research administration offices and Dean’s Offices, the Office for Sponsored Programs, the Office of Technology Development, the Office of the General Counsel) to ensure timely service delivery, risk management, and compliance with all applicable regulatory, funder, and university requirements.

Position Summary:

Reporting to the Senior Director of the Office of Research and Academic Compliance, the Research and Academic Compliance Officer (RACO) will manage compliance and risk management activities/functions in areas across the university. The Officer will provide direct and vital support to constituents in all risk areas and attend to their compliance, operations, and policy needs with strong emphasis on financial conflict of interest, conflicts of commitment, export control, international collaborations and other foreign activities, while managing and integrating as necessary across other compliance domains. The RACO partners closely with community members and leaders to ensure risks are understood, controls are designed and operating effectively, and activities support safe and secure research and academic practices in compliance with applicable laws, regulations, and internal policies. Under minimal supervision, the Officer executes risk assessments, oversees issue identification and management, documents, tracks and reports risk metrics, sets priorities for and monitors ongoing resolutions and mitigations, and escalates emerging issues appropriately. Operating with a high degree of autonomy, the role serves as the primary risk and compliance liaison between schools and units across campus and the Senior Director of ORAC, and the Office of the Vice Provost for Research (OVPR), which includes change management and training and education. The Officer also promotes a strong risk and compliance culture by embedding risk awareness into day-to-day business activities and training for schools/units and represents the Office of Research and Academic Compliance on school-wide and university-wide committees and teams

Job-Specific Responsibilities:

Projects and priorities in the following areas will involve a variety of complex organizational constructs; interests and responsibilities will evolve as needs arise:

Leadership and Expertise:

• Act as the primary non-financial research compliance liaison from ORAC to a large portfolio of academic and research areas encompassing hundreds of faculty, students, and administrators

• Maintain knowledge of and provide input for sponsored research policies, procedures, and guidelines in functional areas to include pre-award, post-award, financial, and research compliance

• Provide consistent consultative expertise and guidance to administrators, faculty, staff, students, visitors, and other constituencies around campus in issues related to research and academic compliance

• Guide decision-making of school and university faculty, administrators, and leaders in accepting or denying international collaborations, students, scholars and visitors based on risk profiles 

• Represent ORAC on university-wide committees, task forces, and working groups to inform decision-making by leadership 

• Provide consultation to faculty related to risk areas and potential impact on Harvard  for academic, research, and professional work outside of the university 

Risk Mitigation and Management:

• Create risk profiles for individuals and entities by performing extensive background research including gathering data, analyzing business connections, and assessing threats to university security and reputation 

• Develop and manage workflows in the areas of export controls, international collaborations, and conflicts of interest including writing rationales, communicating to constituencies around campus, and maintaining proper records and auditable files on behalf of the university 

• Provide regulatory review of and provide terms for contracts with industry partners for the Office for Technology Development (OTD) to evaluate compliance-related clauses in agreements

• Conduct export control reviews for educational and research activities, including classifying technology in accordance with U.S. regulations, vetting end-users, determining applicability of U.S. sanctions, and collecting and analyzing data regarding the research purposes and potential end-users of Harvard-owned or created technology

• Conduct deemed export reviews in conjunction with academic visa applications, data sharing, and other domestic activities

• Review all planned international collaboration activities within grant applications prior to submission to sponsor for risk of foreign influence, noncompliance, and risk to the university and create expectations around operational compliance for the research team

• Develop Technology Control Plans to mitigate risk related to access of Harvard systems and resources 

• Develop fCOI management plans to ensure compliance with the University fCOI policy and all applicable sponsor requirements

Compliance and Operations:

• Conduct audits and investigations as necessary on behalf of ORAC, OVPR, and academic units in response to allegations of noncompliance to gather evidence, create risk reports, and mitigation/corrective action plans

• Create written expectations for operational compliance among faculty and research teams and provide referrals to campus resources related to research security and compliance where applicable

Education, Training, and Communication:

• Create and deliver educational programs and training seminars to members of academic departments, laboratories, centers, institutes, etc., about non-financial compliance in research and education through established operations channels

• Develop content and guidance for research compliance and other functional areas

• Other duties as required