Faculty Discuss Response to Epstein Report, Conflict of Interest Reporting


Harvard administrators outlined responses the University has taken regarding the late convicted sex offender Jeffrey E. Epstein’s ties to Harvard during a monthly meeting of the Faculty of Arts and Sciences Tuesday.

After University President Lawrence S. Bacow initiated a review into Epstein’s ties to Harvard in 2019, the committee recommended in 2020 that Harvard revise its policies concerning external gifts as well as those regarding appointments of visiting fellows.

Bacow said Tuesday one of the changes the University made after the report was increasing vetting of external gifts prior to acceptance. University Provost Alan M. Garber ’76 additionally reminded faculty of the University’s gift policy guide released in May 2020.

Bacow said while some policies for reviewing donor gifts had existed before the Epstein report, “they failed us here” because the University lacked a centralized system to “implement the policies as they were written.”


“Our decentralized structure was such that it was possible for a decision to be made by the president not to accept a gift from a donor, and for various parts of the institution not to hear that,” Bacow said. “That was, in part, because we did not have development officers report up to one individual.”

Fundraising deans from across Harvard’s schools now all report to Vice President for Alumni Affairs and Development Brian K. Lee and meet on a biweekly basis, according to Bacow. He said this new practice ensures University decisions to reject donor gifts can be “easily and directly communicated” to prevent Harvard affiliates from accepting gifts from a previously rejected donor.

Graduate School of Arts and Sciences Dean Emma Dench said while GSAS also previously had requirements in place that technically prevented Epstein from being eligible for a visiting fellowship, the School lacked “safeguards” at the time of Epstein’s appointment to review requested exceptions to the policy.

“Those safeguards are now in place, so any requested exceptions to the written policy must be personally reviewed and decided by the GSAS Dean, and the GSAS Dean may consult with other faculty as the Dean deems appropriate,” Dench said.

At the faculty meeting, administrators also discussed a new University-wide standardized system to report conflicts of interest and financial disclosure. Vice Provost for Research Richard D. McCullough also shared that the University’s new policy would require reporting with a “zero dollar threshold.”

“About a year and a half ago, we set out to take a look at the financial COI policy and created an online tool to make it easier for reporting to occur on both financial COI and outside activities, and to align the schools to have a single University policy, especially given the several joint departments we have at the University and multiple faculty with joint appointments,” McCullough said.

He acknowledged the recent attention shed on University researchers and their financial ties. In November 2018, the Justice Department established the China Initiative in an attempt to curb intellectual property theft by China. Notably, under the program, officials arrested Charles M. Lieber — the former Harvard Chemistry department chair — last January on charges of lying to federal officials about his involvement in a Chinese talent recruitment program.

Though McCullough said 90 percent of FAS faculty had filled out the new disclosure forms, some faculty in attendance had qualms about the new policies.

“There’s no clear reason why academic talks given outside of the U.S. should be treated differently,” said Derek J. Penslar, a History professor. “The increasing currency of Zoom has only led to increased Zoom gatherings."

“Staff assistants have been whittled away, and now it turns out we need to keep our own records for reporting policies,” said Ann M. Blair ’84, chair of the History department. “I hope there is some flexibility in how this can be implemented in a way that is less burdensome.”

Garber concluded the meeting by thanking faculty members for their cooperation and stating that University officials are “committed to working with” faculty, while noting that many of the reporting requirements are outside the University’s decision-making scope.

“The federal government has instituted requirements, and the fact is that it influences everything we do in this area,” Garber said. “There is incredible time pressure, and I deeply regret that.”

—Staff writer Meera S. Nair can be reached at

—Staff writer Andy Z. Wang can be reached at