Why It’s Important
MIT faculty and staff’s first and primary responsibility is to support and advance MIT’s mission. The disclosure and management of conflicts of interest is critical to maintaining the integrity of MIT’s educational and research mission, the credibility of its faculty and staff, meeting responsibilities to funding agencies to ensure future funding, and maintaining the public’s trust in its research and related activities. It is every researcher’s responsibility to be familiar with MIT’s Conflict of Interest in Research Policy.
A conflict of interest (COI) may arise from any situation in which financial or other personal considerations have the potential to compromise a researcher’s professional judgment and objectivity in the design, conduct or reporting of research. Conflicts of interest can arise from an individual’s engagement with entities outside the Institute such as with for-profit businesses, foreign institutions and government entities, not-for-profit groups, professional societies, other academic institutions or through activities such as consulting, holding management or advisory board positions, having ownership interests in a company, receipt of royalties and other activities from which an individual or his or her family receives remuneration.
MIT’s COI Policy sets the financial thresholds for what constitutes a Significant Financial Interest (SFI). Having an SFI is not wrong or an automatic COI. However, discussion and disclosure of the SFI are critical first steps in the process of determining whether an SFI is related to or could lead to a real or perceived COI with your MIT research and teaching activities and whether the conflict can be managed or must be eliminated. It is important to inform and discuss this topic with your department, lab or center head, COI Officer or dean as early as possible, prior to engaging in or signing contracts for an engagement. The Community COI Portal is a great resource to access COI-specific guidance documents on consulting, starting a company, appropriate use of certain appointments, completion of on-line forms for consulting activities, etc.
How to Comply
Individual Conflict of Interest compliance at MIT involves completing MIT-specific COI training on-line and disclosure of financial relationships through these processes:
- Faculty and staff must submit an annual report on their outside professional activities (OPA) and the details of any changes during the year to their department head as outlined in MIT’s policy on Outside Professional Activities. Contact your department head or dean’s office for more information.
- PIs and others, who are independently responsible for the design, conduct, and reporting of research must answer financial conflict of interest screening questions prior to submission of each proposal as part of the proposal certification process. Additional disclosure may be required at the time of award, driven in large part due to sponsor requirements. Many sponsors including the NIH and NSF, mandate an annual update of financial conflict of interest disclosures for the life of the award. You will receive specific instructions by e-mail for completing these disclosures at the appropriate times. Disclosures are filed electronically via MIT’s pre- and post-award management system in Kuali Coeus. You may access the COI disclosure module through the website coi.mit.edu. Contact firstname.lastname@example.org for more information or questions.
- Online MIT-specific training is required to be completed for a number of sponsors before awards can be activated. COI training completed at other institutions cannot be transferred to replace MIT’s COI training requirements. Researchers will be notified when such a training requirement is needed. The training is good for 4 years. More information can be found at the COI website.
Conflict of Interest with Respect to Use of MIT’s Name
MIT’s name must not be used in ways that suggest or imply the endorsement of other organizations, their products, or their services. The use of MIT’s name, logo, seal, and photographs in the advertising and other promotional material and activities of outside organizations is prohibited when such use is likely to be understood as an endorsement, even if such an endorsement is not the intention of the person or organization seeking to use MIT's name.
For example, during the course of a consulting engagement, a faculty member, in his/her capacity as a subject matter expert, and in their individual capacity, may provide a professional evaluation of products or services, based on researched and factual evidence. If a faculty member is serving on the Scientific Advisory Board of a company, all company websites, communications, and materials, must accurately depict that relationship and not state or imply that the role is more than advisory.
Faculty members should be careful to avoid identifying the Institute with their personal opinions or conclusions in public or private reports that support the outside financial interests of the faculty member. The MIT Technology Licensing Office (TLO) is responsible for coordinating, reviewing and approving Use of Name requests at MIT, pursuant to Section 12.3 of MIT's Policies and Procedures, Use of Institute Name. For further information, please contact the TLO at email@example.com.
Conflict of Interest with Respect to Procurement of Goods and Services
During the proposal certification process, it must be disclosed whether any goods or services will be required from an entity in which the Investigator(s) have an SFI. PI’s are responsible for seeking prior approval to procure such goods and services. In some cases, MIT may be able to manage the conflict with proper reporting to the research sponsor. Contact the MIT Procurement office for more information.
Conflict of Interest with Respect to Human Subjects Research
Conflicts of interest related to research involving human subjects pose special concerns. The Institute and its researchers have ethical obligations to honor the rights and protect the safety of persons who participate in research conducted by Institute personnel. Financial interests held by those conducting the research or the research’s sponsor may compromise or appear to compromise the fulfillment of those ethical obligations and the well-being of the research subjects, as well as the integrity of the related research. Accordingly, there is a strong presumption against permitting any person with related financial interests to participate in the conduct of such research, particularly if the protocol involves more than minimal risk to the subject. Contact the COUHES office for more information.