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, meet responsibilities to funding agencies to ensure future funding, and continue to maintain the public’s trust in its research and related activities.
An individual financial conflict of interest may arise when an individual or his or her immediate Family (including spouse, domestic partner and/or immediate children) has a financial interest that does or has the potential to compromise or bias professional judgement and objectivity in the performance of his or her Institutional Responsibilities in favor of personal financial gain. 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 through activities such as consulting, holding management or advisory board positions, ownership of a company, its stock or other securities, receipt of royalties and other activities from which an individual or his or her Family receives Remuneration. The existence of a conflict of interest or the appearance of one does not imply wrongdoing on anyone’s part. When conflicts of interest do arise, however, they must be disclosed, reviewed and either eliminated or properly managed. It is important to inform and discuss with your department head or dean activities which may pose a real or perceived conflict of interest, prior to engaging in them.
How to Comply
Individual Conflict of Interest compliance at MIT involves disclosure of financial relationships through two 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. Other sponsors may also ask for disclosures at the time of award. For certain sponsors such as NIH and NSF, federal regulations mandate an annual update of financial conflict of interest disclosures throughout the life of the award. Instructions for completing these disclosures may be accessed through the website coi.mit.edu. Disclosures are filed electronically via MIT’s pre and post award management system in Kuali Coeus. Contact the Director of OSP or MIT’s Conflict of Interest Officer for more information.
Conflict of Interest with respect to Use of MIT’s name
Public association of MIT’s image or name with commercial interests may lead to a conflict of interest. In the course of consulting or research, a faculty member may provide a professional evaluation of products or services, based on researched and factual evidence. However, 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. Contact MIT’s Technology Licensing Office (TLO) for more information.
Conflict of Interest with respect to Procurement of goods and services
PI’s are responsible for seeking prior approval to procure goods and services from an organization in which the PI has a financial interest. Federal regulations prohibit this, but 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.