Definitions

a
Aggregate

means the consolidated total of monies received from a single entity (i.e. through Remuneration, Sponsored Travel, Equity Interests, etc.).

c
COI Committee

means MIT’s committee or the individual that advises the Institutional Official with respect to conflict of interest matters.

Conflict of Interest Officer

means the MIT staff member responsible for supporting the Institutional Official in implementing this Policy.

d
Designated Official

means either the Conflict of Interest Officer or, in complex cases, the Investigator’s Department, Lab, or Center Head; School Dean; or any other member of the senior administration designated by the Institutional Official to review disclosures to determine if there is a relationship between an Investigator’s Significant Financial Interest, and for PHS Investigators, reimbursed or sponsored travel, and his or her Institutional Responsibilities.

e
Equity Interests

means stock, stock options, warrants, and other existing or contingent ownership interests in a commercial entity.

f
Family

means an Investigator’s spouse or domestic partner and dependent children.

Financial Conflict of Interest

means a Significant Financial Interest and for PHS Investigators, Sponsored Travel, that MIT reasonably determines could directly and significantly affect the design, conduct, or reporting of research.

i
Institutional Official

means the individual within MIT that is ultimately responsible for the review of disclosures of Significant Financial Interests and the management of Financial Conflicts of Interest. The Institutional Official is the Vice President for Research.


Institutional Responsibilities

means the Investigator’s responsibilities associated with his or her MIT appointment or position, such as research; teaching; administration; conference attendance, research presentations or lectures at other universities or uncompensated publication review; and service on MIT committees.


Investigator

means the individual or individuals who are independently responsible for the design, conduct, or reporting of the research project. This is typically, the principal investigator and any co-principal investigator (i.e. the project leadership), though in some cases the principal investigator may determine that others are independently responsible for the project. Some sponsors have specific requirements for identifying Investigators. See the Office of Sponsored Programs website for more information.

o
Outside Professional Activities

means compensated and uncompensated activities undertaken outside of an Investigator’s Institutional Responsibilities.

p
PHS

means the Public Health Service of the U.S. Department of Health and Human Services, including, but not limited to the National Institutes of Health (NIH), the Administration for Children and Families, Administration on Aging, Agency for Healthcare Research and Quality, Agency for Toxic Substances and Disease Registry, Centers for Disease Control and Prevention, Federal Occupational Health, Food and Drug Administration, Health Resources and Services Administration, Indian Health Service, and Substance Abuse and Mental Health Services Administration. The most current list can be found at http://www.usphs.gov/aboutus/agencies/hhs.aspx

r

Related Entity

means any domestic or foreign, public or private, for profit, non-profit or governmental organization in which the Investigator, alone or in combination with his or her Family, holds a Significant Financial Interest.

Remuneration

includes salary and payments for services, such as consulting fees, honoraria or paid authorship, and cash or in kind gifts from entities for which you provide services and, for PHS Investigators, Sponsored Travel.

s
Significant Financial Interest

means a financial interest that meets any of the criteria for significance set forth below and is received or held:

  1. by an Investigator; or
  2. by an Investigator and members of his or her Family; or
  3. solely by members of the Investigator’s Family, but only if the financial interest could reasonably appear to be related to the Investigator's Institutional Responsibilities,

A financial interest is deemed to be significant if:

    1. the aggregate value of Remuneration and Equity Interests in lieu of payment received from a US or foreign publicly traded entity during the 12 month period preceding the disclosure exceeds $5,000; or
    2. the aggregate value of Equity Interests in a US or foreign publicly traded entity exceeds $5,000 and the entity is sponsoring any of the Investigator’s research; or
    3. the aggregate value of Equity Interests in a US or foreign publicly traded entity exceeds $100,000 and the entity’s business, or any portion thereof, reasonably appears to be related to any of the Investigator’s Institutional Responsibilities; or
    4. the aggregate value of Remuneration received from a US or foreign non-publicly traded entity or non-profit institution received during the 12 month period preceding the disclosure exceeds $5,000; or
    5. any Equity Interest is held in a US or foreign non-publicly traded entity; or
    6. the aggregate value of Remuneration received from a foreign governmental organization during the 12 month period preceding the disclosure exceeds $5,000; or
    7. the aggregate value of income related to intellectual property rights and interests paid by an entity other than MIT exceeds $5,000.

Significant Financial Interest does NOT include:

  1. Remuneration from MIT; (including salary and royalty payments) and
  2. Remuneration paid to an Investigator’s Family by any entity what would not reasonably appear to be related to the Investigator’s Institutional Responsibilities; and
  3. Remuneration from authorship of academic or scholarly works, regardless of the source; and
  4. Remuneration from seminars, lectures, or teaching engagements sponsored by, or from advisory committees or review panels for, U.S. Federal, state, or local governmental agencies; U.S. institutes of higher education (e.g. Whitehead Institute and Broad Institute); U.S. research institutes affiliated with institutes of higher education, academic teaching hospitals, and medical centers; and
  5. Equity Interests in or income from investment vehicles, such as mutual funds and retirement accounts, so long as the Investigator does not directly control the investment decisions for these vehicles.
Sponsored Travel

(applies only to PHS Investigators) means (a) travel expenses paid to an Investigator or travel paid on an Investigator’s behalf, by a single entity in any 12-month period and (b) travel reimbursed to or paid on behalf of an Investigator’s Family by a single entity in any 12-month period ONLY if such travel reasonably appears to be related to the Investigator’s Institutional Responsibilities. See the PHS Addendum for more information.