The role of an OPA approver for a DLCI requires critical thinking and attention to detail within the framework of institutional compliance policies. These roles are assigned only to those individuals with the appropriate seniority and authority.
As an OPA approver, you have the ultimate responsibility of approving an OPA disclosure. Before reviewing any disclosures, it is important to familiarize yourself with the applicable policies, process and guidance and to refresh your knowledge regularly, as the guidance and process may be updated periodically.
Best Practices
To ensure a comprehensive, timely assessment:
- Understand the Conflict of Commitment policy and Financial Conflict of Interest policy, which drive the questions in MyCOI-OPA+
- Understand the functionalities of MyCOI-OPA+, such as assigning reviews to other subject matter experts
- Complete OPA disclosure reviews within two weeks of submission
- Establish your DLCI’s process and cadence for reviews, as well as shared responsibilities among approvers (DLCI heads, DAFs, and similar)
Policies and Guidance to Review
- Overview of FCOI and COC policies
- Conflict of Commitment (COC) Policy
- OPA guidance
- Using MyCOI-OPA+ to disclose
- Unified disclosure form in MyCOI-OPA+ [PDF]
Reporter Guidance by Role
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Administrative staff do not use MyCOI-OPA+ to disclose their OPAs. Review Administrative Staff OPA guidance to understand the process that applies to them.
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Visiting professors and visiting scientists, engineers, or scholars are required to report their OPAs as a condition of their MIT appointment.
Prior to making their disclosures, visitors should review:
- Definitions of OPA and Reasonably Related
- What types of OPAs are required to be disclosed or not
In their OPA disclosures, visitors should report:
- Their home institution
- Any other engagements which may/appear to be “reasonably related” to their MIT responsibilities.
Their home institution may have a similar disclosure requirement, especially if they are here from a company.
Reviewing the Disclosure
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Assessing and Mitigating Risk will help you when you come across certain situations that may be reported, such as:
- Acceptance and use of gifts in research
- Traveling outside of the US on MIT related business or research activities
- Foreign research collaborations they may spend time on
- Serving in an advisory role at a foreign entity
- Holding an honorific or other title at a foreign entity
If you come across a country on this list, or have have specific concerns about an international engagement, await guidance before moving forward with any approvals:
- Ensure that there are sufficient details reported in the engagement such as role, deliverables, subject matter/topic they are advising/consulting on, etc.
- If this information is not provided, request it from the discloser before assigning.
- Assign the disclosure review to Research Compliance (lisacav@mit.edu). You must assign this type of review; there is no automatic review of engagements with a foreign country.
Only assign reviews of disclosures that are from Countries of Concern, sanctioned countries, or elevated-risk countries, or that raise questions for you. Please do not assign all reviews of engagements with a foreign country to Research Compliance.
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You will not see any numbers reported for how much time was spent on an OPA. MIT no longer requires the reporting of exact time, so this is not ‘missing’ from an OPA disclosure. Instead, in the certification text for each OPA disclosure, the discloser is certifying that they are within the Permitted Time for their rank.
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People who are required to complete an OPA disclosure in MyCOI-OPA+ may not all have engagements (i.e., OPAs) to report. This is OK. However, they still have to certify this on an annual basis.
Submission of an OPA disclosure certifying that they have no engagements to report results in a disclosure that has no engagements to review. Unless you know that they have an engagement that should be reported (in which case, you should reach out to the discloser), there is no action required other than to approve their disclosure. Do not return their disclosure.
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The system requires a disclosure from an individual with an active MIT appointment in a rank which requires disclosure on a yearly basis. If they leave MIT, they will be removed from this process when their appointment formally ends. In rare cases, an exemption may be requested (i.e., health issues). Please address with your assistant dean as necessary.
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Having a holistic view of a researcher’s commitments and interests can provide a more comprehensive understanding, aiding in informed decision-making.
Visibility of FCOI disclosures to OPA approvers
In MyCOI-OPA+, you have the option to view FCOI disclosures, if any exist, for persons in your DLCI. OPA approvers should not take any action regarding FCOI disclosures, nor are you obligated to review the FCOI disclosure for each OPA discloser who may have one. However, information provided in the FCOI disclosure of an individual may be helpful to you if something seems ”off” in their OPA disclosure.
COI team review of OPA disclosures
If an individual is required to submit both an FCOI and an OPA disclosure, their OPA disclosure will first be routed to the COI team for review. The system sends a notification to the COI team when such an OPA disclosure is submitted. Once the COI team completes their review of the OPA disclosure, it will be available for you to approve.
For an individual who does not also have an FCOI disclosure, the COI team will not receive notifications for OPA disclosures. However, if you are reviewing an OPA disclosure and believe a COI perspective would be beneficial, please feel free to assign that review to COI with your specific question or concern.