Because of MIT’s commitment to academic integrity and objectivity in research, all Investigators must comply with the Institute’s Policy on Financial Conflicts of Interest in Research, regardless of sponsor. By following MIT policy and the procedures that support the policy, including online PI certification for proposals, PIs comply with the Financial Conflict of Interest disclosure requirements of most sponsors.
United States Public Health Service
- Applicability: PHS, NIH, and most subordinate HHS agencies
- Policy: 42 CFR Part 50 Subpart F
- Who must disclose: Principal Investigators, Co-Investigators, Key Persons, and others who meet the PHS definition
- Effective date: August 25, 2011
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NOTE: Disclosable interests include those held by Family as defined in MIT policies (the investigator’s spouse and dependent children)
- Income greater than $5,000 from a source other than MIT
- Equity of any amount in a private company, $5,000 in a public company
- Royalty income from a source other than MIT
Income: aggregated greater than $5,000.00 USD over the twelve months preceding the disclosure from any publicly or privately traded entity. This includes salary, honoraria, consulting fees, etc. Income does not include: salary, royalties, etc. you receive from MIT; “income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles; income from seminars, lectures, or teaching engagements sponsored by a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education; or income from service on advisory committees or review panels for a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.”
- Equity: greater than $5,000.00 USD in a publicly traded entity on the date of disclosure; ownership of any amount in a non-publicly traded entity.
- Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
Travel
All travel paid for by an outside entity that is either directly paid for or reimbursed directly to the individual must be disclosed.
Travel paid for by MIT; US federal, state, local government entities; US institutes of higher education or research institutions affiliated therewith; or US academic hospitals and medical centers does not need to be disclosed.
US Department of Energy (DOE)
- Applicability: DOE and all subordinate offices, agencies, and national laboratories
- Policy: Interim Conflict of Interest Policy
- Who must disclose: Principal Investigators, Co-Investigators, Key Persons, and others who meet the DOE definition
- Effective date: December 20, 2021
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NOTE: Disclosable interests include those held by Family as defined in MIT policies (the investigator’s spouse and dependent children)
- Income greater than $5,000 from a source other than MIT
- Equity of any amount in a private company, $5,000 in a public company
- Royalty income from a source other than MIT
Income: aggregated greater than $5,000.00 USD over the twelve months preceding the disclosure from any publicly or privately traded entity. This includes salary, honoraria, consulting fees, etc. Income does not include: salary, royalties, etc. you receive from MIT; “income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles; income from seminars, lectures, or teaching engagements sponsored by a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education; or income from service on advisory committees or review panels for a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.”
- Equity: greater than $5,000.00 USD in a publicly traded entity on the date of disclosure; ownership of any amount in a non-publicly traded entity.
- Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
Travel
All travel paid for by an outside entity that is either directly paid for or reimbursed directly to the individual must be disclosed.
Travel paid for by MIT; US federal, state, local government entities; or US institutes of higher education or research institutions affiliated therewith does not need to be disclosed.
National Science Foundation (NSF)
- Applicability: NSF and all subordinate offices and agencies
- Policy: NSF Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 24-1) and 2 CFR part 200
- Who must disclose: Principal Investigators, Co-Investigators and other personnel who meet the NSF definition. (NSF I-Corps external personnel may be required to certify through MIT)
- Effective date: May 20, 2024
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NOTE: Disclosable interests include those held by Family as defined in MIT policies (the investigator’s spouse and dependent children)
“Anything of monetary value”
“[A]nything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options, private equity, or other ownership interests); venture or other capital financing, and intellectual property rights (e.g., patents, copyrights, and royalties from such rights)”
The term does not include:
- salary, royalties or other remuneration from the proposing organization;
- any ownership interests in the organization, if the organization is an applicant under the Small Business Innovation Research Program (SBIR) or Small Business Technology Transfer Program (STTR);
- income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities;
- income from service on advisory committees or review panels for public or nonprofit entities;
- an equity interest that, when aggregated for the investigator and the investigator’s spouse and dependent children, meets both of the following tests: (i) does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value; and (ii) does not represent more than a 5% ownership interest in any single entity; or
- salary, royalties, or other payments that, when aggregated for the investigator and the investigator’s spouse and dependent children, are not expected to exceed $10,000 during the prior twelve-month period.
Travel
No separate travel disclosure requirement.
National Aeronautics and Space Administration (NASA)
- Applicability: NASA and all subordinate offices and agencies
- Policy: NASA Grant and Cooperative Agreement Manual Section 29.7, Conflicts of Interest Policy (2024 Ed.)
- Who must disclose: Principal Investigators, Co-PIs, Key Persons, and others who meet the NASA definition
- Effective date: December 1, 2023
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NOTE: Disclosable interests include those held by Family as defined in MIT policies (the investigator’s spouse and dependent children)
“Anything of monetary value”
“[A]nything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options, private equity, or other ownership interests); venture or other capital financing, and intellectual property rights (e.g., patents, copyrights, and royalties from such rights)”
The term does not include:
- salary, royalties or other remuneration from the proposing organization;
- any ownership interests in the organization, if the organization is an applicant under the Small Business Innovation Research Program (SBIR) or Small Business Technology Transfer Program (STTR);
- income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities;
- income from service on advisory committees or review panels for public or nonprofit entities;
- an equity interest that, when aggregated for the investigator and the investigator’s spouse and dependent children, meets both of the following tests: (i) does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value; and (ii) does not represent more than a 5% ownership interest in any single entity; or
- salary, royalties, or other payments that, when aggregated for the investigator and the investigator’s spouse and dependent children, are not expected to exceed $10,000 during the prior twelve-month period.
Travel
No separate travel disclosure requirement.
Updated August 2025