COI vs. OPA: What You Need to Know

This chart summarizes the financial conflict of interest (fCOI) and outside professional activities (OPA) policies under which faculty members, other investigators and staff must disclose certain information to MIT in order to achieve compliance with federal, state, and Institute requirements. Additional details and links to policy are provided following the chart.

Please note that the fCOI and OPA disclosure processes at MIT do not replace sponsor-specific disclosure requirements, especially for federal sponsors. Review all sponsor-specific proposal and award information, or speak to your contact in Research Administration Services to ensure you have disclosed all required information to meet sponsor requirements.

  Conflict of Interest (COI) Outside Professional Activities (OPA)

Purpose

To protect the integrity and objectivity of research conducted by MIT investigators, and comply with related policies and regulations.

To identify and manage outside professional activities of MIT faculty and staff to ensure no interference or conflict with academic, research or other Institute responsibilities.

Who files

Principal Investigators and others, as required by the sponsor (i.e. key persons on PHS funded proposals) who share responsibility for the design, conduct or reporting of externally supported research.

Faculty, other academic staff, research staff, and administrative staff. Support and service staff are not required to report OPA.

What should be disclosed

Review what you need to know before starting your disclosure  and the online Significant Financial Interest Decision Tree tool to help determine Significant Financial Interests (SFIs) to disclose.

See the MIT OPA Faculty Sample Form for examples of outside activities and relationships that must be reported.

 

Prior approval requests for certain outside activities should be made whenever necessary. To determine which activities may need prior approval, see the VPR information on Outside Professional Activities.

When is disclosure required

Depends upon source of funding, including, but not limited to:

  • At proposal stage
  • At time of award, prior to start of research
  • When adding new or revising existing SFIs (NIH/PHS Investigators w/in 30 days of acquiring new interest, 90 days for all others)
  • When requests for additional funding are submitted
  • Annually

An annual report on OPA is required, covering activity during the prior summer and academic year. The online OPA reporting process normally opens in May and closes in August. 

 

For prior approval requests, before engaging in activity 

Disclosure Required Under Policies Established by

Massachusetts Iinstitute of Technology

Massachusetts Institute of Technology

Online Systems

Conflict of Interest Disclosure Module

MIT OPA Portal

MIT Office with Administrative Responsibility

Office of the Vice President for Research

  • Office of the President
  • Office of the Provost (Academic areas only)

 

Financial Conflicts of Interest

Financial Conflicts of Interest must be identified and either managed or eliminated. Disclosure of Significant Financial Interests is an integral part of this process.
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.

Forms, policies and procedures, and other guidance can be found on the VPR Financial Conflicts of Interest in Research website.


Outside Professional Activities

The Institute’s policies governing outside professional activities are designed to encourage active participation in research enriched in many cases by interaction with industry, business, government, and other activities and institutions.

  • Information for MIT Faculty regarding Outside Professional Activities is available in MIT’s Policies and Procedures §4.5. Department heads and center/laboratory directors counsel faculty and researchers regarding specific cases. The Faculty Policy Committee recommends appropriate modifications of policies and procedures to the Faculty.
  • Non-faculty research staff are subject to specific rules concerning outside professional activities depending on their position at the Institute and detailed in Policies and Procedures §2.0§5.0, and §6.0 for each appointment type. A summary of normally conferred consulting privileges for various positions at MIT can be found on the VPR Outside Professional Activities page.

Reports of outside professional activities (whether compensated or uncompensated) must include all foreign and domestic activities. Outside professional activities must be reported and updated during the annual OPA reporting cycle which starts in May of each year, via the MIT Outside Professional Activities (OPA) portal.

Portions of the contents of this page were adapted from materials prepared by UCLA Research Policy and Compliance and are provided here with their permission.