Overview of Financial Conflict of Interest Disclosure Process

Prior to submitting proposals in Kuali Coeus for internal or external funding, Investigators identified in the proposal must: 

1. Complete PI certification in KC. PI certification includes three COI Screening questions to help identify potential conflicts of interest.
2. If a potential conflict is identified, complete a full FCOI disclosure in MyCOI-OPA+. This is to provide additional information regarding the relationship of the project to the Significant Financial Interest. 
3. Certify and submit the full disclosure in MyCOI-OPA+ prior to routing the proposal for Department, Lab or Center Head approval.

Prior to award activation:

1. If no conflict was identified at proposal stage, an Investigator may be required to complete a full FCOI disclosure in MyCOI-OPA+.  
2. The full FCOI disclosure must be reviewed and approved by the COI officer.

You will need to answer the following screening questions as part of your first FCOI disclosure, or when revising your existing FCOI disclosure.

Gather any documentation that will help with identifying these organizations, such as:

• W-2 forms from organizations other than MIT
• 1099s 
• Quarterly statements showing equity

Screening questions:

• From any for-profit organization. – Did you receive in the last 12 months, or do you expect to receive in the next 12 months, salary, director's fees, consulting payments, honoraria, royalties; or other payments for patents, copyrights or other intellectual property; or other direct payments exceeding $5,000?
• From any privately held organization. – do you have stock, stock options, or other equity interest of any value?
• Some publicly traded stock must be disclosed, but only in specific circumstances. – Do you own now, or expect to own in the next 12 months, more than $5,000 in stock, in a PUBLICLY HELD ORGANIZATION that provides funds to MIT in support of your Institutional Responsibilities (e.g. teaching, research, committee, or other administrative responsibilities)? 
  • Do not include investments where you do not directly influence investment decisions, such as mutual funds and retirement accounts. 
  • Do include stock/options, warrants and other existing ownership interests.
• Some publicly traded stock must be disclosed, but only in specific circumstances. – Do you own now, or expect to own in the next 12 months, $100,000 or more in stock in a PUBLICLY HELD ORGANIZATION whose business, or any portion thereof, could reasonably appear to be related to your MIT Institutional Responsibilities? 
  • Do not include investments where you do not directly influence investment decisions, such as mutual funds. 
  • Do include stock/options, warrants and other existing ownership interests.
• From US educational institutions, US teaching hospitals or US research institutions affiliated with US educational institutions – Did you receive in the last 12 months, or do you expect to receive in the next 12 months, payments for services, which in aggregate exceed $5,000 (e.g. payments for consulting, board positions, patents, copyrights or other intellectual property)? 
  • Do not include payments for scholarly or academic works (i.e. peer-reviewed (vs. editorial reviewed) articles or books based on original research or experimentation, published by an academic association or a university/academic press).
• From FOREIGN educational institutions, teaching hospitals or research institutions affiliated with foreign educational institutions – Did you receive in the last 12 months, or do you expect to receive in the next 12 months, payments for services, which in aggregate exceed $5,000? 
  • Do not include payments for scholarly or academic works or any payments or reimbursements made through MIT. However, payments made directly to you must be reported. 
  • Do include payments for salary, consulting, board positions, patents, copyrights or other intellectual property.
• From a not-for-profit organization (i.e. foundation or professional society) – Did you receive in the last 12 months, or do you expect to receive in the next 12 months, compensation in any form exceeding $5,000? 
  • Do not include payments for scholarly or academic works.
• An Investigator could have a Significant Financial Interest due to financial holdings of his or her Family. From any organization – Did your FAMILY (spouse/domestic partner and/or dependent children) receive in the last 12 months, or do they expect to receive in the next 12 months, payments or equity in excess of $5,000 from an ANY organization whose line of business, or any portion thereof, could reasonably appear to be related to any of your Institutional Responsibilities? 
  • Do not include payments for scholarly or academic works. 
  • Do include all forms and combinations of equity, salary, director's fees, consulting payments, honoraria, royalties, or other payments for patents, copyrights or other intellectual property or any other direct payments.
• Do you have SUBCONTRACTS, PURCHASING or OTHER CONTRACTUAL ARRANGEMENTS at MIT with organizations in which you have a Significant Financial Interest?

For each SFI which meets one of the above thresholds, provide the following:

• Public or private organization
• Organization type (e.g. For-profit Organization, Not For Profit)
• Are you/Family founder/co-founder of entity
• A description of the entity’s business focus and specifically your work or role with the entity
  • For example: "‘Soya-tastic’ is an international organization exploring soya bean farm sustainability. I serve as a Member of the Board of Directors to provide guidance on policies and objectives to ensure the organization fulfills its mission."
• An explanation of any involvement of students, staff or MIT resources/facilities and your work with this entity
• Relationship details (you will be required to provide at least one but you should enter all that apply):
  • Income from royalties (other than MIT), board or advisory memberships, consulting, speaking engagements (exclude U.S. universities, U.S. federal, state and local governments, U.S. institutes of higher education, research institutes affiliated with institutes of higher education), service as an employee (in the previous 12 months or currently)
  • Stock and Equity (any equity in a non-publicly traded company, common stock holdings, stock options)
  • Goods purchased from the entity for research and other activities at MIT
  • Subaward(s) under your direction issued to the entity
  • Gifts received

Describe the relationship between each project (awards and pending proposals) and each SFI: 

• You must include any involvement with students, staff and MIT resources. 
• If there is no relationship between the work you are performing for this entity and a project, explain how they are different.

Examples describing no relationship:

• There is no relationship between the work performed for Related Entity and this project, as this project involves the development of a rapid diagnostic for bio-sensing of diseases, which is not in the area of Entity's interest.
• Related Entity’s business has nothing to do with the project regarding device for electrical and chemical modulation of pathological neural activity.
• This project involves organizing a computational conference on sustainability. The Related Entity activity involves providing strategic advice on applying autonomous systems to mechatronics.
• My work for Related Entity involves giving advice about yeast genetic engineering. This research project is aimed at understanding basic cell biological processes such as protein folding and intracellular trafficking.