Print/Save to PDF

FCOI vs. OPA Disclosures: What Is the Difference?

This chart summarizes the Financial Conflict of Interest (FCOI) and Outside Professional Activities (OPA) policies under which faculty, researchers, research staff, academic instructional staff, postdocs, and others as directed must disclose certain information to MIT using the MyCOI-OPA+ disclosure module in order to achieve compliance with federal, state, and Institute requirements. NOTE: While subject to the Institute’s Conflict of Commitment policy, administrative staff are not required to disclose using MyCOI-OPA+ but must follow guidance specific to them as outlined in the OPA guidance document for Administrative Staff.

Please note that the FCOI and OPA disclosures made to MIT do not constitute a disclosure to the sponsor of research such as federal sponsors. It is the responsibility of the individual researcher to provide details of their outside engagements to the sponsor. 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.

	Financial Conflict of Interest (FCOI)	Outside Professional Activities (OPA)
Purpose	To ensure that personal financial interests don’t influence, or appear to influence, a researcher’s work thereby protecting the integrity and objectivity of research conducted by MIT investigators, and comply with related policies and regulations.	To identify and manage Outside Professional Activities (OPA), whether compensated or not, are appropriately balanced with MIT responsibilities and do not pose risks to institutional, research or compliance obligations.
Who discloses	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, researchers, research staff, academic instructional staff, postdocs, and others as directed
What should be disclosed	Review Overview of the FCOI Disclosure Process to help determine which Significant Financial Interests (SFIs) to disclose.	Any outside professional activity which is or appears to be Reasonably Related to your Institutional Responsibilities. NOTE: Prior approval requests for certain outside activities should be made whenever necessary as noted in the OPA Guidance document. See the OPA Guidance document for examples of outside activities and relationships that must be reported.
When is disclosure required	Depends upon source of funding, including, but not limited to: At proposal stage (during proposal certification), if there is a potential conflict of interest At award stage (when an award is received), if no disclosure was submitted at proposal On a rolling basis: Within 90 days of acquiring or changing a Significant Financial Interest (SFI) PHS and some other federally sponsored investigators must disclose within 30 days, and include Sponsored Travel in their disclosure If 12 months have passed since their last FCOI disclosure	Disclose in the MyCOI-OPA+ Disclosure Module within 30 days of entering into a new engagement. New and updates to existing engagement should be made on a rolling basis as they occur throughout the year. One year from the date of last disclosure if no new engagements occur.
Online Systems	MyCOI-OPA+	MyCOI-OPA+
MIT Office with Administrative Responsibility	Office of the Vice President for Research	Office of the Vice President for Research Office of the Provost Human Resources (for staff related OPA matters)

^{Updated August 2025}