New policy on employee conflict of commitment

Dear colleagues,

Following two years of gathering thoughtful input from across the MIT community, we write to inform you of two important and positive developments. First, we are launching a new streamlined system, known as MyCOI-OPA+, for consolidated reporting of financial conflicts of interest (FCOI) and outside professional activities (OPA). In addition, we have formalized MIT’s longstanding practices in a Conflict of Commitment (COC) policy, which applies to all Institute employees.

The new consolidated system and related policy updates simplify current reporting processes, improve transparency, and ensure compliance with federal requirements. For faculty and academic and research staff, the new MyCOI-OPA+ system combines recordkeeping on FCOI and OPA, establishes an internal database of entities, and allows updates at any time, replacing the annual disclosure process for OPA. The net result will be a reduced administrative burden for the user.

In what should also be a welcome change, administrative, support, and service staff will not be required to report outside activities unless specifically directed to do so in accordance with the COC policy.

The COC policy aims to strike a clear and fair balance between the advantages of outside professional activities to MIT teaching and research and the expectation that each employee makes their primary professional commitment to MIT. The policy also complements the existing policy on Financial Conflicts of Interest in Research and the appointment-based OPA reporting requirements. Please note that the new policy does not expand the availability of permitted time for OPA beyond the appointment types that already have it per MIT Policies & Procedures.

What to expect

All staff and faculty should become familiar with these policy and reporting requirements.

• Faculty, academic instructional staff, academic and sponsored research staff (including all postdocs), and others as directed will file disclosures using MyCOI-OPA+, at least annually and upon taking on any new OPA or significant financial interest. The system will be introduced to units on a rolling basis beginning in September. Some initial setup will be required (details to come), and training will be available. In the meantime, if you have a funding proposal due, a disclosure on file that is expiring, or an award on hold pending an FCOI disclosure, VPR staff may prompt you to use the system sooner.
• All other staff: If you are a member of the administrative staff (including sponsored research administrative staff), support staff, or service staff, you will not use the MyCOI-OPA+ system and should refer to the OPA guidance regarding outside activities reporting.
• Graduate students considering outside professional activities should continue to follow the COI and OPA policies outlined in Graduate Policies and Procedures. Students will not use MyCOI-OPA+ unless specifically instructed to do so as part of a research proposal or award process.

For further information about these changes, please refer to coi.mit.edu or reach out with any questions.

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We are grateful to the many administrators and faculty who advised on the development of MyCOI-OPA+, and especially to the faculty testers who engaged with it and provided invaluable feedback.

We thank you, as ever, for your commitment to excellence and integrity in your work at MIT.

Sincerely,

Anantha P. Chandrakasan
Provost

Ian A. Waitz
Vice President for Research

Ramona Allen
Vice President for Human Resources