What Do Researchers Need To Do?
The best ways to mitigate concerns regarding undue foreign influence are by educating yourself and your staff about relevant regulations and policies, completing all sponsor and Institute disclosure procedures, and providing ongoing communications regarding any new or changing relationships with foreign entities. The following resources are provided to help you fulfill those responsibilities. We will continue to update and expand the resources on this page, as necessary, so please check back periodically.
MIT uses the CITI Program for the training needs of faculty, researchers, students and staff. CITI has developed a four-part course titled Undue Foreign Influence: Risks and Mitigations which covers the following:
- Undue Foreign Influence Impacts and Concerns for Academia
- Reporting, Research Integrity, and Effective Practices to Manage Undue Foreign Influence Risk
- Cybersecurity and Compliance Considerations for Safeguarding Research
- Nondiscrimination Considerations When Managing Undue Foreign Influence
Anyone who is involved in research at MIT is encouraged to complete this course. Each module can be completed in approximately 30 minutes or less.
Use the links below for:
- Instructions to set up your account (first time users)
- Instructions to add new courses to your existing profile
(Valid MIT certificate required.)
In compliance with individual sponsor requirements, certain collaborations and/or affiliations with foreign as well as domestic entities or individuals must be disclosed in proposals and reports. Such collaborations may include exchanges of staff, materials, data, funding, or other significant activity which could result in joint authorship.
Failure to fully disclose foreign/domestic collaborations, affiliations, and resources in funding applications and other documents can have serious consequences, and may endanger MIT’s eligibility for future federal funding.
When an MIT Principal Investigator submits a proposal to the Kuali Coeus system for final review by MIT Research Administration Services (RAS) and further submission to a federal agency, the PI is certifying that all information is complete and accurate to the best of his or her knowledge, and failure to disclose may lead to charges of providing fraudulent information. In some cases, failure to disclose has led to criminal charges against individual researchers.
Additional information on recent actions taken by various government agencies against researchers who have not fully disclosed their foreign support and affiliations can be found in this July 7, 2020 article in Nature, this July 15, 2020 article in Chemistry World, and this November 27, 2020 article in Bloomberg Law.
Please contact the appropriate sponsor liaison or contract administrator in RAS if you have any questions on disclosure requirements. The policies of the various agencies are not consistent and are being continuously modified. The disclosure policies of some key agencies are summarized below:
- Department of Defense
- Department of Energy
- National Aeronautics and Space Administration
- National Institutes of Health
- National Science Foundation
For disclosure policies of other federal research sponsors, please review the program announcements and proposal preparation guides, and contact your RAS contract administrator with any questions.
Portions of the contents of this section were adapted from materials prepared by UCLA Research Policy and Compliance and are provided here with their permission.
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)|
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.
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:
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 Institute of Technology
MIT Office with Administrative Responsibility
Office of the Vice President for Research
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:
- by an Investigator; or
- by an Investigator and members of his or her Family; or
- 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:
- 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
- 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
- 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
- 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
- any Equity Interest is held in a US or foreign non-publicly traded entity; or
- the aggregate value of Remuneration received from a foreign governmental organization during the 12-month period preceding the disclosure exceeds $5,000; or
- 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:
- Remuneration from MIT; (including salary and royalty payments) and
- 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
- Remuneration from authorship of academic or scholarly works, regardless of the source; and
- 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
- 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.
The International Coordinating Committee (ICC) [website] guides MIT faculty, researchers, students and staff in planning, negotiating and implementing international activities. Their website is a source of valuable resources for the entire MIT community, and they are available to assist and advise researchers at the earliest stages of any engagement with foreign entities.
International proposals in the following categories require additional “elevated risk” review by the ICC and the MIT Senior Risk Group:
- projects funded by people or entities from China (including Hong Kong), Russia and Saudi Arabia;
- projects which involve MIT faculty, staff or students conducting work in these countries;
- and collaborative projects with people or entities from these countries.
Special attention will be paid to risks related to intellectual property, export controls, data security and access, economic competitiveness, national security, and political, civil and human rights, as well as potential impacts on the MIT community, consistency with MIT’s core values, and alignment with MIT’s academic mission. As international circumstances change, the list of countries subject to this additional review may be modified.
Make sure that you and your staff complete all necessary Export Control Training and that you check the Export Control website for current updates. Remember, exports refer not only to physical items, but also to intangibles such as ideas and information.
As stated above, the unlawful transfer of research materials and samples is a significant concern of the U.S. Government; items such as biologicals, chemicals, batteries and fuel cells, or radioactive materials may be restricted or have specific licensing requirements. The Export Control page on Biological, Hazardous, or Radioactive Material provides links to current guidance regarding shipping such items. When in doubt, contact the Export Control Office for further guidance.
For an overview of current Federal regulations for working with non-U.S. collaborators and sponsors see our Regulations for Non-U.S. Activity page.