External Academic Appointments and Other Outside Professional Activities

Guidance to Faculty and Principal Investigators Regarding International Activities

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What should I do if I have accepted, or am considering accepting, an appointment as a visiting/adjunct/associate/distinguished professor at another university?

MIT normally does not allow a faculty member to accept a continuing or regular professorship or similar academic appointment at another university — regardless of whether it is a U.S. or foreign institution — since such a position can conflict with the faculty member’s obligations and commitments to MIT. However, exceptions may be considered in rare cases, and temporary or visiting appointments are possible at both U.S. and foreign institutions during periods of sabbatical or other leave from MIT.  You should not accept such an appointment, either continuing or temporary, without talking to your department head and seeking permission from your dean, and your department head or dean may consult with the Provost. Certain MIT policies are particularly relevant to the evaluation of these types of opportunities. MIT Policies & Procedures Section 3.1 states that “a professorial appointment normally obligates a faculty member to render full-time service to the Institute.”  Pursuant to MIT Policies & Procedures Section 4.3, “faculty should seek the permission of their dean when they have the opportunity to teach at other not-for-profit or for-profit institutions or when they are presented with other opportunities that might conflict with their faculty commitment.” Pursuant to Policies & Procedures Section 4.4, faculty and others acting on behalf of MIT “have the obligation to avoid ethical, legal, financial, or other conflicts of interest and to ensure that their activities and interests do not conflict with their obligations to the Institute or its welfare.” Even if you receive permission from your department head and dean, you must still report all appointments and affiliations at other universities, domestic and foreign, in your OPA reporting form as part of MIT’s outside professional activity (OPA) disclosure process

If you are considering accepting an academic appointment or other engagement with a foreign university or organization, then in addition to the above you should also contact exportcontrolhelp@mit.edu, and the export control team can screen the organization against U.S. sanctions lists and also advise on other potential export control risks.

You may need to disclose your academic appointment with another university in connection with your federal awards, particularly if it is at a foreign university. Please be sure to carefully review the applicable funding opportunity instructions and agency-specific guidance to determine which of your activities must be disclosed. This information may need to be included in your curriculum vitae or biosketch or in the current and pending or other support portion of the application or subsequent progress reports. If you have specific questions, please contact the research-compliance-help@mit.edu mailbox to discuss your individual situation.

If you are contemplating a visiting/adjunct/associate/distinguished professorship or other academic appointment at a university in China, Russia, North Korea or Iran, then as part of your planning — and to help inform discussions with your department head—you should contact research-compliance-help@mit.edu to get assistance in determining whether the parameters of the appointment could be considered by the U.S. government as participation in a “foreign government-sponsored talent recruitment program.” The U.S. government identifies talent recruitment programs involving the foregoing countries as of heightened risk, and some federal agencies prohibit funding recipients from participation in these countries’ talent recruitment programs and/or impose special disclosure requirements on external academic appointments.

If you receive compensation greater than $5,000, then you may also need to report your compensation as part of the financial conflict of interest disclosure process if you apply for external funding through MIT.

Consultation with your department head and others at MIT, and permission from your dean, in no way relieves you of full responsibility for your actions and your need to continually avoid ethical, legal, financial, and other conflicts of interest and to ensure that your activities and interests do not conflict with your obligations to MIT or its welfare.  MIT’s Conflict of Interest Officer maintains a resource to help faculty consider issues when planning for an academic appointment at another university  Foreign institutions can have drastically different policies around intellectual property ownership and disposition, publication allowances, confidentiality of research, and other important matters. If you are entering into an academic appointment with another university, you should engage personal legal representation to advise you on the impact of the university’s policies and any local rules governing academic activities, intellectual property and employment (and that can also translate any policies or agreements for you if they are written wholly or partially in a language for which you are not fluent).

March 4, 2021

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How should my outside activities and compensation be disclosed?  If I disclose these activities through one potential channel, or via a public website, is that sufficient?

If you engage in outside activities or receive compensation from an outside source — either within or outside the U.S.— you must be aware of three separate disclosure requirements relating to your MIT responsibilities, each described below. Disclosing information in one context does not satisfy the requirement to disclose the same information in another context, nor is inclusion of information on your public CV or personal website sufficient to satisfy these independent disclosure obligations

  • Outside Professional Activities (OPA) –  It is the obligation of faculty members to keep their department heads informed continually in adequate detail regarding all outside professional activities, service on external committees, and other special assignments, whether within or outside of MIT. OPA reporting for faculty takes place on an annual basis through an online certification portal, in a process that is communicated to faculty by their respective department heads. In addition to annual reporting and certification requirements, it is the ongoing obligation of faculty members to discuss with their department heads the assumption of outside activities that are new in scope or kind, before entering an agreement to undertake them. Please see MIT Policies & Procedures Section 4.5 for more detail.
  • Financial Conflicts of Interest (fCOI) – If you apply for external funding through MIT, you will need to disclose your significant financial interests, including those of your immediate family if their financial interests relate to your MIT responsibilities. Please see the foregoing link for a more precise definition, but significant financial interests generally include aggregate remuneration from any single source of greater than $5,000, equity interests greater than $5,000 in publicly traded entities, and equity interests of any amount in non-publicly traded entities. You will be automatically prompted to disclose your significant financial interests when you complete the online PI certification as part of the proposal process. More information is available at https://coi.mit.edu/reference-and-user-guides/what-do-i-need-know-starting-my-coi-disclosure.
  • Federal Funding Agency Disclosures – Each federal funding agency has its own disclosure and reporting requirements and procedures. These vary widely in scope, but can require disclosure of current and pending research support, foreign engagements and activities, a professional biosketch, lists of collaborators, lists of publications, and disclosure of certain financial interests. Summaries of agency-specific guidelines are maintained by the Office of the Vice President for Research. Please be sure to carefully review the applicable funding opportunity instructions and agency-specific guidance to determine which of your activities must be disclosed.  If you have specific questions, please contact the research-compliance-help@mit.edu mailbox to discuss your individual situation.

February 19, 2021

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What types of international activities should I report through MIT’s outside professional activity (OPA) process?

Whether conducted domestically or internationally, your OPA reporting must include all compensated outside professional activities and all other outside professional activities requiring substantial time commitment, even with no or nominal compensation.

Examples of compensated outside professional activities to report include:

  • Consulting or research for a company, university or other entity, including service as an expert witness;
  • Part-time employment or appointment at a company, university or other entity (including a government agency);
  • Membership on a corporate, technical, scientific or advisory board;
  • Speaking at corporate or other conferences or seminars, including speaking at academic conferences or seminars for other universities in connection with the receipt of an honorarium, monetary prize or other compensation;
  • Providing commissioned papers, reports, or editing services;
  • Teaching/lecturing outside MIT, at universities or companies, in degree or non-degree programs, including in connection with the receipt of an honorarium, monetary prize or other compensation;
  • Participating in a talent or other academic recruitment program for a company, university, government or other entity, including in exchange for support in the form of research funding, lab facilities or research staff, or in connection with the receipt of an honorarium, monetary prize or other compensation; and
  • Teaching in MIT’s executive, professional, international or other special or summer programs.

Examples of uncompensated outside professional activities to report include:

  • Appointment at a company, university or other entity (including a government agency);
  • Service to professional societies or outside educational institutions;
  • Service on government or industry review boards or panels, or special commissions or committees; and
  • Teaching in MIT’s executive, professional, international or other special or summer programs.

February 19, 2021

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