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Reporting Outside Professional Activities

David Litster

At the end of every academic year faculty and research staff at MIT are asked to report to their department head or laboratory director information about their outside professional activities during the past year. This year there will be two new forms in the OPA package. The new forms are for those who are principal investigators or co-investigators on projects funded by the U.S. Public Health Service (i.e., NIH) or the National Science Foundation. Everyone else may discard them.

Since October 1995, agency regulations have required all investigators who submit a proposal to the PHS or the NSF to disclose to MIT the existence of any significant financial interest that might appear to be affected by the investigator’s research. The PHS and the NSF issued the regulations in response to a few well-publicized situations in clinical medical research. The intent was to identify and avoid a conflict which might arise if the outcome of the investigator’s research could materially impact his or her personal wealth. It is the responsibility of MIT to certify to the agency that there is no conflict of interest or, if there is one, that it is being managed appropriately.

The law also requires that PHS- and NSF-supported investigators update their disclosures annually. Earlier this year, federal officials were at MIT and expressed their concern that the Institute’s compliance with the law was not entirely satisfactory. From colleagues with whom I have spoken, it seems that not everyone recognized the importance of this disclosure process, and that our current forms are so detailed and hard to figure out that they provide little incentive to comply. Accordingly, we have simplified the forms, and the annual updates will be done as part of the annual report to the Institute on outside professional activities. We hope this will be administratively more convenient as well as indicate that the process is important to MIT. The same forms will be used for the disclosure that is required whenever you submit a new proposal to one of these two funding agencies.

If you would like to see the current draft of the two new forms, you may find them on the Web at http://photon.mit.edu/opa/. The disclosure level is low, $10,000, and the reach is broad, being the aggregated amounts for the investigator, investigator’s spouse, and all dependent children. Consequently, almost every PHS or NSF investigator whose spouse is employed by a for-profit company or a public or non-profit organization will have to make a disclosure; almost none of these will represent any kind of conflict of interest but they will generate work for those involved. However, you will only need to disclose that the financial interest exceeds the threshold, not how much it actually is. Whatever we may think about the effort involved, the regulations do require these disclosures and we do need to comply. As we all know, even completely innocent connections can be misunderstood if not disclosed, so the disclosure will provide a measure of protection for PHS/NSF investigators and for the Institute.

These new forms were created and the disclosure process modified in order to be available in time for this year’s disclosure of outside professional activities to MIT. We intend to monitor the process and to work with the Committee on Outside Professional Activities to make any changes that will make it function even better in the future. If you have comments or suggestions as you go through the process this year, please send them to me (litster@mit.edu) or to Bill Porter (wlporter@mit.edu), who is the chairman of the Committee on Outside Professional Activities.

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