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To contact the COI officer, please e-mail coi-help@mit.edu.
In the information about travel reporting requirements, it lists an exemption for travel sponsored by a research institute. Does this include foreign research institutes?
Foreign universities and foreign research institutes affiliated with them are not included in the exemption and travel sponsored or reimbursed by them does require a travel disclosure.
In the NIH Progress Report, does listing someone by name in the “all personnel report” mean that person has been identified as a key person and will be subject to the regulations regarding training and COI disclosure?
No. Only if you identify an individual specifically as a Key Person in a progress report or a proposal will they be subject to the regulation requirements.
On a Fellowship Application to NIH, we sometimes see a Co-sponsor in addition to the Sponsor listed in the Key/Persons. Should we dissuade fellowship applicants from including Co-Sponsors?
If the two sponsors have different areas of expertise, e.g. the Co-Sponsor works at a hospital while the Sponsor is MIT faculty, they should both be included. However, unless there is a clear addition to the field of expertise, these should generally be limited to the Sponsor. (Note; if the co-Sponsor is from another institution, they will need to go to IS&T to get a Kerberos account and MIT certificate in order to complete the proposal Certification and COI disclosure & Training)
If we are the sub on an NIH prime award and our PI determined some people are Key Persons, but the prime awardee does not include them, do we need to name them as Key Persons, have them complete Key Person certification and submit a proposal disclosure (if needed based on certification answers)?
Yes. If the MIT PI identified them as Key Persons for the MIT portion of the project, they should be included in the Key Persons on the proposal and the regulations/requirements apply.
Should/could Travel Disclosures be entered when the trip is booked, or only after completion of the trip?
You can log travel into the Coeus Travel Disclosure at the time of booking, and can then later update it if the trip is changed or canceled. If entering a trip in advance, when you get to the Certify page, Quit, do not certify. This will save all your entries to this point but will not submit it for review, leaving it available for future editing. Just be sure that the travel report is Certified and submitted within 30 days of completing the trip.
Who can maintain key persons?
RAS staff are the only personnel to maintain key persons in an Award in the KC system. If Key Person(s) should be deleted or added to an Award, please contact your RAS Contract Administrator for further review.
Will an aggregator be able to see that a PI has completed their certification?
Yes, if completed, you will see next to PI/co-I/Key Person’s name, "Certification Completed and Answered By ________ - mm/dd/yyyy hh:mm)"
If I have no Active SFIs in Step 2 why can’t I continue with my disclosure?
If you have no active SFIs in Step two but do not see the Continue With Disclosure Button please use the Return to Screening Questions button to review your answers there to see if any responses to screening questions need to be edited. If your screening answers determine that you have no conflicts, and you have no active Significant Financial Interests, you automatically skip past steps two and three and proceed directly to Step Four – Certify.
If individuals are named in an NIH Notice of Grant Award when it is initially received, but not named in the NOAs for following incremental years, are they still Key Persons?
Yes. They must still be treated as named key persons and prior approval from NIH is required before removing them as Key Persons on the award.
If you are deleting a Key Person from an award in Kuali Coeus, do you have to go to NIH for approval?
Not if the person is not named in the award notice from NIH. You would, however, still need to include the change to key persons in the Progress Report with NIH.
Who needs to complete an OPA form?
Administrative staff, Faculty, Other Academic staff and Research Staff. Support and Service staff do not need to fill them out. Please contact your department headquarters for more information.