Page 66 - Mass General Brigham - Innovators Guide 1.0

66 INNO V AT O RS GUIDE | M ASS GENERAL BRIGH AM

13
Managing Conflicts

13 of Interest (COI)

The HMS I(b)Rule, the “Research Support Rule,” initially prohibits receiving HMS I(d): The HMS I(d) Rule, or the “External Activity Rule,” states that
sponsored clinical or non-clinical research support from a company if the all Mass General Brigham researchers who serve in a fiduciary role to a
innovator has: for-profit biomedical company may not participate in clinical research on
the company’s technology nor receive sponsored research support from
i. Any equity in a private company, or the company. A fiduciary role includes but is not limited to members of the
ii. Equity greater than 1% in a public company. fiduciary board of directors, executive positions, managers of or members
This prohibition may be overcome through a petition to the Mass General of a member-managed limited liability company, and partners in a
Brigham and HMS faculty COI committees that demonstrates that the partnership or limited liability partnership. Serving on a Scientific Advisory
benefits of the proposed research outweigh the risks and the financial Board is not considered a fiduciary role.
interest can be appropriately managed. Note that “sponsored research Like the Executive Position Rule, the External Activity Rule applies only to
support” has a specific, and broad, definition, and includes gifts that are financial interests held by the faculty member (not family members).
made solely for the support of the Faculty member’s research or laboratory,
and equipment and materials under many circumstances. Again, OII There are no exceptions to this rule.
assists in the petition process.

The following are two additional HMS policies that have been adopted by
Mass General Brigham of which innovators should be aware.
HMS I(c): The HMS/Mass General Brigham I(c) Rule, or the “Executive
Position Rule,” prohibits full-time HMS faculty, and Mass General Brigham
Researchers who are also Institutional Officials, from serving in an
executive position in a for-profit business engaged in commercial or
research activities of a biomedical nature. An “executive position” includes
positions that carry certain titles, e.g., CEO, COO, CFO, Scientific or Medical
Director, but also has a broader scope and includes any position that is
responsible for a material part of the operation or management of
a Business.

The Executive Position Rule applies only to positions held by the faculty
member (not family members).
There are no exceptions to this rule.