(F)
Procedures for reporting and investigating allegations of research
misconduct
(1)
Reporting allegation, inquiry, and investigation.
(a)
General
comments
(i)
All inquiries and investigations will be reviewed and generally will be carried
through to completion and all significant issues will be pursued
diligently.
(ii)
An allegation may be closed at the inquiry or
investigation stage on the basis that respondent has admitted responsibility
and a resolution with the respondent has been satisfactorily reached, provided
that applicable federal agency requirements regarding early termination of the
process are met.
(iii)
Appropriate university official(s) may impose a
temporary suspension of duties, pending conclusion of the inquiry and/or
investigation or take other appropriate action as necessary, including but not
limited to actions intended to protect federal funds.
(iv)
Participants and
their advisors should treat the matter with discretion and respect for the
reputation of the parties involved. Both the inquiry and the investigation will
be handled in such a way to promote confidentiality, providing information only
to those who need to know. Reasonable efforts will be made to protect the
identity of the respondent and the complainant(s) from all except those who
have a need to know. The university, however, cannot guarantee anonymity or
complete confidentiality due to public records law and the need to complete an
appropriate investigation. The identity of individuals who report or provide
evidence regarding allegations of misconduct in research or scholarship may be
disclosed to the respondent or others. The reporting of potential academic
misconduct or illegal activity to the sponsor, journal, governmental agency, or
other entity having apparent authority to investigate or address the alleged
misconduct is not an abuse of confidentiality.
(v)
The university
strives for an expeditious and thorough investigation and provides the
respondent an opportunity to comment on all allegations during the inquiry
stage and, if initiated, during the investigation.
(vi)
The integrity of
the process will be maintained by disclosure and evaluation of any prejudicial
conflict(s) of interest. Individuals judged by the RIO or the DO to have a
conflict of interest that would jeopardize the credibility of the inquiry or
investigation will not be assigned to inquiry or investigation panels nor to
decision-making roles in the process.
(vii)
It is a
violation of university policy to retaliate against an individual for reporting
in good faith an allegation of research misconduct.
(viii)
The university
will make a good faith effort to notify the respondent of the steps taken in
the process. If the respondent has not provided current contact information to
the university or does not respond to notices, these proceedings will continue
and if applicable, the committee will document how the respondent's absences
impeded the process.
(b)
Federal
requirements
(i)
The national science foundation, the public health service
and other federal agencies have published formal regulations regarding the
investigation of allegations of research misconduct involving activities
supported by those agencies (See appendix a). Each of these regulations
contains a definition of research misconduct, prescribes certain time limits
for inquiries and investigations, and requires reporting to the agencies under
certain conditions and at specified stages in the process.
(ii)
The RIO will
determine the applicability of external regulations in each particular case.
The university will comply with the requirements of the federal
regulations.
(c)
Allegations
(i)
Allegations of possible research misconduct may be
through any means of communication, as prescribed by federal guidelines (e.g.
NSF and PHS).
1
The
disclosure may be by written or oral statement or other communication to an
institutional official. If an allegation is received orally, the university
official receiving the allegation is to document, in as much detail as possible
prior to the assessment stage, the information provided, the name of the person
providing the information (if known), and that record will be used as the
allegation for purposes of this policy.
(d)
Allegation
assessment
(i)
The purpose of the assessment is to determine if an inquiry is warranted. An
inquiry is warranted if the allegation falls within the definition of research
misconduct under this policy and is sufficiently credible and specific so that
potential evidence of research misconduct may be identified.
(ii)
The RIO will
assess the allegation in consultation with at least three impartial senior
faculty members (with a faculty appointment below the dean level) identified by
the RIO. The RIO will provide a description of allegations to the faculty
members participating in assessment via electronic mail. Assessment will be
initiated within five business days of receipt of the
allegation.
(iii)
The RIO will forward potential misconduct that does not
fall within the definition of research misconduct under this policy through
other administrative channels as appropriate.
(iv)
After
assessment, the allegation will either be dismissed or move to the inquiry
stage. If the allegation moves forward, the RIO will prepare a written charge
for the inquiry committee that: describes the allegations and any related
issues identified during the allegation assessment; and states that an
investigation is warranted if the committee determines that:
(1)
there is a
reasonable basis for concluding that the allegation falls within the definition
of research misconduct and,
(2)
the allegation
may have substance, based on the committee's review during the
inquiry.
(e)
Inquiry
(i)
The inquiry is an
extension of the allegation assessment process where the university conducts an
initial review of the available evidence to determine whether to conduct an
investigation. An inquiry does not require a full review of all the evidence
related to the allegation nor involve a formal hearing. The purpose of an
inquiry is not to reach a final conclusion as to whether research misconduct
occurred or who was responsible. Rather, the purpose is to determine whether
there is sufficient substance to an allegation to warrant a formal
investigation.
(ii)
The RIO will oversee the inquiry process and inform the
DO, and respective dean that an inquiry has been initiated.
(iii)
The RIO will
make a good faith effort to notify the respondent that an inquiry has begun and
provide the respondent with the written charge. If the inquiry subsequently
identifies additional respondents, they must be notified in writing of the
applicable charges. On or before the date on which the respondent is notified,
or the inquiry begins, whichever is earlier, the RIO must take all reasonable
and practical steps to obtain custody of all the research records and evidence
needed to conduct the research misconduct proceeding, inventory the records and
evidence and sequester them in a secure manner, except that where the research
records or evidence encompass scientific instruments shared by a number of
users, custody may be limited to copies of the data or evidence on such
instruments, so long as those copies are substantially equivalent to the
evidentiary value of the instruments.
(iv)
Within three
business days, the respondent may submit a written response to the allegations.
This response will be provided to the inquiry panel for review. The respondent
is not required to submit this response, but it is provided as an initial
opportunity to inform the committee about information the respondent believes
they should know as they proceed with the inquiry.
(v)
The RIO will form
a committee to secure the necessary and appropriate assistance to ensure a
thorough and authoritative evaluation of the allegation(s). The RIO will seek
guidance from members of the university research council in the selection of
the inquiry committee, which will consist of three senior faculty members,
including at least one member of the university research council or a research
council designee, with the additional assistance, if needed, of an expert in
the academic discipline involved, either from within the university or
elsewhere. Individuals who have served in the allegation assessment will be
excluded from the inquiry committee.
(vi)
The RIO will
inform the respondent of the names of the inquiry committee members. The
respondent has one week to object in writing to the RIO to a committee member
on the basis of conflict of interest; the conflict must be explained in
sufficient detail so as to allow the RIO to make a determination about the
committee member.
(vii)
The respondent may have an advisor and/or collective
bargaining representative present during respondent's meetings with the inquiry
panel.
(a)
The
RIO must be notified at least twenty-four hours prior to the meeting or hearing
that an advisor and/or collective bargaining representative will attend, and
whether the advisor and/or collective bargaining representative is an
attorney.
(b)
A collective bargaining representative and/or other
advisor may be present during meetings and hearings in which the respondent is
present. Respondents must cooperate by providing the respondent's own account
of the matter under review during interviews. An advisor and/or collective
bargaining representative of a respondent may not interfere with the objectives
of the committee or the committee's interview of respondent, or disrupt the
process in a manner that prevents an effective interview.
(c)
An advisor or
collective bargaining representatives are expected to make themselves available
on the dates and times that meetings and hearings are scheduled; meetings and
hearings will not be rescheduled more than once due to unavailability of any
party's advisor and/or collective bargaining representative.
(d)
The respondent
and their advisor and/or collective bargaining representative are not permitted
to record, photograph, or audio record meetings or proceedings.
(viii)
The inquiry committee will request written statements from individuals and
conduct separate meetings with any persons involved for the purpose of
clarification and fact-finding.
Detailed documentation shall be kept in
the research and sponsored programs office to permit later assessment of the
adequacy of the inquiry.
(ix)
The inquiry
should be completed within sixty days. If the inquiry exceeds that timeframe,
the record of the inquiry will document the reason for the
delay.
(x)
If the respondent refuses to participate in the
process, the inquiry committee will use their best efforts to reach a
conclusion concerning the allegations, noting in the report the respondent's
failure to cooperate and its effect on the evidence.
(f)
Reporting on the
inquiry
(i)
The
inquiry committee will prepare a written report that includes the name and
position of the respondent, the names and titles of the inquiry panel members,
a statement of the allegation(s), a description of the evidence reviewed,
summaries of the relevant interviews, and the conclusions of the inquiry that
includes the basis for recommending or not recommending that the allegations
warrant an investigation.
(ii)
If the inquiry
concludes that an investigation is warranted, the respondent will be provided
the opportunity to comment on the report within fourteen days, and any such
comment will become part of the record. The individual who made the allegation
also may review and comment on that portion of the report directly related to
the testimony or other evidence brought forth by that individual. Any comments
that are submitted by the complainant will be attached to the final inquiry
report.
(a)
If
the inquiry produces sufficient evidence to warrant a formal investigation, the
RIO will initiate a formal investigation. The determination to proceed with an
investigation will be based on the recommendation of the inquiry committee in
consultation with the RIO and members of the research council.
(b)
The RIO shall
decide if and when external funding agencies, if any, are to be notified, what
any such notification shall include, and to whom it should be directed. Any
such notice shall be submitted by the RIO, or his or her
designee.
(c)
The RIO and DO will determine what additional
notification(s) may be necessary. Reasonable efforts will continue to be made
to protect the identity of the respondent and the complaint(s).
(iii)
If
the inquiry concludes that an investigation is not warranted, the RIO shall so
inform any persons involved in the inquiry to whom the identity of the
respondent was disclosed.
(iv)
The report of
the inquiry, along with any formal comments on the report, will be forwarded to
the RIO, who will notify the appropriate director(s), the DO, and any other
appropriate university official.
(v)
Records and
documentation of all inquiry proceedings and findings will be kept in the
research and sponsored programs office for at least seven years after the
termination of the inquiry.
(vi)
The RIO will
forward potential misconduct that does not fall within the definition of
research misconduct under this policy through other administrative channels as
appropriate.
(vii)
Unsupported allegations of research misconduct not
brought in good faith may lead to disciplinary action against the
complainant(s).
(g)
Investigation
(i)
The purpose of the investigation is to determine
whether research misconduct has been committed, by whom, and to what extent,
and to make recommendations with respect to disciplinary actions. In the course
of the process, the investigation may also determine that there are additional
instances of possible research misconduct that would justify broadening the
scope beyond the initial allegations. The investigation must begin within
thirty calendar days after the determination by the RIO that an investigation
is warranted.
(ii)
The RIO will oversee the investigation process and
inform the DO and appropriate dean that an investigation has been
initiated.
(iii)
The RIO will, prior to notifying respondent of the
allegations, take all reasonable and practical steps to obtain custody of and
sequester in a secure manner all research records and evidence needed to
conduct the research misconduct proceeding that were not previously sequestered
during the inquiry. The need for additional sequestration of records for the
investigation may occur for any number of reasons, including the institution's
decision to investigate additional allegations not considered during the
inquiry stage or the identification of records during the inquiry process that
had not been previously secured.
(iv)
Upon determining
that an investigation is warranted, the RIO will appoint an investigating
committee of up to five senior faculty members.
(a)
The committee
will include at least one member of the university research council or their
designee, and may include one or more experts from outside the university when
necessary. One of the committee members will be appointed by the RIO to serve
as the committee chair. Individuals who have served on the inquiry panel or
been involved in the preliminary assessment of the allegation will be excluded
from the investigation committee. One exception to this exclusion, for one
member of the investigation committee, is permitted only when approved by the
research council.
(b)
The RIO will seek guidance from members of the research
council in the selection of the investigation committee.
(c)
The RIO will
inform the respondent of the names of the appointed committee members. The
respondent has one week to object in writing to the RIO to a committee member
on the basis of conflict of interest; the conflict must be explained in
sufficient detail so as to allow the RIO to make a determination about the
committee member.
(v)
The RIO will
inform the respondent in writing of the initiation of the investigation, the
composition of the investigating committee, the charge to that committee, and
his/her obligation to cooperate in the investigation.
(vi)
The
investigating committee will gather and evaluate evidence and reach a
determination within one hundred twenty days of appointment of whether research
misconduct has indeed occurred, and if so to what extent and by whom. If the
investigation exceeds that time-frame, the record of the investigation will
document the reason for the delay. A committee determination that misconduct
has occurred should also include recommended sanctions (e.g., reprimand,
demotion, or discharge) or other actions appropriate for resolution of the
matter such as correction of the research reporting.
(vii)
During that
investigation, the respondent will be informed of the identity of all witnesses
called before the committee.
(viii)
The
investigating committee will pursue diligently all significant issues and leads
discovered that are determined relevant to the investigation, including any
evidence of any additional instances of possible research misconduct, and
continue the investigation to completion.
(ix)
The
investigation committee may review and inspect laboratory notes, grant and
contract files, reports, scholarly publications, manuscripts and other
pertinent documents and electronic materials or communications and to
laboratory or clinical facilities and materials.
(x)
The investigative
committee must seek to collect information from and, if possible, interview
each respondent, complainant, and any other available person who has been
reasonably identified as having information regarding any relevant aspects of
the investigation, including witnesses identified by the respondent, and record
or transcribe each interview, provide the recording or transcript to the
interviewee for correction, and include the recording or transcript in the
record of the investigation.
(xi)
The respondent
may have an advisor and/or collective bargaining representative present during
meetings with the investigation panel.
(a)
The RIO must be
notified at least twenty-four hours prior to the meeting or hearing that a
collective bargaining representative and/or other advisor will attend, and
whether the collective bargaining representative and/or other advisor is an
attorney.
(b)
An advisor and/or collective bargaining representative
may be present during meetings and hearings in which the respondent is present.
Respondents must cooperate by providing the respondent's own account of the
matter under review during interviews. An advisor and/or collective bargaining
representative of a respondent may not interfere with the objectives of the
committee or the committee's interview of respondent, or disrupt the process in
a manner that prevents an effective interview.
(c)
An advisor and/or
collective bargaining representatives are expected to make themselves available
on the dates and times that meetings and hearings are scheduled; meetings and
hearings will not be rescheduled more than once due to unavailability of any
party's advisor.
(d)
The respondent and advisor and/or collective bargaining
representatives are not permitted to record, photograph, or audio record
meetings or proceedings.
(xii)
The
investigating committee will keep the respondent, provost, and the appropriate
dean apprised of any additional allegations or other developments during the
investigation.
(h)
Formal findings of the investigation committee,
resolution and outcome
(i)
A finding of misconduct requires that a preponderance
of the evidence establishes that:
(a)
Research misconduct, as defined in this policy,
occurred; and
(b)
The research misconduct is a significant departure from
accepted practices of the relevant research community; and
(c)
The respondent
committed the research misconduct intentionally, knowingly, or
recklessly.
(ii)
The respondent has the burden of proving by a
preponderance of the evidence any affirmative defenses raised, including honest
error or a difference of opinion.
(iii)
The
investigation committee will prepare a written report on the formal findings of
the investigation and its recommendations regarding the outcome. The report
will include:
(a)
The name(s) and title(s) of the respondent and the
nature of the allegation(s) of research misconduct;
(b)
The names and
titles of the members of the committee;
(c)
The specific
allegations of research misconduct investigated;
(d)
A statement of
findings for each allegation of research misconduct, including:
(i)
A statement on
whether the research misconduct was falsification, fabrication, plagiarism or
deliberate violation of regulations;
(ii)
Whether it was
committed intentionally, knowingly, or recklessly; and
(iii)
A summary of
the facts and the analysis which support the conclusion considering the merits
of any reasonable explanation by the respondent.
(e)
Identification
and summary of the research records and evidence reviewed, as well as any
evidence taken into custody but not reviewed;
(f)
A summary of the
facts and analysis supporting the report's conclusions;
(g)
If applicable,
identification of any funding agency support, the name of the agency, and
documentation sufficient to document the support for example, the numbers of
any grants that are involved, grant applications, contracts, and publications
listing the agency providing support;
(h)
A copy of the
institutional policy under which the investigation was
conducted;
(i)
Identification of publications that need correction or
retraction, and
(j)
A list any current external support or applications for
funding that the respondent has pending.
(iv)
The respondent
and complainant have thirty days to comment on the report, and such comments
will become part of the record.
(v)
The committee
will submit its report and respondent's comments, to the RIO, and the DO. The
DO, after consultation with the RIO and investigation committee, will decide
whether to concur or reject the finding of misconduct and decide what action
should be taken. He or she will notify the respondent, the RIO, the appropriate
dean, department or program chair, and any other appropriate university
official of the decision. In consultation with the appropriate university
official(s), the RIO will then decide if, and when, external funding agencies,
publishers, and/or co-authors, if any, are to be notified, what any such
notification shall include, and to whom it should be directed. Any such notice
will be submitted by the RIO.
(vi)
If the DO
rejects the findings of the investigation committee or the recommended
outcomes, the DO will, as part of his/her written determination, explain in
detail the basis for rendering a decision different from the findings or
recommended outcomes of the investigation committee.
(vii)
Investigation
files will be maintained in a secure manner in the research and sponsored
programs office or in a secured location under the direction of research and
sponsored programs for seven years after completion of
proceedings.
(viii)
The university will undertake efforts, as appropriate
and feasible, to restore the reputations of persons alleged to have engaged in
misconduct when allegations are not confirmed, and also undertake efforts to
protect the positions and reputations of those persons who, in good faith, made
allegations.
(ix)
An individual who has been found by the DO to have
committed misconduct, may appeal the imposed disciplinary actions by following
the applicable grievance policy.
Appendix A: Federal Research Misconduct
Policies
US Department of Health & Human Services, 42 CRF parts 53
and 90, May 17, 2005
https://ori.hhs.gov/front_misconduct
The National Science Foundation (NSF) Regulations, 45 CFR Part
689, March 18, 2002
https://www.nsf.gov/oig/regulations/
National Endowment for the Humanities
https://www.neh.gov/grants/manage/research-misconduct-policy
National Aeronautics & Space Administration, 14 CFR Part
1275, July 14, 2004
http://edocket.access.gpo.gov/2004/04-15432.htm
[This policy was adapted with permission from the DHHS Office
of Research Integrity]
1
"Promptly after
receiving an allegation of research misconduct, defined as a disclosure of
possible research misconduct through any means of communication¦" (requirements
for institutional policies and procedures on research misconduct under the new
PHS policies on research misconduct - 42 CFR Part 93) .