What is Research Misconduct?
According to UCONN Health’s Policy, research misconduct means willful fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results.
a. Fabrication is making up data or results and recording or reporting them, i.e., there is no experimental evidence to support the fabricated data.
b. Falsification is manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the research record; i.e., the experimental evidence may have been selectively edited, deliberately subjected to incorrect statistical analysis, or in the case of images, inappropriately manipulated.
c. Plagiarism is the appropriation of another person’s ideas, processes, results, or words without giving appropriate credit. Authorship disputes are not defined as plagiarism in this policy. (Please refer to the page on plagiarism elsewhere in this site for more information on this topic.)
What is not Research Misconduct?
Research misconduct does not include honest errors or differences of opinion regarding data which have been included in publications, presentations or proposals. Also, violations of UConn Health policies on human or animal subjects research, data ownership, conflicts of interest in research or fiscal propriety, while of significant concern, are not considered forms of research misconduct.
What do I do if I suspect someone of Research Misconduct?
First, do not immediately jump to any conclusions because you have observed some action or behavior that you suspect is research misconduct. Research in a complex institutional environment such as that at UConn Health takes on many forms, and may not be adequately understood by someone who is not intimately associated with a particular program. If you have a significant concern about something you have observed, you should gather together your facts and consider discussing your concerns, in confidence, with someone with greater experience and who you trust, for counsel. This may be a colleague, your supervisor, your Department Head, the Associate Dean for Research in your School, UConn Health’s Associate Vice President for Research Compliance or UConn Health’s Research Integrity Officer (RIO). Your concern can be presented hypothetically, or even anonymously, to help you sort out your thoughts in order to decide whether to file a formal allegation of research misconduct. It is important to remember that an allegation of research misconduct that proves to be unwarranted, even if made in good faith, can have a major impact on the reputation of the Respondent (the person against whom the allegation is made). So it is important to be sure of your facts. However, it is also important that research misconduct, if it is really happening, NOT be allowed to go unreported.
If you decide to file an allegation about your concerns, guidance about the various ways to report them may be found in UConn Health Policy #2003-33, “Reporting Compliance Concerns”. It is important to note that allegations of research misconduct may be made anonymously, as described in that Policy. You may even report your concern to the agency or organization funding the work about which you are concerned.
Further information about this question is available from UConn Health’s RIO.
What will happen once I report my suspicions of Research Misconduct?
The process for reviewing allegations of research misconduct is complex, involving several stages. The first stage is confirmation that the allegation involves research misconduct, and not some other violation of policy or compliance. This is performed by the RIO in conjunction with the Standing Committee on Research Misconduct (RMC). Once the RMC formally initiates an inquiry into the allegation the Respondent (the person alleged to have committed the research misconduct, or the head of the research program in which the misconduct was alleged to occur if the allegation does not specify who may be responsible) will be notified of the allegation (as well as several senior administrators in the Respondent’s School), the RIO will begin a process of evidence sequestration, and the RMC will review the evidence and may interview selected witnesses. You as the Complainant will be interviewed by the RMC, assuming you did not report the allegation anonymously. If the RMC decides there is sufficient evidence to warrant a formal investigation (the next stage), a new investigation committee (the Special Review Board [SRB]) will be appointed. You will be provided with a copy of the report of the RMC’s inquiry, assuming your identity is known to the RMC. If the RMC decides against recommending a formal investigation, UConn Health will exercise its best efforts to restore the reputation of the Respondent, and the review of the allegation ends.
If a formal investigation is initiated by the SRB, a much more rigorous review of all publications, presentations and grant applications (and the data described in those documents) prepared by the Respondent, going back six years from the date of the initial instance of alleged research misconduct will be conducted. The final decision on whether research misconduct has occurred will be made by the SRB.
More details may be found in UConn Health’s Policy.
What will happen to me if I report my suspicions of Research Misconduct?
If you make an allegation of research misconduct, regardless of the path you choose for make the report, you will eventually be contacted by UConn Health’s RIO. It is rare that an allegation or report made through alternate channels contains sufficient facts or information upon which to initiate an inquiry. The RIO will request an interview in order to:
- confirm that your concerns fall within the definition of research misconduct;
- determine whether a conflict of interest exists between you and any member of the RMC;
- inform you that every effort will be made not to divulge your identity to the Respondent, but that once the specifics of the allegation are known, the Respondent may be able to infer your identity, or that it may be necessary to divulge your identity to federal agencies or others involved in the inquiry/investigation process (your identity will not be directly divulged to the Respondent);
- confirm the details of your allegation, and work with you to document those details in written form;
- confirm that you understand that once an inquiry has been initiated, it cannot be suspended because you have withdrawn the allegation;
- ensure that you have a copy of UConn Health’s Policy;
- explain that you may will be offered an opportunity to be interviewed by the RMC, but that you will not participate in the fact-finding phase, or in any other aspect of the determination of misconduct, other than as a witness. You are not required to be interviewed by the RMC.
Can I submit my concerns about Research Misconduct anonymously?
Yes, UConn Health Policy #2003-33, “Reporting Compliance Concerns provides a way to report your suspicions anonymously. If you submit your allegation anonymously, it will eventually be referred to UConn Health’s RIO. Since your identity will not be known, you will never be contacted, and there is no guarantee that your allegation will contain enough information upon which to initiate an inquiry.
Can I discuss my concerns about Research Misconduct “theoretically”?
Yes, you can confer with the RIO on a theoretical basis, as long as you do not divulge names or sufficient facts that would allow the identification of a person or research program associated with your concerns. Once you divulge a name(s) or identify a research program, UConn Health is obligated to follow through with its research misconduct review process.
What can happen to me if the report of my suspicions of Research Misconduct are not substantiated?
Provided your suspicions were reported in good faith, UConn Health’s Policy on Non-Retaliation prohibits any retaliation taken against you by the Respondent or anyone else at UConn Health. If it is determined that you acted in bad faith, you may face disciplinary action by UConn Health. Making an allegation is not in good faith if you knowingly or recklessly disregard information that would negate the allegation or testimony you provide.
What if my suspicions of Research Misconduct involve someone not affiliated with UCONN Health?
There are many possible scenarios involving research misconduct by someone not affiliated with UConn Health. You may have attended a seminar where you suspect that data presented was fraudulently created or plagiarized. You may have noticed questionable data in your role as a reviewer of a manuscript submitted for publication in a scientific journal. You may have come across plagiarized writings as a reviewer of a grant application. You may be reading a text book and come across plagiarized writings. These are but a few examples of the many ways you might be presented with possible research misconduct by a scientist from another institution.
The first thing you should do is be sure of your facts. If you suspect plagiarism, compare the alleged plagiarized document/data against the source, so that you can present your concerns in a manner that is easily understood. If you suspect that an image has been inappropriately manipulated, consult an authority who has expertise in the forensic analysis of images. Organizations concerned with research integrity, such as the U.S. Office of Research Integrity (ORI) can provide advice on such matters.
Once you are sure of your facts, then you should report your concern to the appropriate authority associated with the venue in which the possible research misconduct has been noted. If it is in a grant application under peer review, notify the person in charge of the review process. If it is in a published paper or textbook, notify the editor. If it is in a public forum such as a seminar or symposium, notify the organizer. If the research was funded by a governmental or private funding agency, you can report your concern to that agency, such as ORI, if the work was funded by the U.S. Department of Health and Human Services. Those individuals are under an obligation to investigate allegations of research misconduct associated with activities under their control, and report the outcome of their investigation to you as a Complainant.
What if my suspicions of Research Misconduct involve someone who is no longer at UCONN Health, but the misconduct was performed here?
UConn Health is obligated to investigate all allegations of research misconduct that are performed in its facilities, with its resources and by its employees or trainees. If the behavior you are concerned about was performed by a former employee or trainee, you should consult with UConn Health’s RIO.
What do I do if someone accuses me of Research Misconduct?
If you are named as a Respondent in an allegation of research misconduct, you will be notified by the RIO as soon as the RMC has initiated an inquiry. This notification could be in person, as the RIO comes to notify you, and to sequester evidence such as lab notebooks and other research records, including your UConn Health owned computer. You should discuss the allegation with the RIO so that you fully understand it, and gather together all of your research records that relate to the allegation, and turn them over to the RIO. This may inconvenience your research, but the RIO will work with you to return your computer as quickly as possible, and provide you with supervised access to your research records whenever you need them. It is very likely that the RMC will wish to interview you as they review the allegation and your research records. It would be very helpful to the process if, prior to the interview, you organize the original research data that is related to the allegation.
You may also wish to think about presenting witnesses who have intimate knowledge of the research in question, in order to explain issues related to the allegation. It is not unusual that an allegation made in good faith is done so because of incomplete information available to the Complainant. Preparing to present explanations of missing information can greatly facilitate the inquiry process.
Finally, you should review the current composition of the RMC to ensure that no conflict of interest exists between you and any member of the RMC. UConn Health’s Policy defines a conflict of interest as:
“A conflict of interest as applied to this policy exists when a member of the Standing Committee on Research Misconduct (see below) or the Special Review Board (see below) has a collaborative professional, personal or financial relationship with a Respondent(s) or Complainant(s) (see below). Membership in the same academic department as a Respondent(s) may, but does not necessarily constitute a conflict of interest. “
If you feel a conflict of interest exists, notify the RIO immediately.
What does it mean to be a Respondent in an allegation of Research Misconduct?
The UConn Health’s Policy defines a Respondent as follows:
“Respondent(s) means the person against whom an allegation of research misconduct is directed or who is the subject of a research misconduct proceeding. A designation of Respondent(s) implies no guilt with reference to the alleged research misconduct; it is merely a convenience necessary in order to conduct an effective proceeding. In the event that no formal Respondent(s) is named, the head of the research unit (e.g., Principal Investigator, laboratory head, protocol sponsor, etc.) will be named as a Provisional Respondent(s) in order to facilitate the proceedings.”
What are my rights if I am accused of Research Misconduct?
As a Respondent to an allegation of research misconduct you are entitled to:
- a fair and objective process of review of the allegation by the RMC;
- request recusal of a member of the RMC from the inquiry on the basis of a perceived conflict of interest; this right does not guarantee such a recusal, a decision on your request will be determined by UConn Health;
- supervised access to any research records sequestered by the RIO in conjunction with the inquiry;
- a copy of the allegation, redacted so as to preserve the anonymity of the Complainant;
- a copy of UConn Health’s Policy;
- present the Complainant (if known to UConn Health) with written questions about the allegation;
- be represented by legal counsel, at your discretion and personal expense;
- review and comment upon the RMC’s draft of its report;
- a copy of the RMC’s final report of its inquiry;
- the UConn Health’s best efforts to restore your reputation in the event that the RMC does not find sufficient basis to recommend further investigation of the allegation.