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Graduate Student Handbook

Policy B: Policy and Procedure for Review of Alleged Misconduct of Research

Preamble

1. Integrity is an obligation of all who engage in the acquisition and application of knowledge. This duty is rooted in the personal and professional ethical responsibilities of scholars and is a commitment to a fundamental moral principle and norm of research. Recent disclosures of questionable practices by scientists have served to stimulate the academic community to review and reaffirm its commitment to integrity in research and to develop mechanisms for investigating allegations of misconduct.

2. Though the concept "integrity in research" embraces a wide range of issues and practices, this policy defines research misconduct as fraudulent or markedly irregular practices in research conduct and in the collection, analysis and reporting of data; including fabrication, falsification, plagiarism or other practices that seriously deviate from those that are commonly accepted within the scientific community for proposing, conducting or reporting research..

3. Primary responsibility for inhibiting misconduct and safeguarding the integrity of research should be exercised by the research community. This responsibility includes: examination of allegations of misconduct, investigation of substantiated allegations, and the imposition of sanctions when appropriate.

4. To provide for orderly and rapid disposition of charges of misconduct, a double-tiered review system will be employed at the University of Connecticut Health Center. Initial review of charges will be made by a Standing Committee of Health Center faculty to determine if sufficient cause exists for more detailed, exhaustive review. (The formation of a Standing Committee minimizes conflict of interest and prejudicial selection of ad hoc reviewers, and allows for accumulation of experience by the Committee in such matters.) Should initial review indicate sufficient cause, a Special Review Board will be appointed to conduct a thorough investigation of the charges and evidence. The Special Review Board will report its findings to the Dean of the School of Medicine or School of Dental Medicine, and the Chancellor and Provost for Health Affairs (Chancellor).

Initial Review of Allegations

1. A Standing Committee of five senior scientists will be appointed by the Chancellor, in consultation with the Dean of the School of Medicine and the Dean of the School of Dental Medicine, and upon the recommendation of the Councils of the Schools of Medicine and Dental Medicine. The Committee will consist of two members from the School of Dental Medicine and three members from the School of Medicine. The Assistant Vice Chancellor for Research will serve, ex-officio, as a non-voting member of the Committee and will be Executive Secretary for the Committee. Term of membership will be three years and can be renewed.

2. The Standing Committee will conduct an inquiry of charges to determine if cause exists for the creation of a Special Review Board to investigate the allegation of misconduct.

3. Only written allegations will be considered by the Standing Committee, and only when they contain sufficient information to be able to initiate an inquiry.

4. Allegations may be delivered in a sealed envelope to the Assistant Vice Chancellor for Research, the Chancellor, the Dean of the appropriate School, or the Chairperson of the Standing Committee. However, only the Chairperson or a designated member of the Standing Committee is empowered to open the sealed envelope and read the allegation. Trivial or frivolous allegations, as determined by the Chairperson and one member of the Standing Committee will not be brought before the Standing Committee for review. If the allegation is not presented to the Standing Committee, all records of the preliminary review, the letter of allegation and a report detailing the reasons why further review was deemed unnecessary, will be labeled, dated, sealed and deposited with the Assistant Vice Chancellor for Research. The Assistant Vice Chancellor for Research will keep this material in a secure fashion for at least three years.

5. The initial inquiry by the Standing Committee will be conducted in confidence and will be completed within 60 days of the initiation of the inquiry, unless circumstances clearly warrant a longer period, in which case the reasons for extending the inquiry beyond 60 days will be included in the Standing Committee’s report of the inquiry. Every attempt will be made to limit any extension to 60 days. The accused will be notified immediately by the Standing Committee of the nature of the charges and that an inquiry will be made. The inquiry will involve only essential people including, when necessary, individuals from other institutions. Members of the Standing Committee who perceive a conflict of interest will absent themselves from this review; a substitute member will be named in these cases. The appropriate Department Head will be notified when an initial inquiry is undertaken; testimony from the Department Head will either be solicited at the discretion of the Standing Committee, or offered by the Department Head at his/her discretion.

   If requested by the Standing Committee, the Chancellor will make appropriate legal counsel available to the Standing Committee.

6. The initial inquiry will be based, as much as possible, on objective analysis of records, such as data books. Interviews with technicians, research associates or collaborators should be limited in the initial inquiry to those essential to define a need for a detailed review. If the Standing Committee does not have the requisite scientific expertise to carry out the initial inquiry, it may solicit additional expertise as necessary.

7. The accused has the right to hear the charge; to raise written questions, and demand answers in written form from the individual(s) making the allegation (assuming the identity of those individuals is known to the Standing Committee); and to testify, accompanied by legal counsel on all matters relevant to the inquiry. The accused may choose not to participate in the review.

8. The Standing Committee will prepare a report of its inquiry, including a summary of the evidence reviewed, interview summaries, whether the allegations were made in bad faith, and the conclusions of the inquiry. The accused will be offered an opportunity to comment on the findings of the inquiry, and those comments, if any, shall be included in the report.

9. Should the initial inquiry indicate that there is a reason to suspect misconduct, as indicated by a majority vote of the total Standing Committee, a recommendation for further investigation will be made to the appropriate Dean and to the Chancellor in the Standing Committee’s report of the inquiry. The accused will be informed of the Committee’s findings by copy of the Committee’s final report of the inquiry. If the initial inquiry concludes that the allegations are unfounded, such will be conveyed in writing to all persons who had knowledge of the initial inquiry. The accused may request that the conclusions of the initial inquiry be made public, however, best efforts will be made not to identify publicly the individual making the initial allegation. In addition the Health Center will undertake diligent efforts to protect the positions and reputations of those persons who, in good faith, made the initial allegation.

10. Should the Standing Committee decide to terminate the initial inquiry for any reason without completing all relevant requirements under federal law, a report of such planned termination, including a description of the reasons for such termination, will be made to the appropriate federal oversite office.

11. Records of the inquiry, including a copy of the Standing Committee’s final report, shall be kept on file and secure for a period of three (3) years following the completion of the inquiry. These records, upon appropriate and reasonable request, will be made available to those agencies which have a statutory right of access.

Full Review by Special Review Board

1. In the case of allegations of research misconduct identified by the Standing Committee as warranting further review, a full investigation will be carried out by an ad hoc Special Review Board (SRB) appointed by the Chancellor with advice from the appropriate Dean(s). The Chancellor will make every possible effort to prevent any real, or apparent, conflict of interest on the part of the members of the SRB.

2. The SRB will consist of three faculty members from the involved School, including one member of the Standing Committee. Every attempt will be made to appoint the SRB in a manner which will guarantee that it has the requisite scientific expertise needed to conduct an investigation. In the event that it is necessary, individuals with appropriate scientific expertise, from institutions other than the University of Connecticut Health Center will be added to the membership of the SRB. (The Chancellor will assure sufficient protection against personal liability for actions taken during the review process for extramural as well as intramural members of the SRB). The Assistant Vice Chancellor for Research will serve as a non-voting, ex-officio member and Executive Secretary of the SRB. The Chancellor will provide appropriate legal counsel to the SRB.

3. The SRB will evaluate the report of the Standing Committee and examine data books, records, publications and other information relevant to the charge of misconduct. The investigation will be conducted in confidence, and best efforts will be made to protect the privacy of the individuals involved in the investigation. The SRB may request interviews with any of the principals or their colleagues. The accused has the right to give testimony on all aspects of the report by the Standing Committee and on all of the evidence acquired by the SRB. The accused has the right to raise written questions and demand answers in written form from the individual(s) who made the original allegations (assuming the identity of those individuals is known to the SRB); to examine in writing or orally, those who give testimony to the SRB; to call witnesses and to be represented by legal counsel. The accused party may choose not to participate in the investigation. The investigation should be completed within 120 days of its initiation. Every attempt will be made to limit extensions of the investigation to 60 days.

4. If the SRB decides to terminate its investigation for any reason without completing all relevant requirements of applicable federal law, a report of such planned termination, including a description of the reasons for such termination, shall be made to the appropriate federal oversight office.

5. The SRB will report its findings and conclusions to the Chancellor, the Dean(s) of the involved School(s), the appropriate Department Head(s), applicable federal oversight offices and the individual(s) accused of fraud or misconduct. Prior to submitting this report, however, the accused will be given an opportunity to comment on the findings, and those comments will be included in the final report. The accused will be provided with a copy of the final report.

   Should the allegation of fraud or misconduct be confirmed by the vote of a majority of the members of the SRB, appropriate action will be taken by the Dean of the involved School with advice from the appropriate Department Head and the Chancellor. Funding agencies directly involved in the support of the research in question will be notified, by the Assistant Vice Chancellor for Research, that an allegation of fraud has been confirmed by formal investigation. If the research involves human subjects, the Institutional Review Board will be notified of the findings.

   If the allegation is not confirmed, the Health Center will undertake diligent efforts to restore the reputation of the accused. The accused has the right to request widespread dissemination of the findings, and the Health Center will exercise its best efforts to do so. Best efforts will be made not to identify the individual(s) making the allegation. The Health Center will make every diligent effort to protect the positions and reputations of persons who, in good faith, made allegations of research misconduct.

   The report of the SRB will include a detailed discussion of the rationale involved in reaching its decision, including a description of the policies and procedures under which the investigation was conducted, how and from whom information was obtained relevant to the investigation, the findings, the basis for the findings and whether the allegations were made in bad faith. The report will include the actual text or an accurate summary of the views of the accused.

6. All records of the SRB will be sealed and deposited with the Assistant Vice Chancellor for Research. The Assistant Vice Chancellor for Research will keep these records in a secure manner for at least three years. If required by federal regulation, documentation of the SRB’s investigation will be made available to the appropriate federal oversight office.

Non-compliance

1. For individuals alleged to engage in fraudulent activities or misconduct who do not cooperate either with the Standing Committee or with the SRB, the review process will be conducted without their participation.

Sanctions

1. Sanctions and penalties for those engaged in fraudulent scientific activities will be determined by the Dean of the appropriate School with advice from the accuser’s Department Head. Sanctions include, but are not restricted to:

• Letter of reprimand
• Notification to professional and/or scientific societies
• Notification to journals which may have published research determined to be fraudulent
• Reassignment of duties
• Termination of grant support
• Adjustment of research space allocation
• Adjustment of salary
• Suspension
• Dismissal

When required by relevant federal regulation, a report of the sanctions imposed on those determined to be engaged in fraudulent scientific activities will be provided to the appropriate federal oversight office.

Appeals

1. Appeals can be made to the Chancellor who may wish to have appeals considered by the Health Center Faculty Review Board, an elected panel of Faculty members that reviews grievances. The University of Connecticut review of Faculty grievances set forth in the University of Connecticut Laws and Bylaws (Article X.B and V.Q) constitute the ultimate step in the appellate process. Full rights of appeal apply to the selection and application of sanctions.

   For students, post-doctoral fellows or staff members, appeals may be made according to the procedures outlined in the University of Connecticut Laws and Bylaws.

Promulgation

1. All Faculty members of the Schools of Medicine and Dental Medicine Research associates, graduate students, postdoctoral fellows, technicians and administrative staff involved in the Health Center's research program will be given a copy of the Policy and Procedures for Review of Alleged Misconduct of Research. The Health Center's personnel department will also provide all new employees with a copy of this policy upon engagement.

2. Each academic department, research unit and graduate degree program should conduct a brief annual review of the Policy and Procedures for Review of Alleged Misconduct of Research.

3. Medical and dental students should be made aware of the Policy and Procedures for Review of Alleged Misconduct of Research document during the first year of basic medical sciences and before initiating research projects.

Revision of Policy Guidelines

1. This document will be periodically reviewed and revised as indicated.

Interim Administrative Actions

In the event that any of the following conditions are determined to exist, the Assistant Vice Chancellor for Research will be responsible for immediate reporting to the relevant research sponsors, if so required by law:

• There is an immediate health hazard involved;
• There is an immediate need to protect Federal funds or equipment;
• There is an immediate need to protect the interests of the person(s)
• making the allegations or of the individual(s) who is the subject of
• the allegations as well as his/her co-investigators and associates, if any;
• It is probable that the alleged incident is going to be reported publicly;
• There is a reasonable indication of possible criminal violation, in which case relevant research sponsors will be notified within 24 hours, if so required by law.

1. In situations where there is an apparent need to take additional interim administrative actions, as appropriate, to protect Federal funds and insure that the purposes of the Federal financial assistance are carried out, the Health Center administration will be responsible for taking such action. Prior to implementing such action, however, the Health In situations where there is an apparent need to take additional interim Center administration shall confer with either the Standing Committee or the SRB, depending upon the stage of review. No interim administrative action shall be taken without the concurrence of either the Standing Committee or the SRB.

2. The Assistant Vice Chancellor for Research will, as required by appropriate federal law, notify the appropriate federal oversight office(s) that an investigation will be initiated, on or before the investigation begins.

3. The Assistant Vice Chancellor for Research will advise the appropriate federal oversight office of any developments during the course of the investigation which disclose facts that may affect current or potential DHHS funding for individual(s) under investigation or that the federal oversight office needs to know to ensure appropriate use of Federal funds.

4. In the event that the SRB is unable to complete its investigation in 120 days, the Assistant Vice Chancellor for Research will submit a request for extension, if required by federal regulation, with the appropriate federal oversight office. Such a request will include an explanation for the delay, an interim report on progress of the investigation, an outline of what remains to be done, and an estimated date of completion of the investigation.

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