Research Integrity Policy | Research

Responsible Office: Office of the Vice Chancellor for Research
Policy Steward: Office of Research Integrity and Ethics
Policy contact: ORIE@wustl.edu

Created 10/18/2000
Revised 01/01/2026

Purpose
Applicability
Scope
Definitions
Responsibilities and Rights
Research Misconduct Criteria
Allegations
Time Limitations and Subsequent Use
Confidentiality
Assessment, Inquiry and Investigation
Organizational Structure
Jurisdiction
Relationships to Other Policies
Protection from Retaliation
Record Keeping
Violations of this Policy

Appendix 1 – Organizational Structure Details
Appendix 2 – Documentation and Communication Requirements

I. Purpose

This policy provides a framework to resolve allegations of research misconduct as rapidly and fairly as possible and to protect the rights and integrity of all individuals involved. Federal regulations and many funding sponsors require that institutions applying for or receiving research funding have an established process for reporting, reviewing, and investigating allegations of research misconduct.

II. Applicability

This policy is applicable to any individual involved in research under the auspices of Washington University and to allegations of research misconduct in all areas of research regardless of the funding source.

III. Scope

This outlines the University’s policy and procedures for responding to allegations of research misconduct.

IV. Definitions

Accepted Practices of the Relevant Research Community: Practices established and commonly accepted by professional codes or norms of the overarching community of researchers and institutions within a field of study.

Allegation: a disclosure of possible research misconduct through any means of communication.

Assessment: the initial review conducted by the Research Integrity Officer (RIO) upon receiving an allegation of research misconduct.

Complainant: an individual or entity who brings forth an allegation of research misconduct in good faith.

Committee on Research Integrity (CRI): a standing University committee, of at least five (5) senior faculty appointed for defined terms of service, which evaluates and adjudicates cases of alleged research misconduct against staff, students, trainees, postdoctoral appointees, and/or faculty members. The CRI determines whether research misconduct has occurred and recommends what, if any, corrective actions and sanctions are warranted.

Conflict of interest: financial, personal, or professional relationships which may compromise, or appear to compromise an individual’s decisions.

Day: calendar day unless otherwise specified. If a deadline falls on a Saturday, Sunday or Holiday, the deadline will be extended to the next business day.

Evidence: any document, tangible item, or testimony offered or obtained during a research misconduct proceeding, including the research record, which tends to prove or disprove the existence of an alleged fact.

Fabrication: making up data or results and recording or reporting them.

Falsification: 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.

Good faith: having a belief in the truth of one’s statements such that a reasonable person in the same position could have, based on the information, known to one at the time. An allegation is not made in good faith if made with knowing or reckless disregard or willful ignorance of certain facts that would disprove said allegation. Good faith as applied to a committee member means cooperating with the purpose of helping the institution meet its responsibilities regarding investigation of allegations of research misconduct.

Intentionally: to act with the aim of carrying out the act.

Knowingly: to act with awareness of the act.

Plagiarism: the appropriation of another person’s ideas, processes, results, or words without giving appropriate credit. Plagiarism does not include self-plagiarism or authorship credit disputes among collaborators.

Preponderance of the evidence: proof by information that, compared with that opposing it, leads to the conclusion that the fact at issue is more likely true than not.

Research: a systematic experiment, study, evaluation, demonstration, or survey designed to develop or contribute to general knowledge (basic research) or specific knowledge (applied research).

Inquiry Panel: an ad hoc panel of faculty appointed by the Research Integrity Officer in response to a specific allegation of research misconduct, who conducts an initial unprejudiced preliminary evaluation of the available facts and circumstances underlying the allegations.

Research Integrity Officer (RIO): a senior faculty member, appointed by the Vice Chancellor for Research, who has primary responsibility for implementing the University’s policies and procedures on research misconduct as outlined herein. The RIO also assists all members of the University community to comply with applicable policies, laws, and regulations related to research misconduct proceedings.

Research misconduct: see Section VI, Research Misconduct Criteria.

Research record: the record of data or results that embody the facts resulting from scientific inquiry, including but not limited to primary research material, research proposals, laboratory records (physical and electronic), research animals, images, machines and equipment, progress reports, abstracts, theses, oral presentations, internal reports, journal articles, and correspondence.

Recklessly: to propose, perform, review research, or report research results, with indifference to a known risk of fabrication, falsification, or plagiarism.

Respondent: the person against whom an allegation of research misconduct is directed or who is the subject of a research misconduct proceeding.

Retaliation: an adverse action taken against an individual involved in a research misconduct proceeding, including but not limited to, complainant, witness, or committee member, by a member of the University community in response to a good faith allegation of research misconduct or good faith cooperation with a research misconduct proceeding.

V. Responsibilities and Rights

Individuals shall act in good faith in making allegations and during their involvement in research misconduct proceedings as well as promptly provide all requested available materials and maintain strict confidentiality of the proceedings. In addition, covered individuals are entitled to certain rights and protections. For instance, the respondent and witnesses may have an attorney or other advisor present at all their interviews during the research misconduct proceedings. This individual is not permitted to actively participate in the proceedings and will be required to channel all communications with the RIO, CRI, Inquiry Panel, and/or any members thereof through the Office of the Executive Vice Chancellor and General Counsel (OGC). A complete list of is available at Rights and Responsibilities of Individuals Involved in Research Misconduct Proceedings. In the event that allegations of research misconduct are made in bad faith or research misconduct proceedings are materially impeded by any member of the University community, including but not limited to the respondent or complainant, the dean of the appropriate school and VCR shall impose sanctions as set forth within Section X.d.

VI. Research Misconduct Criteria

Research misconduct is defined as:

Fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results; or
Knowing violations of federal and institutional rules and regulations governing the conduct of research involving human research participants that are serious or continuing; or
Violations of the University’s Policy for Authorship on Scientific and Scholarly Publications (“Authorship Policy”)

Research misconduct does not include honest error or differences of opinion or differences in interpretations of data.

A finding of research misconduct requires that:

There be a significant departure from the accepted practices of the relevant research community; and
The research misconduct be committed intentionally, knowingly, or recklessly; and
The allegation be proven by a preponderance of evidence.

The lack of records adequately documenting the questioned research is evidence of research misconduct where it is established by a preponderance of the evidence that the respondent:

Had research records and intentionally, knowingly, or recklessly destroyed them,
Had the opportunity to maintain the records but did not do so, or
Maintained the records and failed to produce them in a timely manner.

The University has the burden of proof for making a finding of research misconduct. The respondent has the burden of proof for any affirmative defenses raised, which includes a claim of honest error or differences of opinion.

VII. Allegations

All members of the University community are expected to report observed, suspected, or apparent research misconduct. Allegations of research misconduct from sources inside or outside the University will be considered. An individual should direct an allegation of research misconduct to the Research Integrity Officer (RIO), the Office of Research Integrity & Ethics (ORIE), or the Vice Chancellor for Research (VCR). An individual may also direct an allegation to deans, department heads, division chiefs, or report anonymously using the University’s Reporting Hotline. Any member of the University community who receives an allegation of research misconduct shall promptly forward it to the RIO. If an individual is concerned about possible research misconduct or is unsure whether an incident qualifies as research misconduct, he or she may contact the RIO or ORIE to discuss the suspected misconduct informally and confidentially.

Individuals are encouraged to submit allegations of research misconduct in writing so as to ensure a clear understanding of the issues raised, although allegations may be made orally. Anonymous allegations are acceptable; however, sufficient detail and/or corroborating evidence must be provided to determine whether an inquiry should be initiated. Allegations should be made in good faith, based on factual issues, and with specific information when possible.

VIII. Time Limitations and Subsequent Use

Research misconduct proceedings will not be initiated if the alleged activity occurred more than six years in the past. The University reserves the right to pursue allegations beyond the six year limitation when necessary to comply with sponsor or regulatory requirements or when there is a pattern of alleged misconduct that warrants further investigation.

IX. Confidentiality

Disclosure of the identity of respondents, complainants, and witnesses involved in research misconduct proceedings is limited, to the extent possible, to those who need to know, as determined by the CRI. For instance, during the inquiry phase, the complainant and witness’s names may be kept confidential; however, disclosure of their identities may be necessary during later stages of the proceedings in order to afford the respondent a full and fair opportunity to respond to the allegations.

All those participating or involved in research misconduct proceedings (e.g. committee members, institutional officials, respondents, witnesses, etc.) shall not disclose or discuss any information regarding the allegations, the proceedings, or the identity of individuals involved in the proceedings except as necessary to the proper discharge of their responsibilities hereunder and as required by law.

X. Assessment, Inquiry and Investigation

Assessment
1. Upon receiving an allegation of research misconduct, the RIO will immediately assess the allegation to determine whether it:
  1. Falls within the definition of research misconduct and
  2. Is sufficiently credible and specific so that potential evidence of research misconduct may be identified
    
    The purpose of the assessment is not to reach a determination on whether research misconduct occurred but rather establish whether the allegation meets the threshold for initiating a formal inquiry.
2. To ensure the University’s obligations to funding sponsors are clearly identified and met during all subsequent stages of the process, the assessment will include an evaluation of the funding sources of the research in question when available.
Sequestering and Handling of Evidence
At the time and/or before the respondent is notified of an allegation, the RIO will take all reasonable and practical steps to obtain custody, inventory, and secure all original evidence (physical and electronic) relevant to the allegation. This includes, but is not limited to, research proposals, laboratory records and notebooks, protocols, data sets, images, biological or physical specimens, machines and equipment, computer files, abstracts, theses, oral presentations, internal reports, drafted manuscripts, published articles, emails, and other correspondence. All available material (e.g., physical papers, data, notebooks, electronic analysis, equipment, etc.) identified as relevant to the allegation shall be promptly provided upon receiving notice of an allegation. At any point during an inquiry or investigation additional evidence may be obtained and/or sequestered.

Upon request and where appropriate, access to or copies of the sequestered records will be provided to the respondent or other individuals who provided the original evidence. All reasonable steps, consistent with time constraints and other obligations imposed by federal regulations, shall be taken to eliminate or minimize any disruption that might be created for ongoing research efforts by such requirements to produce documentation. Individuals involved in the securing of evidence relevant to the allegation shall not discuss or disclose the request with anyone outside of the official proceedings, without approval from the RIO, ORIE, or VCR. At the conclusion of and dependent upon the outcome of the proceedings, sequestered records will be returned as appropriate.

Records associated with misconduct proceedings may be redacted to protect personal privacy, confidentiality, and protected health information (PHI) in accordance with HIPAA requirements, or when portions of the record are irrelevant to the proceedings, the allegation(s), or the research in question. Unredacted records will be provided to authorized individuals or entities when required by funding sponsors and/or federal regulations.
Inquiry
The inquiry is an unprejudiced preliminary evaluation of the available facts and circumstances underlying the allegations to determine if a full investigation is warranted.
1. To initiate the inquiry process, the RIO will:
  1. Appoint an Inquiry Panel in accordance with Appendix 1.
  2. Provide written notice to the respondent. The notification will include a description of the allegation(s) of research misconduct made against the respondent along with an explanation and documentation of the University’s policies in regard to research misconduct including the respondent’s rights and responsibilities. The respondent will also be notified the University will not tolerate acts of retaliation against any individual participating in a research misconduct proceeding.
  3. At the time or before the RIO notifies the respondent, the RIO shall notify the VCR, the respondent’s department head , and the appropriate dean of all allegations of research misconduct and the initiation of the inquiry process.
  4. If evidence or allegations of additional misconduct arise during the inquiry process, the RIO will provide written notice of the inquiry panel’s intention to broaden its inquiry to the respondent, appropriate dean and department head, and VCR.
2. Inquiry Process
  1. The purpose of an inquiry is to conduct a rapid, thorough, and unprejudiced preliminary evaluation of the available facts and circumstances underlying the allegations. An inquiry does not require a full review of all available evidence; rather the inquiry panel will determine by a preponderance of the evidence:
    1. if the allegation falls within the definition of research misconduct
    2. whether or not the conduct, if it did occur, would constitute research misconduct, and
    3. whether there is sufficient evidence of the alleged misconduct to warrant a full investigation.
  2. The inquiry panel will review the evidence and conduct interviews of the respondent and other persons the panel considers useful to its inquiry. All interviews with witnesses and respondents are conducted separately.
  3. All interviews conducted by the inquiry panel will be transcribed in accordance with Appendix 2.
  4. The panel shall identify additional issues, leads, or allegations of research misconduct as it reviews relevant evidence.
3. A draft written report will be generated, in accordance with Appendix 2, of its inquiry and recommendations for further action, which will be provided to the respondent. The respondent shall have seven days from receipt to review and comment on the draft report. The panel will then finalize the inquiry report, which may include revisions based on the comments received from the respondent. Any and all comments submitted by the respondent shall be made part of the final inquiry report and submitted to the CRI for consideration.
4. Conclusion of Inquiry
  1. Prior to receiving the final inquiry report, the CRI will be notified in writing of the allegations of research misconduct and the respondent’s identity.
  2. Upon review of the final inquiry report the CRI shall decide, by majority vote, whether to accept or reject the recommendations included in the final inquiry report and thus whether to initiate an investigation or dismiss the allegations. During its determination, the CRI may also address any additional significant issues, leads, or allegations, if applicable.
  3. The RIO shall notify the respondent, the VCR, and the dean of the respondent’s school of the determination of the CRI and provide each with a copy of the final inquiry report. Additionally, the respondent’s department head will be notified in writing of the outcome of the proceedings.
  4. If the allegations are dismissed by the CRI, documentation shall be maintained in sufficient detail to permit a later assessment of the reasons why the CRI decided not to conduct an investigation as detailed in Section IX.a.
  5. If the CRI determines there is sufficient basis to warrant an investigation, a prompt and thorough investigation into the allegation shall be initiated by the CRI within thirty days of the completion of the inquiry.
  6. Absent extraordinary circumstances, the inquiry shall be completed within ninety days of the initiation of the inquiry. The inquiry may extend beyond ninety days only with approval of the VCR and/or funding sponsor, as required. If granted, the reason for any extension will be documented in the official record and noted in the final inquiry report. The RIO will provide notice to the respondent and any other individuals, as appropriate, if there is an extension.
Investigation
An investigation is the responsibility of the CRI and includes an examination of all relevant evidence and conduct interviews with all individuals involved to determine by a preponderance of evidence whether research misconduct has occurred and to recommend what, if any, corrective actions and sanctions are warranted.
1. To initiate an investigation, the RIO will:
  1. Provide written notice to the respondent including a description of all allegations that will be investigated. The CRI will diligently pursue all significant issues and leads that are determined to be relevant. If there is evidence of additional allegations the RIO will provide written notice of the CRI’s intention to broaden its investigation to the respondent, other implicated individuals, appropriate dean and department head, and VCR.
  2. Sequestering any additional evidence relevant to the allegations, as described in Section X.b.
2. Investigation Process
  1. Within thirty days of the CRI’s determination that an investigation is warranted, or at any other time as required, funding sponsors or federal agencies shall be informed of the research misconduct proceedings by the VCR, or designee, in accordance with applicable requirements.
  2. The CRI will make a good faith effort to determine the scope/extent of the misconduct and whether there is evidence of other instances of research misconduct related to any other research with which the individual is involved.
  3. The CRI will diligently pursue all significant issues, leads, or additional allegations of research misconduct.
  4. All interviews with witnesses and respondents are conducted separately. All interviews conducted by the CRI will be transcribed as described in Appendix 2.
  5. By majority vote, the CRI shall decide whether to dismiss the allegation of research misconduct or make a determination that research misconduct occurred. The determination need not be unanimous.
  6. The CRI will generate a draft report of its investigation, determinations, and recommendations for sanctions and/or corrective actions, in accordance with Appendix 2.
  7. The draft report shall be promptly submitted to the respondent as well as copies of, or supervised access to, the evidence on which the report is based. The respondent shall be allowed thirty days from receipt of the draft report to provide comments on the report. The CRI will generate the final CRI report which may include revisions based on comments received from the respondent. Any and all comments submitted by the respondent will be made a part of the final report.
3. Investigation Conclusion
  1. The RIO will provide a copy of the final CRI report to the respondent, the VCR, and to the dean of the respondent’s school. Additionally, notice of the investigation outcome is provided to the respondent’s department head. In instances where the CRI determines research misconduct has occurred, the respondent’s department head will also be provided with a copy of the final CRI report.
  2. Absent extraordinary circumstances, the investigation shall be completed within one hundred eighty days. The investigation may extend beyond one hundred and eighty days with the written approval of the VCR and funding sponsor or federal agency, when applicable. If an extension is granted, the reason and terms of the extension will be documented in the official record and noted in the final CRI report. The RIO will provide notice to the respondent and any other individuals, as appropriate, if there is an extension.
4. The VCR or designee will provide periodic progress reports to funding sponsors supporting the research in question as required.
5. Final Disposition of Investigation Proceedings
  The appropriate dean, based on the respondent’s primary appointment, and the VCR will review the final CRI report, including the CRI’s recommended sanctions and/or corrective actions. Together, the dean and VCR will determine which actions are appropriate under the circumstances.
  1. Imposition of sanctions related to a finding of research misconduct:
    If the CRI determines research misconduct has occurred, the respondent shall be given an opportunity to present to the dean and VCR, in person or in writing (as the respondent may elect), any facts or considerations the respondent believes should be taken into account in the determination of appropriate sanctions within seven days after receipt of the final CRI report. The dean and VCR shall impose sanctions as appropriate, no later than thirty days and no earlier than five days after receipt of the final CRI report, subject to the following exceptions:
    1. For termination of an appointment of a faculty member with tenure, or of a non-tenured faculty member prior to the end of a current term of appointment, a proceeding shall be instituted by the University before the Hearing Committee, in accordance with Section IX. of the University’s Policy on Academic Freedom, Responsibility, and Tenure. The Hearing Committee shall review the final investigation report and related documentation and may hear such additional relevant, non-cumulative testimony as it deems necessary.
    2. Sanctions against a student shall be imposed in accordance with the University Student Conduct Code or other relevant policies of the student’s school.
  2. In the absence of a finding of research misconduct, the CRI may recommend corrective actions. The Dean and VCR shall determine if any corrective actions should be completed.
  3. The imposition of sanctions and/or other corrective actions may be delegated to the department head and/or the OVCR, who will require the respondent or other individuals, as appropriate, to fulfill corrective measures as deemed necessary.
  4. Corrective actions may include, but are not limited to:
    1. Formal education in the responsible conduct of research, authorship ethics and requirements, data management, human subjects, and/or animal care and use
    2. Revision or development of standard operating procedures (SOPs) to improve data storage and/or security.
    3. Monitoring and/or oversight of research projects, such as mentoring by senior faculty for a defined period, or the addition of research team members with specific qualifications.
  5. Any actions imposed by funding sponsors shall be administered by the VCR or designee.
Other Actions and Communications
1. The VCR or designee will keep relevant external entities, including but not limited to, collaborating scientists, other institutions, and journal editors informed of the status of the proceedings and any outcomes on a need-to know basis in accordance with funding sponsor requirements and federal regulations.
2. The VCR or designee will notify the external entities prior to closing a research misconduct proceeding prematurely for any reason, including but not limited to, an admission of guilt by the respondent, as required.
3. The final inquiry and CRI investigation reports, copies of research records and evidence reviewed, transcripts of any interviews, and copies of all relevant documents shall be provided to external entities, as required. This may also include the final sanctions and/or institutional actions imposed by the dean and VCR.
4. The RIO shall keep individuals within the University, including but not limited to, witnesses and collaborating scientists, informed of any outcomes on a need-to-know basis.
5. If the CRI dismisses the allegation of research misconduct for any reason, the RIO, the VCR and appropriate dean will make diligent efforts to restore the respondent’s reputation.
6. At any time during misconduct proceedings, the VCR may implement preliminary corrective actions when necessary to protect the public, safeguard research records or specimens, ensure the integrity of ongoing research, or prevent further potential misconduct. Such actions will be appropriate to the circumstances and implemented in a manner that supports the integrity of the process.
Admissions of Guilt
If a respondent admits to all of the allegations of research misconduct, the CRI may decide to discontinue the proceedings at any point during the inquiry or investigation. The respondent will provide a written admission statement addressing each allegation of research misconduct, in accordance with policy requirements. The admission statement must identify, at a minimum, the following: the individual responsible, whether the misconduct is fabrication, falsification, or plagiarism, and whether the misconduct was committed recklessly, knowingly, or intentionally and must specify which research records were affected. The respondent will meet with the RIO and one or more CRI members to review the written admission statement. This meeting will be transcribed in accordance with Appendix 2. The CRI’s acceptance of an admission of guilt is contingent upon the scope of the misconduct to which the respondent is admitting. The CRI will assess the scope pursuant to Section X.d.2.ii of this policy.

XI. Organizational Structure

Key elements of the organizational structure are outlined below. Further details are available in Appendix 1.

The VCR appoints the RIO, who holds the primary responsibility for implementing the University’s policies and procedures on research misconduct.
The RIO shall serve as the ex-officio chair of all research misconduct proceedings and assist all members of the University community to comply with applicable policies, laws, and regulations related to research misconduct proceedings.
ORIE is responsible for providing administrative support for all research misconduct proceedings at the University and assisting the RIO in addressing allegations of research misconduct.
The RIO shall appoint an inquiry panel. The RIO may appoint ad hoc members to ensure the membership of the CRI has the proper expertise during the proceedings.
The CRIs administers investigations of alleged research misconduct. Two standing committees serve the School of Medicine and the Danforth Campus schools, respectively.

XII. Jurisdiction

In a case involving alleged misconduct by (1) an individual who holds a joint appointment in two schools of the University, (2) an individual who holds a prime appointment in one school, but is collaborating with a faculty member from another school of the University, or (3) a student enrolled in a program that crosses school lines, the RIO shall determine which CRI will take jurisdiction over the case taking into consideration the respondent’s prime appointment and where the research was conducted.
When allegations involve research conducted at multiple institutions, one institution will be designated as the lead institution if a joint research misconduct proceeding is conducted. In a joint research misconduct proceeding, the lead institution will obtain research records and other evidence pertinent to the proceeding, including witness testimony, from the other relevant institutions. By mutual agreement, the joint research misconduct proceeding may include committee members from each institution involved. The determination of whether further inquiry and/or investigation is warranted, whether research misconduct occurred, and the institutional actions to be taken may be made by the institutions jointly or tasked to the lead institution.

XIII. Relationships to Other Policies

If, at any time during the proceedings, the allegation(s) appears to intersect with other University policies or concerns, such as employment-related matters, violations of Title IX, discrimination or harassment, student conduct, or other legal or regulatory frameworks, the relevant components will be referred to the appropriate University office for review and action. Such referrals will not preclude or delay the research misconduct proceedings, which will proceed independently and in parallel, unless coordination is required to avoid duplication, conflict, or procedural harm.

XIV. Protection from Retaliation

The University is committed to and strongly believes in the importance of protecting all individuals from retaliation for activities in cooperation with, or initiation of, research misconduct proceedings. The University will not tolerate acts of retaliation, actual or perceived, against individuals participating in research misconduct proceedings. If any person involved in a research misconduct proceeding feels s/he has been adversely affected by retaliation, they should notify the RIO, ORIE, CRI, or VCR immediately.

Administrative Review and Processes to Address Potential Retaliation
1. The RIO is responsible for taking reasonable and practical steps to protect all individuals from retaliation for his/her activities, as outlined in this policy. The RIO will provide written notice to the appropriate dean and department head, the VCR, and other individuals as deemed necessary. Based on observations and/or conversations with the individuals involved in the proceedings, including the CRI members, the RIO may determine administrative steps are needed to address any potential opportunities for retaliation. Administrative steps may include, but are not limited to, seeking intervention by Human Resources, discussions with the dean, department head or division chief to develop actions to assure protection, consultation with OGC or other steps necessary to protect against retaliation. The RIO shall update the CRI on the steps taken to protect the individual.
2. Formal Complaint of Retaliation
  If an individual feels that the administrative steps have not provided adequate protection, the individual may submit a formal written complaint of retaliation to the RIO who will initiate an investigation. The written complaint of retaliation must include a) identification of the University member who committed an adverse action against the individual; and b) any documents or information that supports the complaint. Once the RIO receives a formal complaint of retaliation, the RIO will provide written notice of the allegations of retaliation to the implicated individual(s), appropriate dean, VCR, and appropriate department head; and appoint a subcommittee of the CRI to review the compliant, which will include, but is not limited to, interviewing the individual and any witnesses deemed appropriate. The CRI subcommittee will prepare a written report of their findings and recommendations for resolution and submit it to the dean and VCR. The appropriate dean and VCR shall take corrective actions, which may include redress of any disadvantage suffered by the individual and sanctions against the individual found to have committed the retaliation. The decision of the dean and VCR is final and the RIO shall update the CRI on the decision of the dean and VCR including the corrective actions taken, if any.
3. Complaints of Retaliation not made in good faith
  If the RIO and the subcommittee of the CRI believe that the allegation of retaliation was not made in good faith, the individual alleging retaliation will be notified in writing of the RIO and CRI’s concerns. The individual shall be allowed seven days from receipt of the written notice to reply to the concerns. If the CRI finds that the allegation was not made in good faith, the matter will be referred to the VCR. The VCR will work with the appropriate dean to impose the appropriate sanctions.

XV. Record Keeping

Records of research misconduct proceedings, including the evidence, will be maintained in a secure manner for seven years or in accordance with the applicable external and/or federal agency or sponsor requirements, whichever is longer. Unless otherwise specified, documentation and communication requirements outlined in Appendix 2 shall be followed for aspects of the assessment, inquiry, and investigation phases.

XVI. Violations of this Policy

Violations of this policy may subject the individual to corrective actions or other sanctions as deemed appropriate by the VCR and/or the dean of the appropriate school. Violations of this policy include but are not limited to, allegations of research misconduct or retaliation made in bad faith, violations of confidentiality requirements, or failure to provide records or evidence upon request.

Appendix 1 – Organizational Structure Details

Vice Chancellor for Research:

Appoints the RIO, who holds the primary responsibility for implementing the University’s policies and procedures on research misconduct. The VCR will take into consideration a faculty member’s research portfolio, rank, expertise, and years of experience when appointing an individual as the RIO. The VCR shall be responsible for providing appropriate expertise and administrative support to the RIO and the CRI. Any expenses incurred as a result of research misconduct proceeding will be allocated to the school of the respondent’s primary appointment.
Appoints faculty members to serve on the CRI. The VCR will take into consideration a faculty member’s research portfolio, rank, expertise, and years of experience when appointing faculty to the CRI.
Ensures compliance with external notification requirements.
Informs individuals, including but not limited to, external collaborating scientists, funding sponsors, federal agencies, institutions, and journal editors of research misconduct proceedings on a need-to-know basis.
Establishes and maintains records for all research misconduct proceedings in accordance with federal regulations.
Provides sufficient institutional and administrative support to comply with applicable federal regulations as well as University and funding sponsor’s requirements.

Research Integrity Officer

Serves as the ex officio chair for all research misconduct proceedings and holds a non-voting role for all investigations.
Assists all members of the University research community to comply with applicable policies, laws, and regulations related to research misconduct proceedings.
Assesses allegations to determine whether it falls within the definition of research misconduct and is sufficiently credible to warrant an inquiry.
Appoints an inquiry panel as outlined in Section V.c.1.
Notifies individuals and entities within the University of research misconduct proceedings on a need-to-know basis.

Office of Research Integrity and Ethics

Has delegated responsibility to provide administrative support for all research misconduct proceedings at the University and to assist the RIO in addressing allegations of research misconduct. In addition to the RIO, a member of ORIE shall be present at all meetings, interviews, and other proceedings regarding allegations of research misconduct.

Inquiry Panel

An inquiry panel shall consist of at least two members: the RIO and a standing or ad hoc member of the CRI.
Panel members shall be carefully selected in order to minimize either the substance or the appearance of personal or professional conflicts of interest. No member of the inquiry will be assigned to an allegation involving his or her own department (small departments) or division (large departments).

Committee on Research Integrity

The Committees on Research Integrity (CRI) work in conjunction with RIO to administer cases of alleged research misconduct against staff, students, trainees, postdoctoral appointees, and/or faculty. Two standing committees serve the School of Medicine and the Danforth Campus schools, respectively. The VCR, with approval from the applicable dean, appoints at least five senior faculty members to each committee. Appointments of the CRI members shall be for staggered three-year terms, which are renewable.
For the School of Medicine, members will include a combination of senior basic and clinical research faculty. For the Danforth Campus, members will include, at a minimum, faculty from the following Schools: Arts and Sciences, Engineering, and Social Work. Typically, membership will not include department heads, division chiefs, or clinical chairs.
The Executive Chair of the Institutional Review Board (IRB) will serve as an ad hoc member of the inquiry and investigation phase for all allegations of research misconduct that involve knowing violations of federal or institutional rules and regulations governing the conduct of research involving human research participants that are serious or continuing as defined by IRB policy.

Committee members

Members shall notify the RIO in writing of any actual or potential, personal or professional, conflicts related to a research misconduct proceeding. The RIO may also determine whether any person involved in the research misconduct proceedings has an unresolved conflict of interest and take appropriate action, including removal or recusal, to ensure that no person with such conflict engages in the research misconduct proceeding.
At any time during the proceedings, the RIO may designate an ad hoc (senior faculty member or non-faculty scientist from within or outside the University) with requisite scientific expertise in the relevant field to assist the CRI. This individual will become an ad hoc voting member of the CRI. The respondent will be notified of any additional appointments.
Barring extraordinary circumstances, all inquiry panel members, including ad hoc members, will remain part of the CRI for the duration of the case in question.

Appendix 2 – Documentation and Communication Requirements

Assessments

Report: The University will retain detailed documentation of the assessment to allow for possible future review as required by funding sponsors or federal regulations. This documentation will include but may not be limited to the following:
1. Date complaint received
2. The name(s) of the respondent, if known
3. A brief summary of the circumstances surrounding the complaint. The complaint only needs to provide the details to adequately describe the actions and events that constitute the research misconduct.
4. A description of each allegation.
5. Rationale for the RIO’s determination (i.e., dismissal or initiation of an inquiry)
6. Associated Funding
7. Other regulatory considerations reviewed, if applicable

Inquiry

Notice to the respondent: The notification will include a description of all allegations of research misconduct made against the respondent along with an explanation and documentation of the University’s policies in regard to research misconduct including the respondent’s rights and responsibilities. The respondent will also be notified the University will not tolerate acts of retaliation against any individual participating in a research misconduct proceeding. If evidence or allegations of additional issues arise during the inquiry process, the RIO will provide written notice of the inquiry panel’s intention to broaden its inquiry to the implicated individuals, appropriate dean, VCR, and appropriate department head. The respondent will be notified of the names of the CRI members and any ad hoc members and will be provided with an opportunity to raise concerns regarding any potential conflicts of interest.
Inquiry report: The report will include, but may not be limited to, the following elements:
1. The name and position of the respondent;
2. A description of the allegations of research misconduct;
3. The research support related to the allegation;
4. The institutional policies and procedures under which the inquiry was conducted;
5. The basis for recommending whether or not the alleged actions warrant a full investigation.

Investigation

Report: The report will include, but may not be limited to, the following elements:
1. Description of the nature of the allegations of research misconduct;
2. Description of the research support related to the allegations of research misconduct;
3. Description of the specific allegations of research misconduct for consideration in the investigation;
4. Policies and procedures under which the investigation was conducted.
5. Identification and summary of the research records and evidence reviewed as well as identify any evidence taken into custody but not reviewed.
6. For each separate allegation of research misconduct identified during the investigation, provide a finding as to whether research misconduct did or did not occur, and if so:
  1. Identify whether the research misconduct was falsification, fabrication, or plagiarism, and if it was intentional, knowing, or reckless;
  2. Summarize the facts and the analysis which support the conclusion and consider the merits of any reasonable explanation by the respondent;
  3. Identify the specific research support;
  4. Identify whether any publications need correction or retraction;
  5. Identify the person(s) responsible for the misconduct; and
  6. List any current support or known applications or proposals for support that the respondent has pending with non-PHS Federal agencies.

Interview Transcripts

All interviews conducted for an inquiry and investigation will be conducted separately, transcribed, and provided to the interviewee. Each interviewee will be provided with a copy of the transcript and given seven days to review the transcript of their interview(s) for accuracy. Changes to the transcript are limited to factual errors only. Additional comments or information may be provided in a separate document that will be included as an amendment to the transcript. The final corrected versions of all transcripts as well as any additional separate document(s) will be part of the official record.
Transcripts may be redacted to protect personal privacy, maintain confidentiality, and safeguard protected health information (PHI) in accordance with applicable HIPAA requirements. Redactions may also be applied when information is determined to be irrelevant to the proceedings, the specific allegation(s), or the research activities under review. Redaction will be performed in a manner that preserves the integrity and meaning of the remaining content and ensures that all information necessary to evaluate the matter is retained. Unredacted transcripts will be provided to authorized individuals or entities when required.

Additional reporting requirement for PHS funded research

The VCR or designee will notify ORI immediately if (1) the health and safety of the public is at risk; (2) if HHS resources or interests are threatened; (3) if research activities should be suspended; (4) if federal action is required to protect the research misconduct proceedings; (5) if the alleged incident might be publicly reported; (6) if the research community or public should be informed; or (7) if reasonable indication of possible criminal violations is found.

Download the Washington University Research Integrity Policy (PDF).

Revision History
Original Policy Date: 10/18/2000
Previously revised: 03/18/2002, 08/10/2007, 10/17/2008, and 11/4/2010