The IAHPC safeguards good scientific practice and follows research integrity. This document describes the organization’s Policy on Research Misconduct and the steps to take if a misconduct is committed.
Research misconduct, as defined by the US Federal Government, means fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. It does not include honest error or differences of opinion.
A finding of Research Misconduct requires that the misconduct be committed intentionally, knowingly, or recklessly. A finding of Research Misconduct also requires that there be a significant departure from accepted practices of the relevant research community and must include any or all of the following:
- Fabricating and making up results or other outputs and making up data or results and recording or reporting them as if they were real.
- Falsifying and manipulating information. In terms of the research, this includes materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the records. In terms of the authors, this includes misrepresenting qualifications or experience and involvement, such as inappropriate claims to authorship or attribution of work, and non-disclosure of a conflict of interest.
- Plagiarizing and appropriation of another person's ideas, processes, results or words without giving them appropriate credit.
Allegations of research misconduct, and proceedings conducted under this Policy, may be damaging to the professional reputations of persons involved. The IAHPC shall protect, to the maximum extent possible, the confidentiality of information regarding the complainant, the respondent, and other affected individuals.
It is the policy of the IAHPC to require the highest ethical standards in the research and, if necessary, to investigate and resolve promptly and fairly all instances of alleged or apparent misconduct.
IAHPC RESEARCH MISCONDUCT POLICY
PROCEDURE IN CASE OF AN ALLEGATION
Submission of Allegations
Any individual who in good faith suspects that a person subject to the IAHPC Research Misconduct Policy is committing or has committed Research Misconduct shall immediately report the information to the IAHPC Chair or the Executive Director, who shall immediately report the information to the Chair. The Executive Director shall initiate the process for assessment of the allegations, as described below.
Preliminary Assessment of Allegations to Determine if Inquiry is Warranted
- Upon receiving an allegation of Research Misconduct, the Executive Director and Chair, within 15 working days of receiving the allegation and without notice to any of the parties involved, shall consult with one another and determine whether an Inquiry is warranted. If they are unable to agree on whether an Inquiry is warranted, the Chair shall appoint a board member to participate in the assessment, and these three individuals shall determine by majority vote whether 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.
- If it is determined that an Inquiry is warranted, the Chair shall promptly:
- appoint a panel of three board members to conduct the Inquiry
- secure the relevant Research Records
- notify the Complainant, the Respondent, and, in cases involving externally-sponsored research, the funder, and
- provide the Respondent with a copy of the allegations and this Policy.
- There is not always sufficient information to permit Inquiry of an allegation. For example, an allegation that a researcher's work should be subjected to general examination for possible misconduct is not sufficiently substantial or specific to initiate an Inquiry. In the case of such a vague allegation, an effort should be made to obtain more information before initiating an Inquiry. This information may be sought from any reasonable source, including the Complainant if known. However, if further information is to be requested from the Respondent or other persons involved in the alleged misconduct, the Chair should secure the relevant Research Records before making such a request.
- Anonymous allegations of Research Misconduct will be considered only if sufficient evidence, in the judgment of the Chair and the Executive Director, is provided to permit Inquiry of the allegations.
- If it is determined that an Inquiry is not warranted, the Chair shall so inform the Complainant in writing. The Complainant may request reconsideration of this decision by addressing a request for reconsideration to the Chair within 15 working days of the date of the Chair's notice. If the Complainant does not request reconsideration, or the Chair upon reconsideration reaffirms his or her determination that an Inquiry is not warranted, the Chair shall also inform the Respondent of the allegations and the action thereon.
If it is determined that an Inquiry is warranted, the following procedures shall apply:
- Sequestration of Research records
- Immediate Sequestration: If the relevant Research Records have not been secured at the assessment stage, the Chair or Executive Director shall immediately locate, collect, inventory, and secure them to prevent the loss, alteration, or fraudulent creation of records. In addition to securing records under the control of the Respondent (see below), the Chair or Executive Director may need to sequester records from other individuals, such as coauthors, collaborators, or Complainants.
- Sequestration of Records from Respondent: The Chair or Executive Director should notify the Respondent that an Inquiry is being initiated simultaneously with, and in any event no earlier than, the sequestration to prevent questions being raised later regarding missing documents or materials and to prevent accusations against the Respondent of tampering with or fabricating data or materials after the notification. The Chair should obtain the assistance of the Respondent's supervisor and the IAHPC Legal Counsel in this process, as necessary. If the Respondent is not available, sequestration may begin in the Respondent's absence.
- Inventory of the Records -- A dated receipt should be signed by the sequestering official and the person from whom Research Records are collected, and a copy of the receipt should be given to the person from whom such records are taken. If it is not possible to prepare a complete inventory list at the time of collection, one should be prepared as soon as possible, and then a copy should be given to the person from whom the Research Records were collected. As soon as practicable, a copy of each sequestered Record should be provided to the individual from whom the Record is taken, if requested. Where the Research Records constitute scientific instruments or other materials shared by a number of users, custody may be limited to copies of the data or evidence on such instruments, or copies of the other materials, so long as those copies are substantially equivalent to the originals.
- Security and Chain of Custody: The Executive Director shall keep original Research Records in a secure place. Upon request, and to the extent feasible, the persons from whom Records are collected may be given access to their own original Records under the direct and continuous supervision of a IAHPC official.
- Data Retention Policy: Persons subject to this Policy are reminded of the IAHPC's Data Retention Policy which requires, among other things, that research data generated while individuals are pursuing research studies as directors, staff, or members of the IAHPC, are to be retained by the organization for a period of three (3) years after submission of the final report on the research project for which the data were collected, unless a longer period is specified by the sponsor.
- Designation of Inquiry Panel; Use of Outside Experts: Within 15 working days of the determination that an Inquiry is warranted, the Chair, in consultation with other Board members as appropriate, shall appoint the Inquiry Panel and designate one of its members to serve as chair. The Inquiry Panel shall consist of no more than three individuals who do not have real or apparent conflicts of interest in the case, are unbiased, and have the necessary expertise to evaluate the evidence and issues related to the allegation, interview the principals and key witnesses, and conduct the Inquiry. Ordinarily, the members of the Inquiry Panel will be drawn from within the IAHPC Board. However, the Chair may designate Panel members from outside the IAHPC if necessary to obtain the relevant expertise and/or avoid conflicts of interest.
The Inquiry Panel shall determine whether additional experts other than those appointed to the Panel need to be consulted during the Inquiry to provide special expertise regarding the analysis of evidence. If consulted, such experts shall provide a strictly advisory function to the Panel and shall not vote. At the request of the chair, they may interview witnesses and participate in Panel deliberations. The experts chosen may be from inside or outside of the IAHPC.
- Notification of Complainant and Respondent: The Chair or Executive Director shall notify the Complainant and Respondent in writing of the opening of the Inquiry. The notification to the Complainant and the Respondent should: identify the research project in question and the specific allegations; provide a copy of this Policy; refer to the definition of Research Misconduct; identify any external funding involved; list the names of the members of the Inquiry Panel (if appointed) and experts (if any); explain the opportunity to challenge the appointment of a member of the Inquiry Panel or expert for bias or conflict of interest; describe the IAHPC's policy on protecting the Complainant against retaliation; and describe the need to maintain confidentiality during the Inquiry and any subsequent proceedings. The notification to the Respondent should, in addition: provide a copy of the allegation(s) and invite the Respondent to respond; explain the Respondent's opportunity to be interviewed, to present evidence to the Panel, and to comment on the draft Inquiry report; and address the Respondent's obligation to cooperate in the Inquiry and any subsequent proceedings.
Criteria Warranting Investigation
The purpose of an Inquiry is to conduct an initial review of the material and evidence to determine whether to conduct an Investigation. Therefore, an Inquiry does not require a full review of all the evidence related to the allegations.
- An Investigation is warranted if there is:
- a reasonable basis for concluding that the allegations fall within the definition of Research Misconduct under this Policy; and
- preliminary information-gathering and preliminary fact-finding from the Inquiry indicates that the allegations may have substance.
The Inquiry Panel shall interview the Complainant, the Respondent, and key witnesses and examine relevant Research Records and materials. Supervised access to the data and/or documents should be available to the Respondent and the Complainant, and to other witnesses as appropriate. Witness interviews shall be summarized in writing by the Panel or staff to the Panel, and witnesses given the opportunity to review and correct such summaries of their own statements.
Time for Completion of Inquiry
The Inquiry must be completed within 60 calendar days of the appointment of the Panel unless circumstances clearly warrant a longer period and the Chair approves an extension. If the Inquiry takes longer than 60 days to complete, the Inquiry Report must include documentation of the reasons for exceeding the 60-day period.
This Policy will be revised and approved annually by the IAHPC Board of Directors.
Federal Register, Vol. 65, p. 76260 (Dec. 6, 2000). 00-30852.pdf (govinfo.gov)