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Bridgewater State University Policy on Maintenance of Integrity in Research

1.0 Introduction

Recent examples of fraud and failure to comply with IRB policy and procedures in research, while rare in occurrence, have raised concern in the public as well as among the federal, state and private funding agencies, which support much of the research now being conducted in the university. In 1981, the Secretary of the U.S. Department of Health and Human Services identified as a major management initiative the development of policies and procedures for dealing with misconduct in science. In 1985, the National Institute of Health (NIH) released a proposed set of detailed procedures dealing with misconduct in research funded by the Public Health Service, aspects of which have been incorporated into regulation. These agencies, along with the Association of American Universities (AAU) and the Association of American Medical Colleges have urged universities to adopt specific policies for handling allegations of fraud or unethical behavior by researchers. Accordingly, the All College Committee has approved the following policy for Bridgewater State University.

Bridgewater State University expects the highest standards of ethical behavior of all members of the academic community involved in the conduct of research. This statement on “Maintenance of Integrity in Research” describes the procedures for dealing with suspected deviations from intellectual honesty and ethical treatment of human subject in research by faculty and staff conducting research at Bridgewater State University. Procedures are defined which will foster the maintenance of high standards in research in the college and protect the rights and reputations of all parties involved in instances of alleged misconduct. The policy also covers charges involving students employed on research grants or contracts. Allegations of academic dishonesty involving students engaged in research as part of their academic program will be dealt with in accordance with University academic policies and the student disciplinary procedures included in the student handbook.

2.0 Guidelines For Identifying Academic Fraud

Fraud in research is defined as deliberate misrepresentation with intent to gain some advantage. While there is no list of examples of academic fraud which would be universally accepted, the AAU Committee on the Integrity of Research (“Report of the Association of the American Universities Committee on the Integrity of Research,” May 19, 1983) has identified four types of fraud or deviance in academic research which will serve as broad guidelines in identifying research fraud.

2.1 Falsification of Data undermines the basic principle on which the scientific process depends. Since the scientific advances depend on accurate collection, analysis and reporting of information, dishonest reporting misleads others and results in the waste of resources, both human and monetary. If practiced in clinical research, falsification could even be directly dangerous to humans. Falsification of data ranges from sheer fabrication to selective reporting, including the omission of conflicting data.

2.2 Plagiarism is especially hurtful to individual researchers since it is an attempt by one individual to receive credit for the work of someone else.

2.3 Abuse of confidentiality is a significant act of fraud in an environment that depends on peer review. It is quite distinct from plagiarism and more difficult to detect, since such abuse does not usually involve verbatim duplication of another’s work. In the present environment, researchers freely discuss their ideas in research proposals submitted to potential sponsors. Proposals usually include extensive data to support the ideas. The ideas and preliminary data may be reviewed by departmental colleagues, university committees, and administrators, as well as extra mural professional colleagues long in advance of eventual publication. Opportunities to abuse confidentiality can occur not only by the actions of the primary reviewers, but also by the actions of those with whom confidentiality is the easiest research ethic to abuse and the most difficult to detect. Students, when engaged in research projects and acting as an agent of the faculty or staff person, shall agree in writing to abide by the appropriate conditions of confidentiality consistent with the BSU Policy on the Maintenance of Integrity in Research.

2.4 Instances of violations of regulations applicable to research also present a problem. Serious violations of rules adopted by appropriate mechanisms to protect research subjects and other persons and animals, while not fraudulent in the traditional sense, undermine the integrity of the research process. The BSU policy guiding the use of human subjects in research is clear. Any deviation from that policy is considered a violation and will be handled according to the procedures outlined below.

3.0 Procedures For Handling Allegations of Misconduct In Research

3.1 All initial reports and/or charges of this ethical misconduct or research fraud at Bridgewater State University should first be directed to the school dean in which the alleged fraud had occurred for a preliminary review. The dean shall inform the department chair and the research supervisors(s) of the allegations. The dean shall also inform the involved faculty member(s) of the nature of the allegations, the nature of the review and the rights of the parties involved, including contractual. Instances involving University staff should first be directed to the Vice President to whom the staff member’s department reports. The Vice President shall also inform the involved staff member(s) of the nature of the allegations, the nature of the review and the rights of the parties involved.

3.2 The college dean or Vice President, after consultation with the department chair or appropriate research supervisor(s), shall promptly (five business days) conduct a preliminary review to determine if there is sufficient prima facie evidence to merit a formal investigation of the charges and shall inform the Provost/Vice President of Academic Affairs that a preliminary review is underway. Confidentiality should be strictly maintained throughout the process of the review in order to protect the rights and reputations of all parties involved.

3.3 Since time is of the essence, the school dean should conduct the preliminary review promptly (five business days) and report the outcome to the Provost/Vice President of Academic Affairs as quickly as possible.

3.4 If, after consideration of the review and recommendation of the college/school, the dean or Vice President then determines that there is not sufficient prima facie evidence to support the charges, no further action needs to be taken, and the President and the party(ies) involved shall be so informed.

3.5 If, after consideration of the review and the recommendation of the school dean, the Provost/Vice President of Academic Affairs determines that sufficient prima facie evidence exists to support the charges, the Provost/Vice President of Academic Affairs shall appoint an ad hoc committee charged with the responsibility of conducting a formal investigation. The membership of the committee shall consist of no fewer than four knowledgeable individuals including one representative from the department or unit of the involved faculty member(s) or non-faculty employee(s) and three other faculty members from related departments or areas. In instances where externally funded research is involved, the Provost/Vice President of Academic Affairs may also appoint a member of the Bridgewater State University Vice President for Administration and Finance staff to serve as an ex officio member of the committee to represent the interests and legal obligation of the University. In addition the Provost/Vice President of Academic Affairs may also appoint an additional member(s) from outside the institution in order to broaden the expertise of the committee.

3.6 At the time the committee is requested to conduct a formal investigation, the Vice President for Administration and Finance staff shall notify the accused faculty member(s) or non-faculty employee(s) of the charges and the function of the committee. The Provost/Vice President of Academic Affairs and the University school dean may determine that the research activities of the involved researcher(s) may be restricted or monitored during the course of the investigation. If so, then the Provost/Vice President of Academic Affairs shall also notify the department chair, and in the case of funded research, the Vice President for Administration and Finance.

3.7 The Provost/Vice President of Academic Affairs shall convene the committee, appoint one of the faculty on the committee to serve as chair, present the charges and allegations and discuss University policies and procedures pertinent to the investigation. The committee shall investigate all charges and facts and may interview any and all parties appropriate to reaching a decision regarding the merit of the charges. The chair of the committee shall meet with the appropriate personnel officer as to existing procedures and safeguards to protect the rights and reputation of all parties involved before carrying out the investigation. The committee should begin its investigation promptly and should provide a written report of its findings and recommendations to the Provost/Vice President of Academic Affairs no later than 60 days after the initiation of the formal investigation. The Provost/Vice President of Academic Affairs may accept the report or return it to the committee for further information or clarification. The committee shall also forward the final copy of this report to the accused party(ies).

3.8 If, on the basis of the findings and recommendations of the committee, and Provost/Vice President of Academic Affairs determines that no unethical or fraudulent acts have been committed, all parties shall be notified accordingly. The Provost/Vice President of Academic Affairs and the school dean shall undertake all necessary efforts to restore fully the reputation and credibility of the researcher(s) under investigation. All interim restrictions on research activity will be removed.

3.9 If, on the basis of the report and recommendation of the committee, the Provost/Vice President of Academic Affairs determines that there is evidence of unethical or fraudulent acts, the Provost/Vice President of Academic Affairs shall report this conclusion as well as recommendations regarding the imposition of sanction and/or disciplinary action to the President. The President shall make the final determination regarding the appropriateness of the recommendation. Sanctions may include, but are not limited to, written reprimand, termination of current research activity, public disassociation of the University from any future unauthorized research activity, restriction from future research activities, and debarment from intramural funded research programs. The President may also determine if the matter warrants disciplinary action pursuant to pertinent articles of in the current contract.

3.10 The President shall determine if information about the charges the investigation, or their disposition should be released to the public, the press, or specific parties, i.e., editors of journals in which papers or reports of research in question may have appeared. In cases involving externally funded research, the sponsoring agency will be notified of the findings of the investigation and the final disposition of any sanction and/or disciplinary action, or restitution to be made.

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