This is an operational staffing guide, not a definition. For what a Research Integrity Officer is under federal regulation, see the Research Integrity Officer (RIO) dictionary term. This guide is about a different question: once an institution has designated an RIO, who else actually staffs the broader research-integrity-and-compliance function around that person, and how do institutions divide the work in practice?
‘Research integrity office’ is not a single federally standardized organizational chart. 42 CFR Part 93 requires that PHS-funded institutions designate a Research Integrity Officer to administer misconduct allegations, but it says nothing about who else must be hired, what they’re called, or how responsibilities outside misconduct handling get divided. In practice, institutions converge on a small number of recurring operating models, shaped less by regulation and more by institution size, research portfolio, and how much oversight work one person can credibly carry.
Why staffing became a live question
A single ‘director of research compliance’ model — one person nominally responsible for conflict of interest, export control, IRB oversight, IACUC oversight, and misconduct — is common at smaller institutions, largely because volume doesn’t justify more headcount. But at institutions with a substantial federally funded research portfolio, that model runs into a structural problem: 42 CFR Part 93 already requires that the person who administers a misconduct inquiry (the RIO) be functionally separate from the person who decides its outcome (the Institutional Deciding Official, or IDO, under § 93.218), specifically so the same individual isn’t investigating and adjudicating. Layering conflict-of-interest review, export-control screening, IRB administration, and IACUC administration onto that same person multiplies both workload and the number of adjacent processes that could plausibly create an appearance of conflict.
The result, at research-intensive institutions in particular, is a move toward splitting the function into two or three distinct leadership roles, each with its own staff, reporting up to a common associate/assistant vice president for research or vice president for research.
The three-way operating model
The most common way institutions split this work, once it outgrows a single office, separates the function along the following lines:
Research Integrity Officer (RIO) — misconduct-specific
Scoped narrowly to what 42 CFR Part 93 actually requires: receiving and initially assessing allegations of fabrication, falsification, and plagiarism; deciding whether to open an inquiry; sequestering records; appointing inquiry and investigation committees; and coordinating reporting to the HHS Office of Research Integrity (ORI). Many institutions also assign this office the Responsible Conduct of Research (RCR) training program required by NIH and NSF, on the logic that RCR training and misconduct response are both about the integrity of research conduct specifically, distinct from broader compliance.
Research Compliance Director (or Research Compliance & Security)
Covers conflict of interest disclosure and management, export control (EAR/ITAR) screening, foreign-travel and foreign-collaboration disclosure, and data/research security obligations that have grown substantially since NSPM-33 directed federal agencies toward disclosure and research-security requirements. This role sits closer to legal and regulatory risk management than to research ethics as such.
Research Protections Director
Covers the three committee-based human- and animal-subject oversight functions: the Institutional Review Board (IRB) for human-subjects research under the Common Rule, the Institutional Animal Care and Use Committee (IACUC) for animal research, and the Institutional Biosafety Committee (IBC) for recombinant/synthetic nucleic acid and biohazard work. These are prospective, protocol-level reviews — approving research before it happens — as distinct from the RIO’s after-the-fact response to an allegation.
A real example: UNLV’s 2024 restructuring
The University of Nevada, Las Vegas restructured its Office of Research Integrity from a single-executive-director model into exactly this three-person leadership structure, announced in October 2024 following an 18-month internal review. The reorganization split responsibility as follows: a Research Compliance Director covering conflicts of interest, export control, foreign travel, and data security; a newly hired Research Protections Director overseeing the IRB, IACUC, and IBC; and a Research Integrity Officer handling misconduct allegations (fabrication, falsification, plagiarism) and administering the RCR training program. According to the university’s own announcement, the change was intended to make the office "more proactive instead of reactive" and followed the Division of Research’s first strategic plan in a decade.
UNLV is one visible example of the pattern, not evidence that every institution follows it exactly. Institutions of similar size vary in where they draw the lines. At UNC Charlotte, for instance, the Research Integrity Officer title sits with an Assistant Vice Chancellor, while a separately titled Director of Research Compliance and Safety handles a more safety-and-biosafety-weighted compliance portfolio. At Penn State, the Research Integrity Officer role reports up through the Office for Research Protections rather than sitting as a co-equal peer office — illustrating that ‘research protections’ and ‘research integrity’ are sometimes nested under one senior administrator (an Associate Vice President for Research) rather than split into parallel offices reporting separately upward.
Smaller institutions: the combined model
Institutions without the funded-research volume to justify three distinct director-level positions commonly combine two or all three functions under one office, sometimes one person. A single research compliance office handling COI, export control, IRB, and IACUC administration, with the same individual or a small shared staff also holding the RIO designation for misconduct purposes, remains common and is not itself a compliance failure — 42 CFR Part 93 requires only that the RIO and IDO functions be held by different people for a given case, not that the RIO be organizationally separate from every other compliance function. What changes as an institution scales up its research portfolio is less a regulatory requirement and more a practical workload and conflict-of-interest-optics threshold.
Where the Institutional Official fits
None of the three roles above is the same as the Institutional Official (IO), a separate, senior signatory role that binds the institution to its federal assurances across IACUC, misconduct, and research-security frameworks. The RIO, compliance director, and research protections director typically report up to (or are functionally accountable to) the IO — most often a vice president for research or provost-level administrator — rather than holding IO authority themselves. A mid-size institution restructuring its research-integrity function is usually deciding how to divide operational responsibility beneath a single IO, not creating additional IOs.
Training and professionalization
Regardless of which staffing model an institution uses, ORI runs the primary professional-development pathway for the RIO role specifically: the RIO Boot Camp, developed with ORI’s Division of Investigative Oversight and periodically co-hosted with a partner institution, and the ORI Handbook for Institutional Research Integrity Officers, a reference work covering the operational mechanics of handling misconduct allegations under Part 93. These are RIO-specific; compliance directors and research protections directors typically draw on separate professional tracks (for example, COI-focused guidance from the Association of American Medical Colleges, or IRB/IACUC-focused training through PRIM&R) rather than ORI’s RIO curriculum.
Frequently asked questions
Does 42 CFR Part 93 require a separate Research Integrity Office, or just a designated RIO?
Just a designated RIO. The regulation requires that PHS-funded institutions name an individual responsible for administering misconduct allegations; it does not mandate a standalone office, a minimum staff size, or organizational separation from other compliance functions, beyond the RIO/IDO separation required for a given case.
Can the same person be the RIO and the Research Compliance Director?
Yes, and at smaller institutions this is common. The regulatory constraint is that the RIO cannot also be the Institutional Deciding Official for the same case (§ 93.218) — combining RIO duties with COI, export-control, or IRB/IACUC administration is a staffing choice, not a violation, though institutions with growing research volume often split it out to reduce workload and the appearance of overlapping roles.
Who does the RIO, compliance director, and research protections director typically report to?
Most commonly an associate or assistant vice president for research, or a vice president for research directly, who in turn often holds or reports to the Institutional Official for the relevant federal assurances.
Is ‘Research Protections’ the same as ‘Research Integrity’?
No, though the titles are frequently confused. Research protections offices typically administer prospective, protocol-level review (IRB, IACUC, IBC) — approving research before it starts. Research integrity, in the RIO sense, is reactive: it responds to allegations of fabrication, falsification, or plagiarism after the fact. Some institutions nest one under the other administratively (as at Penn State, where the RIO role sits within the Office for Research Protections); others run them as co-equal peer offices (as at UNLV).
Related CASRAI resources
- Research Integrity Officer (RIO) — the regulatory definition and operational duties under 42 CFR Part 93
- The Institutional Official (IO) — the senior signatory role the RIO, compliance director, and research protections director report up to
- CHRC Certification: Certified in Healthcare Research Compliance — a relevant credential for research compliance directors
References
- 42 CFR Part 93, Subpart B, § 93.233 (Research Integrity Officer or RIO), § 93.218 (Institutional Deciding Official). U.S. Department of Health and Human Services, via eCFR.gov.
- HHS Office of Research Integrity, RIO Handbook for Institutional Research Integrity Officers and RIO Boot Camp program materials (ori.hhs.gov).
- University of Nevada, Las Vegas, ‘Research Integrity Office Restructures to Lessen Administrative Burden on Researchers,’ UNLV News, October 2024.
