CASRAI Dictionary

Tag: federal research misconduct policy

  • Research Misconduct Federal Funding: Grant Risk

    When an allegation of research misconduct is opened against a federally funded project, the grant does not simply continue as normal. The funding agency can defer draw-downs, restrict how funds are spent, or suspend the award outright, while the awardee institution — not the agency — conducts the inquiry and investigation under research misconduct federal funding rules that require prompt notification, safeguarding of funds, and, if misconduct is confirmed, cost recovery or debarment.

    Research misconduct is fabrication, falsification, or plagiarism in proposing, performing, or reviewing federally funded research, or in reporting its results — a definition set by the Office of Science and Technology Policy’s 2000 Federal Policy on Research Misconduct (65 Fed. Reg. 76,260) and applied by every major federal research funder.

    What Is Research Misconduct Under Federal Policy?

    Federal research misconduct policy applies a single, government-wide standard: fabrication, falsification, or plagiarism (FFP) committed in proposing, performing, or reviewing federally funded research, or in reporting its results. Under the OSTP Federal Policy on Research Misconduct, a finding requires proof that the conduct represents “a significant departure from accepted practices,” was committed “intentionally, or knowingly, or recklessly,” and is established “by a preponderance of the evidence” — a civil, not criminal, standard.

    Honest error and legitimate differences of scientific opinion are explicitly excluded. The policy also does not cover authorship disputes, harassment, or general grant-management violations, which fall under separate institutional or agency processes.

    • Fabrication — making up data or results and recording or reporting them.
    • Falsification — manipulating materials, equipment, or data so the research record is not accurately represented.
    • Plagiarism — appropriating another person’s ideas, processes, results, or words without credit.

    What Happens to Grant Funds During an Investigation?

    A grant under a misconduct inquiry does not automatically stop, but the funding agency retains authority to take interim administrative actions to protect federal funds while the institution investigates. These typically include deferring decisions on continued funding, restricting the purposes for which existing funds may be spent, requiring special award certifications, or — where the risk is severe — suspending the active award pending outcome.

    Responsibility for the investigation sits primarily with the recipient institution, not the funder. Under Public Health Service (PHS) rules governing NIH-funded research (42 CFR Part 93), and the parallel National Science Foundation framework (45 CFR Part 689), the institution runs its own inquiry and investigation while the agency monitors, can intervene, and controls the purse strings throughout.

    Investigation stage Typical fund status Who acts
    Institutional assessment / inquiry Funds usually continue; agency may be informed Research Integrity Officer (RIO)
    Formal investigation opened Agency may defer, restrict, or condition funding Institution investigates; ORI or NSF OIG notified
    Investigation concluded, misconduct found Suspension, termination, or debarment possible Agency Inspector General / Deciding Official

    Who Must Notify the Funding Agency, and When?

    Every institution receiving PHS or NSF funding is required, as a condition of its funding assurance, to notify the relevant federal office once a formal investigation is opened. For NIH and other Public Health Service awards, that notice goes to HHS’s Office of Research Integrity (ORI); for NSF awards, it goes to the NSF Office of Inspector General (OIG).

    Notification cannot wait for the case to close. If the institution determines during an inquiry or investigation that public health or safety is at risk, that federal interests or resources are threatened, that research activities should be suspended, or that there is a reasonable indication of a possible civil or criminal law violation, it must notify the agency immediately — not at the standard reporting milestones.

    • Immediate notice — health/safety risk, threat to federal resources, or suspected civil/criminal violation.
    • Formal notice at investigation opening — required under the institution’s PHS or NSF assurance.
    • Closing report — the full institutional record, transmitted to ORI or NSF OIG after a final misconduct determination and any institutional appeal.

    What Are the Consequences If Misconduct Is Confirmed?

    If an investigation substantiates research misconduct, the funding agency can impose administrative sanctions independent of, and in addition to, any action the institution itself takes. Under ORI’s guidance on federal policy, “the Federal Government can debar researchers who commit misconduct from receiving Federal funds for a specified period of time,” and institutions commonly pursue their own parallel actions such as termination of employment or mandated supervision of future work.

    Available federal administrative actions include:

    • Correction of the published research record and retraction of affected papers.
    • Letters of reprimand or special certification requirements on future awards.
    • Suspension or termination of the active award, with recovery of misspent federal funds.
    • Suspension or debarment from federal funding, published on the General Services Administration’s SAM.gov exclusions list.
    • Referral to the Department of Justice where civil or criminal fraud is suspected.

    Cost recovery is a distinct lever from debarment: an institution can be required to repay funds tied to fabricated or falsified data even where an individual researcher, not the institution, is the primary respondent.

    How Does the 2024 Final Rule Change the Process?

    The compliance landscape shifted materially with HHS’s Final Rule updating 42 CFR Part 93, published in the Federal Register on 17 September 2024 and formally titled “Public Health Service Policies on Research Misconduct.” The rule took effect 1 January 2025, but institutions were required to apply its new procedural requirements to any allegation received on or after 1 January 2026, with updated institutional policies due to ORI no later than the annual report covering 2025 (filed by 30 April 2026).

    The Final Rule extends two of the timelines research administrators rely on most:

    • Inquiry period: extended from 60 days under the 2005 regulation to 90 days.
    • Investigation period: extended from 120 days under the 2005 regulation to 180 days.

    It also formalises a new pre-inquiry “institutional assessment” stage (§93.306), in which the Research Integrity Officer must document whether an allegation falls within the misconduct definition and PHS jurisdiction before an inquiry is opened — with no fixed time limit for this new stage. The rule further clarifies confidentiality obligations, allowing institutions to disclose respondent identities to journals, co-authors, and collaborating institutions where there is a legitimate need to know, and expands provisions covering multiple respondents and multi-institution proceedings.

    Frequently Asked Questions

    Does the Funding Agency Investigate Misconduct Directly, or Does the Institution?

    The institution conducts the initial inquiry and investigation, not the federal funding agency. Agencies such as ORI or the NSF OIG monitor the case, can intervene if the institution is unable or unwilling to act, and retain authority over the grant throughout.

    What Standard of Proof Applies to a Misconduct Finding?

    A finding requires proof “by a preponderance of the evidence” — more likely than not — not the criminal “beyond a reasonable doubt” standard. The conduct must also be shown to have been committed intentionally, knowingly, or recklessly, and to represent a significant departure from accepted research practice.

    What Is the First Phase of a Research Misconduct Response?

    The process begins with an institutional assessment or inquiry — a preliminary review to decide whether an allegation has enough substance to warrant a full investigation. Under the 2024 Final Rule, this assessment stage is now formally documented before any inquiry clock starts running.

    To Whom Does the Federal Research Misconduct Policy Apply?

    The policy applies to anyone proposing, performing, or reviewing federally funded research — including applicants, grant recipients, subrecipients, project participants, and peer reviewers — at any institution receiving Public Health Service or comparable federal research funding.

    Implications for Research Administrators

    The practical exposure is threefold: a live award can be frozen or restricted mid-project, cost recovery can claw back funds already spent, and delayed or incomplete notification to the funder is a compliance failure in its own right, separate from the underlying allegation. Research integrity offices should treat the 2026 compliance deadline as a trigger to audit their policies against the extended 90/180-day timelines and the new institutional-assessment stage — a policy still reflecting the 2005 regulation’s 60/120-day clock no longer matches what ORI expects in an institutional record.

    The Final Rule’s added reporting elements — sequestration inventories, interview transcripts, and multi-institution coordination — point toward longer, more paperwork-intensive proceedings even as deadlines extend. For anyone administering federally funded research, what happens to the grant while a case runs is as important as the underlying definition of misconduct itself.

  • Sanctions for Research Misconduct: Debarment, Funding Bans and Criminal Prosecution Compared

    Sanctions for research misconduct fall into three distinct enforcement tracks: institutional and federal debarment (led in the United States by the Office of Research Integrity), funder-imposed bans such as those applied by UKRI and Wellcome, and, in rare cases, criminal prosecution for fraud involving public funds. Each track has its own decision-maker, standard of proof, and range of outcomes, and the three are frequently confused in general explainers.

    Research misconduct is formally defined under US federal regulation as fabrication, falsification, or plagiarism (“FFP”) committed in proposing, performing, or reviewing research, or in reporting research results (45 CFR § 93.103). No equivalent single statutory definition exists in the United Kingdom, where funders and employers apply their own policies against the same broad FFP framework.

    What sanctions exist for research misconduct?

    Three separate mechanisms can be triggered by a single proven case of research misconduct, and they are not mutually exclusive. An institution can dismiss a researcher, a federal or national funder can bar them from future awards, and — only in the most serious cases involving fraud against public money — a prosecutor can bring criminal charges.

    The table below compares the three tracks as they currently operate.

    Enforcement track Who imposes it Typical sanction range Standard of proof
    Federal debarment (US) HHS Office of Research Integrity / federal agency Supervision or funding restriction (commonly around three years) up to lifetime exclusion from federal funds Preponderance of the evidence
    Funder sanctions (UK) UKRI, Wellcome, NIHR and other funders individually Grant termination, repayment demands, time-limited bar on future applications Funder’s own investigation findings
    Criminal prosecution National courts (e.g. US Department of Justice) Fines, restitution, imprisonment Beyond reasonable doubt

    Institutional actions — reprimand, retraction requests, termination of employment — typically happen first and independently of whether a funder or prosecutor later gets involved.

    How does ORI debarment work in the United States?

    ORI oversees misconduct findings in Public Health Service–funded research under 42 CFR Part 93, and can recommend administrative actions ranging from a certification requirement to full debarment. Debarment itself is executed through the government-wide exclusion mechanism at 2 CFR Part 180, which bars a researcher from receiving any federal award, not only from the agency that funded the original research.

    Debarment periods are not fixed by statute. ORI case records and published analyses of federal misconduct findings indicate that a supervised-research period or funding restriction of around three years is the most common outcome, with longer bars — up to a lifetime exclusion — reserved for the most serious or repeated cases. The National Institutes of Health can additionally exclude a debarred individual from serving on grant review panels.

    • Certification of research integrity for a fixed period
    • Supervision requirements on future federally funded work
    • Time-limited exclusion from federal funding and review committees
    • Lifetime debarment in the most severe or repeat cases

    How do UKRI and UK funders sanction research misconduct?

    The UK has no single federal debarment register equivalent to the US system. Instead, individual funders investigate and sanction cases against their own grant conditions, and institutions handle the underlying employment consequences separately.

    Wellcome’s grant conditions state that where an organisation upholds a research misconduct allegation, sanctions “may vary in length, depending on the severity of the misconduct” — which can include grant termination, repayment demands, and a time-limited bar on future applications to that funder. UKRI applies a comparable case-by-case approach across its research councils rather than a single published tariff, and the UK Research Integrity Office supports institutions in running consistent, fair investigation processes rather than issuing sanctions itself. Plagiarism findings that concern disputed authorship credit are frequently resolved at institutional level even before a funder becomes involved.

    Because UK sanctions are funder-specific rather than government-wide, a researcher barred by one funder is not automatically barred by another — a structural difference from the US debarment model that institutional research administration offices need to track carefully when advising on eligibility.

    When does research misconduct lead to criminal prosecution?

    Criminal prosecution is rare and reserved for cases where misconduct overlaps with fraud against public funds, false statements to a federal agency, or theft — not for FFP findings alone. The evidentiary bar is far higher than for an administrative debarment finding, which is one reason so few cases reach a courtroom.

    Two US cases illustrate the outer edge of this track. In 2005, University of Vermont researcher Eric Poehlman became the first American scientist sentenced to prison over research misconduct-related fraud, receiving one year and a day and an order to repay roughly $180,000 after fabricating data in federal grant applications. In 2015, former Iowa State University researcher Dong-Pyou Han was sentenced to 57 months in federal prison for making false statements in NIH-funded HIV vaccine research — one of the longest custodial sentences on record for research fraud in the US.

    No comparable UK criminal prosecutions for research misconduct itself exist on the public record; related conduct there is more commonly pursued, if at all, under general fraud law rather than a research-specific statute.

    Frequently asked questions about sanctions for research misconduct

    What are the penalties for research misconduct?

    Penalties include institutional actions (reprimand, retraction, termination), funder sanctions (grant termination, repayment, time-limited application bans), and federal debarment from all future government funding. Criminal penalties — fines and imprisonment — apply only in rare cases involving fraud against public money.

    What is the most severe sanction for research misconduct?

    The most severe administrative sanction is lifetime federal debarment, which permanently excludes a researcher from receiving any US government funding or serving on review panels. Where fraud against public funds is proven, imprisonment is the most severe outcome overall, though it is far less common than debarment.

    Can you go to jail for research misconduct?

    Yes, but only in cases that cross into criminal fraud, such as fabricating data to obtain federal grant money. Documented examples include Eric Poehlman (one year and a day, 2005) and Dong-Pyou Han (57 months, 2015), both convicted over federally funded research fraud rather than FFP findings alone.

    What are the three types of research misconduct?

    Under the US federal definition, the three types are fabrication (inventing data), falsification (manipulating data, materials, or processes), and plagiarism (appropriating others’ ideas or words without credit) — collectively known as FFP under 45 CFR § 93.103.

    What these sanctions mean for institutions and researchers

    The practical implication for research administrators is that a single misconduct finding can trigger overlapping consequences on different timelines: an institution may act within weeks, a funder’s sanction may follow months later, and a criminal referral — where warranted — can take years to resolve. Advising researchers or institutional leadership requires tracking all three tracks separately rather than assuming one outcome implies another.

    For publishers and standards bodies, the growing use of AI-assisted fabrication and image manipulation is pushing debarment and funder-sanction frameworks to adapt faster than criminal law can follow, since prosecution requires proof of intent to defraud rather than mere data manipulation. Institutions should expect funders on both sides of the Atlantic to keep tightening administrative sanctions — debarment periods and funder bans — well ahead of any corresponding shift in criminal enforcement.

  • Who Handles Research Misconduct in 4 Countries?

    Who handles research misconduct depends entirely on the jurisdiction: no single global regulator exists. The United States channels federally funded cases through the Office of Research Integrity (ORI) under 42 CFR Part 93; the UK relies on individual universities advised by the UK Research Integrity Office (UKRIO); Australia splits oversight between the NHMRC/ARC-run Australian Research Integrity Committee (ARIC) and institutions applying the Australian Code for the Responsible Conduct of Research; and Canada’s Tri-Agency Secretariat on Responsible Conduct of Research (SRCR) enforces the Tri-Agency Framework across CIHR, NSERC and SSHRC-funded work. In all four systems, the employing institution — not the national body — conducts the actual investigation.

    Research misconduct is fabrication, falsification, or plagiarism in proposing, performing, reviewing, or reporting research — a definition first codified in US federal regulation and echoed, with local variation, across the other three systems discussed below.

    Contents

    Who actually investigates research misconduct?

    In every major research system, the first-line investigator is the researcher’s own institution, not a national regulator. National bodies — ORI, UKRIO, ARIC, and Canada’s SRCR — exist to set standards, provide oversight, and in some cases review procedural fairness, but they rarely re-investigate the underlying facts themselves.

    This “institution-first” model is near-universal because misconduct findings usually require discipline-specific expertise, access to lab notebooks, data, and witnesses that only the host institution can readily obtain. National oversight bodies then step in at different points: before a case (setting definitions and required procedures), during it (advising or auditing), or after it (reviewing the outcome or deciding on federal funding consequences).

    United States: the Office of Research Integrity (ORI)

    The Office of Research Integrity (ORI), part of the US Department of Health and Human Services, oversees misconduct involving research funded by the Public Health Service, including the National Institutes of Health (NIH). ORI does not typically conduct the initial fact-finding itself.

    • Institutions receiving PHS funding must maintain written misconduct policies compliant with 42 CFR Part 93, the federal research misconduct regulation.
    • Institutions run the inquiry and investigation; ORI oversees the process, can require corrective action, and can impose federal funding debarment.
    • The National Science Foundation (NSF) runs a parallel, separate process for NSF-funded research through its Office of Inspector General.
    • ORI’s statutory definition of research misconduct — fabrication, falsification, or plagiarism — is the reference definition most other countries cite or adapt.

    United Kingdom: institutions advised by UKRIO

    The UK has no statutory national investigator. Responsibility sits with the employing university or research organisation, which must operate a misconduct procedure consistent with the Concordat to Support Research Integrity (Universities UK, 2019).

    • The UK Research Integrity Office (UKRIO) is an independent charity, not a regulator — it provides advice, a model investigation procedure, and training, but has no statutory power to investigate or sanction.
    • UK Research and Innovation (UKRI), the national funder, requires funded organisations to have robust misconduct procedures as a condition of grant funding, per its Grant Research Practice policy.
    • The newer UK Committee on Research Integrity (UK CORI) monitors sector-wide research integrity but does not investigate individual cases either.
    • Appeals, where permitted, are handled internally by the institution, managed by someone other than the original decision-maker.

    Australia: NHMRC, ARC and the Australian Research Integrity Committee

    Australia operates a shared responsibility model. Institutions investigate under the Australian Code for the Responsible Conduct of Research (2018), jointly issued by the National Health and Medical Research Council (NHMRC), the Australian Research Council (ARC), and Universities Australia.

    • The Australian Research Integrity Committee (ARIC), a joint NHMRC/ARC initiative, reviews the process an institution followed — not the substance of the misconduct finding — when a complainant or respondent challenges procedural fairness.
    • NHMRC and ARC can withdraw or withhold funding from institutions found not to comply with the Code, giving Australia a funding-conditionality lever similar to the US ORI model.
    • Unlike the US and UK, Australia has an explicit national committee (ARIC) with a formal review remit, though it stops short of full investigative authority — a gap frequently raised in Australian research-integrity policy debate.

    Canada: the Tri-Agency Framework and SRCR

    Canada’s three federal granting agencies — the Canadian Institutes of Health Research (CIHR), the Natural Sciences and Engineering Research Council (NSERC), and the Social Sciences and Humanities Research Council (SSHRC) — jointly known as the Tri-Agency, govern misconduct through the Tri-Agency Framework: Responsible Conduct of Research.

    • The Secretariat on Responsible Conduct of Research (SRCR) administers the Framework, advises institutions, and tracks cases, but institutions conduct the actual investigation.
    • Institutions receiving Tri-Agency funds must sign a Memorandum of Understanding agreeing to investigate allegations under the Framework and report outcomes to the SRCR.
    • Consequences for non-compliance can include suspension or termination of Tri-Agency funding to the institution or individual — the same funding-lever mechanism used by ORI and NHMRC/ARC.

    Side-by-side comparison of powers and remit

    The table below summarises where investigative authority actually sits, and what each national body can and cannot do.

    Jurisdiction National body Who investigates National body’s actual power Governing framework
    United States Office of Research Integrity (ORI) Institution Oversight, funding debarment for PHS-funded research 42 CFR Part 93
    United Kingdom UKRIO (advisory charity) Institution Advice, model procedure — no statutory power Concordat to Support Research Integrity (2019)
    Australia ARIC (NHMRC/ARC joint committee) Institution Procedural-fairness review; funding conditionality via NHMRC/ARC Australian Code for the Responsible Conduct of Research (2018)
    Canada SRCR (Tri-Agency Secretariat) Institution Framework administration; funding suspension via Tri-Agency Tri-Agency Framework: Responsible Conduct of Research

    The consistent pattern: every national body relies on funding conditionality — not direct investigative power — as its main enforcement lever. Only the institution has authority to determine the facts of a specific allegation.

    Answer-first Q&A

    Who investigates research misconduct?

    The employing research institution investigates in the US, UK, Australia, and Canada. National bodies such as ORI, UKRIO, ARIC, and the SRCR set standards, provide advice, or review process fairness, but they do not typically conduct the fact-finding themselves — institutional panels of academic peers do.

    Which agencies oversee research misconduct?

    In the US, the Office of Research Integrity and the institution jointly oversee PHS-funded cases. The NSF Office of Inspector General covers NSF grants separately. In the UK, UKRI sets funding conditions while UKRIO advises. In Australia, NHMRC and ARC jointly run ARIC. In Canada, the Tri-Agency (CIHR, NSERC, SSHRC) oversees via the SRCR.

    What counts as research misconduct?

    Research misconduct generally means fabrication, falsification, or plagiarism in proposing, performing, reviewing, or reporting research — the core US federal definition. UKRIO frames it more broadly as behaviours that deliberately or recklessly fall short of expected research standards, distinguishing it from honest error or lesser “questionable research practices.”

    What happens if research misconduct is confirmed?

    Confirmed findings can trigger institutional disciplinary action, correction or retraction of the published record, and notification of funders. National bodies can add consequences: ORI can debar researchers from federal funding; NHMRC/ARC and Canada’s Tri-Agency can suspend or withdraw institutional or individual grant funding.

    What this means for institutions and researchers

    Institutions operating across borders — a common reality for multinational research collaborations — must satisfy multiple, non-equivalent oversight regimes simultaneously. A joint US-UK-Australia project can trigger three separate procedural obligations: 42 CFR Part 93 compliance for PHS funding, Concordat-aligned procedures for UK partners, and Australian Code compliance for NHMRC/ARC-funded co-investigators.

    Research administrators should map which funders and jurisdictions apply before a misconduct concern arises, not after. Confirming institutional procedures satisfy every applicable framework — rather than assuming one national standard covers a whole consortium — reduces the risk of a finding being challenged on procedural grounds in a partner jurisdiction.

    The direction of travel in all four systems is toward tighter funder-driven conditionality rather than new statutory investigative powers: expect national bodies to keep strengthening reporting and audit requirements on institutions, rather than assuming direct investigation duties themselves.

  • Research Misconduct Policy: Lehigh’s 2026 Update Sets the Pace for Peer Institutions

    A research misconduct policy is the institutional and federal framework that defines fabrication, falsification, and plagiarism (FFP) in research, and sets out how allegations are reported, investigated, and adjudicated. Lehigh University’s new research misconduct policy took effect on 1 January 2026, and it is not an isolated update: dozens of US research universities revised their policies for the same date, all responding to the first substantial rewrite of the federal research misconduct rule in two decades.

    Research misconduct policy in the United States is not institutional discretion. Any university receiving Public Health Service (PHS) funding — the great majority of federally funded research institutions — must maintain a policy satisfying 42 CFR Part 93, administered by the HHS Office of Research Integrity (ORI). When that regulation changes, every covered institution’s policy changes with it. That happened in 2024, and 1 January 2026 is when the consequences arrived on campus.

    What does Lehigh’s new research misconduct policy change?

    Lehigh’s Office of Research Integrity finalised its revised policy on 19 December 2025, in a notice from Naomi E. Coll, Director of Research Policy and Compliance, confirming that the policy would take effect on 1 January 2026. The document sets out how the university assesses, inquires into, and investigates allegations of research misconduct against academic, scientific, and professional staff, students, and contractors, regardless of funding source.

    What distinguishes Lehigh’s process is its provenance rather than its content: the policy was drafted by a faculty working group with one representative from each college, presented to the Faculty Senate in November 2025, and opened to a university-wide online public comment period before finalisation. That sequence — draft, Senate review, public comment, publication — is now a template other institutions are following as they race the same federal deadline.

    What is the federal research misconduct policy institutions must follow?

    The federal research misconduct policy originates with the Office of Science and Technology Policy’s 2000 Federal Policy on Research Misconduct and is codified for PHS-funded research at 42 CFR Part 93. It defines research misconduct as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results — honest error and honest differences of opinion are explicitly excluded.

    A formal finding requires three elements together: a significant departure from accepted practices of the relevant research community, conduct that was intentional, knowing, or reckless, and proof by a preponderance of the evidence. Non-PHS agencies apply parallel rules — the National Science Foundation administers its own version at 45 CFR Part 689 — so multi-funder institutions must reconcile more than one regulatory text in a single policy.

    What changed in the 2024 ORI Final Rule (42 CFR Part 93)?

    ORI published its final rule in the Federal Register on 17 September 2024 — the first substantive revision to the 2005 regulation. The rule became legally effective on 1 January 2025, but institutions only had to apply it to allegations received on or after 1 January 2026, which is why the current wave of policy rewrites is landing now rather than a year ago.

    • Defined intent standard: “Intentionally,” “knowingly,” and “recklessly” — previously undefined terms central to any finding — now carry fixed regulatory definitions.
    • New “institutional record” definition: the rule specifies, for the first time, exactly which documents (inquiry and investigation reports, sequestered evidence indexes, appeal records) must be compiled and preserved.
    • Seven-year retention rule: institutions must secure the institutional record and all sequestered evidence for seven years after the proceeding — or any related HHS proceeding — concludes, whichever is later.
    • Longer inquiry window: the initial inquiry phase is extended from 60 to 90 days, giving Research Integrity Officers more time before deciding whether a full investigation is warranted.

    ORI has confirmed it will not require institutions to submit revised policies until the annual report covering 2025 is filed, due by 30 April 2026 — but the policies themselves, and the procedures behind them, must already be in force for any allegation received from 1 January 2026 onward.

    Which other universities are revising policies for 2026?

    Lehigh is one of a cohort. Institutional policy pages and faculty handbooks show a cluster of revisions timed to the same compliance date, though each institution has followed its own governance path to get there.

    Institution Policy action Date Notes
    Lehigh University New research misconduct policy finalised Effective 1 Jan 2026 Faculty working group, Senate review, public comment
    Columbia University Revised policy approved by University Senate Approved 12 Dec 2025; effective 1 Jan 2026 Realigns definitions with the PHS Final Rule
    Auburn University Policy on Research Misconduct republished 21 Nov 2025 Updated allegation-resolution framework
    Ohio State University Research Misconduct policy revised March 2025 Among the earliest movers ahead of the deadline
    Wayne State University Interim Research Misconduct Policy (26-01) Interim, 2025–26 cycle Document numbering signals the 2026 compliance cycle
    Duke University Misconduct in Research policy (established) Bound to 42 CFR Part 93 / 45 CFR Part 689 Long-cited model policy; must reflect the revised rule by the deadline

    The pattern is consistent: governance bodies — Faculty Senate, University Senate, or equivalent — are being used explicitly to legitimise the revision, not just administrative sign-off. That marks a shift from prior cycles, where research misconduct policy updates were typically handled as compliance housekeeping rather than faculty-governance business.

    Common questions on research misconduct policy

    What are the three forms of research misconduct under US federal policy?

    US federal policy recognises three forms of research misconduct: fabrication (making up data or results), falsification (manipulating materials, equipment, or data so the research record is inaccurate), and plagiarism (appropriating another person’s ideas, processes, results, or words without credit). This “FFP” definition has applied since the 2000 OSTP policy and is unchanged by the 2026 rule.

    What is considered research misconduct in the US?

    Conduct only counts as research misconduct if it is a significant departure from accepted practices of the relevant research community, committed intentionally, knowingly, or recklessly, and proven by a preponderance of the evidence. Honest error, differences of scientific opinion, and most authorship disputes are explicitly excluded from the definition.

    What is 42 CFR Part 93?

    42 CFR Part 93 is the codified federal regulation — the Public Health Service Policies on Research Misconduct — that sets binding rules for how PHS-funded institutions must respond to allegations. Its 2024 revision, effective for allegations from 1 January 2026, is the first major overhaul since 2005 and drives the current round of university policy rewrites.

    What does the federal research misconduct policy cover?

    The federal research misconduct policy covers federally funded research and funding proposals across all fields — including medicine, social sciences, engineering, and statistics — conducted at universities, federal laboratories, and other funded research institutions. It governs the inquiry, investigation, and adjudication phases but does not supersede separate rules on human-subjects protection, animal welfare, or financial conflicts of interest.

    What this means for research administrators

    The consequences of research misconduct under the federal framework range from correction of the research record and letters of reprimand to suspension of funding, debarment from future federal awards, and referral for civil or criminal fraud proceedings. For research administrators, the sharper immediate risk is procedural: if an institution’s inquiry, evidentiary, or retention procedures do not match the 2026 rule, findings made under a defective process are vulnerable on appeal.

    Three takeaways follow. First, Research Integrity Officers should confirm their policy explicitly defines “intentionally,” “knowingly,” and “recklessly” in the regulatory terms now fixed by the final rule, rather than leaving them undefined as most pre-2026 policies did. Second, retention schedules need extending to the mandated seven years and mapped against the newly defined “institutional record.” Third, institutions routing revisions through faculty governance — as Lehigh, Columbia, and Auburn have done — are building a stronger due-process record that may matter if a finding is later contested.

    The compliance clock does not stop at 1 January. ORI’s own review of revised policies, via the annual report covering 2025, falls due on 30 April 2026 — a second checkpoint on which institutions treated this as a genuine revision to research administration practice, and which merely updated a document to survive it.

  • Federal Research Misconduct Policy: 42 CFR Part 93 Baseline

    The federal research misconduct policy is a uniform definition of fabrication, falsification, and plagiarism (FFP) that the Office of Science and Technology Policy set in 2000, which federal funding agencies implement through their own regulations — most consequentially, for the health sciences, via 42 CFR Part 93. That regulation sets a compliance floor; institutional policies at universities such as Duke and Lehigh sit on top of it, and in places go further than it requires.

    Federal research misconduct policy is not a single statute. It is the 2000 Office of Science and Technology Policy (OSTP) statement of principles, translated agency-by-agency into binding regulation — 42 CFR Part 93 for the Public Health Service, 45 CFR Part 689 for NSF, and comparable rules at NASA, DOD, USDA and EPA. This article explains the federal baseline, the 2024 final rule that reshaped 42 CFR Part 93 from 1 January 2026, and how far real institutional policies diverge from — or exceed — that floor.

    What is the federal research misconduct policy?

    The Federal Policy on Research Misconduct was finalised by OSTP and published in the Federal Register on 6 December 2000 (65 FR 76260), following a National Science and Technology Council (NSTC) initiative begun in 1996. It applies to research funded by, conducted by, or proposed to federal agencies, and it exists to give every agency a shared definition so that a finding at one institution means the same thing across the federal system.

    The policy defines research misconduct as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. It explicitly excludes honest error and honest differences of opinion. A finding requires all three of the following elements:

    • A significant departure from accepted practices of the relevant research community;
    • The conduct was committed intentionally, knowingly, or recklessly; and
    • The allegation is proven by a preponderance of the evidence — the same civil standard used in most federal administrative proceedings, not the higher “clear and convincing” bar.

    OSTP’s policy does not itself create rights or obligations. It only takes legal effect once each funding agency implements it through regulation or administrative mechanism, which is why the practical compliance burden for most US research institutions runs through agency-specific rules rather than the OSTP text itself.

    What does 42 CFR Part 93 require of institutions?

    42 CFR Part 93 is the Public Health Service’s codification of the federal policy, administered by the HHS Office of Research Integrity (ORI). It governs misconduct allegations involving PHS support — chiefly NIH, CDC, FDA and AHRQ funding — and is the regulation most research-intensive US universities build their institutional policy around, since it covers the largest share of federally sponsored biomedical and behavioural research.

    Under 42 CFR Part 93, PHS-funded institutions must maintain written procedures and carry out three organisationally separated phases when an allegation surfaces:

    1. Inquiry — an initial assessment of whether the allegation has substance and warrants a full investigation.
    2. Investigation — formal development of a factual record, leading to a recommended finding.
    3. Adjudication — a separate institutional official reviews the investigation record and recommendation and decides on findings and corrective action, with any appeal handled independently of the inquiry and investigation stages.

    Institutions must notify ORI when an inquiry proceeds to investigation and forward the full evidentiary record, investigative report, and the subject’s written response on completion. ORI can then impose administrative actions — including debarment listed on the GSA’s List of Parties Excluded from Federal Procurement and Nonprocurement Programs — independent of any institutional employment action.

    What changed under the rule taking effect in 2026?

    HHS finalised amendments to 42 CFR Part 93 in 2024, and institutional compliance became mandatory from 1 January 2026 — the most consequential revision since the regulation was first adopted in 2005. PHS-funded institutions had to update written policies, notification procedures, and recordkeeping to match the amended rule by that date.

    Because that deadline has only just passed, institutions are in an early implementation window: some have already published revised policy text referencing the amended regulation by name, while others are still finalising internal approval. Research administrators reviewing an institutional policy today should check its printed effective date rather than assume it reflects the amended rule by default.

    How do institutional policies compare: Duke, Lehigh and beyond?

    42 CFR Part 93 sets a floor, not a ceiling. Institutions retain — and routinely exercise — authority to adopt policies broader in scope or more explicit in remedy than the federal minimum requires. Two cases show the range:

    • Duke University revised its Policy and Procedures Governing Misconduct in Research to track the amended 42 CFR Part 93 for the January 2026 compliance date, retaining the federal FFP definition and the inquiry–investigation–adjudication structure while specifying Duke-level committee composition and timelines the federal rule leaves to institutional discretion.
    • Lehigh University applies its research misconduct policy to all research activity conducted at the university, regardless of funding source — a materially broader scope than 42 CFR Part 93, which by statute only reaches PHS-supported work. Lehigh’s policy also commits explicitly to restoring the reputation of respondents investigated but not found to have committed misconduct, a safeguard the federal text encourages generally but does not mandate.

    This divergence is structural, not accidental. Different sponsors administer separate, non-identical regulations — 45 CFR Part 689 (NSF), 14 CFR Part 1275 (NASA), DOD Instruction 3210.7, USDA’s 2 CFR Part 422, EPA Order 3120.5, ONR Instruction 5041.2B, alongside 42 CFR Part 93 (PHS). A university with grants from several agencies has an incentive to write one all-funder policy meeting the strictest applicable standard, rather than run separate tracks — the consolidation behind policies like Lehigh’s.

    Dimension 42 CFR Part 93 (federal floor) Typical institutional policy
    Scope of covered research PHS-supported research only Often all institutional research, any funder (e.g. Lehigh)
    Standard of proof Preponderance of evidence (mandatory floor) May apply the same or a higher internal standard, but must still report to the agency at preponderance
    Phases Inquiry, investigation, adjudication Same phases, often with added pre-inquiry assessment step
    Reputational remedy for cleared respondents Encouraged in principle Sometimes made an explicit, named commitment (e.g. Lehigh)
    Agency notification Mandatory to ORI at defined trigger points Same, plus internal governance and public-records handling

    For research administrators managing multi-sponsor portfolios, the task is not choosing between federal and institutional rules — it is writing an institutional policy broad enough to satisfy the strictest applicable federal regulation while staying consistent for cases with no federal funding at all.

    Answer-first Q&A on federal research misconduct policy

    What is the federal policy for research misconduct?

    It is the 2000 OSTP-issued definition of fabrication, falsification, and plagiarism, adopted uniformly across federal research agencies and then implemented through agency-specific regulations. For Public Health Service-funded work, that implementation is 42 CFR Part 93, administered by HHS’s Office of Research Integrity.

    What constitutes research misconduct according to federal regulations?

    Research misconduct requires all three of: a significant departure from accepted research-community practice, conduct that was intentional, knowing, or reckless, and proof by a preponderance of the evidence. Honest error and genuine differences of scientific opinion are explicitly excluded from the definition.

    What are the three types of research misconduct?

    Federal policy recognises three forms, commonly abbreviated FFP: fabrication (making up data or results), falsification (manipulating materials or altering results so the record is inaccurate), and plagiarism (using another person’s ideas, results, or words without appropriate credit).

    What does fabrication involve according to the US federal research misconduct policy?

    Fabrication is defined as making up data or results and recording or reporting them as if genuinely obtained — distinct from falsification, which alters or omits real data, and plagiarism, which misattributes another researcher’s genuine work. Inquiry committees must identify which category an allegation falls into before an investigation can proceed.

    Where federal rules end and institutional policy begins also matters for adjacent governance questions, including authorship disputes, which the federal policy excludes from its scope unless plagiarism is involved, leaving institutions to set their own authorship-dispute procedures separately from misconduct proceedings.

    Institutions that have not yet formally re-issued their policy against the amended 42 CFR Part 93 text should treat the 1 January 2026 compliance date as already binding, not upcoming, and audit committee composition, notification templates and recordkeeping against the amended rule rather than the pre-2024 version still circulating in older policy PDFs.

  • Concordat to Support Research Integrity: A Signatory Self-Assessment Guide for 2026

    The Concordat to Support Research Integrity is the UK’s non-statutory, sector-wide framework for research conduct, first published in 2012 and refreshed on 4 April 2025. Signatory universities, institutes, and funders commit to five duties — rigour, ethical compliance, an integrity culture, fair misconduct handling, and continuous improvement — verified through an annual public self-assessment statement. Organisations had until 1 April 2026 to align fully with the refreshed edition, a deadline that has now passed.

    The Concordat to Support Research Integrity is a voluntary sector agreement, hosted since late 2025 by the UK Committee on Research Integrity (UKCORI), that sets out shared principles and responsibilities for maintaining rigour and honesty across UK research.

    What Is the Concordat to Support Research Integrity?

    The Concordat to Support Research Integrity is a pan-disciplinary, UK-wide reference document setting out five commitments for researchers, research-supporting staff, research organisations, and funders. It carries no statutory or regulatory force; adherence is instead enforced contractually, through individual employment or enrolment terms and through funder grant conditions, according to the UK Research Integrity Office (UKRIO).

    The document was first developed in 2012 by a coalition of national funding bodies and university mission groups. It covers every UK research sector and discipline, from arts and humanities to biomedicine, and does not replace discipline-specific ethics guidance — it supplies the overarching principles that sit above it.

    What Are the Five Commitments and Five Principles?

    The Concordat’s five commitments define what signatories must do; a nested set of five principles, embedded within Commitment 1, define the standard those actions must meet. Together they form the structure every annual self-assessment is measured against.

    1. Maintain the highest standards of research integrity, underpinned by five principles: honesty, rigour, transparency and open communication, care and respect, and accountability.
    2. Ensure research is conducted according to appropriate ethical, legal, and professional frameworks, obligations, and standards — including when working internationally.
    3. Embed a culture of research integrity, built on good governance, best practice, and support for researcher development.
    4. Use transparent, timely, robust, and fair processes to deal with allegations of research misconduct, including questionable research practices (QRPs) that fall short of intentional misconduct.
    5. Strengthen the integrity of research and review progress regularly and openly, including collaboration with other bodies to improve implementation.

    UKCORI distinguishes research misconduct — deliberate breaches of Commitment 1’s principles occurring at any stage from ideation to publication — from questionable research practices, defined as minor infractions such as avoidable errors that occur without clear intent to deceive. Authorship disputes over who qualifies for credit on a publication are a recurring category of alleged questionable practice raised under Commitment 4; institutions drafting Concordat-aligned policy increasingly cross-reference their authorship criteria and dispute-resolution guidance when doing so.

    How Does the Annual Self-Assessment and Public Statement Work?

    Signatory organisations must publish an annual research integrity statement on their own website, publicly demonstrating how they implemented the five commitments over the preceding year. This is the Concordat’s principal accountability mechanism, since the document itself carries no statutory force.

    The Research Integrity Concordat Signatories (RICS) Group — the strategic steering body for the Concordat, whose members include UK Research and Innovation, Universities UK, Wellcome Trust, Cancer Research UK, and the Scottish Funding Council — provides a standard annual-statement template, produced on its behalf by UKRIO. Use of the template is not mandatory but is encouraged, because consistent formatting lets the sector track trends in policy and practice nationally.

    An effective self-assessment and the statement built from it should typically:

    • Declare practical measures taken against each of the five commitments, not just Commitment 1.
    • Name a senior role holder accountable for research integrity oversight, plus a first point of contact for concerns.
    • Confirm a confidential reporting mechanism exists for questionable research practices and misconduct allegations.
    • Reflect honestly on gaps and areas for improvement, rather than presenting only successes.
    • Function as an “ask-once” assurance document that satisfies multiple funders’ terms and conditions simultaneously, reducing duplicate reporting burden.
    • Be approved through institutional governance channels and published alongside prior years’ statements for year-on-year comparability.

    Because research funders have no external body overseeing their own compliance, they meet their Concordat obligations solely by self-reporting through the same public annual-statement mechanism as universities and institutes — a gap worth flagging to funder-facing offices completing their own self-assessments. Research administration teams coordinating grant compliance are typically best placed to own this reconciliation, since annual statements double as evidence against multiple funders’ terms and conditions.

    What Changed in the 2025 Refresh, and Has the April 2026 Deadline Passed?

    The Concordat has been revised twice since 2012. The refreshed 2025 edition was published on 4 April 2025 following a sector-wide review and consultation led by the RICS Group, and organisations were given until 1 April 2026 to align with its new expectations — a deadline that, as of this article’s publication, has now passed.

    Edition Published Key driver What changed
    Original 2012 Sector-led initiative by funding bodies and university mission groups Established the first UK-wide framework and the five commitments
    2019 revision 25 October 2019 House of Commons Science and Technology Committee report on research integrity, July 2018 Strengthened misconduct-handling and transparency expectations
    2025 refresh 4 April 2025 RICS Group sector consultation, 2024–2025 Reaffirmed the five-commitment structure; updated annual-statement expectations; transferred secretariat to UKCORI

    The structural core is unchanged — the five commitments and five principles carry over intact from 2019 to 2025 — but the governance around the Concordat has moved. Secretariat support transitioned from Universities UK to UKCORI, and the RICS Group’s terms of reference were formally approved in November 2025. Institutions still working from 2019-edition policy wording should treat mid-2026 as the point to confirm their annual statement and internal policies now reference the 2025 text, not the superseded one.

    Common Questions About the Concordat

    What is the Concordat to Support Research Integrity?

    It is the UK’s national, non-statutory framework for research conduct, first published in 2012 and refreshed in 2025. It sets five commitments for researchers, institutions, and funders, verified through annual public self-assessment statements rather than external audit or regulation.

    What are the five commitments required of signatories?

    Signatories commit to upholding rigour and honesty, following ethical and legal frameworks, embedding an integrity culture, running fair misconduct processes, and reviewing progress openly. These five commitments are underpinned by five principles: honesty, rigour, transparency, care and respect, and accountability.

    What does the Concordat ask universities to do about reporting misconduct?

    Employers must publish accessible misconduct and questionable-practice policies that include a confidential reporting route through a named point of contact. They must also run fair, timely, documented investigations with appeals processes, and protect anyone who raises concerns from victimisation.

    Is the Concordat legally binding?

    No. The Concordat is not statutory or regulatory guidance. It becomes binding only indirectly, through individual employment or enrolment terms and through funders’ grant conditions — which is why uptake still varies across funders and disciplines.

    Implications and Outlook for Signatory Institutions

    With the April 2026 transition window closed, research offices, integrity officers, and institutional leaders now carry a live compliance gap if their published annual statement, policies, or website text still cite the superseded 2019 wording. Because the RICS Group explicitly retained the five-commitment structure, most institutions will not need to rebuild policy frameworks from scratch — the practical work is auditing existing wording against the 2025 text, confirming named accountable roles are current, and republishing the annual statement under the updated template.

    Institutions maintaining structured terminology for related governance concepts may find it useful to cross-check definitions against CASRAI’s open research-integrity dictionary when updating internal policy language. Expect the RICS Group and UKCORI to publish further implementation guidance as the first full reporting cycle under the 2025 Concordat completes; institutions that have not yet reconciled their statements should treat that as an immediate priority, not a future task.

  • Research Misconduct Investigations: How ORI and UKRIO Procedures Compare

    Grant administrators rarely encounter research misconduct allegations often — but when one arrives, the clock starts immediately, and the procedural path depends entirely on which side of the Atlantic the funding sits. A US Public Health Service (PHS) grant triggers a federally regulated process overseen by the Office of Research Integrity (ORI); a UK Research England or UKRI grant triggers an institution-led process shaped, but not enforced, by the UK Research Integrity Office (UKRIO). Confusing the two — assuming ORI’s binding timelines apply to a UK case, or that UKRIO can compel an outcome the way ORI can — is a common and costly error for administrators managing cross-border collaborations.

    This guide sets out, side by side, what each body actually is, how each defines misconduct, and how the investigation stages differ — so administrators handling an allegation tied to a grant know which rulebook applies.

    How ORI and UKRIO define research misconduct

    Both frameworks agree on a common core — fabrication, falsification, and plagiarism (FFP) — but they diverge sharply in scope.

    ORI operates under 42 CFR Part 93, the PHS Policies on Research Misconduct. Its definition is deliberately narrow: research misconduct means fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. A finding requires three elements to be met: a significant departure from accepted practices in the relevant research community; committed intentionally, knowingly, or recklessly; and proven by a preponderance of the evidence. Honest error and legitimate differences of scientific opinion are explicitly excluded.

    UKRIO, by contrast, works from a broader, non-statutory definition: “behaviours that deliberately or recklessly fall short of the standards expected in the conduct of research.” Its guidance, aligned with the UK Concordat to Support Research Integrity (Universities UK, 2019), extends beyond FFP to cover breaches of ethical approval, undeclared conflicts of interest, and mismanagement of research data — while also naming a distinct, lower-severity category, “questionable research practices” (QRPs), for avoidable errors that fall short of intentional misconduct.

    Regulator versus adviser: two different roles

    The most consequential difference is not definitional but structural: ORI is a federal oversight body; UKRIO is an independent charity with no regulatory power.

    • ORI sits within the US Department of Health and Human Services and directly oversees how institutions handle misconduct allegations tied to PHS-funded research (including NIH grants). It can conduct its own oversight review of an institution’s findings, recommend administrative actions, and refer findings to the HHS Departmental Appeals Board.
    • UKRIO was established as an independent advisory charity in 2006. It publishes a model investigation procedure that UK research organisations may adopt or adapt, offers case-by-case advice, and promotes good practice — but it does not investigate cases itself, does not mandate a single national procedure, and has no statutory sanctioning power.

    UK funders address this gap contractually rather than through a regulator. UKRI’s Guidance for Research Organisations on the Investigation of Research Misconduct (April 2025) requires any organisation receiving UKRI funding to investigate allegations against staff or students under its own Grant Terms and Conditions, with UKRI able to take funding action if an organisation fails to do so.

    How an investigation actually runs, stage by stage

    Both systems separate a preliminary triage stage from a full inquiry, but they name and time these stages differently.

    Stage ORI (US, PHS-funded research) UKRIO model (UK institutions)
    Trigger Allegation received by institution’s Research Integrity Officer Concern raised with a “Named Person” or responsible officer
    Triage Assessment: does the allegation meet the FFP definition and involve PHS funding? Initial assessment: does it fall within the misconduct procedure’s scope?
    Formal fact-finding Inquiry (institution-level, time-limited) Initial investigation to establish if there is a case to answer
    Full review Investigation, following a sufficient inquiry finding Full investigation by an academic panel, including external members
    Standard of proof Preponderance of the evidence Not codified nationally; set by each institution’s procedure
    External oversight ORI oversight review of institutional findings; report to PHS agency None mandatory; UKRIO offers advice only
    Appeal route HHS Departmental Appeals Board Institutional appeal, managed by someone other than the original Named Person

    Under the UKRIO model, once a panel reports its findings, the Named Person decides on next steps: referral to institutional disciplinary proceedings, correction of the published record, and notifying relevant funders. Where allegations are not upheld, the same procedure is meant to protect the reputation of the person accused — a feature both systems share in principle, though neither publishes comparable statistics on false-allegation rates.

    Answer-first: common questions on research misconduct

    What are the three types of research misconduct?

    Both ORI and most UK institutional policies converge on the same core triad: fabrication (inventing data or results), falsification (manipulating research materials, equipment, or data to misrepresent results), and plagiarism (using another person’s ideas, processes, or words without credit). This is often abbreviated FFP.

    What are some examples of research misconduct?

    Common examples include inventing patient consent records, selectively deleting inconvenient data points, copying text or images from another paper without attribution, and misrepresenting the outcome of a statistical test. UKRIO guidance also treats proceeding without required ethical approval as a form of misconduct, even without FFP intent.

    What counts as research misconduct?

    Conduct counts as misconduct when it represents a significant, intentional or reckless departure from accepted research standards — not an honest mistake or a genuine scientific disagreement. ORI requires proof by a preponderance of the evidence; UKRIO-aligned institutions apply a similar intent-based threshold under their own procedures.

    What this means for research administrators

    For administrators managing grants that cross jurisdictions — a common scenario in NIH-funded international collaborations or Horizon Europe partnerships involving UK institutions — three practical points follow from the comparison above:

    • Know which body has enforcement power. Only ORI can conduct oversight review and refer a case to a federal appeals process; UKRIO cannot compel an institutional outcome.
    • Check the funder’s own reporting clause. UKRI’s April 2025 guidance obliges the receiving institution — not UKRIO — to investigate and report; PHS grant terms impose parallel obligations that run through ORI.
    • Do not assume a single global timeline. ORI-regulated inquiries and investigations run to defined federal timeframes; UKRIO-aligned UK procedures are set institution by institution, so the applicable deadline sits in the local Code of Practice for Research, not in UKRIO’s own documents.

    Administrators supporting research administration functions across both systems should hold copies of both the relevant institutional misconduct procedure and the specific grant terms — the procedural detail, not the high-level definition, is where jurisdictional mismatches cause delay.

    Where the two systems are heading

    Both frameworks are converging on the same underlying principle even as their governance models remain distinct: misconduct findings should correct the scholarly record, not just discipline an individual. UKRI’s 2025 guidance tightened institutional reporting obligations, and ORI continues to publish case summaries and administrative actions as a transparency mechanism. Neither change closes the structural gap — one system regulates, the other advises — so for the foreseeable future, administrators handling cross-border allegations will need to work both playbooks rather than assume one substitutes for the other.

    As with contributor-role standards, where CASRAI originated the CRediT taxonomy in 2014 and the standard is now stewarded by NISO as ANSI/NISO Z39.104-2022, research integrity governance illustrates a broader pattern in research administration: originating bodies and enforcement bodies are frequently separate, and knowing which is which is a prerequisite for compliant practice.

  • Whose Responsibility Is It to Identify and Report Research Misconduct? UK and US Duties Explained

    Search interest in “whose responsibility is it to identify and report research misconduct” spikes around research-ethics coursework and institutional training, but the confusion it reflects is real and consequential. The honest answer is that whose responsibility it is to identify and report research misconduct depends on the role: the duty is shared, not singular, and it is formalised differently in the UK and the US. Principal investigators, co-authors, supervisors, peer reviewers, editors and institutional officers each hold a piece of the obligation, and neither UK nor US frameworks let any one of these roles opt out.

    This explainer sets out who owes a formal duty to report, which institutional office receives and manages that report, and what legal protection exists for the person who raises the concern.

    Who Carries the Individual Duty to Report?

    The starting point in both UK and US frameworks is that everyone involved in producing, reviewing or supervising research shares a duty of vigilance. A widely cited analysis of collaborative authorship, published in PMC (Helgesson et al., 2017), concludes that “every author shares the responsibility to be attentive to signs of misconduct” and is obliged to act if fraud or fabrication is suspected in a paper they co-author — co-authorship does not dilute individual accountability.

    In practice, the individuals expected to identify and escalate concerns include:

    • Principal investigators (PIs) — responsible for the conduct of their research programme and for acting on concerns raised by team members.
    • Co-authors and collaborators — expected to query irregularities in data, methods or results before a manuscript is submitted or published.
    • Supervisors of doctoral and early-career researchers — responsible for training on research standards and for reporting concerns about supervisees’ conduct.
    • Peer reviewers and journal editors — obliged under Committee on Publication Ethics (COPE) guidance to raise suspected fabrication, falsification or plagiarism (FFP) identified during review, rather than simply rejecting the manuscript.
    • Institutional Review Board / ethics committee members — responsible for flagging non-compliance with approved protocols.

    None of these roles constitutes the sole responsible party. That is the most common misconception behind the search query: there is no single “correct” answer among a multiple-choice list of individuals, because UK and US institutional policy assign the duty collectively.

    Institutional Duty: RIOs, Named Persons and Responsible Officers

    Once an individual raises a concern, formal responsibility shifts to a designated institutional office. The terminology and statutory basis differ between the UK and US, though the underlying model — an initial assessment, followed by a full investigation panel with external academic input — is similar in both systems.

    In the UK, the Concordat to Support Research Integrity (Universities UK, revised 2019) requires every signatory institution to have a published misconduct procedure and to designate a responsible individual — commonly titled the Named Person or Responsible Officer — to receive and triage allegations. UK Research and Innovation’s April 2025 guidance for research organisations goes further, requiring any organisation receiving UKRI funding to investigate allegations of research misconduct involving its staff or students, regardless of who funded the specific project in question. The UK Research Integrity Office (UKRIO) is not a statutory regulator; it is an independent advisory body that publishes a model procedure institutions can adopt or adapt.

    In the US, the equivalent office is the Research Integrity Officer (RIO), a role every institution receiving Public Health Service funding must designate under 42 CFR Part 93. The federal Office of Research Integrity (ORI), within the Department of Health and Human Services, oversees PHS-funded misconduct activity, defines fabrication, falsification and plagiarism (FFP) in federal regulation, and can review institutional findings on appeal.

    Aspect United Kingdom United States
    Sector-wide framework Concordat to Support Research Integrity (Universities UK, rev. 2019) 42 CFR Part 93 (HHS/PHS regulations)
    Designated institutional role Named Person / Responsible Officer Research Integrity Officer (RIO)
    Federal/national oversight body None statutory; UKRIO advises, UKRI mandates investigation for its grantees Office of Research Integrity (ORI), HHS
    Core definition used Fabrication, falsification, plagiarism and other serious deviations from accepted practice Fabrication, falsification, plagiarism (FFP) per 42 CFR §93.103
    Whistle-blower statute Public Interest Disclosure Act 1998 (amends Employment Rights Act 1996) Retaliation protections built into 42 CFR Part 93 institutional assurances

    Common Questions on Reporting Research Misconduct

    Who has the primary responsibility for investigating allegations of research misconduct?

    The host institution holds primary investigative responsibility, not the individual who raises the concern. A designated officer — the Research Integrity Officer in the US or the Named Person in the UK — triages the allegation, and a panel including external academic members conducts the full investigation if warranted.

    Who do you report research misconduct to?

    Concerns should go to the institution’s designated contact — typically the Research Integrity Officer, Named Person, or a supervisor/department head who escalates it formally. Many institutions also run confidential ethics or research-integrity hotlines for concerns raised anonymously.

    Who oversees research misconduct nationally?

    In the US, the Office of Research Integrity oversees PHS-funded misconduct activity on behalf of HHS. In the UK, no single statutory regulator exists; UKRIO provides advisory guidance and a model procedure, while UKRI mandates investigation as a funding condition for its grantees.

    What conduct counts as research misconduct under federal regulations?

    US federal regulation (42 CFR Part 93) defines research misconduct as fabrication, falsification, or plagiarism (FFP) in proposing, performing, or reviewing research, or in reporting results. Honest error and legitimate differences of scientific opinion are explicitly excluded.

    Whistle-Blower Protections: Reporting Without Retaliation

    Fear of retaliation is the most cited reason researchers stay silent about suspected misconduct, so both jurisdictions build legal protection into the reporting pathway.

    • UK: The Public Interest Disclosure Act 1998, which amends the Employment Rights Act 1996, protects workers who make a “protected disclosure” — including a reasonable belief that a legal obligation, such as a research or funding-body requirement, is being breached — from dismissal or detriment.
    • US: Institutions holding PHS funding must provide, as a condition of their assurance under 42 CFR Part 93, protection for complainants and witnesses against retaliation, and must diligently protect confidentiality where feasible during the assessment and inquiry stages.

    Institutional attribution practices also support accountability once an investigation is under way. Contributor role taxonomies used at submission — such as CRediT, which CASRAI originated in 2014 and which is now stewarded by NISO as ANSI/NISO Z39.104-2022 — make it easier for investigators to establish which named author was responsible for which specific contribution, rather than relying on blanket authorship credit. Research administrators building or reviewing misconduct procedures may find it useful to consult CASRAI’s overview of contributor role taxonomies and the individual CRediT roles alongside broader guidance on authorship standards.

    Implications for Research Administrators and Institutions

    For research administration offices, three practical implications follow from the shared-duty model:

    • Policy visibility matters as much as policy existence. The Concordat requires institutions not just to have a procedure but to publicise it to staff and the public — a written policy that nobody can find fails the spirit of Commitment 4.
    • Reporting channels need redundancy. Because responsibility is distributed across PIs, supervisors, co-authors and reviewers, a single named contact is not enough; institutions typically also need a confidential hotline route and a clear escalation path via department heads.
    • Investigation and disciplinary process must stay separate. UKRIO and ORI guidance both stress that the misconduct investigation determines what happened; any resulting disciplinary action is a distinct, subsequent process, with its own procedural safeguards.

    Institutions that receive UKRI funding should also note that the funder’s own guidance, updated in April 2025, requires investigation of allegations against staff or students as a condition of the funding relationship — independent of whether the specific allegation concerns a UKRI-funded project.

    A Shared, Structured Duty

    There is no single office or job title that owns research misconduct reporting end to end. Individual researchers — PIs, co-authors, supervisors and reviewers — carry a front-line duty to notice and escalate; a designated institutional officer (Research Integrity Officer in the US, Named Person or Responsible Officer in the UK) carries the duty to receive, triage and investigate; and national bodies (ORI in the US; UKRIO advisory guidance and UKRI funding conditions in the UK) set the framework both operate within. As funders sharpen their compliance requirements — UKRI’s April 2025 guidance being the most recent UK example — institutions should expect the expectation of distributed accountability, not a single responsible party, to keep hardening rather than simplifying.

  • Procedure for the Investigation of Misconduct in Research: A Step-by-Step Committee Guide

    When a university receives a formal allegation of research misconduct, the committee handling it needs a defensible, evidence-based procedure for the investigation of misconduct in research — not an improvised process assembled under pressure. UK institutions have historically anchored their local policies to the UK Research Integrity Office (UKRIO) template procedure, most recently revised in 2023. That document has now been sunset: UKRIO published a replacement, the Detailed Procedure for Investigating Breaches of Research Integrity, in December 2025, alongside long-standing US practice codified by the Office of Research Integrity (ORI). This guide synthesises both models into one practical procedure — covering intake, inquiry, formal investigation and reporting — that institutional committees can apply directly.

    What Counts as Research Misconduct

    Most frameworks converge on a common core: fabrication, falsification and plagiarism (FFP). ORI applies this narrow FFP definition when it proposes federal findings against researchers funded by the US Public Health Service. UK practice, shaped by the Concordat to Support Research Integrity (Universities UK), is broader.

    UK institutional policies typically also capture:

    • Mismanagement of conflicts of interest that were not properly declared
    • Breach of duty of care to research participants, patients or animals
    • Misrepresentation of involvement, including ghost or guest authorship
    • Improper handling of a misconduct allegation itself, including victimising a whistleblower

    Committees should confirm which definition their institutional policy uses before opening a case. Scope decisions made at intake determine whether a matter proceeds as misconduct, as poor research practice, or as a contributorship dispute better resolved through clearer role attribution.

    The Procedure at a Glance: Four Phases from Intake to Report

    Institutional procedures differ in their exact labels but converge on the same underlying logic. The table below maps UKRIO terminology against the ORI model used across US federally funded research.

    Generic phase UKRIO term ORI (US) term Core purpose
    1. Intake Receipt of Allegations Allegation Log the complaint and confirm it falls within scope and jurisdiction
    2. Screening Assessment Inquiry Establish whether there is a prima facie case warranting full investigation
    3. Formal investigation Investigation Investigation Panel-led evidentiary examination, typically with an external member
    4. Outcome Outcome / Report Investigation Report / adjudication Findings, sanctions and correction of the research record
    5. Appeal Appeal (institution-specific) Institutional and federal oversight review Review of process fairness and proportionality of any sanction

    Step-by-Step: Running Each Phase

    The sequence below reflects UKRIO’s revised phase structure and ORI’s assessment-inquiry-investigation model, condensed into a working checklist committees can follow.

    Phase 1: Intake and Initial Screening

    The designated Research Integrity Officer or Named Person logs the allegation in writing, confirms it concerns research conducted under the institution’s auspices, and checks it is not vexatious, out of time, or already covered by another process such as a student misconduct or HR grievance procedure. Both the respondent and complainant are typically notified that a review has opened.

    Phase 2: The Inquiry (Preliminary Assessment)

    A small screening panel gathers initial evidence — underlying data, correspondence, relevant publications — to decide whether a prima facie case exists. This is a fact-finding exercise, not a determination of guilt. Many cases close here because the conduct reflects honest error or a legitimate difference of scientific opinion rather than misconduct.

    Phase 3: The Formal Investigation

    If the inquiry finds sufficient grounds, a Formal Investigation Panel is convened, usually including at least one member external to the institution. The panel interviews the complainant, respondent and witnesses, scrutinises data and lab records, and applies the balance-of-probabilities standard used across UK and most US institutional procedures.

    Phase 4: Outcome, Reporting and Correcting the Record

    The panel issues a written report: allegations upheld, partially upheld, or not upheld. Where misconduct is confirmed, action can include disciplinary sanctions, retraction or correction of affected publications, and notification of co-authors, journals, funders and, where relevant, professional or regulatory bodies.

    Phase 5: Appeal

    Most institutions allow an appeal limited to procedural irregularity, new evidence, or disproportionate sanction, heard by a senior figure with no prior involvement in the case. The appeal outcome is normally final at institutional level, though funders such as UKRI may separately review an institution’s handling of a case tied to their funding.

    Answer-First: Committee FAQs

    What are the phases of a research misconduct allegation?

    Most procedures run through four to five phases: intake (logging and scoping the allegation), inquiry or assessment (checking for a prima facie case), formal investigation (panel-led evidence review), and outcome and reporting, followed by an optional appeal stage.

    What is the first phase in response to a research misconduct allegation?

    The first phase is intake, sometimes called Receipt of Allegations. A designated Research Integrity Officer logs the complaint in writing, confirms it falls within the institution’s jurisdiction and definition of misconduct, and notifies the respondent before any evidence review begins.

    Who investigates allegations of research misconduct?

    The employing or funding institution investigates in the first instance, usually through a Formal Investigation Panel including an external member. Bodies such as UKRIO and ORI provide advice and procedural frameworks but do not typically run individual case investigations themselves.

    Whose responsibility is it to identify and report research misconduct?

    Reporting is a shared duty. Principal investigators, co-authors, reviewers, students and professional staff must raise good-faith concerns, usually to a named Research Integrity Officer. Institutional policies typically protect whistleblowers from retaliation once a concern is raised honestly.

    Roles, Prevention and Governance Implications

    Investigation procedures are remedial — they respond after harm has occurred. Prevention is cheaper and protects institutional reputation long before a case reaches a panel. Evidence-based measures include mandatory research integrity training at induction and supervision milestones, data management plans reviewed at project setup, and clear contributor-role disclosure on every output.

    Authorship disputes are a recurring trigger for misconduct allegations. Transparent attribution of who did what — using a structured framework such as the CRediT contributor role taxonomy, which CASRAI originated in 2014 and which is now stewarded by NISO as ANSI/NISO Z39.104-2022 — reduces the ambiguity that often escalates into a formal complaint. Institutions embedding role transparency into their research administration workflows give committees clearer evidence to work with if a dispute does arise.

    The governance stakes are rising. UKRI’s April 2025 guidance for research organisations ties funder confidence directly to the robustness of an institution’s misconduct procedure, and poorly documented cases increasingly surface in funder audits and, where publications are affected, in retraction and correction notices tracked by services such as Retraction Watch. Committees that document each phase properly do more than defend individual decisions on appeal — they protect the institution’s standing with funders and publishers.

    Looking ahead, expect UKRIO’s December 2025 Detailed Procedure and equivalent US federal guidance to keep converging on shared definitions, external panel membership and proportionate, documented outcomes. Institutions that update their local policy to reference the current UKRIO and ORI models now, rather than after their next case, will be better placed to run a fair, defensible investigation when an allegation lands.

  • ORI Research Misconduct Policy: 2026 Annual Assurance Renewal Explained

    The ORI research misconduct policy that governs Public Health Service (PHS)-funded research changed materially for 2026, and the annual paperwork cycle that keeps an institution’s assurance active has not paused to accommodate the transition. Every institution that holds a PHS assurance under 42 CFR Part 93 — whether or not it has an open case — must file its Annual Report on Possible Research Misconduct between 1 January and 30 April 2026, and for the first time that filing sits alongside a revised regulatory framework institutions are expected to have already adopted.

    This is a mechanics piece, not a restatement of the Final Rule’s substance. It sets out exactly what the U.S. Department of Health and Human Services’ Office of Research Integrity (ORI) expects institutions to submit for the 2026 assurance renewal cycle, which form to use, and where the transition from the 2005 regulation creates procedural traps for research integrity officers (RIOs) and sponsored-programs staff.

    What changed: the Final Rule and the 2026 effective date

    ORI’s revised Public Health Service Policies on Research Misconduct — published in the Federal Register on 17 September 2024 and codified at 42 CFR Part 93 — took effect on 1 January 2026. It is the first substantive rewrite of the misconduct regulation since 2005, and it introduces more than twenty-five newly defined terms, including “institutional record,” “administrative record,” “intentionally,” and “recklessly,” aimed at tightening consistency across institutional proceedings.

    The core three-part definition of research misconduct is unchanged: fabrication, falsification, or plagiarism (FFP) that represents a significant departure from accepted practices of the relevant research community, committed intentionally, knowingly, or recklessly, and proven by a preponderance of the evidence. What has changed is procedural detail — respondent comment rights on draft investigation reports, record-retention protocols, and interim-action notification triggers are now spelled out in greater depth.

    Critically, the Final Rule is not retroactive. Allegations received before 1 January 2026 continue to be handled under the 2005 version of Part 93 unless the institution and the respondent agree in writing to proceed under the new rule. Institutions running dual-track proceedings across the transition need to document, case by case, which regulatory version applies.

    Who must file an assurance renewal, and via which form

    Any institution that receives PHS-supported research funds — including awards from NIH, CDC, FDA, HRSA, and other PHS agencies — must maintain an active research misconduct assurance with ORI. Once an assurance is established, the institution is obligated to file annually, regardless of whether it received any misconduct allegations that year.

    • Form: Annual Report on Possible Research Misconduct, Form PHS-6349, submitted through ORI’s online Annual Report system (ARPRM).
    • Filing window: 1 January through 30 April each calendar year, covering the prior calendar year’s activity.
    • 2026 deadline: 30 April 2026, covering the reporting period 1 January–31 December 2025.
    • No-activity institutions: institutions with no PHS-supported research or no allegations in the reporting period may still owe a report; small or inactive institutions should confirm with ORI’s Assurance Program whether a Small Institution or no-activity statement applies to their circumstances.
    • Access: ORI’s Annual Report system now requires two-factor authentication (2FA) — institutions should confirm their registered email with the Assurance Program ([email protected]) well before the deadline to avoid last-minute access issues.

    The 2026 assurance renewal checklist

    Beyond the Form PHS-6349 filing itself, 2026 is unusual because institutions are also expected to have brought their internal policies and procedures into alignment with the new 42 CFR Part 93 requirements. ORI published a Sample Policies and Procedures document in June 2025 specifically to help research integrity officers, compliance staff, and institutional counsel update their templates ahead of the 1 January 2026 effective date.

    Item 2005 rule (pre-2026 cases) 2026 Final Rule
    Effective date 16 June 2005 1 January 2026
    Defined terms in 42 CFR Part 93 Baseline set 25+ additional defined terms
    Applies to allegations received Before 1 Jan 2026 (default) From 1 Jan 2026 onward, or earlier by written agreement
    Annual Report on Possible Research Misconduct Form PHS-6349, Jan–Apr window Unchanged: Form PHS-6349, Jan–Apr window
    Institutional policy alignment N/A Sample Policies and Procedures released June 2025

    Institutions preparing their 2026 renewal should treat the filing as a two-part exercise: (1) submit Form PHS-6349 through ARPRM by 30 April 2026 for the 2025 reporting year, and (2) confirm that the policies and procedures referenced in that assurance actually reflect the post-1-January-2026 regulatory text, not the 2005 language many institutional websites still carry. ORI’s own research administration compliance guidance and case-summary archive remain useful references for RIOs benchmarking their inquiry and investigation timelines against the 60-day inquiry and 120-day investigation targets that persist in the revised rule.

    Frequently asked questions

    What is the deadline for the ORI 2026 annual assurance renewal?

    Institutions holding a PHS research misconduct assurance must file the Annual Report on Possible Research Misconduct (Form PHS-6349) between 1 January and 30 April 2026, covering research misconduct activity from the 2025 calendar year, via ORI’s online ARPRM system.

    Which institutions must maintain an ORI research misconduct assurance?

    Any institution receiving Public Health Service-supported research funds — from NIH, CDC, FDA, or other PHS agencies — must hold an active assurance under 42 CFR Part 93 and file annually, even in years with no reported allegations.

    Does the new ORI Final Rule apply retroactively to open cases?

    No. Allegations received before 1 January 2026 are handled under the 2005 version of 42 CFR Part 93 by default, unless the institution and respondent agree in writing to proceed under the revised rule instead.

    What form and system do institutions use to submit their annual report?

    Institutions submit Form PHS-6349 through ORI’s Annual Report on Possible Research Misconduct system (ARPRM), which now requires two-factor authentication tied to the institution’s registered email address.

    Implications for research administrators

    The overlap between the Final Rule’s 1 January 2026 effective date and the routine 30 April annual report deadline compresses an already tight compliance calendar. Research integrity officers now need to reconcile three separate obligations in the same window: filing the standard annual report, confirming that institutional policies match the revised regulatory text, and correctly classifying any pending allegation as either a 2005-rule case or a 2026-rule case for procedural purposes.

    ORI’s most recent published Annual Report, covering 2024 activity, recorded 713 allegations of possible research misconduct and 117 new cases opened that year, with 38 cases carried over from prior years — a caseload that gives some sense of scale for institutions weighing how much internal capacity to dedicate to inquiry and investigation infrastructure under the tightened procedural clock.

    • Audit institutional policy language against ORI’s June 2025 Sample Policies and Procedures document before certifying compliance in the 2026 assurance filing.
    • Tag open cases by intake date to determine which regulatory version (2005 or 2026) governs each proceeding.
    • Confirm ARPRM account access and two-factor authentication setup well ahead of the 30 April deadline — do not wait for filing week.
    • Brief institutional review boards and legal counsel on the expanded defined terms, particularly “recklessly” and “intentionally,” which affect how misconduct findings are documented.

    Looking ahead

    The 2026 cycle is likely to be the messiest transition year institutions face under 42 CFR Part 93 for some time: two regulatory regimes running in parallel, a compressed policy-update timeline, and an unchanged annual filing deadline that does not care which rule applies to a given case. Institutions that treat the 30 April 2026 Form PHS-6349 submission purely as a data return — rather than as an opportunity to verify their underlying policies actually match the current regulation — risk finding gaps only when ORI reviews a proceeding. Research administrators tracking related standards work, including contributor-role and authorship frameworks referenced in misconduct findings, can cross-reference CASRAI’s CRediT contributor role and authorship resources when documenting responsibility in a research record.