Research Integrity Policy

II. Definitions

Allegation: a disclosure of possible research misconduct through any means of communication.
Complainant: an individual or entity who brings forth an allegation of research misconduct in good faith
Committee on Research Integrity (CRI): A standing university committee, at least five (5) senior faculty appointed for defined terms of service, which evaluates and adjudicates cases of alleged research misconduct against staff, students, trainees, postdoctoral appointees, and/or faculty members. The CRI determines whether, based on a preponderance of the evidence, research misconduct has occurred and recommends what, if any, corrective actions and sanctions are warranted.
Conflict of interest: financial, personal or professional relationships which may compromise, or appear to compromise an individual’s decisions.
Evidence: any document, tangible item, or testimony offered or obtained during a research misconduct proceeding, including the research record, which tends to prove or disprove the existence of an alleged fact.
Fabrication: making up data or results and recording or reporting them.
Falsification: manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the research record.
Good faith: having a belief in the truth of one’s statements such that a reasonable person in the same position could have, based on the information known to one at the time. Examples include: (i) An allegation is not made in good faith if made with knowing or reckless disregard or willful ignorance of certain facts that would disprove said allegation; (ii) Good faith as applied to a committee member means cooperating with the purpose of helping the institution meet its responsibilities regarding investigation of allegations of research misconduct.
Plagiarism: the appropriation of another person’s ideas, processes, results, or words without giving appropriate credit.
Preponderance of the evidence: proof by information that, compared with that opposing
it, leads to the conclusion that the fact at issue is more probably true than not.
Research: a systematic experiment, study, evaluation, demonstration, or survey designed to develop or contribute to general knowledge (basic research) or specific knowledge (applied research).
Research Integrity Inquiry Panel (RIIP): An ad hoc group of faculty appointed by the Research Integrity Officer in response to a specific allegation of research misconduct, which conducts an initial unprejudiced preliminary evaluation of the available facts and circumstances underlying the allegations. The RIIP will determine (a) whether or not the conduct, if it did occur, would constitute research misconduct, and (b) whether there is sufficient evidence of the alleged misconduct to warrant a full investigation. The RIIP does not make a determination as to whether the research misconduct occurred.
Research Integrity Officer (RIO): The RIO is a senior faculty member with a standing appointment by the Vice Chancellor for Research, who has primary responsibility fornimplementing Washington University’s policies and procedures on research misconduct as outlined herein. The RIO also serves as the nonvoting Chair of the Committee on Research Integrity for all research misconduct proceedings. The RIO also
assists all members of the Washington University community to comply with applicable policies, laws, and regulations related to research misconduct proceedings.
Research misconduct: see introduction section
Research record: the record of data or results that embody the facts resulting from scientific inquiry, including but not limited to primary research material, research proposals, laboratory records (physical and electronic), research animals, images, machines and equipment, progress reports, abstracts, theses, oral presentations, internal reports, journal articles, correspondence.
Respondent: the person against whom an allegation of research misconduct is directed or who is the subject of a research misconduct proceeding.
Retaliation: an adverse action taken against an individual involved in a research misconduct proceeding, including but not limited to, complainant, witness, or committee member, by a member of the WU community in response to a good faith allegation of research misconduct or good faith cooperation with a research misconduct investigation.

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

IV. Rights and Responsibilities
Individuals covered by this policy shall act in good faith during their involvement in the research misconduct proceedings as well as promptly provide all requested available materials and maintain strict confidentiality of the proceedings. A complete list of each individual’s rights and responsibilities is available at: http://research.wustl.edu/ComplianceAreas/ResearchIntegrity/Pages/default.aspx.
V. Allegations
All members of the Washington University community are expected to report observed, suspected, or apparent research misconduct. All allegations of research misconduct from sources inside or outside the university will be considered. An individual should direct an allegation of research misconduct to the Research Integrity Officer (RIO), the Research Ethics and Compliance Office (RECO), or the Vice Chancellor for Research. An individual can also direct an allegation to deans, department heads, division chiefs, or as directed by the Washington University Code of Conduct. Any member of the Washington University community who receives an allegation of research misconduct shall promptly forward it to the RIO. If an individual is concerned about possible research misconduct or is unsure whether an incident qualifies as research misconduct, he or she may contact the RIO or the RECO to discuss the suspected misconduct informally and confidentially. Individuals are encouraged to submit allegations of research misconduct in writing so as to assure a clear understanding of the issues raised, although allegations may be made orally. Anonymous allegations are acceptable; however, sufficient detail and/or corroborating evidence must be provided to determine whether an inquiry should be initiated. Allegations should be made based on factual issues and provide specific information when possible. An allegation should include:
1. The name(s) of the respondent, if known;
2. A brief summary of the circumstances surrounding the complaint,
3. A description of each allegation.

All individuals are expected to act in good faith when making allegations of research misconduct and while cooperating with research misconduct proceedings. In the event that allegations of research misconduct are made in bad faith or research misconduct proceedings are materially impeded by any member of the Washington University community, including but not limited to the respondent or complainant, the dean of the appropriate school shall impose sanctions subject to the limitations set forth within Section VIII.E. Investigations of research misconduct will not be initiated if the alleged activity occurred more than 6 years in the past. If the alleged activity began more than 6 years in the past, but continued into the 6 year period, it will be reviewed.

VI. Organizational Structure
A. The Vice Chancellor for Research shall appoint a Research Integrity Officer (RIO), who holds the primary responsibility for implementing Washington University’s policies and procedures on research misconduct as outlined herein. The RIO shall serve as the nonvoting chair of all research misconduct proceedings and assist all members of the Washington University community to comply with applicable policies, laws, and regulations related to research misconduct proceedings.
B. Committee on Research Integrity (CRI): The CRI works in conjunction with Washington University’s RIO to administer cases of alleged research misconduct
1. At the School of Medicine, the Vice Chancellor for Research, with approval from the Dean of the School of Medicine, shall appoint a standing committee of at least five (5) senior faculty members appointed at the School of Medicine, known as the Committee on Research Integrity (CRI). One member must be a basic research department head and one, a clinical department head, and the remaining members must be faculty, who are not department heads. This committee administers cases of alleged research misconduct
against staff, students, trainees, postdoctoral appointees, and/or faculty members with primary appointments at the School of Medicine.
2. At the Danforth Campus, the Vice Chancellor for Research, with approval from the applicable Dean, shall appoint a standing committee of at least five (5) senior faculty members, known as the Committee on Research Integrity (CRI) from the following schools:
Arts & Sciences, School of Engineering & Applied Science and the Brown School. Ad hoc
members from the remaining Schools at the Danforth Campus may be appointed by the RIO to ensure the membership of the CRI has the proper expertise during the research misconduct proceedings. This committee administers cases of alleged research misconduct against staff, students, trainees, postdoctoral appointees, and/or faculty members with primary appointments in the Schools at the Danforth Campus.
3. Appointments of the CRI members shall be for staggered three-year terms, which are renewable. The VCR will take into consideration a faculty member’s research
portfolio, rank, expertise, and years of experience when appointing these individuals to the CRI.
4. The Executive Chair of the Institutional Review Board (IRB) will serve as a voting ex officio member of the RIIP and the CRI f or all allegations of research misconduct that involve knowing violations of federal or institutional rules and regulations governing the conduct of research involving human research participants that are serious or continuing.
5. In a case involving alleged misconduct by (1) an individual who holds a joint appointment in two schools of the university, (2) an individual who holds a prime appointment in one school, but is collaborating with a faculty member from another school of the university, or (3) a student enrolled in a program that crosses school lines, the RIO shall determine which CRI will take jurisdiction over the case taking into consideration the respondent’s prime appointment and where the research was conducted.
C. The Vice Chancellor for Research shall be responsible for providing appropriate expertise and administrative support to the RIO and the CRI, additional expenses incurred as a direct result of the investigation will be allocated to the school of the respondent’s primary appointment. The Research Ethics and Compliance Office (RECO) has been delegated the responsibility to provide administrative support for all research misconduct proceedings at Washington University and to assist the Vice Chancellor for Research and the RIO in responding to allegations of research misconduct. A member of the RECO shall be present at all meetings, interviews, and other proceedings regarding allegations of research misconduct.
VII. Confidentiality
All those participating or involved in research misconduct proceedings shall not disclose
or discuss any information regarding the allegations, the proceedings, or the identity of
individuals involved in the proceedings except as necessary to the proper discharge of their responsibilities hereunder and as required by law.
VIII. Inquiry and Investigation
A. Initial Review of an Allegation
1. Upon receiving an allegation of research misconduct, the RIO will immediately assess the allegation to determine whether it:
a. Falls within the definition of research misconduct and
b. Is sufficiently credible and specific so that potential evidence of research misconduct may be identified.
2. Absent a finding by the RIO that the complaint is frivolous or insubstantial on its face or does not allege an instance of research misconduct, the RIO will promptly initiate the inquiry process.
B. Sequestering and Handling of Evidence At any point during an inquiry or investigation, evidence may be obtained and/or sequestered. The RIO will, in good faith, take all reasonable and practical steps necessary to obtain custody, inventory, and secure all original evidence (physical and electronic) relevant to the allegation including, but not limited to, research proposals, laboratory records, protocols, images, specimens, machines and equipment, abstracts, theses, oral presentations, internal reports, journal articles, and correspondence. All available material identified as relevant to the allegation
shall be promptly provided. The lack of research records adequately documenting the questioned research is evidence of research misconduct where it is established by a preponderance of the evidence that the respondent:
1. Intentionally, knowingly, or recklessly had research records and destroyed them,
2. Had the opportunity to maintain the records but did not do so, or
3. Maintained the records and failed to produce them in a timely manner. Upon request and where appropriate copies of the sequestered evidence will be provided to the respondent except for materials not amenable to copying or the respondent will be given reasonable, supervised access to the sequestered evidence. Copies of sequestered evidence will also be provided upon request to the individual(s) who provided the original material to the RIO except for materials not amenable to copying. All reasonable steps, consistent with time constraints and other obligations imposed by federal regulations, shall be taken to eliminate or minimize any disruption that might be created for ongoing research efforts by such requirements to produce documentation. Individuals involved in the securing of evidence relevant to the allegation shall not discuss or disclose the request with anyone outside of the official proceedings, without approval from the RIO, RECO, or
the VCR. At the conclusion of and dependent upon the outcome of the proceedings, sequestered evidence will be returned as appropriate. Records of research misconduct proceedings, including the evidence, will be maintained by the Office of the Vice Chancellor for Research in a secure manner for seven (7) years after completion of university proceedings or, when related to PHS funds, the completion of any PHS proceedings involving the research misconduct allegation.
C. Inquiry Process
The inquiry, which is the responsibility of the RIIP, is an unprejudiced preliminary evaluation of the available facts and circumstances underlying the allegations to determine if a full investigation is warranted.
1. To initiate the inquiry process, the RIO will:
a. Appoint a Research Integrity Inquiry Panel (RIIP). The RIIP shall consist of at least two (2) members: the RIO and a standing member of the CRI. The RIO may also solicit assistance from an appropriate individual (senior faculty member or nonfaculty scientist from within or outside the university) with requisite scientific expertise in the relevant field. This individual will become an ad hoc voting member of the CRI. RIIP members shall be carefully selected in order to minimize either the substance or the appearance of personal or professional conflicts of interest. No member of the RIIP will be assigned to an allegation involving his or her own department (small departments) or division (large departments). All RIIP members will continue to serve as members of the CRI for the duration of the case in question. The respondent will be notified of the names of the CRI members and any ad hoc members and will be provided an opportunity to voice concerns regarding any potential conflicts of interest.
b. Provide written notice to the respondent. The notification will include a description of all allegations of research misconduct made against the respondent along with an explanation and documentation of the university’s policies in regard to allegations of misconduct including the respondent’s rights and responsibilities. The respondent will also be notified the university will not tolerate acts of retaliation against any individual participating in a research misconduct proceeding. If evidence or allegations of additional issues arise during the RIIP process, the RIO will provide written notice of the RIIP’s intention to broaden its inquiry to the implicated individuals, appropriate dean, Vice Chancellor for Research, and appropriate department head.
c. At the time or before the RIO notifies the respondent, the RIO shall:
i. Sequester all records and evidence relevant to the allegation, as described in Section VIII.B.
ii. Notify the Vice Chancellor for Research, the respondent’s department head, and the dean of the respondent’s school of all allegations of research misconduct and the initiation of the inquiry process.
2. The RIIP will review the evidence and conduct interviews of the complainant, the respondent, and any other key witnesses the RIIP may consider necessary to its inquiry. At this stage the complainant’s name may be kept confidential, but s/he will be made aware that as the process moves forward, the complainant’s identity may have to be revealed in order to afford the respondent a full and fair opportunity to respond to the allegations.
3. All interviews conducted by the RIIP will be transcribed by a certified court reporter. Each interviewee will be provided with a copy of the transcript and given five (5) days to review the transcript of their interview(s) for accuracy. Changes to the transcript are limited to factual errors. Additional comments or information may be provided in a separate document. The final corrected versions of all transcripts will be part of the official record of the misconduct proceedings.
4. The respondent may have an attorney or other individual present at all meetings, interviews, and other proceedings with the RIIP to act as an adviser. This individual will not be permitted to actively participate in the proceedings and will be required to channel all communications with the RIO, CRI, RIIP, and/or any members thereof through the Office of the Executive Vice Chancellor and General Counsel.
5. During the inquiry, the RIIP will diligently pursue all significant issues, leads, new allegations of research misconduct as well as complaints of retaliation.
6. The RIIP will determine by a preponderance of the evidence (a) whether or not the conduct, if it did occur, would constitute research misconduct, and (b) whether there is sufficient evidence of the alleged misconduct to warrant a full investigation.
7. The RIIP will generate a draft written report of its inquiry and recommendations for further action. The report will include, but may not be limited to, the following elements:
a. The name and position of the respondent;
b. A description of the allegations of research misconduct;
c. The research support related to the allegation;
d. The institutional policies and procedures under which the inquiry was conducted;
e. The basis for recommending whether or not the alleged actions warrant a full investigation.
8. The RIO shall promptly submit to the respondent a written draft RIIP report. The respondent shall be allowed five (5) working days from receipt of the draft RIIP report to comment on the report. Based on the comments received, the RIIP will revise the report as appropriate and will then generate the final RIIP report. Any and all comments submitted by the respondent shall be made a part of the final RIIP report and will then be submitted to the CRI for review and determination.
9. Conclusion of Inquiry
a. Prior to receiving the final RIIP report, the CRI will be notified in writing of the allegations of research misconduct and the respondent’s identity. Members shall notify the RIO in writing of any actual or potential, personal or professional, conflicts. The RIO may also determine whether any person involved in handling an allegation of research misconduct has an unresolved personal, professional, or financial conflict of interest and take appropriate action, including recusal, to ensure that no person with such conflict is involved in the research misconduct proceeding;
b. After review of the final RIIP report including the recommendations whether to proceed to a full investigation or to dismiss the allegations, the CRI shall, by majority vote, decide whether to accept or reject the recommendations of the RIIP and thus whether to initiate an investigation or dismiss the allegations. During its determination, the CRI may also address any additional issues identified by the RIIP, if applicable. The RIO shall then notify the respondent, the Vice Chancellor for Research, and the dean of the respondent’s school of the determination of the CRI and provide each with a copy of the final RIIP report. The respondent’s department head will be notified in writing of the determination of the CRI.
c. If the CRI determines an investigation is not warranted, the allegations are dismissed. In the event that the allegations are dismissed, the Office of the Vice Chancellor for Research shall maintain documentation in sufficient detail to permit a later assessment of the reasons why the CRI decided not to conduct an investigation.
d. If the CRI determines there is sufficient basis to warrant an investigation, a prompt and thorough investigation into the allegation shall be initiated by the CRI within thirty (30) calendar days of the completion of the inquiry.
10. Absent extraordinary circumstances, the inquiry shall be completed within sixty (60) calendar days of the initiation of the inquiry. The inquiry may extend beyond sixty (60) calendar days only with a written request by the RIO and the written approval of the Vice Chancellor for Research. If granted, the reason for any extension must be documented in the official record and noted in the final RIIP report. The RIO will provide written notification to the respondent and any other individuals, as appropriate, if there is an extension.
D. Investigation Process
An Investigation, which is the responsibility
of the CRI, includes an examination of all relevant evidence and interviews with all individuals involved to determine whether research misconduct has occurred and to recommend what, if any, corrective actions and sanctions are warranted.
1. An investigation is initiated by the RIO by:
a. Providing notice to the respondent. The notice will include a description of all allegations that will be investigated. The CRI will diligently pursue all significant issues and leads that are determined to be relevant. If evidence or allegations of additional issues, the RIO will provide written notice of the CRI’s intention to broaden its investigation to the respondent, other implicated individuals, appropriate dean, Vice Chancellor for Research, and appropriate department head.
b. Sequestering any additional evidence relevant to the allegations, as described in Section VIII.B.
c. Designating an expert in the respondent’s field to assist the CRI in its investigation, if additional expertise is required. This individual will become an ad hoc voting member of the CRI for the duration of the proceedings. The respondent will be notified of any additional appointments to the CRI occurring in the investigation phase.
2. Within 30 days of the CRI determination that an investigation is warranted, or at any other time as required by federal regulations, external research sponsors and regulatory agencies shall be informed of the research misconduct proceedings by the Vice Chancellor for Research in accordance with applicable laws, regulations, and rules. Upon request, and as required by law, the Vice Chancellor for Research will also provide a copy of the final RIIP report, evidence reviewed, transcripts of any interviews, and copies of all relevant documents. See VIII.G for other notifications related to an investigation.
3. The CRI will make a good faith effort to determine the scope/extent of the misconduct and whether there is evidence of other instances of research misconduct related to any other research with which the individual is involved.
4. All interviews conducted by the CRI will be transcribed by a certified court reporter, as outlined in Section VIII.C.3.
5. The respondent shall be permitted to have an attorney or other individual present to the same extent specified under Section VIII.C.4.
6. The CRI’s responsibility is to determine whether, based on a preponderance of the evidence, research misconduct has occurred and to recommend what, if any, corrective actions and sanctions are warranted. By majority vote, the CRI shall decide whether to dismiss the allegation of research misconduct or make a determination that research misconduct occurred. The determination need not be unanimous.
7. The CRI will generate a draft report of its investigation, determinations, and recommendations for further action, if any. The report may also set forth recommendations as to the appropriate sanctions and/or corrective actions and will include, but may not be limited to, the following elements:
a. Description of the nature of the allegations of research misconduct;
b. Description of the research support related to the allegations of research misconduct;
c. Description of the specific allegations of research misconduct for consideration in the investigation;
d. Policies and procedures under which the investigation was conducted.
e. Identificationand summary of the research records and evidence reviewed, and identify any evidence taken into custody but not reviewed.
f. For each separate allegation of research misconduct identified during the investigation, provide a finding as to whether research misconduct did or did not occur, and if so:
i. identify whether the research misconduct was falsification, fabrication, or plagiarism, and if it was intentional, knowing, or in reckless disregard;
ii. Summarize the facts and the analysis which support the conclusion and consider the merits of any reasonable explanation by the respondent;
iii. Identify the specific research support;
iv. Identify whether any publications need correction or retraction;
v. Identify the person(s) responsible for the misconduct; and
vi. List any current support or known applications or proposals for support that the respondent has pending with non-PHS Federal agencies.
8. The RIO shall promptly submit to the respondent the draft report as well as copies of, or supervised access to, the evidence on which the report is based. The respondent shall be allowed five (5) working days from receipt of the draft report to provide comments on the report. Based on the comments received, the CRI will revise the report as appropriate and generate the final CRI report. Any and all comments submitted by the respondent will be made a part of the final report.
9. The RIO will provide a copy of the final CRI report to the respondent, the vice chancellor for research, and to the dean of the respondent’s school. The RIO will notify the respondent’s department head, in writing, of the outcome of the investigation. When the CRI determines research misconduct has occurred, the respondent’s department head will also be provided a copy of the final CRI report.
10. Absent extraordinary circumstances, the investigation shall be carried through to completion within one hundred twenty (120) calendar days. The investigation may extend beyond one hundred twenty calendar days only with the written approval of the Vice Chancellor for Research. If an extension is granted, the RIO will (a.) document the reason and terms of the extension in the final CRI report and the official record, (b.) notify the respondent and any other applicable parties in writing of an extension, (c) assist the Vice Chancellor for Research to provide periodic progress reports to any research sponsors as requested or as required by law. Additionally, requests for extending the investigations involving PHS funding must be submitted in writing to ORI for approval.

E. Final Disposition of the Proceedings
The appropriate dean, based on the respondent’s primary appointment, shall review the final CRI report, including the CRI’s recommended sanctions and/or corrective actions, and impose such sanctions and/or corrective actions as the dean considers appropriate under the circumstances, as described below:
1. Imposition of sanctions related to a finding of research misconduct:
a. If the CRI determines that research misconduct has occurred, the respondent shall be given an opportunity to present to the dean, in person or in writing (as the respondent may elect), any facts or considerations the respondent believes should be taken into account in the determination of appropriate sanctions within five (5) calendar days after the RIO forwards the final CRI report as described in section VIII.D.9. The dean shall impose sanctions as appropriate, no later than thirty (30) calendar days and no earlier than five (5) calendar days after the RIO forwards the final CRI report, subject to the following exceptions:
i. Should the dean recommend termination of appointment of a faculty member with tenure, or of a nontenured faculty member prior to the end of a current term of appointment, a proceeding shall be instituted by the university before the Hearing Committee, in accordance with Section IX. of the Washington University Policy on Academic Freedom, Responsibility, and Tenure. The Hearing Committee shall review the reports of the RIIP and CRI and related documentation and may hear such additional relevant, noncumulative testimony as it deems necessary.
ii. The dean shall impose sanctions against a student in accordance with the University Student Judicial Code or other relevant policies of the student’s school.
b. In cases involving PHS funding, the vice chancellor for research shall assist in administering and enforcing any HHS administrative actions imposed on members of the institution
2. Imposition of corrective actions in the absence of a finding of research misconduct
a. Absent a finding of research misconduct, the CRI may recommend corrective actions to be completed by an individual. The dean will determine if any corrective actions should be completed. Corrective actions may include, but are not limited to, formal education in the responsible conduct of research, monitoring and/or oversight of research projects, or the addition of research team members with specific qualifications.
3. The dean may delegate the imposition of sanctions and/or other corrective actions to the department head and/or the VCR, who will require the respondent or other individuals, as appropriate, to fulfill corrective measures as deemed necessary.

F. Other Actions and Notifications
1. The Office of the Vice Chancellor for Research shall keep individuals or entities outside of the university, including but not limited to, collaborating scientists, other institutions, and journal editors informed of any outcomes on a need-to-know basis.
2. The Research Integrity Officer shall keep individuals within the university, including but not limited to, witnesses and collaborating scientists, informed of any outcomes on a need-to-know basis.
3. If the CRI dismisses the allegation of research misconduct for any reason, the RIO, the vice chancellor for research and the respondent’s dean will make diligent efforts to restore the respondent’s reputation.
4. From the time the CRI decides to initiate an investigation or at any other time as required by federal regulations, the vice chancellor for research shall keep external agencies informed regarding the status of research misconduct proceedings in accordance with applicable laws, regulations, and rules. The vice chancellor for research shall notify ORI immediately if (1) the health and safety of the public is at risk; (2) if HHS resources or interests are threatened; (3) if research activities should be suspended; (4) if federal action is required to protect the research misconduct proceedings; (5) if the alleged incident might be publicly reported; (6) if the research community or public should be informed; or (7) if reasonable indication of possible criminal violations is found.
5. The vice chancellor for research shall notify ORI prior to closing research misconduct proceeding prematurely for any reason, including but not limited to an admission of guilt by the respondent.
6. When an investigation involves PHS funding, the vice chancellor for research will provide to the Health and Human Services Office of Research Integrity (ORI) the following: the final CRI report, copies of research records and evidence reviewed, transcripts of any interviews, and copies of all relevant documents. The vice chancellor for research shall also notify the ORI of the sanctions and/or institutional actions imposed by the dean and will ensure full and continuing cooperation during the ORI’s oversight review as specified in federal regulations.

G. Admissions of Guilt
1. The CRI shall carry inquiries and investigations through to completion and pursue diligently all significant issues; however, if a respondent chooses to admit to all of the allegations of research misconduct against him/her, the CRI may close a case at the inquiry or investigation, on the basis that the respondent has admitted guilt. A written confession shall be prepared outlining each of the allegations of research misconduct, summarizing the evidence, and illustrating the elements of a finding of research misconduct:
a. There be a significant departure from accepted practices of the relevant research community; and
b. The misconduct be committed intentionally, knowingly, or recklessly; and
c. The allegation be proven by a preponderance of the evidence.
2. The Respondent will meet with the RIO and one or more CRI members to review the written confession. This meeting will be transcribed by a certified court reporter. The Respondent will be provided an opportunity to review the transcript, as outlined in Section VIII.C.3.
3. When all relevant issues are resolved, the written confession is signed by the Respondent. If a Respondent admits guilt for a portion of the allegations or all relevant issues are not able to be resolved, the RIIP/CRI will continue with the inquiry or investigation.
4. Prior to accepting an admission of guilt, the CRI will make a good faith effort to determine the scope/extent of the misconduct and whether there is evidence of other instances of research misconduct related to any other research with which the individual is involved.
5. For allegations involving PHS funded research, notification in advance of closing based on the admission of guilt will be submitted to the ORI for approval.

IX. Protection from Retaliation
The university is committed to and strongly believes in the importance of protecting all individuals from retaliation for his/her activities in cooperation with, or initiation of, research misconduct proceedings, provided, however, such activities were not
undertaken in bad faith . The university will not tolerate acts of retaliation, actual or perceived, against individuals participating in research misconduct proceedings. If any person involved in a research misconduct proceeding feels s/he has been adversely affected by retaliation, they should notify the RIO, RECO, CRI, or VCR immediately.

A. Administrative Review and Processes to Address Potential Retaliation
The RIO is responsible for taking reasonable and practical steps to protect all individuals from retaliation for his/her activities, as outlined in this policy. The RIO will provide written notice to the appropriate dean and department head, the vice chancellor for research, and other individuals as deemed necessary.

Based on observations and/or conversations with the individuals involved in the proceedings, including the CRI members, the RIO may determine administrative steps are needed to address any potential opportunities for retaliation. Administrative steps may include, but are not limited to, seeking intervention by Human Resources, discussions with the Department Head to develop actions to assure protection, consultation with OGC or other steps necessary to protect against retaliation. The RIO shall update the CRI on the steps taken to protect the individual.

November 4, 2010