Skip to main content

Institutional Assessment

The RIO has primary responsibility for conducting the Institutional Assessment and houses all related (complaint, materials, rationale, and any respondent response) and gathered records to ensure consistency, confidentiality, and integrity for a minimum of 7 years after case conclusion or as required by regulation. Informal requests for information or consultation with the RIO or other University entities don't constitute formal allegations and don't initiate these procedures. A complainant will have 60 days following the discovery of an alleged violation to file a complaint unless he or she can show good reason (as determined by the CRO) for having that deadline waived. Once a formal complaint is received, the purpose of the Institutional Assessment is to determine whether it meets the criteria of an allegation of research or scholarly misconduct and therefore warrants a formal inquiry.  The Institutional Assessment must be completed within 7 calendar days of receipt. A complaint advances to a formal inquiry only if it:

  • Should be characterized as an allegation (as opposed to an informal request for guidance);
  • The allegation involves a research or scholarly activity (see A);
  • Falls within the definition of research or scholarly misconduct(see Policy §III.B–C); and
  • Is sufficiently credible and specific to permit identification of potential evidence of misconduct.

1.     Any community member who becomes aware of possible research or scholarly misconduct must report it promptly by submitting a written complaint to the RIO or CRO within 60 calendar days of discovering the alleged violation or misconduct. The CRO may grant extensions for good cause, in consultation with the RIO. Any University official who receives a complaint must forward it immediately to the RIO.

2.     Upon receipt of a complaint alleging misconduct, the RIO shall conduct the Institutional Assessment. If the RIO is unavailable, the CRO may authorize the Dean of the relevant college to perform the assessment. If multiple colleges are implicated, the CRO may appoint a Dean to conduct a secondary assessment. Whether conducted by the RIO or a delegated Dean—the assessment must be completed within 7 calendar days of receipt of the complaint to determine if the complaint warrants a formal inquiry. The RIO will inform the respondent(s) of the alleged misconduct and, if the respondent(s) so desire(s), receive an account(s) or statement from the respondent(s).

3.     The preliminary review shall be conducted to preserve, insofar as possible, the confidentiality of the inquiries made and of the information gathered. The assessor may gather information beyond that submitted with the complaint and informally on a confidential basis confer with others in the university community as appropriate to determine whether a formal inquiry is warranted. The following measures may be taken by the assessor:

  • Review relevant materials (e.g., submissions, protocols, consent forms, data, and correspondence, etc.) and institutional records (e.g., training logs, disclosures, and protocol deviation reports) for related patterns.
  • Request clarification from the complainant or other affected individuals. Receive an account or statement from the respondent(s), if voluntarily provided. Consult subject-matter experts (e.g., IRB, compliance, legal) for scientific or regulatory insight.
  • To protect any research records relating to the alleged misconduct until all proceedings are complete, the CRO or RIO shall take the following interim administrative actions:
  • Obtain custody of all research records and evidence needed, inventorying them, and securely sequestering them to protect their integrity. If records or evidence involve shared instruments, custody may be limited to copies of data or evidence, provided copies are substantially equivalent in evidentiary value to the originals. Where appropriate, respondent(s) shall be given copies of, or reasonable, supervised access to the research records.
  • Implement interim measures (e.g., suspending activities, restricting access, providing support) to protect participants, sponsors, and research integrity, as necessary.
  • If research activities are externally sponsored, taking appropriate actions to protect sponsor funds and equipment and ensuring external funding purposes are carried out.
  • The CRO, RIO, Dean(s), and Provost shall undertake reasonable and practical efforts to alleviate any diminution of the reputation(s) of the respondent(s) and the complainant who made the allegation of misconduct, and to guard against retaliation by upholding fairness, impartiality, and respect throughout the process.

4. Conclusions:

  • A complainant may request withdrawal of the complaint at any time, provided the respondent(s) agree(s) to the withdrawal; However, if the allegation meets the criteria for misconduct and remains credible, the RIO will continue the process regardless of withdrawal.
  • If all formal allegation criteria are met, the complaint proceeds to the inquiry phase and a formal notification is made. The RIO notifies the complainant, respondent(s), and the relevant Dean in writing of the decision to proceed to inquiry. If Dean completes the assessment, the Dean immediately forwards the full assessment and supporting materials to the RIO who then notifies the complainant and respondent(s) in writing of the decision to proceed to inquiry.
  • If the complaintdoesn't meet formal-allegation criteria, because it does not involve a research or scholarly activity, falls outside the definition of research misconduct, or is not sufficiently credible and specific so that potential evidence of research misconduct may be identified, then the complaint will be referred to a different administrative process or be closed without further action. If a complaint is closed, then a record will be maintained with a confidential written report maintained by the RIO, CRO, or designee stating the reasonsthe complaint was closed. The written report will not be referenced or included in any personnel or other official record of either the complainant or of the respondent(s). The RIO will prepare a confidential dismissal report (retained for at least 7 years) and then notifies the complainant in writing of the determination that the complaint was closed. Prior to discontinuing the process, a written explanation must be documented. If applicable, this rationale must be shared with the appropriate federal and sponsoring entities in accordance with the terms and conditions of the associated award(s). In some instances, federal agencies may require the institution to proceed with the investigation or may elect to undertake their own reviews, as authorized by governing agency. The complainant(s) may appeal a dismissal to both the CRO and RIO within 10 business days, specifying the factual basis for reversing the decision, and submitting a written rationale for reconsideration. Appeal letters should be sent jointly to the CRO and RIO who will jointly review appeals and issue a final decision.

5. Upon conclusion, the respondent(s) has(have) the right to submit to their dean written comments concerning the preliminary review outcome, which comments will be attached and included thereafter with the preliminary review outcome.

6. Upon conclusion, the RIO will issue a written report to the CRO which addresses/includes:

  • Names and positions of the complainant and respondent;
  • Description of each allegation;
  • Outlines federal support (e.g., grant numbers, contracts, related publications), if applicable;
  • Inventory and description of sequestered evidence;
  • Summary of interviews conducted;
  • Timeline and procedural steps taken;
  • Any forensic or scientific analyses conducted;
  • RIO or Dean recommendation on whether the allegation warrants inquiry and the rationale.
  • The report, along with any respondent comments, shall be part of the inquiry record; as applicable.

7. Upon conclusion, the RIO shall immediately determine whether a federal or state law or policy (e.g., DHHS or NSF) concerning research misconduct applies and, if it does, conform also to its requirements throughout the application of these procedures. This may require immediate notification of the federal or state agency, appropriate interim action(s) to safeguard research data or materials or to protect agency funds and equipment, or periodic reporting to and consultation with agency officials. For example, in cases of alleged research misconduct involving sponsorship by the U.S. Department of Health and Human Services (DHHS), the RIO is required to immediately notify its Office of Research Integrity (ORI) if it is ascertained that any of the following conditions exist:

  • The health or safety of the public is at risk, including an immediate need to protect human or animal subjects;
  • Federal resources or interests are threatened;
  • Research activities should be suspended;
  • There's reasonable indication of possible violations of civil or criminal law;
  • Federal action is required to protect the interests of those involved in the research misconduct proceeding;
  • It's probable that the research misconduct proceeding may be made public prematurely and the agency may wish to safeguard evidence and protect the rights of those involved; or
  • The research community or public should be informed.