Allegations of Research Misconduct Policy
Policy Summary
The George Washington University (“GW” or “university”) strives to uphold the highest standards of rigor and integrity in the conduct of research and scholarly work. This Allegations of Research Misconduct Policy (policy) describes the GW process for handling allegations of research misconduct in accordance with applicable federal regulations, applicable sponsor requirements, and ethical principles inherent to the responsible conduct of research and scholarly work. The purpose of this policy is to set forth definitions, roles and responsibilities, and standards for handling allegations of research misconduct.
Related Regulations
Regulations related to this policy include, but are not limited to, the following:
42 CFR Parts 50 and 93 – Public Health Service (PHS) Policies on Research Misconduct;
45 CFR Part 689—National Science Foundation (NSF) Research Misconduct Policy; and
other local, state, or federal laws and regulations that may apply in the context of research and scholarly work.
Who is Governed by this Policy
The following individuals, collectively “GW Community Members”, are governed by this policy:
- Faculty
- Staff
- Postdocs
- Students
- Any individual paid by, under the control of, or affiliated with GW, including, but not limited to, trainees, fellows, collaborators, contractors, and guest researchers engaged in the conduct of research or scholarly work at or with GW.
Policy
Introduction
Aligned with its research mission, the university seeks to foster and adhere to the highest standards of ethical research and scholarly work. This includes establishing and implementing policies and procedures that ensure the handling of allegations of research misconduct in a fair, competent, thorough, and objective manner.
A. Scope and Applicability
This policy applies to all allegations of research misconduct on the part of GW Community Members engaged in the conduct of research or scholarly work, regardless of the source of funding.
This policy applies only to alleged research misconduct occurring within six years of GW or a pertinent agency or funder receiving an allegation of research misconduct. The subsequent use exception (see definitions) provides the circumstances under which there is an exception to this six-year limitation.
Where the research or scholarly work that is the subject of an allegation of research misconduct involves federal agency funds, the applicable federal regulations will apply to the research misconduct proceeding in addition to this policy. In the event of a conflict between applicable federal regulations and this policy, the federal regulations will control.
B. Definitions
Accepted practices of the relevant research or scholarly community. Practices established by applicable regulations and funding components, as well as commonly accepted professional codes, methods, or norms used by the community of researchers or scholars relevant to the allegation(s).
Administrative record. Comprises the institutional record relevant to the allegation(s), including documentation of correspondence, meetings, interviews, and other aspects of the proceeding that may constitute evidence or document the institutional process undertaken.
Allegation. A disclosure of possible research misconduct through any means of communication and brought directly to the attention of a GW institutional official, funder, or regulatory agency.
Complainant. A person who, in good faith, makes an allegation of research misconduct.
Conflict of interest. The real or apparent interference of an individual’s interests with the interests of another individual or organization, where potential bias may occur due to prior or existing personal, financial, organizational, or professional interests or relationships.
Evidence. Information or material offered or obtained during a research misconduct proceeding that tends to prove or disprove the existence of an alleged fact. Evidence includes documents, whether in hard copy or electronic form, information, tangible items, and testimony.
Fabrication. Making up scholarly or research data or results and recording or reporting them.
Falsification. Manipulating scholarly work or 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 allegation or testimony. Having a reasonable belief in the truth of one’s allegation or testimony based on information known at the time of raising the allegation or providing the testimony. An allegation or testimony is not made in good faith if it is made with reckless disregard for, or willful ignorance of, facts that would disprove the allegation or testimony.
Inquiry. Initial information gathering and preliminary fact-finding to determine whether an allegation or apparent instance of research misconduct has substance and warrants an investigation.
Institutional Deciding Official (IDO). The GW institutional official who makes final determinations on allegations of research misconduct and any institutional actions related to allegations of research misconduct. The GW Provost shall serve as the IDO.
Institutional record. Comprises the records compiled or generated by the university during all phases of the research misconduct proceeding in accordance with applicable regulatory requirements, except records that the university did not consider or rely on in conducting the proceeding.
Intentionally. To act intentionally means to act with the aim of carrying out the act.
Investigation. The formal development of a factual record and the examination of that record that meets the criteria and follows the procedures outlined in this policy and as set forth in applicable regulations.
Knowingly. To act knowingly means to act with awareness of the act.
PHS support. PHS funding, or applications or proposals for PHS funding, for biomedical or behavioral research, biomedical or behavioral research training, or activities related to that research or training, that may be provided through funding for PHS intramural research; PHS grants, cooperative agreements, or contracts; subawards, contracts, or subcontracts under those PHS funding instruments; or salary or other payments under PHS grants, cooperative agreements, or contracts.
Plagiarism. The appropriation of ideas, processes, images, results, or words of another person or source without giving appropriate credit. Plagiarism includes the unattributed verbatim or nearly verbatim copying of sentences and paragraphs from another source’s or person’s work that materially misleads the reader regarding the contributions of the author. It does not include the limited use of identical or nearly identical phrases that describe a commonly used methodology. Plagiarism does not include self-plagiarism or authorship or credit disputes, including disputes among former collaborators who participated jointly in the development or conduct of a research project or scholarly work. Self-plagiarism and authorship disputes do not meet the definition of research misconduct under this policy.
Preponderance of the evidence. Proof by evidence that, compared with evidence opposing it, leads to the conclusion that the fact at issue is more likely true than not.
Recklessly. To act recklessly means to propose, perform, or review research or scholarly work, or report research results, with indifference to a known risk of fabrication, falsification, or plagiarism.
Research. A systematic experiment, study, evaluation, or survey designed to develop or contribute to generalizable or specific knowledge, including, but not limited to, basic, applied, or demonstration research, in all disciplines and fields.
Research Integrity Officer (RIO). The institutional official responsible for administering GW’s written policies and procedures for addressing allegations of research misconduct and doing so in compliance with applicable laws, federal regulations, and sponsor requirements.
Research misconduct. Fabrication, falsification, or plagiarism in proposing, performing, or reviewing research or scholarly work, or in reporting research results. Research misconduct does not include honest error or differences of opinion. A finding of research misconduct requires that there be a significant departure from accepted practices of the relevant research or scholarly community; that the research misconduct be committed intentionally, knowingly, or recklessly; and that the allegation be proven by a preponderance of the evidence. The review of allegations of research misconduct under this policy cannot itself constitute research misconduct.
Research or scholarly record. Any data or results that embody the facts resulting from research or scholarly inquiry including, but not limited to, grant or contract applications, whether funded or unfunded; grant or contract progress and other reports; laboratory notebooks; notes; correspondence; videos; photographs; X-ray film; slides; biological materials; computer files and printouts; manuscripts and publications; equipment use logs; laboratory procurement records; animal facility records; human and animal subject protocols; consent forms; medical charts; and patient research files. “Data or results” shall be interpreted broadly to encompass all forms of scholarly information about the research or scholarly work at issue without regard to the type of recording or storage media, including, but not limited to, raw numbers, field notes, interviews, notebooks and folders, laboratory observations, computers and other research equipment, CD-ROMs, hard drives, all data storage devices, research interpretations and analyses, tables, slides, photographs, charts, gels, individual facts, statistics, tissue samples, reagents, and documented oral representations of research results.
Respondent. The individual(s) against whom an allegation of research misconduct is directed or whose actions are the subject of the research misconduct proceeding.
Retaliation. Any adverse action taken against a complainant, witness, committee member, or other university official in response to a good-faith allegation of research misconduct or good-faith cooperation with a research misconduct proceeding. The university’s Non-Retaliation Policy provides additional guidance with respect to retaliation.
Scholarly work. Activity or endeavors involving the serious and detailed study of an academic subject, typically involving a peer-review process before publication.
Subsequent use exception. This policy applies only to allegations received by GW and/or a pertinent agency involved in funding or overseeing the research or scholarly work in question within the previous six years, unless the allegations fall under the subsequent use exception defined in 42 CFR 93.104. The subsequent use exception, as defined in 42 CFR 93.104, will be applicable even where the research or scholarly work that is the subject of the research misconduct proceeding is not funded by PHS.
C. Roles and Responsibilities
GW's General Responsibilities
The university will endeavor to inform all GW Community Members about this policy and make the policy publicly available. GW, through the Office of the Vice Provost for Research (OVPR), will respond to each allegation of research misconduct in a thorough, competent, objective, and fair manner.
OVPR will take all reasonable and practical steps to ensure the cooperation of complainants, respondents, witnesses, committee members, and other relevant GW individuals involved in research misconduct proceedings. OVPR will also take precautions to ensure that individuals responsible for carrying out any part of the research misconduct proceeding do not have unresolved personal, professional, or financial conflicts of interest relevant to the proceeding. In addition, OVPR will make reasonable efforts to prevent retaliation against complainants, respondents, witnesses, committee members, and other individuals participating in research misconduct proceedings in good faith.
As appropriate, in connection with a research misconduct proceeding, OVPR may also take steps to manage published data or acknowledge that data may be unreliable, including correcting the scientific or scholarly literature.
The university will maintain confidentiality of research misconduct proceedings to the extent possible, including limiting disclosure of the identity of respondents, complainants, witnesses, and committee members to those who need to know as determined by OVPR in accordance with applicable regulations and as allowed by law. Those who need to know may include institutional review boards, journals, editors, publishers, co-authors, and collaborating institutions. This limitation on disclosure no longer applies once GW has made a final determination of research misconduct findings, but disclosure will remain subject to any applicable confidentiality agreements. Except as may otherwise be required by applicable law, GW will maintain confidentiality for any records or evidence from which research participants might be identified and will limit disclosure of such records or evidence to those who need to know to carry out a research misconduct proceeding.
Research Integrity Officer Role and General Responsibilities
The GW RIO will assume the primary responsibility for implementation of this policy. The same individual will not serve as both IDO and RIO. At the IDO’s discretion, the IDO may designate another institutional official with the appropriate level of administrative authority who does not have an unresolved conflict of interest to serve in the role of RIO and manage the proceeding as the designated institutional official. If the RIO has an unresolved conflict of interest with the complainant, respondent, or other key individual involved in the proceeding, the IDO will designate another institutional official with the appropriate level of administrative authority who does not have an unresolved conflict of interest to serve in the role of RIO and manage the proceeding as the designated institutional official.
At any stage in the proceeding, the RIO or designated institutional official may confidentially consult ad hoc subject matter experts as appropriate. The RIO or designated institutional official may also consult, on a confidential basis, with other GW compliance units or offices as necessary to conduct the proceeding.
In compliance with applicable regulations, the RIO or designated institutional official shall ensure complete and accurate documentation, adhere to applicable timelines, fulfil reporting obligations, and respond to sponsor or agency requests.
Institutional Deciding Official Role and General Responsibilities
The GW IDO is responsible for rendering a final institutional determination of whether research misconduct occurred. As appropriate, the IDO may coordinate with the RIO or other designated institutional official on matters described in this policy. If the IDO has an unresolved conflict of interest with the complainant, respondent, or other key individual involved in the proceeding, the GW President will designate another institutional official with the appropriate level of administrative authority who does not have an unresolved conflict of interest to serve in the role of IDO.
D. Reporting Suspected Research Misconduct in Good Faith
GW Community Members have a shared responsibility to report suspected research misconduct in good faith. Allegations should be brought confidentially to the RIO or other institutional official orally or in writing. Although anonymous allegations are acceptable, they must contain sufficient information, as determined by the RIO or designated institutional official, to enable an assessment.
As part of their responsibility to maintain confidentiality, the RIO will take all reasonable and practical steps to protect the positions and reputations of complainants who bring allegations in good faith and to protect them from any form of retaliation. OVPR will make every effort to honor a complainant’s request for non-disclosure of their identity; however, absolute non-disclosure cannot be guaranteed. As part of their obligation to cooperate throughout the proceedings, the complainant should also maintain confidentiality to protect the reputations of those involved.
If, at any time during a research misconduct proceeding, an allegation is identified as not having been brought in good faith, the RIO will determine whether any action should be taken against the complainant and may consult the IDO and/or other institutional officials in this regard.
E. Assessment
The purpose of an assessment is for OVPR to review readily accessible information relevant to the allegation and determine whether an allegation warrants an inquiry.
Upon receiving an allegation of research misconduct, the RIO or designated institutional official will promptly assess the allegation to determine whether an inquiry is warranted.
This includes a determination of whether the allegation: (a) falls within the definition of research misconduct; (b) falls within the six-year time limitation or the subsequent use exception; and, (c) is sufficiently credible and specific such that potential evidence of research misconduct may be identified.
If the RIO or designated institutional official determines that the allegation meets these three criteria, they will promptly document the assessment, initiate an inquiry, and sequester all research or scholarly work records and other evidence. If the RIO or designated institutional official determines that the alleged misconduct does not meet the criteria to proceed to an inquiry, they will prepare sufficiently detailed documentation in an assessment report describing GW’s justification for not proceeding to an inquiry. GW will securely retain this documentation, including the institutional record and all sequestered evidence, for seven years after completion of the proceeding, unless applicable federal law or regulations require a longer period.
F. Inquiry
Purpose of the Inquiry Process
The purpose of the inquiry is to conduct an initial review of the available evidence to determine whether an allegation warrants an investigation. The inquiry does not require a full review of all related evidence, nor does it involve determining whether research misconduct occurred or whether it occurred intentionally, knowingly, or recklessly.
GW will complete the inquiry within 90 days of its initiation unless circumstances warrant a longer period, with reasons for exceeding the time limit clearly documented in the inquiry report.
The RIO may determine whether to conduct the inquiry independently or to convene a committee of subject matter experts to assist with the inquiry.
If an inquiry committee is formed, the RIO or designated institutional official will ensure that all inquiry committee members are free from potential, perceived, or actual personal, professional, or financial conflicts of interest with the respondent and understand their task. The committee members shall keep the identities of respondents, complainants, and witnesses confidential for the duration of the inquiry except for those who need to know, and help conduct the research misconduct proceedings impartially in compliance with this policy and applicable regulatory requirements.
The RIO, designated institutional official, or inquiry committee may interview the respondent(s), complainant(s), and any witnesses during the inquiry. Any interviews conducted during the inquiry will be recorded and transcribed. The respondent will not be present during the complainant or witness interviews, but will be provided with a transcript of each interview. If appropriate, names or other identifying factors will be redacted to protect the confidentiality of the interviewee to the greatest extent possible.
Notifying the Respondent and Sequestering Evidence
At the time of or before beginning the inquiry, OVPR will take all reasonable steps to notify the respondent(s), in writing, that an allegation(s) of research misconduct has been raised against them, that relevant research or scholarly work records have been or will be sequestered, and that an inquiry will be conducted to determine whether to proceed with an investigation. If additional allegations emerge subsequent to the initial inquiry notification, OVPR will provide additional written notification regarding any new allegations to the respondent(s). Notification(s) to respondent(s) will include a description of the allegations, but will not include the complaint. Once an inquiry is initiated, respondents may, at their own expense, consult with legal counsel or a non-lawyer personal adviser (who is not a witness or university official involved or to be involved in the proceedings) in an advisory capacity.
If additional respondents are identified, OVPR will provide written notification to each individual to inform them of the allegations as described above. All additional respondents will be afforded the same rights and opportunities as the initial respondent. Only allegations specific to a particular respondent will be included in the notification to that respondent.
Before or at the time of notifying the respondent(s) and whenever additional items become known or relevant to the inquiry or investigation, OVPR will take all reasonable and practical steps to obtain the original or substantially equivalent copies of all research or scholarly work records and other evidence that are pertinent to the proceeding, inventory these materials, sequester the materials in a secure manner, and retain them for seven years after the conclusion of the proceeding, unless applicable federal law or regulations require a longer period.
Where appropriate, OVPR will also provide the respondent(s) copies of, or reasonable supervised access to, any sequestered research or scholarly work records.
A respondent’s destruction of research or scholarly work records documenting the questioned research or scholarly work is evidence of research misconduct where GW establishes by a preponderance of evidence that the respondent intentionally or knowingly destroyed records after being informed of the research misconduct allegations. A respondent’s failure to provide research or scholarly work records documenting the questioned research or scholarly work is evidence of research misconduct where the respondent claims to possess the records but refuses to provide them upon request.
Documenting the Inquiry
At the conclusion of the inquiry, regardless of whether an investigation is recommended to be warranted, the inquiry committee, RIO, or designated institutional official will prepare a written inquiry report including the following:
- The names, professional aliases, and positions of the respondent(s) and complainant(s).
- A description of the allegation(s) of research misconduct.
- Details about the PHS or other funding, including any grant numbers, grant applications, contracts, and publications listing PHS or other support.
- The composition of the inquiry committee, if used, including name(s), position(s), and subject matter expertise.
- An inventory of sequestered research and scholarly work records, and other evidence and description of the sequestration process.
- Transcripts of any interviews conducted.
- Inquiry timeline and procedural history.
- Any scientific or forensic analyses conducted.
- The basis for recommending that the allegation(s) warrant an investigation.
- The basis on which any allegation(s) do not merit further investigation.
- Any comments on the inquiry report by the respondent or the complainant(s).
- Any institutional actions implemented, including internal communications or external communications with journals or funding agencies.
- Documentation of potential evidence of honest error or difference of opinion.
Completing the Inquiry
The university will provide the respondent(s) a copy of the draft inquiry report for review and comment, and may provide relevant portions of the report to the complainant(s) for comment. If appropriate, names or other identifying factors will be redacted from the draft inquiry report to protect the confidentiality of the complainant(s) to the greatest extent possible. If appropriate, and in compliance with applicable law and regulation, the reason(s) warranting an inquiry period longer than 90 days may also be redacted from the draft inquiry report. Any comments received will be attached to the final inquiry report. The RIO or designated institutional official will then transmit the final report with recommendations to the IDO, who will make a final institutional determination as to whether an investigation is warranted.
GW will notify the respondent(s) of the inquiry’s final outcome and provide the respondent(s) with copies of the final inquiry report, any pertinent regulations, and this policy. If appropriate, names or other identifying factors will be redacted from the final inquiry report to protect the confidentiality of the complainant(s) to the greatest extent possible. If appropriate, and in compliance with applicable law and regulation, the reason(s) warranting an inquiry period longer than 90 days may also be redacted from the final inquiry report. GW may choose to notify the complainant(s) of the outcome of the inquiry. If there is more than one complainant, and GW chooses to notify one complainant of the outcome of the inquiry, GW will endeavor to notify all complainants.
Determination of whether an Investigation is Warranted
The RIO, designated institutional official, or inquiry committee will conduct a preliminary review of the evidence to recommend to the IDO whether an investigation is warranted. An investigation is warranted if (a) there is a reasonable basis for concluding that an allegation falls within the definition of research misconduct, and (b) preliminary information-gathering and fact-finding from the inquiry indicate that an allegation may have substance
If the respondent raises any affirmative defenses against the research misconduct allegation(s), the respondent has the burden of presenting and proving, by a preponderance of evidence, any defenses raised. GW will give due consideration to credible and specific evidence of honest error or differences of opinion presented by the respondent(s).
If the IDO determines that an investigation is not warranted, GW will keep sufficiently detailed documentation, including a detailed justification for not proceeding to an investigation. The institutional record from such proceedings will be provided to regulatory agencies, as appropriate, and stored in a secure manner for seven years after the conclusion of the proceeding, or longer if required by applicable law or regulation.
If the IDO determines that an investigation is warranted, the university will provide written notice to the respondent(s) of the decision to conduct an investigation and will fulfill all applicable reporting requirements to federal agencies and sponsors.
G. Investigation
Purpose of the Investigation and Investigation Process
The purpose of an investigation is to formally develop a factual record, examine the record, and recommend findings to the IDO. The IDO is responsible for making a final determination on each allegation of research misconduct.
OVPR will initiate the investigation within 30 days after the IDO’s determination that an investigation is warranted, and will complete all aspects of the investigation within 180 days of its initiation, including conducting the investigation, preparing the draft investigation report for each respondent, providing the opportunity for respondent(s) (and complainant(s), if appropriate) to comment on the draft investigation report, transmitting the institutional record to the IDO (including the final investigation report), and decision by the IDO. If circumstances warrant a longer period, GW may, in compliance with applicable law and regulation, take longer than 180 days to complete the investigation. If GW is unable to complete an investigation within 180 days, the reasons for exceeding the 180-day time limit must be clearly documented in the investigation report.
As part of its investigation, OVPR will pursue diligently all significant issues and relevant leads, including any evidence of additional instances of possible research misconduct, and continue the investigation to completion. A finding of research misconduct must be proved by a preponderance of the evidence.
Notifying the Respondent and Sequestering Evidence
OVPR will notify the respondent(s) in writing of the allegation(s) within 30 days of the IDO’s determination that an investigation is warranted and before the investigation begins. If any additional respondent(s) are identified during the investigation, OVPR will notify respondent(s) in writing of the allegation(s) and provide them with an opportunity to respond consistent with this policy and any applicable regulations. If additional respondents are identified during the investigation, OVPR may choose to either conduct a separate inquiry or add the new respondent(s) to the ongoing investigation. If new allegations emerge during the investigation, the university will also notify the respondent(s) in writing of those new allegations. To the extent it has not already done so during the inquiry, OVPR will obtain the original or substantially equivalent copies of all research or scholarly records and other evidence, inventory these materials, sequester them in a secure manner, and retain them for seven years after its proceeding or any pertinent agency proceeding, whichever is later.
Convening an Investigation Committee
After identifying appropriate subject matter experts and documenting that they are free of potential, perceived, or actual personal, professional, or financial conflicts of interest, the RIO or designated institutional official will convene the members of the investigation committee, which can include the same committee members from the inquiry. The RIO or designated institutional official will advise the committee members of their responsibility to impartially conduct the research misconduct proceedings in compliance with this policy and any applicable regulations. The RIO or designated institutional official will ensure that the investigation is sufficiently documented and that the investigation committee understands and fulfils its required tasks, including conducting interviews, pursuing leads, and examining research records and other evidence relevant to making a recommendation on the merits of the allegation(s).
Committee members may serve on more than one investigation committee when there are multiple respondents involved in the same investigation.
Conducting Interviews
The investigation committee will interview each respondent, complainant(s), and any other available person who has been reasonably identified as having information regarding the allegations, including witnesses identified by the respondent(s). The RIO or designated institutional official will number all relevant exhibits and refer to any exhibits shown to the interviewee during the interview by that number to ensure appropriate documentation of the record. Interviews conducted during the investigation will be recorded and transcribed, with transcripts made available to the interviewee for correction. Transcripts with any corrections and exhibits will be included in the institutional record. The respondent(s) will not be present during any witness interviews, but the RIO or designated institutional official will provide the respondent(s) with a transcript of each interview, with redactions as appropriate to maintain confidentiality to the greatest extent possible.
Documenting the Investigation
At the conclusion of the investigation, the investigation committee, RIO, or designated institutional official will prepare a written investigation report for each respondent, including the following:
- Description of the nature of the allegation(s) of research misconduct, including any additional allegation(s) addressed during the research misconduct proceeding.
- Description and documentation of the PHS or other support, including any grant numbers, grant applications, contracts, and publications listing PHS or other support. This documentation includes known applications or proposals for support that the respondent has pending with PHS and non-PHS Federal agencies, if applicable.
- Description of the specific allegation(s) of research misconduct considered in the investigation of the respondent.
- Composition of investigation committee, including name(s), position(s), and subject matter expertise.
- Inventory of sequestered research or scholarly records and other evidence, except records the institution did not consider or rely upon. This inventory will include manuscripts and funding proposals that were considered or relied upon during the investigation, along with a description of the sequestration process.
- Transcripts of all interviews conducted.
- Identification of the specific published papers, manuscripts submitted but not accepted for publication (including online publication), PHS or other funding applications (if applicable), progress reports, presentations, posters, or other research records that contain the allegedly falsified, fabricated, or plagiarized material.
- Any scientific or forensic analyses conducted.
- A copy of GW policies and procedures under which the investigation was conducted.
- Any comments made by the respondent and complainant(s) on the draft investigation report and the committee’s consideration of those comments.
- A statement for each separate allegation of whether the committee recommends a finding of research misconduct.
If the investigation committee recommends a finding of research misconduct for an allegation, the investigation report must, for that allegation, (a) identify the individual(s) who committed the research misconduct; (b) indicate whether the research misconduct constituted falsification, fabrication, and/or plagiarism; (c) indicate whether the research misconduct was committed intentionally, knowingly, or recklessly; (d) identify any significant departure from the accepted practices of the relevant research or scholarly community and that the allegation was proven by a preponderance of the evidence; (e) summarize the facts and analysis supporting the conclusion and consider the merits of any explanation by the respondent; (f) identify the specific PHS or other support, if any; and (g) state whether any publications need correction or retraction.
If the investigation committee does not recommend a finding of research misconduct for an allegation, the investigation report will provide a detailed rationale for its conclusion.
Completing the Investigation
OVPR will provide each respondent with a copy of the draft investigation report for that respondent and, concurrently, a copy of, or supervised access to, the research records and other evidence that the investigation committee considered or relied upon. If appropriate, names or other identifying factors will be redacted from the draft investigation report to protect the confidentiality of the complainant(s) to the greatest extent possible. If appropriate, and in compliance with applicable law and regulation, the reason(s) warranting an investigation period longer than 180 days may also be redacted from the draft investigation report. The respondent(s) will submit any comments on the draft report to OVPR within 30 days of receiving the draft investigation report, and such comments will be included in the final investigation report. If OVPR chooses to share a copy or relevant portions of the draft investigation report with the complainant(s) for comment, the complainant(s) will submit any comments to OVPR within 30 days of their receipt of the report, and any comments will be added to the final investigation report.
If a respondent raises any affirmative defenses against the research misconduct allegations, the respondent has the burden of presenting and proving, by a preponderance of evidence, any defenses raised. GW will give due consideration to credible and specific evidence of honest error or difference of opinion presented by the respondent(s).
H. University Administrative Actions
The university may take appropriate administrative actions against respondents when the IDO makes a finding of research misconduct or when the university accepts an admission of research misconduct from a respondent. Consistent with applicable law and GW policies, administrative actions are determined by the IDO after consultation with the RIO and other institutional officials as appropriate, and may include, but are not limited to, the following:
- withdrawal or correction of all pending or published abstracts and papers emanating from the research or scholarly work where research misconduct was found;
- withdrawal or correction of the dissertation or thesis emanating from the research or scholarly work where research misconduct was found;
- removal of the responsible person from the particular project(s), letter of reprimand, special monitoring of future work, probation, suspension, salary reduction, or initiation of steps leading to possible rank reduction;
- suspension or expulsion of a student from their academic program;
- revocation of student’s degree or certificate;
- restitution or reimbursement of funds as appropriate;
- termination of university employment or affiliation.
If the IDO determines specific administrative actions are appropriate, and the respondent believes there are mitigating factors relevant to the decision to impose administrative actions, the respondent shall bear the burden of demonstrating such mitigating factors by a preponderance of evidence. The IDO will review and consider evidence presented by the respondent in this regard.
The termination of a respondent's university employment or affiliation, by resignation or otherwise, before or after an allegation of possible research misconduct has been alleged, will not lead to termination of the research misconduct proceeding under this policy or as required by applicable law.
I. Additional Administrative Actions
Restoration of the Respondent's Reputation
If the university determines not to proceed from an inquiry to an investigation and/or finds no research misconduct after an investigation, the RIO or designated institutional official will consider reasonable, practicable, and appropriate efforts, if requested by and in consultation with the respondent, to address any concerns relating to the respondent's position, reputation and any public knowledge of the research misconduct allegations. Depending on the particular circumstances, the RIO or designated institutional official may consider such actions as notifying those individuals aware of or involved in the inquiry and/or investigation of the final outcome, publicizing the final outcome in a forum in which the allegation of research misconduct was previously publicized, or including clear reference to findings of no research misconduct under this policy in the respondent's official personnel file. Upon the respondent’s reasonable request, the IDO will consider additional measures to address concerns relating to the consequences of the research misconduct proceeding, including consideration of interim support (ordinarily not to exceed one year) for the respondent’s ongoing research activities.
Protection of the Complainant and Others
The RIO or designated institutional official will undertake reasonable efforts to protect the position or reputation of complainants who made allegations of research misconduct in good faith and others participating in good faith in research misconduct proceedings. When appropriate, the RIO or designated institutional official will consult with the individual and the IDO to determine necessary steps for such protection.
Failure to Cooperate with Research Misconduct Proceeding
If a complainant, respondent, witness, committee member, or other individual fails to cooperate with the research misconduct proceeding, the RIO or designated institutional official will nevertheless carry the proceeding to conclusion in accordance with this policy and applicable law. The RIO may determine whether any action should be taken against an individual who, under this policy and applicable law, has been found by the RIO or designated institutional official to have failed to cooperate with the proceedings. The RIO or designated institutional official may consult with the IDO and other appropriate institutional officials regarding such actions.
Protection of Funds and Resources
University officials will take interim administrative actions during a research misconduct proceeding, as appropriate, to protect federal or institutional funds or resources, protect ongoing research activities, and protect any animal subjects or human research participants involved in or relevant to a research misconduct proceeding.
J. Other Considerations and Special Circumstances
Multiple Institutions
If the alleged research misconduct involves multiple institutions, GW will coordinate with the other affected institutions to determine whether a joint research misconduct proceeding should be conducted. If a joint proceeding is conducted, the cooperating institutions will choose an institution to serve as the lead institution. In a joint research misconduct proceeding, the lead institution will obtain research records and other evidence pertinent to the proceeding, including witness testimony, from the other relevant institutions. By mutual agreement, the joint research misconduct proceeding may include committee members from the other institutions involved. The determination of whether an inquiry and/or investigation is warranted, whether research misconduct occurred, and institutional actions to be taken may be made by the institutions jointly, if appropriate, or tasked to the lead institution or respective institutions.
Respondent Admissions and Settlement
During research misconduct proceedings, a respondent may admit to having committed research misconduct. To ensure that the entire scope of research misconduct is addressed, any admission by a respondent must be in writing, signed, and reviewed and approved by the RIO or designated institutional official. The admission must specify the entire scope of falsification, fabrication, and/or plagiarism that occurred and which research records were affected, and include sufficient specificity to meet requirements of regulatory agencies and/or research sponsors as applicable. If required by applicable law, when the university deems it appropriate to close the proceedings based on a respondent's admission, the signed admission will be approved by the RIO or designated institutional official only after notification of and consultation with relevant federal agencies and/or research sponsors. The university may still take appropriate administrative actions in cases where a respondent has admitted to research misconduct.
GW may also close a research misconduct proceeding at the assessment, inquiry, or investigation stage when a settlement with the respondent has been reached. Closure due to settlement with the respondent will only take place after notification of and consultation with relevant federal agencies and/or research sponsors. The university may still take appropriate administrative actions in cases where a respondent has settled the research misconduct proceeding with the university, unless the settlement precludes such actions.
Notification during Special Circumstances
At any time during the research misconduct proceedings where the research or scholarly work in question involves federal funding or oversight, GW will immediately notify the pertinent agency if any of the following circumstances arise:
- Health or safety of the public is at risk, including an immediate need to protect human or animal subjects.
- Pertinent agency resources or interests are threatened.
- Research activities should be suspended.
- There is 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.
- Any pertinent agency may need to take appropriate steps to safeguard evidence and protect the rights of those involved.
Contacts
| Contact | Phone Number | Email Address |
|---|---|---|
| Office of the Vice Provost for Research | 202-994-6255 | askovpr gwu [dot] edu |
| Office of Research Integrity and Compliance | 202-994-6255 | resinteg gwu [dot] edu |
Responsible University Official: Vice Provost for Research
Responsible Office: Office of the Vice Provost for Research
Effective Date: December 17, 2025
Origination Date: February 8, 1991
Last Material Change: December 17, 2025
Last GW Community Comment Period: October 13, 2025 - November 24, 2025; see a thematic summary of feedback here.
Next Scheduled Review: 2026 - 2027 Academic Year
To provide feedback on this policy, please contact the Responsible Office(s) listed above or the Office of Ethics, Compliance, and Risk. More information describing university policies is outlined in the University Policy Principles.
Noncompliance with this policy can be reported through this website.
