The purpose of this Policy on Handling Allegations of Research Misconduct (the “Research Misconduct Policy”) is to describe how Brown University (“Brown”) handles Allegation(s) of Research Misconduct. It outlines the rights and responsibilities of the parties involved in Research Misconduct reviews when Brown receives Allegation(s) of Research Misconduct.

This policy applies to all individuals involved in research at Brown, including any person involved in the review of Research Misconduct Allegations and Research Misconduct Proceedings involving Brown research paid by, under the control of, or affiliated with Brown at the time of the alleged Research Misconduct, including but not limited to scientists, trainees, technicians, other staff members, students, fellows, guest researchers, or collaborators. 

Brown prohibits any form of dishonesty or misconduct in research. Brown maintains high standards of research integrity. All individuals involved in research at Brown must conduct research in a manner reflecting these standards.

Research Misconduct is a specific type of misconduct that involves Falsification, Fabrication, or Plagiarism in proposing, performing, or reviewing research, or in reporting research results. Research Misconduct does not include honest error or differences of opinion.

When an Allegation of Research Misconduct is received by the Brown Research Integrity Officer or that person’s designee (“the RIO”), the RIO will review and handle the Allegation in accordance with the procedures outlined in the Standard Operating Procedures for Handling Allegations of Research Misconduct at Brown University (the “Research Misconduct SOP”), which incorporates procedures established by regulations and policies of U.S. Federal agencies, including but not limited to the Public Health Service Policies on Research Misconduct (42 C.F.R Part 93) and the National Science Foundation Research Misconduct Policy (45 C.F.R Part 689).

Particular circumstances in an individual case, such as requirements of an external sponsor, may require a variation in procedures set forth in the Research Misconduct SOP. Any variation in those procedures must uphold the principles of the Research Misconduct SOP, including fair treatment for the subject of the Allegation.

For the purpose of this policy, the terms below have the following definitions:

All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. University supervisors and employees with student oversight duties are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure and enforce compliance with it.

Brown Employees and Individuals Associated with Brown: All employees or individuals associated with Brown University have a responsibility to report observed, suspected, or apparent Research Misconduct involving Brown community members or Brown research to the RIO. Any individual who is unsure whether a suspected incident falls within the definition of Research Misconduct may contact the RIO to discuss the suspected Research Misconduct without making a formal Allegation. If the circumstances do not meet the definition of Research Misconduct but fall under different policies, the RIO will refer the individual or Allegation(s) to other offices or officials with responsibility for those policies.

Brown Employees: Brown employees must reasonably cooperate with the RIO and other University officials in the review of Allegation(s) and the conduct of Inquiries and Investigations. Employees have an obligation to preserve and provide relevant Evidence related to Research Misconduct Proceeding to the RIO or other institutional officials officially engaged in an Inquiry or Investigation.

Research Integrity Officer: The RIO has primary responsibility for implementation of this policy and the Research Misconduct SOP, as well as any other related procedures. If the RIO has an actual or perceived Conflict of Interest related to a particular Research Misconduct matter, Brown must mitigate that Conflict of Interest, which mitigation may include appointing another appropriate individual to serve as RIO for that matter.

In addition to the responsibilities outlined in the policy, the RIO will:

• take reasonable and practical steps to identify Research Records and Evidence needed to conduct the Research Misconduct Proceeding, inventory the records and Evidence, and sequester them in a secure manner.
• appoint the person(s) conducting the Inquiry and, if applicable, Investigation and ensure that necessary and appropriate expertise is available to carry out a thorough and authoritative evaluation of the relevant Evidence in an Inquiry or Investigation.
• maintain confidentiality as appropriate and required by this policy, applicable law and regulations, and otherwise required or expected.
• assist during the Inquiry and Investigation and support  institutional personnel in complying with this policy, related procedures, and applicable standards imposed by government or external funding sources.
• keep the DO and others with a need to know apprised of the progress of the Research Misconduct Proceeding.
• be responsible for securing and maintaining the confidentiality of all documents and Evidence.
• take appropriate or required action to notify other involved parties, such as sponsors, law enforcement agencies, professional societies, and licensing boards, of those actions.
• report relevant information to external sponsor(s) of implicated research, as required by regulation.

Deciding Official: The DO has primary authority for making decisions about Research Misconduct, including making a Finding, after considering the reports and recommendations from the Inquiry and, if applicable, Investigation. If the DO has an actual or perceived Conflict of Interest related to a particular Research Misconduct matter, Brown must mitigate that Conflict of Interest, which mitigation may include appointing another appropriate individual to serve as DO for that matter.

The DO will:

• review the final Inquiry and/or Investigation report, the recommendations of the Inquiry or Investigation committee, and any written comments made by the Respondent on the draft report(s).
• decide whether to conduct an Investigation.
• after the conclusion of an Investigation, determine whether Research Misconduct occurred, and whether to impose sanctions or take other appropriate action(s), including administrative actions.
• coordinate with relevant institutional officials to confirm that the findings of the DO, as well as the final Investigation report and a description of any pending or completed administrative actions, are provided to any sponsor(s) as required or appropriate.

Complainant: The Complainant may have an opportunity to testify during  the Inquiry and Investigation and be informed of the results of the Inquiry and Investigation. The Complainant is responsible for making Allegation(s) in Good Faith and cooperating, in Good Faith, with an Inquiry or Investigation.

Respondent: The Respondent is responsible for cooperating with the conduct of an Inquiry or Investigation. The Respondent will have the opportunity to be interviewed by and present Evidence during the Inquiry and Investigation, to review the draft Inquiry and Investigation reports, and to have the advice of counsel. 

Failure to comply with this and related policies is subject to disciplinary action, up to and including suspension without pay, or termination of employment or association with the University, in accordance with applicable (e.g., staff, faculty, student) disciplinary procedures.

Brown is a community in which individuals are encouraged to share concerns with University leadership. Additionally, Brown’s Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184).

The following information complements and supplements this document. The information is intended to help explain this policy and is not an all-inclusive list of policies, procedures, laws and requirements.