VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #R003

5.3. Inquiry and Investigation Committees Committees appointed to conduct inquiries or investigations must be impartial, appropriately qualified, and free of unresolved conflicts of interest. The IIO and the IDO will appoint the inquiry and investigation committees. 6. ALLEGATIONS OF RESEARCH MISCONDUCT All employees or individuals associated with VCOM have an obligation to report observed, suspected, or apparent misconduct in science to the IIO or other VCOM leadership. If an individual is unsure whether a suspected incident falls within the definition of scientific misconduct, they may call the IIO to discuss the suspected misconduct informally. If the circumstances described by the individual do not meet the definition of scientific misconduct, the IIO will refer the individual or allegation to other offices or officials with responsibility for resolving the problem. At any time, an employee may have confidential discussions and consultations about concerns of possible misconduct with the IIO or other VCOM leadership and will be counseled about appropriate procedures for reporting allegations. Upon receipt of an allegation, the IIO will notify the IDO and VCOM Counsel. The IIO will then conduct an immediate assessment, no later than within 10-15 days, to determine if the allegation is sufficiently credible and specific to fall under the Research Misconduct definition. 6.1. Inquiry If the assessment warrants further review, an Inquiry Committee will be formed within 30 days of the decision to investigate (§ 93.310(a)). The IIO will serve as Chair of the Inquiry Committee and will appoint at least three (3) members who understand their commission, keep the identities of respondents, complainants, and witnesses confidential, and conduct the research misconduct proceedings in compliance with the PHS regulation. VCOM may use the same committee members on the Inquiry Committee in the subsequent Investigation Committee (§ 93.310(f)). The purpose of the inquiry is to determine if there is a reasonable basis for a formal investigation (§ 93.306(b)), not to draw a final conclusion about whether misconduct definitely occurred. The inquiry must be completed within 90 days of initiation (§ 93.307(h)) unless an extension is granted. Extensions must be fully documented and justified. • Respondent Notification: The respondent will be notified in writing of the allegations and the inquiry’s purpose before the time of the first interview (§ 93.307(c)). • Inquiry Report: The IIO will prepare a written inquiry report that will make a recommendation as to whether a full investigation is required. The inquiry report must include the name and title of the committee members and experts, if any; the allegations; funding support; a summary of the inquiry process used; a list of the research records reviewed; summaries of any interviews; a description of the evidence in sufficient detail to demonstrate whether an investigation is warranted or not; and the committee's determination as to whether an investigation is recommended and whether any other actions should be taken if an investigation is not recommended. The report will be provided to the IDO and VCOM Counsel who will review the report prior to it being finalized and shared with the respondent. • Notice and Respondent Opportunity to Comment: The respondent will be given an opportunity to comment on the report. Within 30 calendar days of their receipt of the draft report, the respondent will provide their comments, if any, to the investigation committee. The respondent’s comments will be included in the final version (§ 97.307(g)(3)).

VCOM Policy on Research Misconduct

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