The University is committed to the timely review and resolution of complaints or concerns about violations of research regulations, policies, procedures, or standards.
As stated in Board of Regents Policy: Code of Conduct and Administrative Policy: Reporting Suspected Misconduct, members of the University community are expected to be proactive to prevent and detect any compliance violations and report suspected violations to supervisors or other University officials in a timely manner. This policy supplements these policies by providing specific guidance related to research compliance concerns. Research compliance concerns include alleged violations of regulations, policies, procedures, or standards related to the conduct of research. Concerns may be related to such topics as the appropriate use of human or animal subjects, compliance with sponsored projects requirements or misuse of research funding, concerns or issues arising from the actions or activities of regulatory boards or committees or biosafety related activities, among others.
Included in For-Cause Investigations
The Research Compliance Office is responsible for conducting or overseeing for-cause investigations related to research compliance concerns. For-cause investigations include research compliance concerns escalated by a University regulatory committee, complaints related to the conduct of regulatory committees themselves, other matters identified through monitoring or trend data, or other issues assigned for review by the Vice President for Research.
Excluded from For-Cause Investigations
Research compliance concerns not falling into these categories, including concerns discovered through routine monitoring activities or concerns reported directly to a regulatory committee or research office, are addressed directly by those offices/committees and do not fall within this policy. Research compliance concerns also do not include scientific misconduct allegations, which are separately handled under Administrative Policy: Research Misconduct. See the definition of “Research Misconduct” in the definitions section below.
The Research Compliance Office will investigate a research compliance concern only one time except in instances involving receipt of material new information. The Research Compliance Office does not review concerns that occurred seven or more years prior to the submission of the complaint, except under the direction of the Vice President for Research who determines that the alleged conduct was not reasonably discoverable earlier.
Reporting a Concern
Complainants may submit any research compliance concern using U Report, the University’s centralized confidential reporting service (including via a confidential web link ). Their concern will then be forwarded to the applicable regulatory committee/office or the Research Compliance Office for review. Concerns may also be reported directly to regulatory committees/research offices as outlined in Administrative Procedure: Preparing, Submitting, Receiving and Investigating a Report of a Research Compliance Concern.
Protection from Retaliation
No member of the University community may retaliate against an individual because of the individual’s good faith participation in:
- reporting or otherwise expressing opposition to suspected or alleged misconduct; or
- participating in any process designed to review or investigate suspected or alleged misconduct or non-compliance with applicable policies, rules, and laws; or
- accessing the Office for Conflict Resolution (OCR) services.
A causal relationship between the good faith participation in one of these activities and an adverse action is needed to demonstrate that retaliation has occurred.
Individuals who believe that retaliation is occurring or has occurred as a result of their good faith participation in one of the above referenced activities, should follow the reporting options available to them in Administrative Policy: Reporting Suspected Misconduct.
Reports of retaliation will be reviewed and investigated in the same manner in which other concerns of misconduct are handled. Any University member who engages in retaliation may be subject to disciplinary action up to and including termination of employment or expulsion.
Intentionally False Reports/Information
Individuals who, knowingly or intentionally, file a false report or provide false or misleading information in connection with an investigation may be subject to disciplinary action up to and including termination of employment, or expulsion.
Phases of Review
For-cause investigations conducted under this policy have several phases including receipt, review and assessment, conclusion/action and reporting. Some investigations may require the convening of an investigative panel or involve a referral to an outside organization for external investigation. These phases are outlined in related procedures listed below.
Conditions Governing Investigations and Outcomes
For-cause investigations will be conducted by individuals without a conflict of interest and will include individuals with the necessary regulatory and subject matter expertise (including involving experts outside the University when internal expertise is not available). Reviews and corrective actions (if needed) will be undertaken in a manner fair to all parties. The Research Compliance Office will work with the appropriate regulatory offices, panels or academic units as appropriate to ensure that humans and animals are protected when research compliance violations occur.
Regulatory committees and/or academic or administrative officials, as appropriate, will take the actions needed to mitigate research compliance concerns found to be compliance violations. Outcome reporting will be accomplished in a manner that encourages transparency and institutional identification of trends and patterns, while protecting the privacy and well-being of witnesses, the complainant (if requested), and others involved in the investigation to the extent possible. At no time may any University employee take retaliatory action against a complainant because of a concern reported in good faith. Individuals reporting concerns are protected from retaliation and covered by other relevant University policies, including Administrative Policy: Reporting Suspected Misconduct.
Reason for Policy
The University community, the public, accreditation entities, and funding sponsors expect that the University has and follows written procedures for addressing allegations and findings of non-compliance with regulatory requirements and standards, and that concerns are addressed in a timely manner. This policy provides direction for the good faith reporting of research compliance concerns, outlines the complaint review and resolution processes, and defines responsibilities as appropriate. The policy also allows the University to identify areas where additional oversight or training is needed.