including institutional oversight, certification of future research applications, prohibition from service on government committees, or debarment. Government agencies may initiate separate proceedings to adjudicate cases involving serious offenses for which severe sanctions, such as a recommendation for debarment, are to be considered.

Research institutions must inform the sponsoring agency in writing when the institution decides to move from an inquiry to an investigation of an allegation of misconduct in science (DHHS, 1989a). A final report of the misconduct investigation must be submitted to the sponsoring agency, and the report may be subject to disclosure in response to requests under the Freedom of Information Act.

Both NSF and PHS rely on research institutions to conduct misconduct inquiries and investigations. But if government officials determine that the report of an institutional inquiry or investigation is not thorough, fair, objective, or responsive to government regulatory requirements, the agencies may intervene and investigate allegations of misconduct directly. The criteria for determining what constitutes an “adequate” inquiry or investigation remain somewhat vague, although PHS and NSF officials have made efforts to clarify the policies, procedures, and criteria that guide their evaluations of investigative reports. 67

Institutional Responses to Requirements

Before government agencies adopted regulations for handling allegations of misconduct in science, most universities and other research centers addressed such complaints through a variety of informal and formal, often confidential processes. In the early 1980s, few academic institutions had formal policies or procedures to review allegations of misconduct in science. For example, a 1982 survey indicated that fewer than one-quarter of the respondent academic institutions and hospitals had written rules to deal with allegations of fraud but that just over one-half were reportedly engaged in formulating such rules. 8 The survey found “vast differences of opinion” (p. 214) about the desirability or necessity of rules or policies for responding to allegations of fraud in research as well as “major disagreements” (p. 207) about the issues to be addressed by such policies (Greene et al., 1985). Since that time, many academic institutions have adopted policies and procedures for handling allegations of misconduct in science, but substantial variation remains in definitions and methods for conducting inquiries and investigations.

Although the DHHS's OSIR and the NSF's OIG have evaluated reports of some misconduct investigations,9 the experience of research



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